Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

A lawful permanent resident from Guatemala became concerned about her niece, who was living with her father. Upon checking her father’s phone, she discovered nude photos and videos of her niece. Rather than contacting law enforcement, she took pictures and videos of these pornographic images with her own phone and sent them to her niece’s mother in Guatemala. After her father was arrested for sex crimes, the niece moved in with her. Months later, the niece reported to police that the resident used the images as leverage and to protect her father. Police found the images on the resident’s phone, leading to her conviction for child exploitation under Indiana law.The Department of Homeland Security charged her as removable for committing an aggravated felony (sexual abuse of a minor) and a crime of child abuse under the Immigration and Nationality Act (INA). An Immigration Judge ordered her removal. She appealed to the Board of Immigration Appeals (BIA), which dismissed her appeal and later denied her motion for reconsideration. She then petitioned for review of both orders.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the Indiana statute under which she was convicted fits within the broad federal definition of “crime of child abuse” for purposes of removal under the INA. The court also found that she did not demonstrate a realistic probability that Indiana would apply its statute to conduct outside the generic federal definition. Additionally, the court upheld the BIA’s determination that she committed a “particularly serious crime,” barring her from withholding of removal and protection under the Convention Against Torture. The Eighth Circuit denied both petitions for review. View "Saavedra-Villanueva v. Blanche" on Justia Law

A sales representative for an agricultural company copied confidential customer and sales information, including emails, reports, and physical documents, to personal storage devices before resigning and joining a competitor. The information included sales forecasts, budgets, product discounts, and historical customer purchase data. After moving to the competitor, he used this information to negotiate agreements and disclose pricing, volume, and dealer terms to his new employer, resulting in nearly all customers from his previous employer’s local operation switching to his new company. The prior employer attempted to maintain the operation but ultimately closed the location due to lost business.The United States District Court for the Southern District of Iowa denied the defendant’s motion for summary judgment on misappropriation claims, finding genuine disputes of material fact. At trial, the defendant moved for judgment as a matter of law regarding damages and causation, which the district court deferred and later denied after a jury found willful and malicious misappropriation of trade secrets, awarding compensatory and exemplary damages. The district court also awarded substantial attorney’s fees and costs to the plaintiff, without reducing the fees to account for unsuccessful claims.Reviewing the appeal, the United States Court of Appeals for the Eighth Circuit affirmed the judgment on the merits, holding that sufficient evidence supported the jury’s verdict regarding causation and damages, and that evidentiary challenges did not warrant reversal. The court clarified that it could not review the denial of summary judgment since it did not involve a purely legal issue. However, it vacated the attorney’s fees award and remanded for the district court to consider the plaintiff’s overall degree of success relative to the relief sought, as required by precedent, leaving the amount of the fee award for the district court to determine in the first instance. View "Wilbur-Ellis Company LLC v. Downing" on Justia Law

During the summer of 2018, housing advocates interacted with tenants at the Yale Park Apartment Complex in Omaha, documenting alleged building code violations and submitting complaints to the City. Based largely on this information, the City’s Chief Housing Inspector applied for and received an inspection warrant. Subsequent searches led to the closure of the complex, and tenants were forced to relocate. The City later provided AB Realty, LLC—the owner—and Kay and Janae Anderson with a list of violations and barred reopening until repairs were made. AB Realty attempted to challenge the closure through the Property Management Appeals Board and faced ongoing notices and prosecution for code violations. After completing repairs and reopening the complex in 2021, AB Realty and the Andersons initiated a lawsuit.The United States District Court for the District of Nebraska granted the defendants’ motion to dismiss in part and stayed proceedings pending the outcome of Kay Anderson’s criminal trial. After a state-court jury convicted Kay on a few counts but acquitted him of most, the district court dismissed the remaining claims against the City of Omaha and associated defendants.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The court held that the search warrant, even excluding disputed information, was supported by probable cause based on the complaints and evidence of violations. It further determined that violations of Nebraska state law regarding warrants did not sustain a federal constitutional claim under 42 U.S.C. § 1983. The court also found AB Realty’s procedural due process allegations insufficiently specific to identify constitutionally protected interests or responsible parties. Finally, the court ruled that AB Realty failed to plead either a per se or regulatory taking under the Fifth Amendment, as the City did not physically appropriate the property and the closure for code violations did not constitute a regulatory taking. All claims against all defendants were dismissed. View "AB Realty, LLC v. Lane" on Justia Law

In this matter, Logan Riffenburg and Vanessa Roper, formerly married, jointly acquired property in Arkansas. After their divorce, each retained a half-interest in the property. Roper subsequently remarried and, with her new husband, filed for Chapter 7 bankruptcy. The bankruptcy trustee sought court approval to sell Roper’s interest in the property to Blue Sun Capital LLC. Riffenburg objected to the sale, but his objection was overruled by the bankruptcy court, which authorized the sale. The court focused on the trustee’s good faith and the fairness of the process but did not address whether Blue Sun Capital was a good-faith purchaser.Following the bankruptcy court’s approval, Riffenburg appealed to the United States Bankruptcy Appellate Panel for the Eighth Circuit (BAP) and requested a stay pending appeal, which was denied. The sale was completed. The trustee then moved to dismiss the appeal as statutorily moot under 11 U.S.C. § 363(m), arguing that the completed sale to a good-faith purchaser could not be unwound in the absence of a stay. The BAP, with one judge dissenting, agreed and dismissed the appeal, finding that Riffenburg had not raised the issue of the purchaser’s good faith in the bankruptcy court.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the BAP’s dismissal. The court held that under its precedent, in order to avoid mootness under § 363(m), an objector must challenge the good faith of the purchaser before the bankruptcy court. Because Riffenburg did not do so, the issue was not preserved for appeal, and the appeal was dismissed as statutorily moot. The Eighth Circuit explicitly stated that this precedent remained binding, even after the Supreme Court’s decision in MOAC Mall Holdings LLC v. Transform Holdco LLC. View "Riffenburg v. Rice" on Justia Law

The defendant was charged with conspiracy to distribute methamphetamine and multiple counts of possession with intent to distribute methamphetamine after a series of controlled buys, traffic stops, and search warrants linked him to large quantities of drugs. Evidence at trial included testimony from cooperating witnesses who described purchasing or selling methamphetamine with the defendant or his associates. Police seized drugs, firearms, and personal items belonging to the defendant from residences connected to him. Additional evidence, such as coded text messages and testimony about the defendant’s role in directing drug sales, further connected him to the offenses.Following a jury trial in the United States District Court for the Southern District of Iowa, the defendant was found guilty of conspiracy and two counts of possession with intent to distribute methamphetamine, but not guilty on other charges, including firearm offenses. The jury determined by special interrogatory that the drug quantity involved was at least 50 but less than 500 grams. At sentencing, the district court attributed a larger drug quantity to the defendant based on additional evidence, applied a manager role enhancement, and used the career offender guideline, resulting in an advisory guidelines range of 360 months to life. Due to mitigating factors, the court imposed a downward-variant sentence of 240 months.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decisions. The appellate court held that the district court did not abuse its discretion in admitting evidence of the defendant’s prior convictions under Rule 404(b), nor did it clearly err in applying the manager enhancement. It further found that any alleged errors in drug quantity findings did not affect the defendant’s guidelines range, as the career offender guideline controlled. Therefore, any procedural error was harmless. The Eighth Circuit affirmed both the convictions and the sentence. View "United States v. Dixon" on Justia Law

Stephen Parr was employed by Union Pacific Railroad Company beginning in 2015. He was trained to report safety concerns via designated company channels and made numerous complaints from 2018 to 2022. In late 2022, Parr began sending complaints to individuals who were not his direct supervisors, which led to discomfort among certain employees. Management responded by instructing Parr to use only the approved reporting channels. After Parr continued to make complaints, Union Pacific initiated an investigation into his conduct, eventually terminating him for insubordination and discourtesy. Parr appealed his termination to the Public Law Board, which reinstated him without backpay.Parr then filed suit in the United States District Court for the Western District of Missouri, alleging Union Pacific retaliated against him for engaging in protected activity under the Federal Rail Safety Act (FRSA). The case proceeded to trial, and the jury found that Parr did not establish a prima facie case of retaliation. The district court denied Parr’s motion for a new trial, based on alleged errors in the jury instructions.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Parr’s claims of instructional error. The court held that the district court’s instructions were consistent with Eighth Circuit precedent, specifically regarding the requirement to prove intentional retaliation. The court also upheld the business judgment instruction and the restriction of the relevant time period for protected activity to December 2022 through February 2023, finding both legally accurate and supported by the evidence. The Eighth Circuit concluded that no abuse of discretion occurred in the jury instructions, and affirmed the judgment of the district court. View "Parr v. Union Pacific Railroad Co." on Justia Law

An Arkansas resident applied to work as a warehouse driver for a chemical company. He received a conditional job offer, which was withdrawn after a third-party testing company reported a positive result for marijuana metabolites. The applicant explained to both the employer and the testing company that he had not used marijuana but had consumed a CBD product for anxiety related to a medical condition. He alleged that, despite notifying the employer of his disability and the possible source of a false positive, the employer did not investigate further or engage in any process to accommodate his disability, nor did the employer respond to his request to return to duty.After the withdrawal of the job offer, the applicant filed a charge of disability discrimination with the Equal Employment Opportunity Commission (EEOC) 266 days later. The EEOC dismissed his charge as untimely and issued a right-to-sue letter. The applicant then filed suit in the United States District Court for the Eastern District of Arkansas, alleging violations of the Americans with Disabilities Act (ADA), race discrimination under Title VII and the Arkansas Civil Rights Act, and a negligence claim against the testing company.The district court dismissed all claims against the testing company, noting the plaintiff conceded the federal statutes did not apply and finding no facts alleged to support racial animus. It declined to exercise supplemental jurisdiction over the remaining state law negligence claim. As to the employer, the court granted judgment on the pleadings, finding the EEOC charge was untimely and the complaint lacked facts showing race discrimination.The United States Court of Appeals for the Eighth Circuit affirmed. It held that the Arkansas 180-day filing deadline applied because the applicant was notified of the job offer withdrawal in Arkansas, making his EEOC charge untimely. The court also found the complaint failed to plausibly allege race discrimination and upheld the district court’s decision not to exercise supplemental jurisdiction over the state law claim. View "Stephens v. Harcros Chemicals" on Justia Law

Hall Trucking, Inc., a company that moves oil rigs, was cited by the Occupational Safety and Health Administration (OSHA) after an employee was fatally struck by a truck during a rig-moving operation. OSHA alleged that Hall Trucking violated the general duty clause under 29 U.S.C. § 654(a)(1), which requires employers to provide a workplace free from recognized hazards. The citation suggested that implementing an internal traffic control plan (ITCP)—including measures such as minimizing interactions between employees and trucks, requiring high-visibility gear, and employee training—was a feasible method to reduce the risk.An Administrative Law Judge (ALJ) of the Occupational Safety & Health Review Commission reviewed the case. The ALJ excluded testimony from Hall Trucking’s expert, finding he lacked specialized knowledge in traffic control and that his opinions amounted to legal conclusions. The ALJ admitted the Secretary’s expert, who had specific experience with ITCPs, and found his testimony reliable. The ALJ concluded that Hall Trucking’s existing safety procedures were inadequate and that an ITCP was a feasible and effective abatement method. Hall Trucking’s arguments regarding the adequacy of its measures, the specificity of abatement steps, and the industry standards were rejected. Additionally, Hall Trucking’s argument that a specific OSHA regulation supplanted the general duty clause was deemed waived because it was not properly raised before the Commission.The United States Court of Appeals for the Eighth Circuit reviewed Hall Trucking’s petition for review. The court held that the ALJ’s factual findings were supported by substantial evidence and that the legal conclusions were not arbitrary, capricious, or contrary to law. The court also found the ALJ’s rulings on expert witness admissibility and reliability were proper. The Eighth Circuit denied Hall Trucking’s petition for review, affirming the Commission’s decision. View "Hall Trucking Inc. v. Secretary of Labor" on Justia Law

A North Dakota truck stop and convenience store challenged a Federal Reserve regulation that set a 21-cent cap on debit card interchange fees charged by cardholder banks to merchants. The dispute centered on the statutory requirement that such fees be “reasonable and proportional to the cost incurred by the issuer with respect to the transaction,” specifically requiring that only the “incremental cost incurred . . . in the authorization, clearance, or settlement of a particular electronic debit transaction” be considered, while excluding other costs not specific to individual transactions.After the Supreme Court held that the plaintiff’s challenge was timely under the Administrative Procedure Act, the United States District Court for the District of North Dakota considered the merits. On summary judgment, the district court found that the Federal Reserve’s regulation impermissibly included non-transaction-specific costs, such as fixed costs related to authorization, clearance, and settlement, network processing fees, fraud-monitoring costs, and fraud losses, in setting the fee cap. The district court concluded this approach violated the statute and ordered the rule vacated, but stayed its decision pending appeal.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The appellate court determined that the statute requires the Federal Reserve to consider only the marginal (incremental) costs of individual debit transactions, not fixed or non-specific costs. It held that the Federal Reserve’s regulation was contrary to law because it failed to distinguish properly between transaction-specific and non-specific costs, and it set a uniform cap without sufficient regard to statutory requirements. The Eighth Circuit affirmed the district court’s judgment vacating the 21-cent cap and remanded for the agency to establish a fee structure consistent with the statutory mandate. View "Corner Post, Inc. v. Board of Governors" on Justia Law

The case concerns a defendant whose probation officer discovered internet-capable devices at his residence, despite his prohibition from possessing such devices. On these devices, authorities found searches for terms like “young naked teen boys” and “boys,” as well as cache images depicting young-looking individuals engaged in sexual acts. The defendant had previous convictions for possession of child pornography and sexual exploitation of a minor.After these discoveries, the United States District Court for the Southern District of Iowa admitted evidence of the defendant’s prior convictions at trial. The court also allowed testimony from a detective regarding typical search patterns of people seeking child pornography. The exhibits containing cache images were handled under special procedures, kept in a red binder and only accessed at the court’s direction. The defendant did not object to the handling of the exhibits or the language used in reference to them during trial.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed several challenges: the sufficiency of the evidence supporting conviction, the admissibility of prior convictions under Federal Rule of Evidence 404(b), the admission of the detective’s testimony under Rule 704(b), and the court’s handling of the exhibits under Rule 403. The Eighth Circuit held that sufficient evidence supported the jury’s findings as to intent and substantial step toward attempted receipt of child pornography. The court concluded the prior convictions were properly admitted for intent, motive, and knowledge, and were not unfairly prejudicial. The detective’s testimony was found not to violate Rule 704(b) because it did not opine directly on the defendant’s mental state. The handling of the exhibits was not erroneous or unduly prejudicial. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Baker" on Justia Law