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

Cemen Tech manufactures concrete production equipment and entered into a Reseller Agreement with G.W. Van Keppel Company in 2016, authorizing Van Keppel to sell and service its products. The agreement included a publicity provision prohibiting either party from making public statements about the other or the agreement without prior consent. In late 2025, Cemen Tech alleged Van Keppel breached contractual obligations and signaled intent to terminate if not remedied. Van Keppel denied the breach, but Cemen Tech formally terminated the agreement in early 2026. Shortly after, Van Keppel sent a message to its customers and employees explaining the termination and defending its performance, which Cemen Tech viewed as a violation of the publicity provision.The United States District Court for the Southern District of Iowa reviewed the matter after Cemen Tech sought a preliminary injunction to prevent Van Keppel from making further public statements about Cemen Tech or the agreement without its approval. The court held a hearing and considered evidence presented by both parties. It granted the injunction, finding Van Keppel’s communication posed a risk of irreparable harm to Cemen Tech’s reputation, goodwill, and customer relationships, and enjoined Van Keppel from making public statements about Cemen Tech or the agreement without Cemen Tech’s consent.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion, examining factual findings for clear error and legal conclusions de novo. Van Keppel challenged the sufficiency of Cemen Tech’s showing of irreparable harm and the breadth of the injunction. The appellate court held that the district court did not abuse its discretion in finding a risk of irreparable harm or in issuing the injunction. Because Van Keppel did not properly raise the overbreadth argument below, it was not considered on appeal. The Eighth Circuit affirmed the district court’s order. View "Cemen Tech, Inc. v. G.W. Van Keppel Co." on Justia Law

Two cousins established a custom T-shirt company in 2012, entering into agreements governing equal ownership and joint authorization of disbursements. One founder took medical leave in 2017, allegedly delegating management duties and compensation to the other. During his absence, he claims he was denied access to company financial records and excluded from payment decisions, contrary to the agreements. The business declined, and in 2023, the founder sold his share for $550,000, releasing all related claims. He later discovered purportedly suspicious financial payments and asserts he would not have agreed to the buyout had he known about them. The company was acquired and dissolved in 2024. The founder then brought federal RICO and state law claims, individually and on behalf of the company, against various related parties, alleging financial misconduct.The United States District Court for the District of South Dakota dismissed the action without prejudice, denied leave to amend the complaint as futile, and awarded attorney fees to two defendants based on an indemnification provision in the buyout agreement. The court found the plaintiff lacked capacity to bring derivative claims because he was no longer a company member, and that his individual claims failed because his injuries were not distinct from those suffered by all shareholders. The plaintiff’s motion for reconsideration was also denied.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court affirmed the district court’s rulings, holding that the plaintiff lacked legal capacity to bring derivative RICO claims and failed to allege a distinct individual injury sufficient for direct RICO claims. The denial of leave to amend was upheld because the proposed amendments would not cure these deficiencies. The court also concluded it had jurisdiction to review the attorney fees award and affirmed that award, finding no reversible error in the district court’s application of the indemnification provision. View "Stewart v. Plains Commerce Bank" on Justia Law

The defendant pleaded guilty to being a felon in possession of a firearm after two incidents in which law enforcement found him with handguns shortly after his parole for a prior second-degree murder conviction ended. In April 2024, police found him intoxicated in a vehicle with a loaded handgun, and in May 2024, he was stopped for erratic driving and admitted to having a gun and consuming alcohol. Upon his arrest, officers discovered a suspected bag of marijuana. The defendant had a lengthy criminal record, including multiple convictions for driving without a valid license, driving while intoxicated, drug offenses, and violent crimes.The United States District Court for the Eastern District of Missouri accepted the plea agreement, dismissed a second count, and calculated a guideline range of 51 to 63 months. After hearing from both parties and reviewing the Presentence Investigation Report, which was not contested, the district court found the defendant’s criminal history to be understated and determined that a longer sentence was necessary to deter further unlawful behavior. The court imposed an 84-month sentence, granting an upward variance from the guidelines.On appeal to the United States Court of Appeals for the Eighth Circuit, the defendant argued that the district court had relied on erroneous facts at sentencing. Applying plain error review, the appellate court found no clear factual errors in the district court’s statements and determined that, even if errors existed, there was no reasonable probability that the defendant would have received a lower sentence absent those errors. The Eighth Circuit affirmed the judgment of the district court, holding that the procedural challenge failed and the sentence was properly imposed. View "United States v. Times" on Justia Law

The plaintiff, John William Scharnhorst, III, was held as a pretrial detainee at the Washington County Detention Center (WCDC) for several months. During his detention, he experienced restrictions on access to books, newspapers, and religious materials. WCDC implemented these restrictions in response to issues with inmates using paper for illicit purposes, such as jamming locks, flooding cells, concealing contraband, and making weapons. The facility limited inmates to four books—three from a book cart and one religious text—and transitioned to providing electronic access to books and newspapers via kiosks and tablets, though access to these devices was time-limited. While religious materials and paper mail could be requested, Scharnhorst claimed that staff inconsistently delivered these materials.The United States District Court for the Western District of Arkansas, adopting a magistrate’s recommendation, granted summary judgment to some defendants and found moot the preliminary injunction requiring daily newspaper uploads. However, it denied summary judgment and qualified immunity to Sheriff Cantrell, Major Denzer, and Lieutenant Ake, finding material disputes about their enforcement of WCDC policies and concluding that, if enforced as alleged, the restrictions violated clearly established First Amendment rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of qualified immunity. Accepting the facts found or likely assumed by the district court, the appellate court held that Scharnhorst did not demonstrate a violation of clearly established law. The Eighth Circuit found that WCDC’s policies did not amount to a “de facto permanent ban” on communication or access to religious materials, as inmates retained access to mail, electronic newspapers, and religious texts. Consequently, the court reversed the district court’s denial of qualified immunity to the defendants and remanded for further proceedings. View "Scharnhorst v. Cantrell" on Justia Law

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