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

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In the United States Court of Appeals for the Eighth Circuit, Defendant Ledra Craig appealed his conviction for various counts related to the distribution of fentanyl. On August 2, 2020, Craig sold fentanyl to two men, R.P. and N.B., at a casino in Missouri. R.P. and N.B. were later found unconscious and R.P. ultimately died. Craig was then arrested and made a statement to officers after waiving his Miranda rights, which was later used as evidence during his trial.Craig raised three main points of contention in his appeal. First, he argued that text messages between him and an unidentified co-conspirator, "Glenn," were wrongly admitted under Federal Rule of Evidence 801(d)(2)(E). The court disagreed, stating that the texts, which discussed drug deals, were made during and in furtherance of a conspiracy. Second, Craig claimed that the court improperly denied him the right to present a complete defense by restricting his ability to question an officer about the circumstances surrounding his inculpatory statement. The court also rejected this argument, noting that Craig had been able to conduct a thorough cross-examination of the officer. Finally, Craig contended that evidence of his prior drug conviction was erroneously admitted under Federal Rule of Evidence 404(b) as it was irrelevant to the current case and served as improper propensity evidence. The court disagreed, stating that the prior conviction was relevant to his intent to engage in the charged conspiracy to distribute drugs. Based on these reasons, the court affirmed Craig's conviction. View "United States v. Craig" on Justia Law

Posted in: Criminal Law
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The case involves Sanimax USA, LLC, who sued the City of South Saint Paul, Minnesota, under 42 U.S.C. § 1983, alleging that the city's zoning and odor ordinances violated the First Amendment and Equal Protection Clause. Sanimax contended that the city enacted these ordinances in retaliation for Sanimax challenging prior ordinances and that the ordinances unfairly singled out Sanimax. The district court granted the city's motion for summary judgment on all counts.Sanimax operates a rendering plant in South Saint Paul that processes animal carcasses and organic byproducts, emitting pungent, foul odors that have drawn numerous complaints from nearby residents and businesses. Sanimax was designated as a "Significant Odor Generator" by the city, and later challenged the constitutionality of the city's odor ordinance, alleging that it was unconstitutionally vague.The United States Court of Appeals For the Eighth Circuit affirmed the district court's decision. The Court found that Sanimax failed to show that the city's actions were a direct retaliation for Sanimax's prior lawsuits challenging the city's ordinances. Additionally, the Court rejected Sanimax's argument that it was unfairly singled out, finding that Sanimax was not similarly situated to other businesses due to the significantly higher number of odor complaints it generated. Lastly, the Court rejected Sanimax's argument that the city's odor ordinance was unconstitutionally vague, finding that the ordinance provided sufficient notice of the prohibited conduct and did not lend itself to arbitrary enforcement. View "Sanimax USA, LLC v. City of South St. Paul" on Justia Law

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The case involves the Reporters Committee for Freedom of the Press, a nonprofit organization that sought to unseal court filings from federal criminal investigations. The District Court in Minnesota dismissed the application for lack of jurisdiction, and the case was appealed to the United States Court of Appeals for the Eighth Circuit.The Reporters Committee's application aimed to unseal electronic-surveillance filings, which were required to be filed under seal by a local rule. The District Court believed the request was too broad since the majority of the materials requested become unsealed after six months. The court suggested negotiations with the United States Attorney’s Office to reach a solution.The Reporters Committee subsequently filed an amended application, seeking an order directing the clerk of the court to presumptively unseal warrants and related documents after 180 days and to begin docketing the government’s applications for electronic surveillance regardless of whether a judge granted them. The Committee claimed these duties arose under the First Amendment and the common-law right of access to public records and documents.The District Court dismissed the application, concluding that the Committee lacked standing because all it had was a “generalized, abstract interest” in unsealing the records. This decision was affirmed by the Appeals Court, which held that the Committee failed to establish it suffered a “concrete” and “particularized” injury. It was also noted that the Committee did not sue anyone who could provide the relief it sought, hence there was a lack of adversity necessary for federal court adjudication. View "Reporters Comm. for Freedom of the Press v. United States" on Justia Law

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The case in question pertains to a dispute over the enforceability of dragnet clauses within mortgages used to secure loans funding Frank Welte’s farming operations. The Vera T. Welte Testamentary Trust, of which Frank Welte is the sole beneficiary, pledged its property as security for these loans, which were provided by Roger Rand, another Iowa farmer. The Trust's primary asset is 160 acres of farmland that were leased to Frank. Upon Rand's death, his estate initiated a foreclosure action against the Trust's farmland. The Trust subsequently filed for chapter 12 bankruptcy, which led to a stay of the foreclosure action against the Trust.The Estate filed a proof of claim and a motion to dismiss the Trust’s bankruptcy petition, alleging that the Trust was not a business trust as required by chapter 12. The Trust objected to the Estate’s proof of claim. The Iowa state court ruled that the dragnet clauses in the mortgage documents secured the loans made to Frank in excess of the face amount of the promissory notes.The United States Bankruptcy Court for the Northern District of Iowa, however, held that the dragnet clauses were not enforceable, thereby concluding that the Trust no longer owed a debt to the Estate. Following this, the United States District Court for the Northern District of Iowa gave preclusive effect to the judgment of the Iowa Court of Appeals concerning the enforceability of the clauses and the amounts owed thereunder.The Trust and the Estate both appealed the district court’s order. The United States Court of Appeals for the Eighth Circuit dismissed the appeal and cross-appeal due to lack of jurisdiction, as the district court's order was not final and required further proceedings in the bankruptcy court. View "The Security National Bank of Sioux City, IA v. Vera T. Welte Testamentary Trust" on Justia Law

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The case was an appeal by the Continental Cement Company (Continental) against a decision by the Federal Mine Safety and Health Review Commission. The Commission had determined that Continental had acted discriminatorily towards one of its employees, Tara Otten, by paying her less than she would have earned had she been working, instead of accompanying mine inspectors during an inspection, an activity known as her "walkaround right".Otten was a miner and designated miners' representative who had been trained to operate mobile equipment. Normally, she would receive a higher wage when operating this equipment. However, when she was performing her walkaround duty, Continental had stopped paying her the higher wage. This action was directed by a human resources specialist at Continental, who based the decision on the collective bargaining agreement.Otten subsequently filed a complaint against Continental with the Mine Safety and Health Administration (MSHA), and the Secretary of Labor filed a discrimination claim on Otten's behalf with the Commission. The Commission sided with the Secretary, agreeing that Continental had discriminated against Otten by causing her to suffer a loss of pay because she exercised her walkaround right. The Commission further held that Continental's decision was motivated by Otten's protected activity.The United States Court of Appeals for the Eighth Circuit, however, disagreed with the Commission's decision. The Court held that while Otten did suffer a loss of pay, which was a violation of the law, it did not automatically mean that Continental had discriminated against Otten. The Court clarified that discrimination occurs when an employer intentionally treats a person worse because of a protected characteristic. In this case, the Court found no evidence that Continental paid Otten less for the reason that she exercised her walkaround right. The Court, therefore, reversed the Commission's determination that Continental violated the discrimination law. View "Continental Cement Company v. Secretary of Labor" on Justia Law

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In the United States Court of Appeals for the Eighth Circuit, the court considered an appeal by Whitehorse Ducharme, who had pleaded guilty to abusive sexual contact with a child and was sentenced to life in prison. Ducharme challenged his sentence on two grounds. First, he asserted that the district court failed to consider the offense level used to calculate his recommended sentencing range. Second, he argued that the court imposed a substantively unreasonable sentence.The Court of Appeals rejected both arguments. Regarding the first, the court noted that the district court had indeed meticulously calculated Ducharme's offense level, and the assertion that it failed to consider the applicable offense level was untenable. Ducharme's actual issue appeared to be with the court's reliance on the § 3553(a) considerations to impose a sentence above what the Guidelines recommended. The appellate court pointed out that once courts have correctly calculated the Guidelines range, they may find a sentence outside that range "appropriate irrespective of the Guidelines range."On the second point, Ducharme argued that a life sentence was substantively unreasonable because the court did not weigh the § 3553(a) sentencing considerations properly. He highlighted his limited criminal history and the fact that a life sentence far exceeded his Guidelines range. However, the court noted that its review of the substantive reasonableness of a sentence is narrow and deferential. The district court had considered the relevant sentencing criteria and given several convincing reasons for the sentence it chose, leading the Court of Appeals to conclude that it did not commit "a clear error of judgment" in varying upward to a life sentence.Thus, the court affirmed the life sentence given to Ducharme. View "United States v. Ducharme" on Justia Law

Posted in: Criminal Law
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In the case before the United States Court of Appeals for the Eighth Circuit, Jesse and Dustin Sierra, convicted of various charges including kidnapping, interstate domestic violence, and aiding and abetting both offenses, respectively, appealed their convictions. Jesse Sierra challenged the district court’s decision to exclude evidence of the victim’s other traumatic experiences, arguing that it violated his Fifth and Sixth Amendment rights. He also argued that the government suppressed exculpatory or impeachment material, violating the Brady v. Maryland precedent. Dustin Sierra challenged the sufficiency of the evidence for his convictions and argued that his trial should have been severed from Jesse's trial due to the prejudicial nature of the testimony and evidence presented. The Court of Appeals affirmed the district court’s decisions, holding that the exclusion of the victim's other traumatic experiences did not violate Jesse's constitutional rights, and that no Brady violations had occurred. The court also found that the evidence against Dustin was sufficient for the convictions and that there was no severe prejudice warranting a separate trial. View "United States v. Jesse Sierra" on Justia Law

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In this breach-of-contract dispute, the United States Court of Appeals for the Eighth Circuit upheld the decision of the District Court of Minnesota, which rejected Reach Companies, LLC's appeal for a new trial after a jury awarded $1,196,364 in damages to Newsert, LLC and David Serata. Reach Companies, a distributor of hand sanitizers, alleged that Newsert, a wholesaler of the same products, continued accepting late shipments despite delays and price fluctuations. Newsert countered that Reach failed to fulfill all but one of its purchase orders, causing Newsert to lose two customers. The court found that the purchase orders were unambiguous with respect to their terms, rejecting Reach’s argument that the "must ship by" dates were simply aspirational. The court also held that the evidence presented at trial was sufficient to prove Newsert's lost profits with reasonable certainty, dismissing Reach's argument that the losses were speculative and didn't account for overhead. Lastly, the court allowed the admission of evidence of prior criminal convictions of Reach’s Vice President for impeachment purposes, as the crimes involved fraud and deceit and were thus relevant to the issues in the case. View "Reach Companies, LLC v. Newsert, LLC" on Justia Law

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The United States Court of Appeals for the Eighth Circuit reviewed a petition by Israel Amador-Morales, a Mexican citizen, challenging the decision of the Board of Immigration Appeals (BIA) to deny his motion to reopen his case. Morales had entered the United States without inspection in 2003, was voluntarily departed in 2012, and then re-entered without inspection in 2013. The Department of Homeland Security (DHS) sought his removal and issued a Notice to Appear alleging his removability under 8 U.S.C. § 1182(a)(6)(A)(i). Morales admitted the allegations and conceded removability in 2016. However, in 2019, he withdrew his admission and concession, and moved to terminate the proceedings. The Immigration Judge denied the motion, ordered his removal, and the BIA dismissed his appeal and denied the motion to reopen.Morales argued that the BIA should have granted his motion to reopen, erred in ruling his objection to the Notice to Appear as untimely, and misconstrued his motion as asking it to compel DHS to exercise prosecutorial discretion. The court, however, found that Morales's objections to the Notice to Appear were untimely as they occurred after the closing of pleadings. The court also determined that the BIA's decision that it lacked the authority to compel the DHS to exercise prosecutorial discretion did not constitute an abuse of discretion.The court denied the petition for review, upholding the BIA's decision to deny the motion to reopen and maintaining Morales's removal order. View "Amador-Morales v. Garland" on Justia Law

Posted in: Immigration Law
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In a case before the United States Court of Appeals for the Eighth Circuit, the plaintiffs, The Arc of Iowa and several parents of children with disabilities, sought to challenge a provision of the Iowa Code that prevents schools from imposing mask mandates unless required by other laws. They had received a preliminary injunction from a lower court that had been vacated by this court due to changing circumstances related to the COVID-19 pandemic. On remand, the district court granted the plaintiffs' motion for summary judgment, declaring that the phrase 'other provisions of law' in the contested Iowa Code section includes Title II of the Americans with Disabilities Act (ADA) and section 504 of the Rehabilitation Act, and that the contested Iowa Code section cannot be cited as the sole basis for denying a student's request for reasonable modification or accommodation under the ADA or the Rehabilitation Act that requires others to wear masks.The defendants, the Governor of Iowa and the Director of the Iowa Department of Education, appealed to the Eighth Circuit, raising issues of exhaustion of remedies under the Individuals with Disabilities Act (IDEA), standing of the plaintiffs, and the propriety and necessity of the relief granted by the district court.The appellate court, after de novo review, found that the plaintiffs failed to meet the requirements for standing, which include having suffered an injury in fact, traceability of the injury to the defendant's conduct, and the likelihood of redress by a favorable judicial decision. The court found that the general risks associated with COVID-19 were not enough to constitute "imminent and substantial" harm for standing. It also concluded that the plaintiffs had not demonstrated that the alleged injuries were fairly traceable to the conduct of the Governor or the Director of the Department of Education. As a result, the court vacated the district court's order and remanded the case with instructions to dismiss due to lack of standing. View "The Arc of Iowa v. Reynolds" on Justia Law