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

Thomas Petters orchestrated a Ponzi scheme through his company, Petters Company, Inc. (PCI), which collapsed in 2008. Following Petters' arrest and conviction, PCI was placed into receivership, and Douglas Kelley was appointed as the receiver. Kelley later filed for bankruptcy on behalf of PCI and was appointed as the bankruptcy trustee. As trustee, Kelley initiated an adversary proceeding against BMO Harris Bank, alleging that the bank aided and abetted the Ponzi scheme.The bankruptcy court and the district court both ruled that the equitable defense of in pari delicto, which prevents a plaintiff who has participated in wrongdoing from recovering damages, was unavailable due to PCI's receivership status. The case proceeded to trial, and a jury awarded Kelley over $500 million in damages, finding BMO liable for aiding and abetting a breach of fiduciary duty. BMO appealed, challenging the availability of the in pari delicto defense, among other issues.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the doctrine of in pari delicto barred Kelley’s action against BMO. The court reasoned that while a receiver might not be bound by the fraudulent acts of a corporation's officers under Minnesota law, a bankruptcy trustee stands in the shoes of the debtor and is subject to any defenses that could have been raised against the debtor. Since PCI was a wrongdoer, the defense of in pari delicto was available to BMO in the adversary proceeding. The court reversed the district court's judgment and remanded the case with directions to enter judgment in favor of BMO. The cross-appeal was dismissed as moot. View "Kelley v. BMO Harris Bank N.A." on Justia Law

Descart Begay, Jr. was convicted by a jury of sexual abuse and aggravated sexual abuse of S.S., a former coworker. After reconnecting via Facebook, Begay visited S.S. at her home on the Red Lake reservation in Minnesota. During his visit, he forcibly raped her twice, once in her bedroom and again near the front door as she tried to escape with her son. S.S. managed to flee and reported the incident to her mother and the police. Begay was arrested shortly after attempting to hide from the officers.The United States District Court for the District of Minnesota conducted a five-day trial, after which the jury found Begay guilty of two counts each of sexual abuse and aggravated sexual abuse. The district court sentenced him to 200 months in prison. Begay appealed, challenging the evidence presented at trial and the sentence imposed.The United States Court of Appeals for the Eighth Circuit reviewed the case. Begay argued that the jury heard too much from the government and too little from him, particularly objecting to the admission of S.S.'s prior consistent statements. The court found that these statements were admissible under Federal Rule of Evidence 801(d)(1)(B) to rebut charges of recent fabrication and to rehabilitate S.S.'s credibility. The court also addressed Begay's claim that his Sixth Amendment rights were violated by limiting cross-examination about S.S.'s sexual history, concluding that any error was harmless given the overwhelming evidence of guilt.Regarding sentencing, the court upheld the district court's application of enhancements for causing serious bodily injury and physically restraining the victim. The court found that S.S.'s lasting psychological damage justified the serious bodily injury enhancement and that the physical restraint enhancement did not constitute double counting.The Eighth Circuit affirmed the judgment of the district court. View "U.S. v. Begay" on Justia Law

Drew Clark committed a series of crimes on May 26, 2021, including three car thefts, home invasions, and brandishing a stolen firearm. He was convicted by a jury of possessing a stolen firearm, three counts of carjacking, and three counts of brandishing a firearm during the carjackings. The district court sentenced him to 339 months in prison. Clark appealed his conviction on two carjacking and associated brandishing charges.The United States District Court for the Eastern District of Missouri initially reviewed the case. At trial, Clark moved for judgment of acquittal on all counts, which the district court denied. After the jury convicted Clark on all counts, the court considered supplemental briefs regarding two specific counts and denied Clark’s motion for acquittal in a written post-trial order.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the jury’s verdict, concluding that the evidence was sufficient for a reasonable jury to find Clark guilty beyond a reasonable doubt. The court found that Clark’s actions during the carjackings, including brandishing a firearm to gain control of the vehicles, met the legal requirements for carjacking and brandishing charges. The court distinguished this case from others by noting that Clark’s use of force was necessary to complete the carjackings. The court also found that Clark’s intent to cause harm was evident from his actions, even if he did not explicitly threaten to kill or seriously harm the victims. The judgment of the district court was affirmed. View "United States v. Clark" on Justia Law

Christian Carrillo Topete was convicted of possessing child pornography, with some images involving minors under 12 years old. The key issue was whether his prior conviction for assault with intent to commit sexual abuse under Iowa law triggered a mandatory minimum sentence of ten years under federal law, which applies if the prior conviction "relates to sexual abuse."The United States District Court for the Northern District of Iowa reviewed Carrillo Topete's criminal history and determined that his prior conviction did indeed relate to sexual abuse. Consequently, the court sentenced him to the mandatory minimum of ten years in prison, which was three years more than he would have received without the prior conviction.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court applied the categorical approach, focusing on the statutory definition of the prior offense rather than the specific facts of the case. The court found that the Iowa statute for assault with intent to commit sexual abuse fits within the federal definition of sexual abuse, which includes physical or nonphysical misuse or maltreatment for sexual gratification. The court also noted that the phrase "relating to" in the federal statute allows for a broader interpretation, encompassing a wider range of prior convictions.The Eighth Circuit affirmed the district court's judgment, holding that Carrillo Topete's prior conviction for assault with intent to commit sexual abuse under Iowa law qualifies as a conviction relating to sexual abuse under federal law, thereby justifying the ten-year mandatory minimum sentence. View "United States v. Topete" on Justia Law

While patrolling Interstate 40 in Lonoke County, Arkansas, State Police Corporal Travis May stopped Tommy Collier for drifting into the shoulder. May noticed Collier's shaking hands, a disorderly car interior, and an unusual travel itinerary, which aroused his suspicion. Collier, a resident of Mississippi, was driving a car rented in Las Vegas with a Utah license plate. After Collier declined a search request, May called a K-9 unit. The drug-detection dog, Raptor, alerted to the presence of drugs, leading to a search that uncovered ten bundles of cocaine. Collier was arrested and later indicted for unlawful possession of cocaine with intent to distribute.The United States District Court for the Eastern District of Arkansas conducted the trial, where Collier was found guilty by a jury. The court imposed a statutory minimum sentence of ten years' imprisonment. Collier appealed, raising several issues, including the reliability of the drug-detection dog, the admission of expert testimony, the standard for a motion to suppress, and the adequacy of Rule 16(a) disclosures.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's judgment on all issues. It held that the drug-detection dog, Raptor, was reliable and that its alert provided probable cause for the search. The court also found no abuse of discretion in admitting expert testimony from Major Roby Rhoads and Senior Forensic Chemist Dan Hedges. The court rejected Collier's argument regarding the standard for a motion to suppress, stating that the district court's evaluation for reasonableness was appropriate. Additionally, the court found no prejudice in the government's Rule 16(a) disclosures and upheld the district court's denial of Collier's motion for a judgment of acquittal based on the cocaine isomer defense. Finally, the court ruled that a curative instruction was sufficient to address the government's brief comment on Collier's post-Miranda silence, and there was no plain error in the instruction given. The judgment of the district court was affirmed. View "United States v. Collier" on Justia Law

A fire damaged a hotel owned by Shri Ganesai, LLC, which had an insurance policy with AmGuard Insurance Company. The policy also covered the mortgagee, Academy Bank, N.A. AmGuard denied Shri's claim, suspecting arson by Shri's principal, Alex Patel. During the investigation, the building suffered additional damage from vandalism and frozen pipes. Shri and Academy sued AmGuard for breach of contract and vexatious refusal to pay. The jury found in favor of the plaintiffs, awarding damages for the fire, vandalism, and freeze damage.The United States District Court for the Western District of Missouri denied AmGuard's motions for judgment as a matter of law and a new trial. AmGuard appealed, challenging the viability of Academy's vexatious-refusal claim, the exclusion of certain evidence, and the sufficiency of the evidence regarding damages from vandalism and frozen pipes. The district court had granted summary judgment to AmGuard on Shri's vexatious-refusal claim but allowed the remaining claims to proceed to trial.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decisions. The court held that Academy's vexatious-refusal claim was viable despite the settlement of the underlying breach-of-contract claim, as AmGuard's delay in payment constituted vexatious conduct. The court also found no abuse of discretion in the district court's exclusion of certain evidence, including the testimony of a witness and parts of Patel's deposition. Additionally, the court ruled that sufficient evidence supported the jury's findings on the timing and extent of the vandalism and freeze damage, and that the expert testimony admitted was reliable. The court concluded that the district court did not err in denying AmGuard's motions for judgment as a matter of law or a new trial. View "Academy Bank, N.A. v. Amguard Insurance Company" on Justia Law

Russell Hotchkiss, a resident of Linn County, Iowa, began sending emails to the Cedar Rapids Community School District officials in September 2021, criticizing their COVID-19 masking and vaccination policies. His communications included threats of criminal charges against board members, particularly targeting Jennifer Borcherding, a board member. Hotchkiss attended board meetings in November and December 2021, where he voiced his opposition aggressively. Following these incidents, the District issued a no-trespass notice to Hotchkiss on January 10, 2022, barring him from District premises due to his disruptive and threatening behavior.Hotchkiss filed a lawsuit on May 17, 2023, claiming First Amendment retaliation under 42 U.S.C. § 1983 and a violation of the Iowa Open Meetings Act. He sought a preliminary injunction to prevent the enforcement of the no-trespass order. The United States District Court for the Northern District of Iowa denied his motion, concluding that Hotchkiss failed to demonstrate irreparable harm. The court noted that Hotchkiss had not attempted to return to District premises, had moved his child to another school district, and had not communicated with the District since the notice was issued.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision. The appellate court affirmed the denial of the preliminary injunction, agreeing that Hotchkiss did not show a likelihood of irreparable harm. The court emphasized that speculative harm does not justify a preliminary injunction and noted Hotchkiss's delay in seeking relief and lack of recent attempts to exercise his First Amendment rights. The court concluded that the district court did not abuse its discretion in denying the preliminary injunction based on the failure to demonstrate irreparable harm. View "Hotchkiss v. Cedar Rapids Community School District" on Justia Law

On August 10, 2020, a derecho caused significant damage to the plaintiffs' property in Cedar Rapids, Iowa. The plaintiffs filed a claim with their insurer, State Farm, which initially paid $2,297.26 for the damage. After further submissions and inspections, State Farm increased the payment by $3,822.68. The plaintiffs' contractor estimated the repair costs at $21,537.45, but State Farm disagreed, leading to further disputes and inspections. Eventually, the plaintiffs requested an appraisal, which set the actual cash value (ACV) at $16,155.48 and the replacement cost value (RCV) at $21,069.59. State Farm paid the plaintiffs the difference between the initial payments and the new ACV but required documentation of repairs for the RCV.The plaintiffs filed a lawsuit in state court for breach of contract and bad faith, which was removed to federal court. The district court granted summary judgment to State Farm, holding that the insurer had not breached the contract because it had paid the ACV and the plaintiffs had not completed repairs within the two-year policy deadline to claim the RCV. The court also found that State Farm had an objectively reasonable basis for its payment decisions, negating the bad-faith claim.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, holding that State Farm did not breach the contract as the plaintiffs failed to complete repairs within the required two-year period. The court also held that State Farm had a reasonable basis for its initial payment decisions and did not act in bad faith. The court concluded that the plaintiffs were not entitled to further payments under the policy and that State Farm's actions were justified. View "Henderson v. State Farm Fire & Casualty Co." on Justia Law

During a night of civil unrest in Des Moines, Iowa, police and Polk County deputies arrested 14 individuals. The arrestees claimed their Fourth Amendment rights were violated and sued 53 defendants under 42 U.S.C. § 1983. The district court issued a comprehensive opinion with around 800 rulings on various motions for summary judgment and qualified immunity, leading to multiple appeals.The United States District Court for the Southern District of Iowa denied qualified immunity to several officers and granted summary judgment to some plaintiffs. The Des Moines defendants appealed these decisions, arguing they had probable cause to arrest anyone in the vicinity of the protests for misdemeanors such as participation in a riot, unlawful assembly, and failure to disperse. The district court found that the officers lacked probable cause or arguable probable cause for these arrests, as they did not provide specific evidence linking the plaintiffs to violent behavior or failure to disperse.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decisions de novo. The court affirmed the denial of qualified immunity to Officers Herman, Holtan, and McCarthy on Klingenberg's unlawful arrest claim, and dismissed Officer Lawler's appeal for lack of jurisdiction. The court also dismissed appeals from Captain Hardy and other officers regarding Lard's and DeBrossard's unlawful arrest claims and Lard's excessive force claim. The court affirmed the grant of summary judgment to the Patton group on their unlawful arrest claims and denied qualified immunity to the Des Moines defendants on the plaintiffs' malicious prosecution claims. Additionally, the court affirmed the grant of summary judgment to the plaintiffs on their phone seizure claims against Officer Youngblut and denied him qualified immunity.The court reversed the district court's denial of qualified immunity to Deputy Smith on Timberlake's unlawful arrest claim, finding no clearly established duty for Smith to ensure the lawfulness of the arrest before taking custody. Finally, the court affirmed the grant of qualified immunity to Officer Holtan and Deputy Callahan on Dunn's and Fugate's unlawful arrest claims, concluding they had arguable probable cause under Iowa's failure to disperse statute. The case was remanded for further proceedings consistent with these rulings. View "Dunn v. Does" on Justia Law

Farnsworth Coleman, the sole member of Coleman Consulting, LLC (CC), entered into a written Confidentiality Agreement with Domtar A.W. LLC (Domtar A.W.) in November 2016 to provide consulting services for a pulp mill in Ashdown, Arkansas. CC was compensated for its services and expenses at an agreed hourly rate. CC later claimed that an oral agreement was made with Domtar A.W. for additional compensation based on a percentage of increased profits from CC's recommendations, which Domtar A.W. denied. CC filed a lawsuit for breach of contract and unjust enrichment after Domtar A.W. terminated the consulting services in May 2017.The United States District Court for the Western District of Arkansas granted summary judgment in favor of Domtar A.W., concluding that the Arkansas statute of frauds barred CC's breach of contract claim because the alleged oral agreement could not be performed within one year. The court also found that CC failed to prove its unjust enrichment claim, as CC had been fully compensated for its services under the written agreement. CC's motion for reconsideration, based on newly discovered evidence, was denied.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 agreed that the oral agreement was subject to the statute of frauds and could not be performed within one year. The court also found that the part performance and detrimental reliance exceptions to the statute of frauds did not apply. Additionally, the court upheld the dismissal of the unjust enrichment claim, noting that CC had been paid for its services and could not use unjust enrichment to enforce an unenforceable oral contract. The denial of the motion for reconsideration was also affirmed, as CC failed to demonstrate due diligence in obtaining the new evidence. View "Coleman Consulting, LLC v. Domtar Corporation" on Justia Law