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

The State of South Dakota charged Ronald Lee Neels with multiple sex-related offenses, including rape, sexual contact, and incest, for the sexual abuse of his adopted daughter over a 14-year period. During the trial, the prosecutor made an opening statement that asked the jury to imagine themselves in the victim's position, which is considered a "Golden Rule" argument and is generally condemned. Neels did not object to this statement at the time. Following his conviction, Neels filed a pro se petition for a writ of habeas corpus, claiming ineffective assistance of counsel for not objecting to the prosecutor's opening statement.The South Dakota Supreme Court summarily affirmed Neels's conviction on direct appeal, stating that the issues raised were without merit. Neels then filed a state habeas corpus petition, which was denied on the grounds of res judicata, as the court found that the issue of prejudice had already been decided on direct appeal. The South Dakota Supreme Court affirmed this decision, holding that the same standard of prejudice applied in both plain error review and ineffective assistance of counsel claims.Neels subsequently filed a federal habeas corpus petition under 28 U.S.C. § 2254. The district court granted the petition, concluding that Neels suffered prejudice from his attorneys' failure to object to the prosecutor's opening statement, despite acknowledging the overwhelming evidence of Neels's guilt. The court reasoned that the magnitude of the prosecutorial misconduct required vacating the conviction to ensure a fair trial.The United States Court of Appeals for the Eighth Circuit reversed the district court's decision. The appellate court held that Neels did not suffer Strickland prejudice from his counsel's failure to object to the prosecutor's opening statement, given the overwhelming evidence of his guilt. The court emphasized that the jury instructions and the strength of the evidence against Neels mitigated any potential prejudice from the prosecutor's improper remarks. View "Neels v. Fluke" on Justia Law

In 2020, a student organization at the University of Minnesota-Twin Cities, along with two students, sued the University for alleged First and Fourteenth Amendment violations. The case centered on the University's allocation of lounge space in the Coffman Memorial Union to certain student organizations, particularly nine cultural centers. The plaintiffs argued that this allocation constituted viewpoint discrimination and gave unbridled discretion to University officials.The United States District Court for the District of Minnesota dismissed three of the five claims and later granted summary judgment in favor of the University on the remaining claims. The court found no evidence of viewpoint discrimination and deemed the unbridled discretion doctrine inapplicable to the University's past allocation decision. The plaintiffs appealed the summary judgment on one claim.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court agreed that the lounge space was a limited public forum and found that the University's allocation process was viewpoint neutral and reasonable. The court noted that the plaintiffs failed to provide evidence of viewpoint discrimination and that the University's decision was based on status-based distinctions, not viewpoint-based ones. The court also upheld the district court's finding that the unbridled discretion doctrine did not apply, as the challenge was to a past decision rather than an ongoing policy.The Eighth Circuit affirmed the district court's summary judgment, concluding that the University's allocation of lounge space did not violate the First Amendment. View "Viewpoint Neutrality Now! v. Regents of the University of Minnesota" on Justia Law

On December 26, 2019, Officers Rozeboom and Malone responded to a shoplifting report at Dick’s Sporting Goods in Papillion, Nebraska. The suspects were described as a black male and black female in a silver four-door sedan. Malone spotted a similar vehicle and conducted a traffic stop. Storrs, a black male, was driving, and Smith, a white female, was the passenger. Despite the discrepancy in the suspect description, the officers detained Storrs and Smith. During the encounter, Storrs and Smith were uncooperative, leading to their arrest and a search of their vehicle, which allegedly smelled of marijuana.The United States District Court for the District of Nebraska granted summary judgment in favor of the officers, finding they were entitled to qualified immunity on all claims. The court determined that the officers had reasonable suspicion for the initial stop and probable cause for the continued detention and search based on the alleged odor of marijuana. The court also found no evidence of excessive force or First Amendment retaliation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision in part, agreeing that the officers had probable cause to arrest Storrs and Smith for obstructing a peace officer and that there was no evidence of excessive force or First Amendment retaliation. However, the court reversed the summary judgment on the claim of unlawful continued detention, finding that the officers lacked reasonable suspicion once they saw Smith was white. The court also found a genuine dispute of fact regarding the alleged odor of marijuana, precluding summary judgment on the illegal search claim. The case was remanded for further proceedings consistent with these findings. View "Storrs v. Rozeboom" on Justia Law

Allan Sanders, a foreman general at Union Pacific Railroad Company, sued his employer under the Americans with Disabilities Act (ADA). Sanders claimed that Union Pacific discriminated against him by imposing work limitations due to perceived cardiovascular health issues and by failing to provide a reasonable accommodation during a cardiovascular test. Sanders had suffered a brief cardiac arrest due to complications from a bleeding ulcer but had fully recovered. Union Pacific required him to undergo a fitness-for-duty evaluation, including a treadmill test, which he could not complete due to knee pain from osteoarthritis. Sanders requested an alternative test on a bicycle, which Union Pacific denied, leading to work restrictions that prevented him from returning to his job.The United States District Court for the District of Nebraska denied Union Pacific’s renewed motion for judgment as a matter of law after a jury found in favor of Sanders on both claims and awarded him damages. Union Pacific appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that there was sufficient evidence for a reasonable jury to conclude that Union Pacific regarded Sanders as disabled due to perceived cardiovascular issues and that Sanders was qualified to perform his job. The court also found that Union Pacific’s refusal to allow an alternative test constituted a failure to provide reasonable accommodation. The court rejected Union Pacific’s “direct threat” defense, concluding that the company’s decision was not objectively reasonable or based on the best available evidence. The appellate court upheld the jury’s verdict on both the disparate treatment and failure-to-accommodate claims. View "Sanders v. Union Pacific Railroad Co." on Justia Law

Enright Seeding, Inc. is involved in a dispute with the International Union of Operating Engineers, Local 150, AFL-CIO, regarding the nature of their collective bargaining agreement. Enright Seeding, a construction industry subcontractor, signed a bargaining agreement with the union in 2007, which included language suggesting it was a § 9(a) agreement under the National Labor Relations Act, indicating majority employee support for the union. The company later claimed that its obligations ended when it repudiated the contract in 2016. The union, however, argued that the agreement was a § 9(a) agreement and that the company violated the Act by not providing requested information.An administrative law judge determined that the agreement was a § 9(a) agreement and that Enright Seeding violated Sections 8(a)(1) and (5) of the Act by failing to provide the requested information. The judge also concluded that even if the agreement was under § 8(f), the company did not clearly repudiate it. A three-member panel of the National Labor Relations Board (NLRB) affirmed this decision, focusing on the § 9(a) status and not addressing the repudiation issue.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the NLRB's decision was not supported by substantial evidence, as there was no actual evidence of majority employee support for the union in 2007, only boilerplate contract language. The court emphasized that all evidence must be considered to determine the status of the relationship, and mere contract language is insufficient. The court also rejected the argument that Enright Seeding was barred from disputing the agreement's status due to the six-month limitation period in § 10(b) of the Act.The Eighth Circuit vacated the NLRB's order and remanded the case for further proceedings, without expressing a view on whether Enright Seeding had effectively repudiated the agreement or whether the union was entitled to the requested information under a § 8(f) agreement. View "NLRB v. Enright Seeding, Inc." on Justia Law

Michelle Collins, a black woman, worked at Union Pacific Railroad Company for 42 years, holding over twenty positions. She alleged that several managers discriminated against her based on race, including assigning her unpleasant tasks and increasing her workload. Collins also reported conflicts with a coworker, Rhonda VanLew, who allegedly made her job more difficult. In 2020, Collins filed an internal complaint about VanLew, and VanLew also filed a complaint against Collins. A Union Pacific analyst concluded that the conflict was appropriately resolved by local management.The United States District Court for the Western District of Missouri granted summary judgment in favor of Union Pacific. The court found that Collins could not establish a prima facie case of race discrimination or retaliation because she did not suffer an adverse employment action. Additionally, the court ruled that Collins's hostile work environment claim failed as she could not prove severe or pervasive harassment based on her race.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the summary judgment on the hostile work environment claim, agreeing that Collins did not sufficiently oppose the summary judgment on this ground in the lower court. However, the court reversed and remanded the discrimination and retaliation claims. The appellate court noted that the district court's analysis relied on outdated legal standards requiring a "materially significant disadvantage," which the Supreme Court had recently clarified was not necessary. The case was sent back to the district court to reconsider these claims under the correct legal framework. View "Collins v. Union Pacific Railroad Co." on Justia Law

The case involves a dispute over a Surface Use Agreement (SUA) between Mikkelson Land, LLLP, and Continental Resources, Inc. The disagreement centers on whether the SUA authorized Continental to install water pipelines on Mikkelson's property. Mikkelson claimed that the SUA did not permit such installations and filed a lawsuit alleging breach of contract, trespass, and seeking injunctive relief. Continental argued that the SUA explicitly allowed for the installation of water pipelines and moved forward with the project, compensating Mikkelson as per the SUA terms.The United States District Court for the District of North Dakota reviewed the case and granted summary judgment in favor of Continental. The court found that the SUA was unambiguous and explicitly authorized Continental to install water pipelines. The court also noted that the SUA included provisions for compensation related to the installation of such pipelines. Additionally, the court considered an addendum to the SUA, which expanded Continental's rights and further supported the installation of the pipelines. The district court concluded that Continental's actions were within the scope of the SUA and dismissed Mikkelson's claims.The United States Court of Appeals for the Eighth Circuit reviewed the appeal and affirmed the district court's decision. The appellate court agreed that the SUA's language was clear and unambiguous, granting Continental the right to install water pipelines. The court emphasized that the SUA specifically contemplated future installations of water pipelines and provided a payment structure for them. The court also found that the addendum to the SUA expanded Continental's rights, allowing for necessary operations, including the installation of water pipelines. Consequently, the appellate court upheld the summary judgment in favor of Continental, rejecting Mikkelson's arguments. View "Mikkelson Land, LLLP v. Continental Resources, Inc." on Justia Law

Kenneth Hunt arrived at the Lee County Courthouse to testify in a criminal case. Directed outside due to courtroom scheduling, Hunt re-entered and sat on a staircase. Officer Dale Acosta confronted Hunt, leading to a heated exchange. Despite Hunt's explanation of his courthouse business, Acosta arrested him for obstruction, claiming Hunt disrupted the county tax office.The United States District Court for the Eastern District of Arkansas dismissed most of Hunt's claims but allowed his Fourth Amendment claim against Acosta, a failure to train or supervise claim against Mayor Jimmy Williams and Chief of Police Martin Wilson, and a Monell claim against the City of Marianna. The court denied qualified and quasi-judicial immunity for Acosta and qualified immunity for Williams and Wilson. Acosta, Williams, and Wilson appealed the denial of immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court's denial of quasi-judicial immunity for Acosta's initial stop of Hunt, as Acosta acted under a judge's directive. However, the court affirmed the denial of quasi-judicial and qualified immunity for Acosta's arrest of Hunt, finding no probable cause for obstruction. The court also reversed the denial of qualified immunity for Williams and Wilson, ruling that Hunt failed to show a pattern of unconstitutional acts by Acosta that would have put them on notice. The case was remanded for further proceedings consistent with these findings. View "Hunt v. Acosta" on Justia Law

Frank Bibeau, a member of the Minnesota Chippewa Tribe, argued that his self-employment income from his law practice on the Leech Lake Reservation was exempt from federal taxation. For the 2016 and 2017 tax years, Bibeau reported his income on a joint federal income tax return with his wife, claiming a net operating loss carryforward that shielded his income from taxes but not from self-employment taxes. After receiving a notice from the IRS regarding his tax debts, Bibeau requested a Collection Due Process (CDP) hearing, arguing his income was exempt. The IRS disagreed and issued a notice of determination to collect the tax.Bibeau petitioned the United States Tax Court, asserting that Indians are generally exempt from federal taxes or that treaties between the U.S. and the Chippewa exempted his income. The Tax Court ruled against him, stating that Indians are subject to federal tax laws unless a specific law or treaty provides otherwise. The court found that neither the Indian Citizenship Act of 1924 nor the 1837 Treaty between the U.S. and the Minnesota Chippewa Tribe contained a specific exemption from federal taxation.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that as U.S. citizens, Indians are subject to federal tax requirements unless specifically exempted by a treaty or act of Congress. The court found that Bibeau failed to point to any statute or treaty that specifically exempted his self-employment income from taxation. The court also noted that the Indian Citizenship Act of 1924 and the 1837 Treaty did not provide such an exemption. Consequently, the Eighth Circuit affirmed the Tax Court’s decision, holding that Bibeau’s self-employment income is subject to federal self-employment taxes. View "Bibeau v. CIR" on Justia Law

Dalonte Foard and his uncle, Thomas Holbert, picked up two foster youths, M.D. and M.J., from their foster home. M.D. and M.J. were taken to a motel where Holbert took provocative photos of them to include in online prostitution advertisements. Holbert attempted to set up the minors with sex buyers but was unsuccessful. Eventually, M.D. left, leaving M.J. at the motel with Foard and his girlfriend, Tashian Hickman. Foard pressured M.J. to engage in sex acts and later created an online prostitution advertisement for her. A sex buyer, Michael Blue, paid for sex acts with M.J., and Foard took a portion of the money. M.J. was later returned to her foster home, and her foster mother called the police.A grand jury indicted Foard for conspiracy to engage in sex trafficking and sex trafficking of M.J. and M.D. The jury found Foard guilty of conspiracy to engage in sex trafficking and sex trafficking of M.J. but acquitted him of sex trafficking M.D. The United States District Court for the District of Nebraska sentenced Foard to 45 years of imprisonment followed by lifetime supervision.The United States Court of Appeals for the Eighth Circuit reviewed the case. Foard raised several challenges, including issues with jury instructions, admission of out-of-court statements, denial of his motion for acquittal, sentencing adjustments, and the substantive reasonableness of his sentence. The court found that the jury instructions permissibly narrowed the indictment, the out-of-court statements were admissible under the co-conspirator exclusion to hearsay, and there was sufficient evidence to support the jury's verdict. The court also upheld the sentencing enhancements for undue influence of a minor, use of electronic communications, vulnerable victim, and obstruction of justice. The court found no error in the district court's denial of a mitigating role reduction and concluded that the 45-year sentence was substantively reasonable. The Eighth Circuit affirmed the district court's judgment. View "U.S. v. Foard" on Justia Law