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

On July 6, 2013, a train carrying crude oil derailed in Lac-Mégantic, Quebec, causing explosions that killed forty-seven people and destroyed the town center. Joe R. Whatley, Jr., as trustee for the wrongful death claimants, sued Canadian Pacific Railroad Company and related entities, alleging liability for the value of the train’s crude oil cargo.The United States District Court for the District of North Dakota found Canadian Pacific liable under the Carmack Amendment for the value of the crude oil cargo and awarded Whatley $3,950,464 plus prejudgment interest. However, the court declined to address whether the judgment reduction provision from the Montreal Maine & Atlantic Railway (MMA) bankruptcy plan applied, stating that it was a matter for the Bankruptcy Court. Canadian Pacific's motion for reconsideration was denied, leading to this appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court abused its discretion by setting aside part of the joint stipulation between the parties, which required the court to decide whether the judgment reduction provision applied. The Eighth Circuit determined that the judgment reduction provision from the MMA bankruptcy plan should apply, reducing Canadian Pacific’s liability to zero, as MMA was solely responsible for the derailment.The Eighth Circuit reversed the district court’s decision and remanded the case for a complete reduction of the judgment against Canadian Pacific, ensuring that Canadian Pacific would not be held liable for more than its proportionate share of the damages, which in this case was zero due to MMA's sole liability. View "Whatley v. Canadian Pacific Railway Co." on Justia Law

In January 2023, law enforcement officers from the Rosebud Sioux Tribe responded to a report of a man brandishing a firearm at Benjamin Fool Bull's home. Witnesses identified Tyson Quigley as the man with the firearm and Erwin White Lance as the man with a baseball bat. Both men were later found in a gold Chrysler sedan, which contained a firearm, ammunition, and other items. Quigley declined to speak with investigators, but White Lance admitted to being invited into the residence and claimed responsibility for the firearm before invoking his right to remain silent.Quigley and White Lance were charged with first-degree burglary and using a firearm during a crime of violence. Quigley was also charged with being a felon in possession of a firearm. White Lance died during the proceedings, and the charges against him were dismissed. The district court granted the Government's motion to exclude White Lance's statements as hearsay, ruling that they were not admissible under Rule 804 or Rule 807. At trial, Quigley was found guilty of being a felon in possession of a firearm but acquitted of the other charges. He was sentenced to 90 months in prison and three years of supervised release.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 White Lance's statement about taking responsibility for the firearm was not sufficiently trustworthy to be admitted under Rule 804(b)(3) or Rule 807. The court noted that the statement was made under circumstances that suggested a motive to protect Quigley and was contradicted by eyewitness testimony. Therefore, the district court did not abuse its discretion in excluding the statement. View "United States v. Quigley" on Justia Law

Michael Swanson killed a motorcyclist while driving his parents' car. After a wrongful-death lawsuit settled, Swanson's personal automobile-liability policy paid up to its coverage limits. The remaining question was which insurer should pay next: Hartford Fire Insurance Company, which provided a commercial automobile policy to Swanson's employer, or Chubb Custom Insurance Company, which provided group excess-liability benefits. Both insurers had "excess clauses" requiring the other to pay first, leading to a dispute.The United States District Court for the Western District of Missouri determined that the excess clauses were mutually repugnant, meaning they canceled each other out. The court granted summary judgment to Hartford, denied Chubb's motion for judgment on the pleadings, and ordered both insurers to share the remaining settlement amount pro rata.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that Hartford's policy was "excess over any other collectible insurance," while Chubb's policy was "excess over any other insurance," making it a true excess policy. The court concluded that Hartford's policy should pay before Chubb's because Hartford's policy was excess over collectible insurance, which included Swanson's personal automobile-liability policy. Chubb's policy, being a true excess policy, would only come into play after all other insurance was exhausted.The Eighth Circuit vacated the district court's judgment and remanded the case with instructions to grant Chubb's motion for judgment on the pleadings, determining that Hartford should pay before Chubb. View "Hartford Fire Insurance Company v. Chubb Custom Insurance Company" on Justia Law

Just Funky, LLC, an Ohio company, and Think 3 Fold, LLC, an Arkansas company, entered into a business relationship in 2020 to supply plush toys to Walmart. Think 3 Fold issued purchase orders to Just Funky in late 2021, but the parties could not agree on a final price. Concurrently, Just Funky provided a loan to Think 3 Fold, which defaulted on the payments. The parties attempted to settle the loan dispute, but Think 3 Fold's late payment complicated matters. They also discussed a larger plush toy deal as part of the settlement, but no agreement was reached. Think 3 Fold paid for a smaller plush toy order, which Just Funky did not deliver.The United States District Court for the Western District of Arkansas ruled in favor of Think 3 Fold, granting summary judgment on Just Funky's breach of contract claim for the larger plush deal, finding no contract was formed due to lack of agreement on essential terms. The court also ruled in favor of Think 3 Fold on its counterclaim for the smaller plush deal, rejecting Just Funky's setoff defense.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's summary judgment, agreeing that no contract was formed for the larger plush deal as there was no meeting of the minds on the price term. The court also upheld the rejection of Just Funky's setoff defense, finding that the $173,000 was part of settlement negotiations and never became due. The judgment of the district court was affirmed. View "Just Funky, LLC v. Think 3 Fold, LLC" on Justia Law

Dimaryn Ware was indicted on multiple firearms-related charges. He moved to dismiss the indictment, arguing that the statutes violated the Second Amendment both on their face and as applied to him. The district court denied his motion, and Ware pled guilty while preserving his right to appeal the denial. He now appeals the denial and several sentencing decisions.The district court, the United States District Court for the Southern District of Iowa, denied Ware's motion to dismiss the indictment. Ware pled guilty to two counts, and the remaining counts were dismissed on the government's motion. At sentencing, the court applied the Base Offense Level from the United States Sentencing Guideline (USSG) § 2K2.1(a)(3), concluding that the offense involved a firearm capable of accepting a large capacity magazine. The court calculated a Guidelines range of 84 to 105 months but varied upward to 144 months' imprisonment, ordering the sentence to run concurrently with a state sentence for a related shooting but consecutively to other state sentences for unrelated offenses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Ware's arguments against the constitutionality of 18 U.S.C. § 922(g)(1) and § 932(b)(1) were foreclosed by precedent, specifically citing United States v. Jackson and United States v. Sharkey. The court also held that the district court did not err in considering conduct underlying an acquitted charge when determining Ware's sentence, as permitted by precedent. Additionally, the court found no clear error in the district court's application of USSG § 2K2.1(a)(3) based on the evidence of the firearm's capability to accept a large capacity magazine. Finally, the court upheld the district court's decision to impose Ware's federal sentence consecutively to his unrelated state sentences and to not reduce his federal sentence based on time served for those unrelated state sentences.The judgment of the district court was affirmed. View "United States v. Ware" on Justia Law

Khemall Jokhoo was previously convicted by a jury of multiple offenses, including aggravated identity theft, impersonating a federal officer, and various fraud charges. His sentence was affirmed by the United States Court of Appeals for the Eighth Circuit. After serving his prison term, Jokhoo was found by the United States District Court for the District of Minnesota to have violated the conditions of his supervised release seven times within a month, leading to an additional one-year prison sentence.Jokhoo appealed, arguing that there was insufficient evidence to support the findings that he failed to work regularly and held unapproved employment with fiduciary responsibilities. He also contended that his sentence was substantively unreasonable, claiming the district court imposed it with a focus on retribution.The United States Court of Appeals for the Eighth Circuit reviewed the case and found no error in the district court's determination that Jokhoo failed to work regularly. The court noted that Jokhoo worked only one day during the nearly month-long period and had ample time to secure employment during his pre-release period. The court dismissed Jokhoo's argument that he needed time to find a new job after being terminated, as he should have anticipated the job loss due to violating a supervised release condition.The appellate court also concluded that any potential error in finding that Jokhoo held unapproved employment with fiduciary responsibilities was harmless. The district court did not need this finding to revoke his supervised release, as other uncontested violations were sufficient. Additionally, the court found that the district court's mention of retribution did not affect Jokhoo's sentence, as the primary reason for the sentence was his repeated rule violations.The Eighth Circuit affirmed the district court's decision. View "United States v. Khemall Jokhoo" on Justia Law

In late September 2023, JT Myore was convicted by a District of South Dakota jury of aiding and abetting carjacking and brandishing a firearm during a crime of violence on August 25, 2019, and of robbery on May 3, 2021. In early November 2023, a second jury convicted him of second-degree murder for a separate incident on May 3, 2021. The district court sentenced him to 540 months imprisonment after a consolidated sentencing hearing in February 2024. Myore appealed both convictions and the combined sentence.The district court found sufficient evidence to support the carjacking and brandishing convictions, rejecting Myore’s argument that the government failed to prove he took the vehicle by force or intimidation. The court also upheld the use of acquitted conduct from the May 2021 incident to enhance his sentence. For the second-degree murder conviction, the court instructed the jury on the lesser included offense of voluntary manslaughter, which Myore opposed. The jury found him guilty of second-degree murder.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed both convictions and the sentence. It held that there was sufficient evidence for the carjacking and brandishing convictions, and that the district court did not err in considering acquitted conduct at sentencing. The court also found no plain error in the jury instructions for the second-degree murder charge, as Myore did not raise heat of passion as a defense. Additionally, the court upheld the obstruction of justice sentencing enhancement, finding that the district court made independent findings that Myore testified falsely at trial. View "United States v. Myore" on Justia Law

Matthew Mungai, a Black man of Kenyan origin, sued the University of Minnesota, alleging racial discrimination and harassment while he was a student. He claimed violations under Title VI, Title IX, 42 U.S.C. §§ 1981 and 1983, the Minnesota Human Rights Act (MHRA), the Fourteenth Amendment, and negligence. Mungai detailed several incidents of racial harassment by students and staff over three years, including derogatory comments and threats. He reported some incidents to university staff and the Student Conflict Resolution Center (SCRC).The United States District Court for the District of Minnesota dismissed Mungai's claims, finding that his amended complaint failed to state a claim. Mungai appealed, focusing on his Title VI claim and challenging the dismissal with prejudice of his Title VI, MHRA, Fourteenth Amendment, and § 1983 claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court adopted the deliberate indifference standard for third-party harassment claims under Title VI, similar to Title IX. To establish liability, Mungai needed to show that the University was deliberately indifferent to known acts of harassment by individuals under its control. The court found that Mungai's allegations did not plausibly show that he reported the incidents to an appropriate person with authority to take corrective action. Additionally, the court found that Mungai did not provide sufficient facts to establish that the University acted with deliberate indifference.The court also upheld the district court's dismissal with prejudice of Mungai's MHRA, Fourteenth Amendment, and § 1983 claims. The MHRA claim was barred by Eleventh Amendment immunity, the Fourteenth Amendment claim could not be brought directly, and the University was not a "person" under § 1983.The Eighth Circuit affirmed the district court's judgment. View "Mungai v. University of Minnesota" on Justia Law

Lugene Shipp and Dione Mobley were charged with conspiring to distribute heroin resulting in death and distribution resulting in death after M.W. died of heroin intoxication. M.W. had purchased heroin from Kami Kinzenbach, who sourced it from Shipp and Mobley. M.W. was found dead in his bedroom with heroin and fentanyl residue. An autopsy confirmed heroin intoxication as the cause of death. Kinzenbach's testimony and electronic messages linked Shipp and Mobley to the heroin sold to M.W.The United States District Court for the Southern District of Iowa conducted a bench trial, convicting Shipp on both counts and Mobley only on the conspiracy count. Shipp and Mobley challenged their convictions based on evidentiary rulings, the Confrontation Clause, and sufficiency of the evidence. Mobley also argued that the district court erroneously relied on acquitted conduct at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court did not err in admitting the electronic messages from M.W. and Sidnee, as they were either not hearsay or fell under hearsay exceptions. The court also concluded that the admission of these statements did not violate the Confrontation Clause since they were not testimonial. Additionally, the court held that there was sufficient evidence to prove that the heroin distributed by Shipp caused M.W.'s death, rejecting the defendants' speculative claims about other potential sources of heroin.Regarding Mobley's sentencing, the court determined that the district court properly considered M.W.'s death and drug quantities associated with the conspiracy, as Mobley was convicted of conspiring to distribute heroin resulting in death. The court affirmed the convictions and sentences of both Shipp and Mobley. View "United States v. Shipp" on Justia Law

The case involves a group of in-state and out-of-state precious metal traders and their representatives (the "Bullion Traders") challenging Minnesota Statutes Chapter 80G, which regulates bullion transactions. The Bullion Traders argued that the statute violated the dormant Commerce Clause due to its extraterritorial reach, as defined by the term "Minnesota transaction."The United States District Court for the District of Minnesota initially found that Chapter 80G violated the dormant Commerce Clause. The case was then remanded by the United States Court of Appeals for the Eighth Circuit for a severability analysis. The district court concluded that striking portions of the "Minnesota transaction" definition cured the extraterritoriality concern and complied with Minnesota severability law.The Bullion Traders appealed, arguing that the severed statute still applied extraterritorially and that the district court erred in applying Minnesota severability law. The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court found that the severed definition of "Minnesota transaction" no longer regulated wholly out-of-state commerce and that the statute, as severed, was complete and capable of being executed in accordance with legislative intent.The Eighth Circuit held that the district court correctly severed the extraterritorial provisions from Chapter 80G, and the remaining statute did not violate the dormant Commerce Clause. The court also agreed that the severed statute complied with Minnesota severability law, as the valid provisions were not essentially and inseparably connected with the void provisions, and the remaining statute was complete and executable. The judgment of the district court was affirmed. View "Styczinski v. Arnold" on Justia Law