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

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Plaintiff appealed an adverse jury verdict on his retaliation claims under the Federal Railroad Safety Act, challenging the jury instructions. The Eighth Circuit agreed with plaintiff that the jury instructions misstated the "honestly held belief" defense in the context of the Act's contributing-factor standard, and misallocated and misstated the burden of proof. The court explained that the plaintiff bears the burden of proving that intentional retaliation in response to protected conduct served as a contributing factor in an adverse employment action, and the defendant then bears the burden of proving an affirmative defense. In this case, the "honestly held belief" instruction failed to reference the contributing-factor standard and the instructions as a whole expressly incorporated this defense into plaintiff's case. Therefore, this failure to allocate the burden of proof to BNSF and to identify that burden of proof as clear and convincing evidence constituted prejudicial error. Accordingly, the court reversed the district court's judgment and remanded for further proceedings. View "Blackorby v. BNSF Railway Co." on Justia Law

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MetLife and Ford appealed the district court's award of benefits, costs and attorney fees in an Employee Retirement Income Security Act (ERISA) action. In this case, while MetLife paid plaintiff her husband's basic life insurance benefit, it denied payment of an optional life insurance (OLI) benefit. The Eighth Circuit affirmed in part and reversed in part, holding that the district court erred in finding that there was no substantial evidence supporting MetLife's denial of OLI benefits, because substantial evidence supported MetLife's assertion that the husband answered an online questionnaire averring that he had not been treated for high blood pressure, when in fact he had. The court also held that there was substantial evidence in the record to support MetLife's reliance upon the plan administrator's representations that the husband would not have been automatically enrolled in the OLI program if he had truthfully answered the high blood pressure question in the screening questionnaire; the OLI benefits could not have been awarded on an equitable estoppel theory; the district court did not abuse its discretion by denying statutory penalties for the delay in providing documents; and attorney fees and costs must be reversed and remanded. View "Sepulveda-Rodriguez v. Metropolitan Life Insurance Co." on Justia Law

Posted in: ERISA

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The Eighth Circuit affirmed defendant's conviction for conspiring to distribute methamphetamine. Even assuming that it was error to allow an officer to testify regarding defendant's pre-Miranda statements and actions, the admission of the testimony did not violate defendant's substantial rights. In this case, the officer testified that defendant gave a false explanation for his presence and hung his head in an apparent show of defeat at having been caught. The court rejected defendant's alleged Confrontation Clause violations, because any violation would not have posed a reasonable probability of altering the outcome of the trial and were not plain error. View "United States v. Valquier" on Justia Law

Posted in: Criminal Law

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Plaintiffs own and operate Telescope Media Group, a company that makes commercials, short films, and live-event productions. Plaintiffs filed suit against Minnesota, seeking injunctive relief preventing Minnesota from enforcing two provisions of the Minnesota Human Rights Act (MHRA), requiring plaintiffs to produce both opposite sex and same sex videos, or none at all. The district court denied a preliminary injunction and dismissed the complaint. Determining that plaintiffs had standing, the Eighth Circuit reversed and held that wedding videos are speech and plaintiffs have a First Amendment right to make them for only opposite sex weddings; plaintiffs, like the creators of other types of films, will exercise substantial editorial control and judgment when making the wedding videos; and Minnesota's interpretation of the MHRA interferes with plaintiffs' speech by compelling them to speak favorably about same sex marriage if they choose to speak favorably about opposite sex marriage, and it operates as a content-based regulation of their speech. Applying strict scrutiny, rather than intermediate scrutiny, the court held that Minnesota seeks to regulate speech itself as a public accommodation and has violated the First Amendment by doing so. Finally, plaintiffs may pursue their free-exercise claim on remand. View "Telescope Media Group v. Lucero" on Justia Law

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The Eighth Circuit affirmed defendant's conviction for two drug trafficking offenses. The government had been unaware of payments that local police made to a cooperating witness and thus failed to disclose the information to the defense. Defendant moved for a new trial based on the nondisclosure. The court held that the undisclosed payments were not material to the outcome of the proceeding and thus the district court did not err by denying defendant's motion for a new trial. In this case, the impeachment value of the payment information was not so devastating as to undermine the entire prosecution. View "United States v. Dones-Vargas" on Justia Law

Posted in: Criminal Law

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Plaintiff and MDHS brought a negligence action against defendants, alleging that a jail official provided and made plaintiff wear shoes that were too small for his feet. The shoes caused a blister on one of his left toes, which ultimately resulted in a severe infection requiring multiple corrective surgeries. The Eighth Circuit reversed the district court's grant of summary judgment for the County, holding that there was a genuine issue of material fact as to whether the county negligently caused plaintiff's injury. In this case, the district court erred when it concluded that plaintiff's infection was not a foreseeable consequence of wearing too small shoes. The court also held that the county was not entitled to vicarious official immunity, because the duty of providing suitable shoes in a county jail setting is ministerial. View "DeLuna v. Mower County" on Justia Law

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Objector was a member of a California class action against Monsanto that alleged that the company used misleading labeling on its Roundup concentrate herbicide. After certification of the class, class counsel filed this action on behalf of a putative class of consumers from the other 49 states. Objector objected to certification of the nationwide class and to the fairness of the settlement on several grounds. The Eighth Circuit affirmed the district court's overruling of the objection and grant of final approval. The court held that the class members were adequately represented and that the settlement was reasonable, fair, and adequate. View "Rawa v. Migliaccio" on Justia Law

Posted in: Class Action

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The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence on the ground that his arrest and subsequent searches of his hotel room and vehicle violated his Fourth Amendment rights. The court held that the evidence taken as a whole provided ample support for the district court's finding that the officers would have applied for a warrant without the illegal search. The court also held that there was also probable cause to support issuance of the search warrant even without information gleaned from the initial search. View "United States v. Anguiano" on Justia Law

Posted in: Criminal Law

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The Eighth Circuit affirmed defendant's conviction and sentence for two counts of being a felon in possession of a firearm. The court held that the district court did not commit plain error by not merging his firearm possession counts; defendant's possession of the gun was not continuous; the admission of a detective's testimony was harmless error; there was no sentencing error because the contested fourth point to defendant's criminal history calculation could be added for the first degree robbery conviction under USSG 4A1.1(e); and defendant's prior Missouri second-degree robbery conviction constitutes a crime of violence. View "United States v. Gilliam" on Justia Law

Posted in: Criminal Law

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Plaintiff filed suit alleging federal constitutional and tort claims against the city, the county, and several city and county employees after his son died of hypothermia. Plaintiff alleged that defendants, by prematurely declaring plaintiff's son dead and therefore cutting off possible aid, caused his death in violation of the due process clause of the Fourteenth Amendment. The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss with prejudice, holding that plaintiff failed to identify a clearly established right and defendants were entitled to qualified immunity where they did not intentionally deny emergency aid to someone they believe to be alive. The court noted that the medical guidelines were not followed here could possibly be the basis for a negligence suit, but it was not the basis for a constitutional one. View "Anderson v. City of Minneapolis" on Justia Law