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

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

Two individuals, Roberto Miranda and Roberto Orellana, traveled together to a restaurant parking lot, where a casino employee handed them a box containing $352,000. The employee had been deceived into surrendering the money, which belonged to the Standing Rock Sioux Tribe. Both men were charged with federal crimes related to transporting stolen money and aiding and abetting that offense. Orellana also faced a charge for illegal reentry into the United States. Each pleaded guilty to the relevant offenses.The United States District Court for the District of South Dakota sentenced Miranda to seventy months’ imprisonment, an upward variance from the Sentencing Guidelines range of 41–51 months, based in part on findings that Miranda minimized his involvement and was not candid. Orellana received a fifty-month sentence, also exceeding his Guidelines range of 30–37 months. Both defendants had entered plea agreements containing broad appeal waivers, though each preserved limited rights to appeal the substantive reasonableness of a sentence above the Guidelines range.On appeal, the United States Court of Appeals for the Eighth Circuit ruled that Miranda knowingly and voluntarily waived his right to challenge the district court’s calculation of his Sentencing Guidelines range and dismissed that part of his appeal. The appellate court found no abuse of discretion in Miranda’s sentence and affirmed it. With respect to Orellana, the Eighth Circuit concluded that the district court committed plain error by speculating, without record support, that Orellana was involved with Mexican drug cartels and that this speculation was a principal basis for the sentence imposed. The court determined this error affected Orellana’s substantial rights and the fairness of the proceedings. Accordingly, the Eighth Circuit vacated Orellana’s sentence and remanded his case for resentencing. View "United States v. Orellana" on Justia Law

The petitioner, a native of The Gambia, entered the United States on a student visa but never attended the educational institution for which he was admitted. Prior to leaving The Gambia, he worked as a professor and was targeted and physically abused by government officials after expressing views critical of the then-president during a lecture. Following his release from detention, he received warnings to avoid political subjects and ultimately left the country without proper clearance. Subsequent bench warrants were issued for his arrest for his method of departure. After a change in government leadership in The Gambia, his wife continued to receive inquiries about his whereabouts.The Department of Homeland Security initiated removal proceedings in 2018, and the petitioner applied for asylum, humanitarian asylum, withholding of removal, and relief under the Convention Against Torture. The Immigration Judge held an evidentiary hearing, found credible evidence of past persecution, and determined the petitioner was initially entitled to a presumption of a well-founded fear of future persecution. However, the judge concluded that substantial changes in The Gambia’s political climate, particularly after the election of President Barrow and the implementation of reforms, rebutted this presumption. Relief was denied, and the petitioner was ordered removed. The Board of Immigration Appeals affirmed the Immigration Judge’s findings, agreeing that the new administration’s steps established a fundamental change in circumstances and that the past persecution was not so severe as to warrant humanitarian asylum.The United States Court of Appeals for the Eighth Circuit reviewed the administrative record and found substantial evidence supporting the decisions of both the Immigration Judge and the Board of Immigration Appeals. The court held that the government successfully rebutted the presumption of a well-founded fear of future persecution, the past harm did not warrant humanitarian asylum, and the petitioner failed to meet the higher standards for withholding of removal and CAT relief. The petition for review was denied. View "Jatta v. Blanche" on Justia Law

Two children, whose parents divorced in Missouri, were involved in a custody dispute. After the parents agreed to a custody arrangement, the children refused to leave the courthouse with their mother. Judge Eric Eighmy intervened, escorting the children to a conference room and later to the juvenile division, where repeated threats of foster care failed to persuade them. Ultimately, Judge Eighmy ordered a juvenile officer to lock the children in holding cells for twenty to forty minutes, after which they agreed to leave with their mother.The children’s father brought suit in the United States District Court for the Western District of Missouri, alleging violations of their Fourth Amendment rights under 42 U.S.C. § 1983. Judge Eighmy’s claim for judicial immunity was denied both at the motion-to-dismiss and summary-judgment stages, and the Eighth Circuit previously affirmed that denial in Rockett ex rel. K.R. v. Eighmy, 71 F.4th 665 (8th Cir. 2023). After a trial, the jury found for the children, awarding $5,000 each in damages. The district court resubmitted the damages issue for clarification and ultimately upheld the jury’s award, also granting $326,637.22 in attorney fees.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo and affirmed the district court’s judgment. The court held that Judge Eighmy’s actions constituted an unreasonable seizure in violation of clearly established Fourth Amendment rights. The court also dismissed the appeal regarding judicial immunity, finding it unreviewable due to procedural forfeiture. The Eighth Circuit affirmed the damages and attorney fees awards, finding no abuse of discretion by the district court. The disposition was to dismiss the appeal in part and affirm the district court’s judgments. View "Rockett v. Eighmy" on Justia Law

Late at night, a police officer in Des Moines, Iowa, stopped a vehicle because its registered owner had an outstanding warrant. David Negrete was the front-seat passenger. The officer detected a strong smell of marijuana and noted Negrete's suspicious behavior, such as shielding his face and looking down. As backup officers arrived, Negrete exited and then re-entered the vehicle at an officer's instruction. After further suspicious movements by Negrete, an officer conducted a frisk, during which methamphetamine was found in Negrete’s pocket. A firearm was also discovered under the seat where Negrete had been sitting and a backpack containing additional drugs and paraphernalia was located on the passenger side floor.Negrete was indicted for being a felon in possession of a firearm. He moved to suppress evidence obtained from his person and the vehicle, arguing that the detention and frisk were unlawful. The United States District Court for the Southern District of Iowa denied the motion, finding the stop and detention lawful and the frisk constitutional except for an inadvertent intrusion into Negrete’s pocket, which yielded no evidence. Negrete entered a conditional guilty plea, preserving his right to appeal the suppression ruling. At sentencing, the district court applied a four-level enhancement for possessing a firearm in connection with another felony offense, finding the loaded gun’s location facilitated Negrete’s drug possession, and imposed a 77-month sentence.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to suppress de novo and its factual findings for clear error. The appellate court held that Negrete’s detention and the frisk were lawful and that the four-level sentencing enhancement was properly applied because the firearm had the potential to facilitate Negrete’s drug possession. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Negrete" on Justia Law

A Black woman employed by Remington Ammunition in Arkansas alleged that she was subjected to race and gender discrimination, a hostile work environment, and retaliation. She claimed her white male coworkers sabotaged her workspace, destroyed a productivity tool she had created, and falsely reported her as absent. She attempted to complain to Human Resources by email but her email was not received. She later complained verbally to supervisors, who did not formally document her complaint. The supervisors investigated and found no evidence of discrimination. Reed subsequently received written reprimands for alleged workplace misconduct and, following an incident with a supervisor, was terminated.After her termination, Reed filed suit in July 2024 in the United States District Court for the Eastern District of Arkansas, Central Division, asserting claims under Title VII of the Civil Rights Act and the Arkansas Civil Rights Act. Remington moved for summary judgment, arguing Reed could not establish a prima facie case for any of her claims. The district court granted summary judgment to Remington and dismissed all claims.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The court held that Reed failed to establish an inference of discrimination, noting she did not show that similarly situated employees were treated differently or that the investigation into her complaints was biased. The court found that Reed could not demonstrate the legitimate reasons for her termination were pretextual. For her retaliation claim, the court concluded the six-month gap between protected activity and termination was insufficient to establish causation, especially given intervening disciplinary events. Regarding the hostile work environment claim, the court found Reed did not provide evidence of harassment severe or pervasive enough to alter her employment, nor did she link any mistreatment to her race or sex. The Eighth Circuit affirmed the district court’s summary judgment in favor of Remington. View "Reed v. The Kinetic Group" on Justia Law

Maria Lily Alvarenga and her son, E.D.B.A., are Honduran nationals who entered the United States unlawfully in April 2019. After encountering Border Patrol, Alvarenga was placed in removal proceedings for being present without admission or parole. She admitted to being a Honduran citizen and lacking a visa or passport. In the second phase of proceedings, Alvarenga sought relief from removal, claiming asylum, statutory withholding of removal, and protection under the Convention Against Torture (CAT), based on alleged gang-related persecution by MS-13. She stated MS-13 attempted to recruit her son, threatened him, and threatened to harm her, though no physical harm occurred, and the threats were not acted upon. Alvarenga did not report these incidents to Honduran authorities.An Immigration Judge determined Alvarenga was removable and denied her claims for relief, finding insufficient evidence of persecution based on a protected ground and no demonstration of government acquiescence in torture. Alvarenga appealed to the Board of Immigration Appeals (BIA), asserting that the IJ erred and violated her due process rights by committing procedural mistakes. The BIA dismissed the appeal, affirming the IJ’s decision.The United States Court of Appeals for the Eighth Circuit reviewed Alvarenga’s petition. The court held that Alvarenga’s due process claim failed because she did not demonstrate prejudice from any alleged procedural errors. Regarding asylum and withholding of removal, the court found substantial evidence supported the BIA’s determination that Alvarenga’s proposed social group was not sufficiently particular or socially distinct, and her claim based on imputed political opinion was not substantiated by precedent. For CAT relief, the court concluded Alvarenga failed to show government acquiescence or awareness of the alleged threats. The Eighth Circuit denied the petition for review, affirming the BIA’s decision. View "Alvarenga v. Blanche" on Justia Law

The plaintiff worked for the City of Rochester, Minnesota Fire Department in an administrative management role and received positive performance reviews for several years. After organizational changes and a strategic review of the department, his supervisors began to question his management abilities, citing critical feedback from colleagues and administrative staff. As a result, his position was reclassified, leading to a reduction in responsibilities and a significant pay cut. The plaintiff, who was sixty years old at the time, chose to retire shortly after being informed of these changes and subsequently filed a lawsuit alleging age discrimination, violation of procedural due process, and civil conspiracy.The United States District Court for the District of Minnesota granted summary judgment to all defendants, dismissing the plaintiff’s claims. The court found that he failed to present a prima facie case of age discrimination, particularly because he was not constructively discharged and did not demonstrate that the employer’s stated reasons for the reclassification were pretextual. The court also held that the procedural due process claim failed since the plaintiff had not utilized available grievance procedures outlined in the collective bargaining agreement, and the civil conspiracy claim failed due to lack of any underlying constitutional violation.The United States Court of Appeals for the Eighth Circuit reviewed the lower court’s grant of summary judgment de novo and affirmed. The appellate court held that the plaintiff did not establish “objectively intolerable” working conditions or employer intent required for constructive discharge. Additionally, he failed to give the employer a reasonable opportunity to address his concerns, which is required for such claims. The court also determined that the plaintiff’s procedural due process claim failed because he voluntarily retired and did not exhaust available remedies. Without an underlying constitutional violation, the civil conspiracy claim was properly dismissed. The district court’s judgment was affirmed in full. View "Pronk v. City of Rochester" on Justia Law

A group of individuals required to register as sex offenders under Missouri’s Sex Offender Registration Act (Mo. SORA), along with their spouses and children, filed suit against Missouri State Highway Patrol officials responsible for enforcing the law. The plaintiffs challenged various aspects of Mo. SORA, including its registration requirements, the lack of individualized risk assessments, the tiered system of registration durations, and reporting obligations for online identifiers. They asserted that these provisions violated their constitutional rights and also caused harm to their family members, who experienced social stigma and other indirect consequences.The United States District Court for the Western District of Missouri dismissed the claims of the family members, finding they were not directly subject to Mo. SORA and that incidental effects on them were irrelevant to the constitutional analysis. The court also rejected the plaintiffs’ Eighth Amendment and Ex Post Facto Clause challenges, concluding that Mo. SORA was not punitive. It found the statute’s requirements regarding online identifiers were not unconstitutionally vague because the registration form specified the information to be provided. The court dismissed the due process and equal protection claims, finding no fundamental rights or suspect classifications were implicated and that the statute was rationally related to legitimate state interests. Regarding the First Amendment, the court held that the prior restraint on use of online identifiers was unconstitutional, and the parties agreed to modify the registration form to remove that requirement.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that (1) Mo. SORA is not punitive for Eighth Amendment or Ex Post Facto purposes, (2) the statute is not unconstitutionally vague regarding online identifiers, (3) no cognizable due process or equal protection claims were stated, (4) the family members lacked standing, and (5) the First Amendment claim was properly resolved by modifying the reporting requirement. View "Does v. Flannigan" on Justia Law