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

An organization based in Virginia requested access to Minnesota’s Registered Voter List under a federal statute, asserting it was entitled to the records despite Minnesota’s exemption from the law. Minnesota denied the request, citing its exemption as a state with continuous election-day registration since August 1, 1994. The organization also sought the information under a Minnesota statute, but was again denied because no Minnesota-registered voter joined the request. The organization acknowledged it could obtain the information by recruiting a Minnesota voter but did not do so. It then filed suit, claiming Minnesota’s exemption from the federal disclosure requirement was unconstitutional, alleging informational injury and other adverse consequences.The United States District Court for the District of Minnesota reviewed the case. Minnesota moved to dismiss, and the United States intervened to defend the statute’s constitutionality. The district court dismissed the organization’s claim on the merits, concluding that the “equal sovereignty” principle does not apply to Congress’s authority under the Elections Clause.On appeal, the United States Court of Appeals for the Eighth Circuit considered whether the organization had Article III standing. The court reviewed standing de novo and focused on whether the plaintiff had suffered a concrete injury in fact. The court held that a purely informational injury does not satisfy Article III’s requirements and found the plaintiff’s alleged downstream consequences insufficient, as they lacked a nexus to the interests Congress sought to protect. The court concluded the plaintiff failed to allege a concrete injury and therefore lacked standing.The Eighth Circuit vacated the district court’s judgment and remanded with instructions to dismiss the complaint for lack of jurisdiction. View "Public Interest Legal Foundation, Inc. v. Simon" on Justia Law

The plaintiff experienced ongoing pain, numbness, and tingling in both hands and upper extremities, which led her to stop working her retail job in June 2016 following surgeries on both hands and forearms. Despite subsequent surgeries and ongoing treatment—including physical therapy and additional procedures on her shoulders—she continued to report symptoms, though medical records at times showed normal strength and range of motion. Throughout this period, she reported being able to perform various daily activities, such as driving, doing housework, and caring for family members, though some medical providers imposed restrictions on lifting weight.The plaintiff applied for disability insurance benefits for a closed period from June 3, 2016 to August 5, 2021. An administrative law judge (ALJ) reviewed her application, considering her medical records, her function report, and opinions from treating and reviewing physicians. The ALJ determined that she had the residual functional capacity to perform sedentary work, which allows for lifting up to ten pounds, and found that she could frequently handle, finger, and reach for objects. Based on this assessment and testimony from a vocational expert regarding available jobs, the ALJ concluded that the plaintiff was not disabled. The United States District Court for the Eastern District of Missouri affirmed the ALJ’s decision.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The Eighth Circuit held that the ALJ’s determination was supported by substantial evidence, particularly in the evaluation and reliance on a medical opinion that was consistent with the claimant’s activities and medical records. The court concluded that the ALJ’s residual functional capacity finding and the denial of disability benefits fell within the permissible zone of choice and therefore affirmed the judgment. View "Post v. Bisignano" on Justia Law

Federal law enforcement intercepted thousands of phone calls between April and June 2021, some of which involved the defendant discussing marijuana and firearm transactions. In April 2022, following a traffic stop, officers detected a strong marijuana odor and, after a brief struggle, arrested the defendant. A search of his vehicle uncovered firearms, large quantities of marijuana, codeine, and cash. The next day, a Glock switch was found in the patrol car where the defendant had been held. He was initially charged in May 2022 by indictment for offenses relating to this incident and later indicted again with 34 codefendants in a broader drug conspiracy case in November 2022.The United States District Court for the Eastern District of Arkansas denied the defendant’s motion to dismiss the indictment on Speedy Trial Act and Sixth Amendment grounds. The trial jury convicted him on several counts, including conspiracy to distribute marijuana, possession with intent to distribute marijuana, possession of a firearm in furtherance of a drug trafficking crime, and use of a communications facility in furtherance of a drug crime. He was acquitted on others, including possession of a machinegun. The district court sentenced him to a total of 150 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed challenges to the indictment’s timeliness, evidentiary rulings admitting certain rap lyrics, and the reasonableness of the sentence. The court held that there was no violation of the Speedy Trial Act or the Sixth Amendment, finding that necessary continuances were justified and adequately explained. The court also concluded that the district court did not abuse its discretion in admitting limited rap lyric evidence, nor did it err in its application of sentencing enhancements or in declining a reduction for acceptance of responsibility. The court affirmed the convictions and the sentence imposed by the district court. View "United States v. Gladney" on Justia Law

A business specializing in adult products sought to open a store in downtown Fargo, North Dakota, in a zone designated for mixed-use development. The proposed store intended to sell items such as lingerie and sexual wellness products, but not sexually explicit media like books or DVDs. To proceed, the business’s landlord applied for a change-of-use permit to allow retail sales and service at the location. The City of Fargo, through its Director of Planning and Development, denied the application, concluding that the business constituted an "Adult Bookstore" as defined by the city’s municipal code, which prohibited such establishments in the downtown zone. The city’s decision was upheld by both the Fargo Board of Adjustment and the Board of City Commissioners.Following these administrative decisions, the business filed suit in the United States District Court for the District of North Dakota, raising constitutional claims including violations of the First Amendment, the imposition of a prior restraint, denial of procedural due process, and unconstitutional vagueness in the city’s code. The business also challenged the Commissioners’ decision under state law, arguing it was arbitrary and capricious. While the lawsuit was pending, Fargo amended its code to explicitly prohibit “Sexual Device Shops” in the relevant zone.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the dismissal of all federal claims, holding that the business’s planned activities were not protected expressive conduct under the First Amendment, the permit process was not a prior restraint, and the business received adequate procedural process. The court also found the city’s ordinance was not unconstitutionally vague. However, the court determined that denying the permit as an “Adult Bookstore” was arbitrary and capricious under state law, reversed the dismissal of the state-law claim, and remanded for further proceedings regarding possible relief. View "Romantix-Fargo, Inc. v. City of Fargo" on Justia Law

The case involves a defendant who was indicted for participating in a drug conspiracy involving methamphetamine and marijuana. Three witnesses testified that they purchased or sold methamphetamine with the defendant at his residence, and that he was involved in distributing significant quantities of narcotics. Text messages and other evidence corroborated these accounts. Law enforcement also established connections between the defendant and his alleged drug suppliers, including evidence from a GPS tracker and observations of meetings. Additional evidence showed that the defendant possessed firearms in the same location where he stored and distributed drugs.A jury in the United States District Court for the District of Nebraska found the defendant guilty of conspiring to distribute and possess with intent to distribute 500 grams or more of methamphetamine. At sentencing, the district court found the defendant responsible for over 11,000 grams of methamphetamine, applied enhancements for firearm possession and for maintaining a premises for drug distribution, and imposed a 300-month sentence after varying downward from the advisory guideline range. The defendant challenged multiple aspects of his trial and sentencing, including evidentiary rulings, the admission of expert and co-conspirator testimony, denial of motions in limine, and sentencing enhancements.The United States Court of Appeals for the Eighth Circuit reviewed and affirmed the district court’s decisions. The appellate court held that the district court did not abuse its discretion or commit clear error in its evidentiary rulings, the admission of expert and co-conspirator testimony, or the application of sentencing enhancements. The court also found that the evidence was sufficient for the jury’s verdict and that any trial errors were either nonexistent or harmless. The sentence imposed was found to be substantively reasonable. Accordingly, the judgment of the district court was affirmed. View "United States v. Parrott" on Justia Law

Two individuals, both former members of several Missouri limited liability companies operating as a commercial insurance brokerage, entered into contracts with their company containing Missouri choice-of-law and forum-selection clauses, as well as customer non-solicitation covenants. The agreements required members to follow certain operating agreements, which included a provision allowing termination of membership interests upon 30 days’ notice. Despite this, both individuals resigned “effective immediately” and began working for a competitor. The company sued them in federal court in Missouri to enforce the contractual terms, while the former members filed lawsuits in California state court seeking to void the agreements.The United States District Court for the Western District of Missouri granted summary judgment for the company on the enforceability of the Missouri forum-selection and choice-of-law clauses, finding the individuals breached the forum-selection clauses by suing in California. The court also found the customer non-solicitation covenants enforceable to the extent the company sought to enforce them. However, it granted summary judgment to the former members on claims that they breached the notice provision and related fiduciary duties, and on certain other contract and tort claims. The court awarded the company attorneys’ fees for the Missouri litigation but only nominal damages for the forum-selection clause breaches, declining to award fees incurred in the California actions.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings on the enforceability of the choice-of-law and forum-selection clauses, as well as the customer non-solicitation covenants. It reversed the findings on the notice provision and fiduciary duty, holding these were breached, and directed entry of judgment for the company on those claims. The court vacated the nominal damages for the forum-selection clause breaches, instructing the district court to determine actual damages, and affirmed the attorneys’ fee awards to the company. The case was remanded for further proceedings consistent with these holdings. View "West Series of Lockton Companies, LLC v. Kaufman" on Justia Law

During an Alcoholics Anonymous meeting in Sikeston, Missouri, George Holland experienced a severe mental health crisis, displaying incoherent speech and ultimately brandishing a small pistol, which he placed in his mouth. The other attendees exited safely, leaving Holland alone and armed inside. Police responded and engaged with Holland from a concealed position outside an open door, repeatedly commanding him to drop his weapon. For most of the encounter, Holland neither pointed the firearm at officers nor threatened them directly. After about fifteen minutes, Holland moved into clear view, holding the gun to his temple. In a sudden motion, he lowered the firearm and shifted his left arm toward it, prompting Officer Martin Simmerman to fire. Holland retreated, and Simmerman, followed by other officers, pursued him into the corridor, firing additional shots. Simmerman discharged fifteen rounds in total, striking Holland at least six times, resulting in Holland’s death.The Holland family brought suit against Simmerman and the City of Sikeston in the United States District Court for the Eastern District of Missouri, alleging excessive force under 42 U.S.C. § 1983, wrongful death, battery, and Monell claims. The defendants moved to dismiss, providing body camera footage. The district court found that the video evidence contradicted key allegations in the complaint, concluded that Simmerman was entitled to qualified and official immunity, and dismissed all claims with prejudice.On appeal, the United States Court of Appeals for the Eighth Circuit found that while the video evidence contradicted the allegation that Holland took no menacing action before the first volley of shots, it did not conclusively show the events during the subsequent volleys. The court held that Simmerman was entitled to qualified immunity for the initial shots but not for the later volleys, as the complaint plausibly alleged excessive force as to those shots. The appellate court reversed the dismissal of the excessive force claim, remanded for reconsideration of the related state-law and Monell claims, and affirmed in all other respects. View "Holland v. Simmerman" on Justia Law

A police officer in Jonesboro, Arkansas, encountered Jayden Prunty standing in the street holding a plastic bag late at night in an area known for high crime. The officer, identifying himself and stating he was conducting drug interdiction, approached Prunty, claimed to smell marijuana, and repeatedly told him to “come here.” Prunty denied the accusation, became visibly nervous, and walked away. When Prunty began to run, the officer caught him and pushed him to the ground. During the ensuing struggle, a firearm discharged, and the officer was shot in the leg. The officer then drew his own weapon and fatally shot Prunty. Prunty was later pronounced dead at the hospital.The administrators of Prunty’s estate brought a civil rights action in the United States District Court for the Eastern District of Arkansas under 42 U.S.C. § 1983, alleging violations of the Fourth and Fourteenth Amendments. The district court granted summary judgment in favor of the officer, finding that the officer’s actions did not violate clearly established rights and that he was entitled to qualified immunity. The court determined that the officer had reasonable suspicion to detain Prunty based on the odor of marijuana, Prunty’s nervous behavior, and attempted flight, and that his use of force was objectively reasonable under the circumstances.Reviewing the case de novo, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the officer did not seize Prunty until applying physical force, at which point reasonable suspicion existed. The court also found the officer’s use of force, including the takedown and subsequent use of deadly force after being shot, was objectively reasonable. Accordingly, the officer was entitled to qualified immunity, and the grant of summary judgment was affirmed. View "Prunty v. Obregon" on Justia Law

Law enforcement officers responded to a report of a possible drug overdose at a residence in Onamia, Minnesota. Upon arrival, they found Jeremy Burton unconscious with drug paraphernalia present. After being revived with Narcan, officers noticed a handgun magazine protruding from Burton’s shorts. During the encounter, another individual tried to prevent officers from retrieving the firearm, but it was ultimately secured. Burton was transported to a hospital and found to have multiple controlled substances in his system. He was charged as a felon in possession of a firearm, with a sentencing enhancement under the Armed Career Criminal Act due to prior convictions.The United States District Court for the District of Minnesota presided over Burton’s trial. The court granted the government’s motion in limine to exclude expert testimony from a pharmacologist regarding the effects of drugs on Burton’s mental state, finding voluntary intoxication was not a defense to the charge. At trial, Burton testified that someone had planted the gun on him while he was unconscious, but the jury found him guilty. The district court sentenced him to 240 months of imprisonment, which was a downward variance from the applicable guidelines range. Burton appealed, arguing error in excluding the expert testimony and that his sentence was substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary ruling for abuse of discretion and, where constitutional issues were implicated, de novo. The appellate court held that voluntary intoxication is not a defense to being a felon in possession of a firearm, and thus the exclusion of the expert testimony was proper. The court also found that the sentence was substantively reasonable, given the district court’s consideration of both aggravating and mitigating factors. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Burton" on Justia Law

Darius Carter, a convicted felon, and his girlfriend, Sarah Mason, sought to obtain firearms but were ineligible to purchase them themselves. They recruited Carter’s mother to serve as a “straw buyer,” who purchased two guns from a pawn shop after Carter and Mason made most of the payments. She falsely certified on federal forms that she was the actual buyer. Months later, Mason was found dead from a gunshot wound to the head, which led investigators to uncover the gun-buying scheme. Carter was subsequently charged with making and conspiring to make false statements in connection with acquiring firearms.The United States District Court for the Eastern District of Missouri allowed the government at trial to present evidence that Mason died under suspicious circumstances, over Carter’s objection that this testimony was irrelevant and prejudicial. Carter was convicted on both counts by a jury. At sentencing, the government presented further evidence implicating Carter in Mason’s murder, arguing for a significant sentence enhancement on the basis that he used one of the illegally purchased firearms to commit the killing. The district court found by a preponderance of the evidence that Carter had committed first-degree murder with one of the guns, applying a sentencing guideline cross-reference that dramatically increased his advisory sentencing range. Carter was sentenced to 180 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit held that although the district court abused its discretion by admitting irrelevant evidence regarding the suspicious nature of Mason’s death, the error was harmless given the overwhelming evidence of Carter’s guilt. The court also found no clear error in the district court’s factual findings at sentencing and held that applying the homicide cross-reference under the Sentencing Guidelines was proper. Accordingly, the appellate court affirmed the district court’s judgment. View "United States v. Carter" on Justia Law