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

After Defendant pleaded guilty to being a felon in possession of a firearm, the district court designated him an armed career criminal and sentenced him to 180 months in prison. Defendant appealed, arguing that his predicate offenses were not committed on different occasions, a requirement for the armed career criminal sentencing enhancement. Alternatively, Defendant argued that the Sixth Amendment required a jury to find that he committed his predicate offenses on different occasions.   The Eighth Circuit affirmed. Defendant’s PSR shows a 2004 burglary conviction and two 2006 battery convictions. According to charging documents, the battery offenses involved different victims and occurred on different days, one on or about March 8 and the other on or about March 11. Defendant argued that the 2006 convictions were committed on the same occasion because he was arrested and convicted on the same dates for both offenses. The court explained that the multi-day gap separating the battery offenses strongly supports a finding that Defendant committed them on different occasions. Accordingly, the court held that all things considered, the district court did not err when it concluded that Defendant committed his prior offenses on different occasions. View "United States v. Christopher Stowell" on Justia Law

MyPillow, Inc. and Chief Executive Officer Michael Lindell (collectively, “Lindell”) appealed the district court’s denial of their motions for a preliminary injunction and for the return of property—Lindell’s cell phone that was seized by federal agents on September 13, 2022. The basis of Lindell’s action arises from an ongoing federal investigation into the individuals responsible for publishing forensic images of election software used in the 2020 election in Mesa County, Colorado. He argued on appeal that the federal investigation violates his First Amendment rights of freedom of speech, freedom of association, freedom of the press, and the right to petition for the redress of grievances. He also contended the search warrant for his phone violates the Fourth Amendment’s prohibition against general warrants.   The Eighth Circuit affirmed the district court’s denial of Lindell’s motion for a preliminary injunction. The court reversed the district court’s decision not to exercise equitable jurisdiction over Lindell’s motion for the return of property as it relates to the continued retention of the cell phone itself and all its data. The court explained that it is unable to determine from the record whether the government can reasonably justify its continued refusal to return Lindell’s cell phone, which at this point was seized nearly a year ago, or the data on it, which is entirely unrelated to the offenses the government is investigating. Accordingly, the court remanded for the district court to hold a prompt hearing and balance the government’s interest in retaining Lindell’s cell phone and all its data against Lindell’s right to get the property back. View "Michael Lindell v. United States" on Justia Law

Kenneth Kraemer and Kraemer Farms, LLC (collectively, “Plaintiffs”) commenced this qui tam action under the False Claims Act (“FCA”), against United Dairies, other dairy farms, and their partners and agents (“Defendants”) alleging that they knowingly filed false crop insurance claims. Plaintiffs’ FCA Complaint alleged that Defendants (1) fraudulently obtained crop insurance payments by falsely reporting a silage-use-only variety of corn as grain and using that false statement to obtain the payments, and (2) were unjustly enriched by receiving the payments. The district court held that Defendants submitted materially false claims but denied Plaintiffs FCA relief because they failed to prove that Defendants knowingly defrauded the United States. However, the court found that certain Defendants had been unjustly enriched and awarded damages to the United States. The United States then filed a post-trial motion urging the district court to vacate or amend its judgment because Plaintiffs do not have standing to seek common law unjust enrichment relief on behalf of the United States. The district court granted the motion and vacated its judgment for lack of subject matter jurisdiction.   The Eighth Circuit affirmed. The court explained that the dismissal of Plaintiffs’ FCA claims must be affirmed even if Plaintiffs are correct that the district court erred in ruling that any violations were not knowing. The court wrote that because it concludes that Defendants in submitting Acreage Reporting Forms supporting their crop insurance applications did not submit materially false claims for crop insurance payments, Plaintiffs contention -the district court applied the wrong legal standard in denying FCA relief on other grounds is of no moment. View "United States ex rel. Kenneth Kraemer v. United Dairies, L.L.P." on Justia Law

Creighton Preparatory School expelled Plaintiff after he made lewd remarks about a teacher. Plaintiff sued Creighton under Title IX of the Education Amendments of 1972 on the theory that the school had discriminated against him by failing to perform an “adequate and impartial investigation.” The district court granted Creighton’s motion to dismiss. It first dismissed the Title IX claim because Plaintiff had failed to “allege [that] his sex played any part in the disciplinary process at all.” Then, with the federal question gone, it declined to exercise supplemental jurisdiction over Plaintiff’s breach-of-contract claim.The Eighth Circuit affirmed. The court explained that Plaintiff does not allege that Creighton faced external pressure to punish male students, much less gave in by expelling him. The court reasoned that without an allegation of that kind, the complaint fails to plausibly allege the sort of “causal connection between the flawed outcome and gender bias” required to make an erroneous outcome theory work.Further, the court wrote that treating men and women differently can support an inference of sex discrimination, but it requires identifying a similarly situated member of the opposite sex who has been “treated more favorably.” For Plaintiff, he had to find “a female accused of sexual harassment” who received better treatment. There are no female students at Creighton, an all-boys school, let alone any who have faced sexual-misconduct allegations. The court explained that to the extent that Plaintiff argues that believing them over him raises an inference of discrimination, there is nothing alleged that the school did so because of his sex. View "Elijah Wells v. Creighton Preparatory School" on Justia Law

Plaintiff was hired as a Law Enforcement Officer by the Sisseton, South Dakota, Police Department. Plaintiff and the City signed a Sisseton Police Department Employment Contract (the “Contract”) requiring Plaintiff to reimburse the City for the cost of her training if she left the Department before completing 36 months of employment. In January 2022, Defendant, the City’s Chief of Police, informed Plaintiff that the Police Commission had lost confidence in her, and Defendant asked Plaintiff to resign, which she did. Plaintiff filed this 42 U.S.C. Section 1983 action, asserting, along with other claims, that the City and numerous individual defendants violated her Fourteenth Amendment procedural and substantive due process rights. The district court granted Defendants’ motion. Plaintiff appealed only the dismissal of her due process claims.   The Eighth Circuit affirmed. The court agreed with the district court the Supreme Court of South Dakota would rule that the Contract did not change an at-will employment relationship. The court explained that for Plaintiff’s claim against the City to survive a motion to dismiss, her complaint must contain “enough facts to state a claim to relief that is plausible on its face.” The court agreed with the district court that the Complaint “failed to allege any unconstitutional policy or custom that enabled” Defendants to deprive Plaintiff of her alleged federal due process rights. Counsel for Plaintiff could only respond that the Complaint plausibly alleged the practice of violating the three-year term in the City’s employee reimbursement contracts. That practice was not alleged in the Complaint and, in any event, is nothing more than a “facially lawful municipal action.” View "Samantha LaCoe v. City of Sisseton" on Justia Law

The University of Iowa expelled graduate student John Doe after investigating two accusations of sexual misconduct brought against him by different complainants. The Iowa Board of Regents affirmed the decision. Doe sued the University and University officials, claiming, in part, discrimination on the basis of sex under Title IX, 20 U.S.C. Section 1681(a), and procedural due process violations, 42 U.S.C. Section 1983. The district court granted qualified immunity to the University officials, dismissed the procedural due process claims against them, and granted the University summary judgment on the remaining claims.   The Eighth Circuit affirmed. The court explained that it is not convinced that institutional efforts to prevent sexual misconduct on campus, including educational programs that challenge students to evaluate the impact of gender norms on rape culture, amount to evidence of external pressure on the University that supports an inference of bias. The court held that Doe failed to provide “sufficient evidence to allow a reasonable jury to find that [the University] disciplined him on the basis of sex.” Accordingly, the court affirmed the district court’s grant of summary judgment on Doe’s Title IX claim. Further, the court explained that the University provided adequate notice of the charges. Therefore, the court wrote that because Doe failed to show the University officials’ conduct violated his federal rights, it affirmed the district court’s dismissal of Doe’s claims against the University officials. View "John Doe v. University of Iowa" on Justia Law

Great River Entertainment, LLC sought coverage from Zurich American Insurance for losses related to the COVID-19 pandemic. The district court granted Zurich’s motion to dismiss for failure to state a claim. Great River appealed and moved to remand because there was not complete diversity of citizenship.   The Eighth Circuit remanded to the district court to consider whether there is federal diversity jurisdiction. The court explained that it cannot proceed without subject matter jurisdiction. The court wrote that based on Great River’s new affidavit, it is unable to conclude that its members were diverse. While Great River’s carelessness has clearly wasted judicial resources, the court explained that it cannot address the merits before determining federal jurisdiction. This is a task better suited for the district court. The court wrote that on remand, the court may also take additional action it deems appropriate. View "Great River Entertainment, LLC v. Zurich American Insurance Co." on Justia Law

Defendant was indicted on three counts of drug possession with intent to distribute. On the morning of the trial, he decided to plead guilty to two of them in exchange for dismissal of the third. The district court performed the usual change-of-plea colloquy. Defendant said that his mind was “crystal clear” and that he was not on any medications or drugs. Yet some of his responses showed hesitation. He said he had little time to go over the plea agreement with his lawyer and felt rushed. On top of that, he regretted not taking an earlier plea offer made while his mother’s recent death weighed heavily on him. Still, the court found Defendant competent to proceed with his proposed plea and confirmed that he was satisfied with his attorney. On appeal, Defendant argued that the district court violated his Sixth Amendment right to counsel at sentencing when it allowed his lawyer to withdraw, neglected to appoint another one, and failed to warn Defendant about the risks of proceeding on his own.   The Eighth Circuit dismissed his appeal, finding that Defendant waived his right to challenge these issues. The court explained that recognizing the validity of appeal waivers provides defendants with an important bargaining chip. The court wrote that applying the miscarriage-of-justice exception here would weaken that presumption of validity and reduce Defendant's bargaining power. As such, the court found that in this case, there is a valid appeal waiver and no showing that a miscarriage of justice would result from its enforcement. View "United States v. Rashaun Williams" on Justia Law

Defendant and co-Defendant were convicted of conspiracy to distribute methamphetamine and, conspiracy to commit money laundering, and possession of firearms in furtherance of a drug trafficking crime. Co-Defendant was also convicted of illegal re-entry. Defendant challenged the sufficiency of the evidence against her, and co-Defendant contends the district court abused its discretion when it refused to allow witnesses who are Mexican nationals to testify by Zoom and admitted evidence of an unrelated assault with a firearm.   The Eighth Circuit affirmed in part and reversed in part the district court’s denial of Defendant’s motion for judgment of acquittal and vacated her conviction for conspiracy to commit money laundering. The court reversed the district court’s denial of Defendant’s motion for a new trial on the drug trafficking and firearms counts and remanded for proceeding. The court affirmed with respect to co-Defendant. The court explained that it is unable to determine whether the district court abused its discretion by not considering a matter that should have been given significant weight by giving significant weight to something improper or irrelevant or if it committed a clear error of judgment. Therefore, the court remanded to the district court for consideration of Defendant’s motion for a new trial as it relates to the drug trafficking conspiracy and related firearms count. View "United States v. Maria Nava" on Justia Law

Defendant shot a man in the chest and led police on a high-speed chase through a residential neighborhood before his eventual capture. When arrested, he possessed a pistol, ammunition, and bags containing methamphetamine and fentanyl. One of the bags appeared to have been opened using teeth, and officers observed Walker becoming lethargic and losing consciousness. Officers administered two doses of Naloxone to revive him before transporting him to a hospital. Defendant eventually pleaded guilty to possessing a firearm as a previously convicted felon in violation of 18 U.S.C. Section 922(g). The district court determined Defendant was an armed career criminal pursuant to 18 U.S.C. Section 924(e), and also determined his extensive and violent criminal history merited an above-Guidelines-range sentence. The district court ultimately varied from a guideline range of 188–235 months and imposed a sentence of 300 months’ imprisonment and five years’ supervised release.   The Eighth Circuit vacated the sentence imposed in this case and remanded for resentencing. The court explained that the district court’s failure to specifically address the standard conditions of supervised release and the third special condition, which relates to the two special conditions that were orally pronounced, was a matter of mere oversight. As such, the court vacated that portion of the judgment and commitment order imposing the standard conditions of supervised release and the third special condition and remand to the district court for a resentencing, limited to the standard conditions and third special condition. View "United States v. Bradley Walker" on Justia Law