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

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The Eighth Circuit affirmed defendant's sentence and rejected the contention that the district court created unwarranted disparities contrary to 18 U.S.C. 3553(a)(6), when it refused to vary from a guidelines provision that other district judges disagree with as a matter of sentencing policy. In this case, defendant was essentially asking the court to compel the district court to disagree with a guidelines provision as a matter of sentencing policy because other sentencing judges have done so. View "United States v. Heim" on Justia Law

Posted in: Criminal Law
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Plaintiffs filed suit against Dometic, alleging that the fire that extensively damaged a storage building and personal property owned by plaintiffs was caused by a defective Dometic refrigerator installed in their RV. The Eighth Circuit affirmed the district court's grant of summary judgment to Dometic, holding that Dometic was immune from liability under Iowa Code 613.18 because it sold, but did not manufacture, design, or assemble the refrigerator. The court held that any design input by Dometic was not related in any way to the boiler tubes, or that Dometic had any role in designing the boiler tubes. View "Merfeld v. Dometic Corp." on Justia Law

Posted in: Products Liability
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Plaintiff and others filed a class action against defendants, alleging claims under the Fair Labor Standards Act (FLSA) and Nebraska law, arising out of an eight-week student-driver training program operated by defendants and intended for new truck drivers. The Eighth Circuit agreed with defendants that the district court abused its discretion by granting plaintiffs' request to extend the Federal Rule of Civil Procedure 16(b) disclosure deadline, despite finding that good cause for the extension had not been shown, based on an erroneous application of Rule 37(c)(1). The court held that the error was not harmless because the jury clearly relied on the opinion of plaintiff's expert in reaching the damages award. Accordingly, the court vacated and remanded for further proceedings. View "Petrone v. Werner Enterprises, Inc." on Justia Law

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The Eighth Circuit denied a petition for review of the BIA's order denying cancellation of removal and ordering petitioner removed, and subsequently denying his timely motion to reopen proceedings. The court held that petitioner was challenging the discretionary conclusion of the BIA against him and thus the court did not have jurisdiction. The court also held that the BIA did not abuse its discretion in denying the motion to reopen, because the BIA had the final authority to decide whether to grant discretionary cancellation-of-removal relief. View "Urrutia Robles v. Barr" on Justia Law

Posted in: Immigration Law
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Plaintiff filed suit against Dollar General after the company denied her request for a leave of absence due to a medical condition, alleging claims under the Americans with Disabilities Act (ADA), the Family Medical Leave Act (FMLA), and state law. The court reversed the district court's dismissal of plaintiff's ADA claim and held that a reasonable jury could conclude that Dollar General was aware of her disability; that she requested an accommodation; and that Dollar General, had it engaged in the interactive process, could have reasonably accommodated her. However, plaintiff's remaining claims failed because she could not show defendants' actions amounted to retaliation and she failed to follow the steps Dollar General had established for requesting FMLA leave. View "Garrison v. Dolgencorp, LLC" on Justia Law

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The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court rejected defendant's claim under Rehaif v. United States, 139 S. Ct. 2191 (2019), and held that there was no plain error where defendant failed to show a reasonable probability that, but for the error, the outcome of the proceeding would have been different. Assuming without deciding that the district court erred in admitting a photo lineup identification in violation of defendant's Sixth Amendment right to confrontation, the court held that admission of such evidence did not affect defendant's substantial rights. The court also held that the evidence was sufficient for a reasonable jury to find defendant guilty beyond a reasonable doubt. Finally, the court held that the district court did not abuse its discretion by imposing two special conditions for defendant's supervised-release term --requiring defendant to participate in anger management treatment and domestic violence treatment -- in light of defendant's behavior problems in the past. View "United States v. Hollingshed" on Justia Law

Posted in: Criminal Law
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The Eighth Circuit affirmed defendant's appeal of the Sex Offender Registration and Notification Act (SORNA) registration requirements as a condition of his release. The court held that the plea agreement, in which defendant entered into knowingly and voluntarily, waived the issue presented and there was no miscarriage in enforcing it. View "United States v. Knight" on Justia Law

Posted in: Criminal Law
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The Eighth Circuit affirmed the district court's denial of defendant's motion to dismiss the indictment on double jeopardy grounds. The court held that the same conduct can result in both a revocation of a defendant's supervised release and a separate criminal conviction without raising double jeopardy concerns. In this case, the imposition of defendant's sentence under 18 U.S.C. 3583(g) was a sanction rather than a punishment for a separate offense, and thus criminal prosecution did not violate double jeopardy. View "United States v. Wilson" on Justia Law

Posted in: Criminal Law
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Iowa inmates filed a 42 U.S.C. 1983 action against the IDOC and IDOC officials, alleging that IDOC's administration of its Sex Offender Treatment Program violates their constitutional rights to equal protection, due process, and necessary medical care. The Eighth Circuit held that the district court erred in concluding that the federal claims must be dismissed without prejudice under 42 U.S.C. 1997e(a), because plaintiffs failed to exhaust their available post-conviction remedies under Belk v. State, 905 N.W.2d 185, 191 (Iowa 2017). In this case, defendants cite no case holding that post-conviction judicial remedies were "administrative remedies" that must be exhausted under section 1997e(a), and the court has not found an opinion that even addresses the question. The panel also held that plaintiffs' claim that defendants' unconstitutional conduct deprived plaintiffs of their statutory right to accrue earned-time credit and of receiving a reduction of sentence was barred by Heck v. Humphrey, 512 U.S. 477 (1994). Accordingly, the panel reversed and remanded for further proceedings. View "Minter v. Bartruff" on Justia Law

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A corporation that acquires substantially all the assets of an unrelated competitor at a secured creditor's private foreclosure sale, in an agreement that declines to assume the competitor's liabilities, is not liable as the competitor’s successor for unpaid pre-acquisition inventory purchases from a third party. The Eighth Circuit affirmed the district court's grant of summary judgment dismissing Westfeldt's counterclaims for successor liability, unfair trade practices, conversion, and unjust enrichment, primarily on the ground that Westfeldt failed to submit evidence that the foreclosure and asset sale were anything but bona fide business transactions. The court held that buying USR assets from Great Western at a foreclosure sale in an agreement that disclaimed assumption of USR liabilities protected Ronnoco from claims that the asset purchase was tainted by commercially inadequate consideration. In this case, Westfeldt offered no evidence that it was prejudiced by the asset sale. Furthermore, there was no evidence that, absent the alleged fraud by Ronnoco, USR would have been able to pay off its entire debt to Great Western and then make payment to Westfeldt. Finally, the district court properly rejected Westfeldt's remaining claims. View "Ronnoco Coffee, LLC. v. Westfeldt Brothers, Inc." on Justia Law

Posted in: Business Law