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

Deepali Tukaye, an Indian cardiologist, was employed by Jack Stephens Heart Institute, which contracted with Conway Regional Medical Center to provide cardiologists. While working at Conway Regional, Tukaye raised concerns about the quality of care provided by a white cardiologist. Following her complaint, the CEO of Conway Regional, Matt Troup, threatened to terminate Jack Stephens’s contract unless Tukaye was reassigned. Jack Stephens did not reassign her, and Tukaye subsequently gave notice to leave her employment. After her notice, Conway Regional renewed its contract with Jack Stephens.Tukaye filed suit in the United States District Court for the Eastern District of Arkansas - Central Division against Troup, the City of Conway, the Health Facilities Board, and John Doe #1, alleging tortious interference with contract, due process violations, and employment discrimination. The district court dismissed her amended complaint with prejudice for failure to state a claim and denied her motion to alter or amend the judgment and to file a second amended complaint.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo and the denial of the Rule 59(e) motion for abuse of discretion. The appellate court limited its review to Tukaye’s tortious interference claim against Troup, as she did not challenge the dismissal of other claims or defendants. The court held that Tukaye’s own action of providing notice to leave constituted a resignation, which was a superseding cause of her harm and defeated the proximate cause element required for tortious interference under Arkansas law. The court also found no manifest error or newly discovered evidence to justify post-judgment relief. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "Tukaye v. Troup" on Justia Law

A security services company and its sole shareholder, who is also its president and CEO, provided security services to two Iowa cities under separate contracts. After the shareholder published a letter criticizing media coverage of law enforcement responses to protests, a local newspaper published articles highlighting his critical comments about protestors and the Black Lives Matter movement. Subsequently, a city council member expressed concerns about the shareholder’s views, and the city council voted unanimously to terminate the company’s contract. The council member also pressured officials in the other city to end their contract with the company. Facing negative publicity, the company voluntarily terminated its second contract to avoid harm to a pending business transaction.The plaintiffs filed suit in the United States District Court for the Southern District of Iowa against the city, the council member, and other council members, alleging First Amendment retaliation, tortious interference with business contracts, and defamation. The district court granted the defendants’ motion to dismiss all claims under Rule 12(b)(6). It found that the shareholder lacked standing to assert a First Amendment retaliation claim for injuries to the corporation, and that the corporation failed to state a retaliation claim because only the shareholder engaged in protected speech. The court dismissed the tortious interference claim for lack of sufficient factual allegations and because the contract was terminated voluntarily. The defamation claim was dismissed for failure to identify any actionable statements by the defendants.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the dismissal of the shareholder’s First Amendment retaliation and defamation claims, but directed that these dismissals be without prejudice. The court reversed the dismissal of the corporation’s First Amendment retaliation and tortious interference claims, finding that the complaint alleged sufficient facts to survive a motion to dismiss, and remanded those claims for further proceedings. View "Conley v. City of West Des Moines" on Justia Law

In 2024, Minnesota enacted a law that revised the criteria for classifying independent contractors in the construction industry, expanding a previous nine-part test to a fourteen-part test. Several construction industry organizations and a general contractor challenged the law, arguing that certain provisions were unconstitutionally vague and that the civil penalties authorized by the statute violated the Excessive Fines Clause of the Eighth Amendment. The plaintiffs specifically objected to requirements regarding written contracts, invoicing, expense responsibility, and profit or loss realization, as well as the potential for significant civil penalties for noncompliance.The United States District Court for the District of Minnesota denied the plaintiffs’ request for a preliminary injunction to prevent enforcement of the law. The court found that the plaintiffs had not demonstrated a likelihood of success on the merits of their constitutional claims. The plaintiffs then appealed this decision to the United States Court of Appeals for the Eighth Circuit.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that the plaintiffs had standing to challenge the law, as they alleged specific conduct targeted by the statute and faced a credible threat of enforcement. However, the court concluded that the challenged statutory terms were sufficiently clear for people of ordinary intelligence and did not encourage arbitrary or discriminatory enforcement. The court also determined that the plaintiffs’ excessive fines claim was premature, as no penalties had yet been imposed and Minnesota law requires a proportionality analysis before penalties are assessed. Because the plaintiffs failed to show a likelihood of success on the merits, the court found no basis for a preliminary injunction and affirmed the lower court’s judgment. View "MN Chapter of Assoc. Builders v. Blissenbach" on Justia Law

Iowa enacted a law making it a state crime for certain noncitizens who had previously been denied admission, excluded, deported, or removed from the United States to enter or be found in Iowa. The law also required state judges to order such individuals to return to the country from which they entered and prohibited state courts from pausing prosecutions based on pending or possible federal immigration status determinations. Two noncitizens residing in Iowa, both of whom had previously been subject to federal removal orders but later lawfully reentered the United States, along with a membership-based immigrant advocacy organization, challenged the law, arguing it was preempted by federal immigration law.The United States District Court for the Southern District of Iowa found that the plaintiffs had standing and granted a preliminary injunction, concluding that the plaintiffs were likely to succeed on the merits of their claim that the Iowa law was preempted by federal law under both conflict and field preemption doctrines. The district court also found that the plaintiffs would suffer irreparable harm if the law went into effect and that the balance of equities and public interest favored an injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion, reviewing legal conclusions de novo and factual findings for clear error. The Eighth Circuit affirmed the preliminary injunction, holding that the plaintiffs had standing and were likely to succeed on the merits because every application of the Iowa law would conflict with federal immigration law by interfering with the discretion Congress grants to federal officials. The court also found that the other factors for a preliminary injunction were met. The Eighth Circuit remanded for the district court to determine the appropriate scope of the injunction in light of recent Supreme Court guidance. View "IA Migrant Movement for Justice v. Bird" on Justia Law

Philip Myers, a native and citizen of Liberia, was adopted by a U.S. citizen and entered the United States as a child. He later sustained several criminal convictions, including for aggravated felonies. In 2021, the Department of Homeland Security initiated removal proceedings against him. Myers claimed derivative citizenship through his adoptive mother, who had become a naturalized U.S. citizen, and also alleged that he had been abused by her. The United States Citizenship and Immigration Services (USCIS) had previously denied his derivative citizenship application, finding insufficient evidence that he was in his adoptive mother’s legal and physical custody at the relevant time. During removal proceedings, Myers, sometimes represented by counsel and sometimes pro se, was found competent to proceed without safeguards. He applied for various forms of relief, including asylum and protection under the Convention Against Torture, but these were denied.The Immigration Judge ordered Myers removed to Liberia. Myers appealed to the Board of Immigration Appeals (BIA), arguing that the competency determination was flawed and that he should have been found incompetent to proceed pro se. The BIA found no clear error in the Immigration Judge’s competency finding and dismissed the appeal. Myers then moved to reopen the proceedings, citing a pending motion with USCIS regarding derivative citizenship, alleged errors in the competency determination, a new asylum claim based on his sexual orientation, and a pending T-visa application as a victim of sex trafficking. The BIA denied the motion to reopen, and Myers was removed to Liberia.The United States Court of Appeals for the Eighth Circuit reviewed the BIA’s denial of the motion to reopen for abuse of discretion and found none. The court also rejected Myers’s constitutional challenge to the statutory requirements for derivative citizenship and found no genuine issue of material fact regarding his nationality claim. The petition for review was denied. View "Myers v. Bondi" on Justia Law

A waste hauling company operating in Kansas City brought suit against a mobile waste compaction business and its franchisor. The waste hauler owns containers that are leased to customers, who sometimes contract separately with the compaction company to compress waste inside those containers. The hauler alleged that the compaction company’s activities damaged its containers and interfered with its business relationships. The hauler sought various forms of relief, including damages, injunctive and declaratory relief, and nominal damages, but ultimately disavowed any claim for actual monetary damages, citing a lack of evidence to support such damages.The United States District Court for the Western District of Missouri denied the hauler’s request for a temporary restraining order, finding no irreparable harm. During discovery, the hauler admitted it could not identify or quantify any actual damages and stipulated it was not seeking damages outside Kansas City. The district court granted the compaction company’s motion to strike the hauler’s jury demand, holding that the hauler had not presented evidence of compensatory damages, that nominal damages were unavailable under Missouri law for the claims asserted, and that the remaining claims were equitable in nature. After a bench trial, the district court entered judgment for the compaction company and its franchisor, finding the hauler failed to prove essential elements of its claims, including actual damages and direct benefit conferred for unjust enrichment.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed. The court held that the hauler was not entitled to a jury trial under the Seventh Amendment because it failed to present evidence of compensatory damages and nominal damages were not available for its claims under Missouri law. The court also affirmed judgment for the compaction company on the trespass to chattels and unjust enrichment claims, finding the hauler failed to prove dispossession, damages, or a direct benefit conferred. View "Allied Services v. Smash My Trash, LLC" on Justia Law

The plaintiff, a former police officer in Dermott, Arkansas, alleged that he was forced to resign in retaliation for reporting a fellow officer’s excessive use of force. The incident in question involved the other officer grabbing an arrestee by the neck while the arrestee was restrained. Subsequently, the officer accused the plaintiff of taking money from a parolee, which the parolee confirmed in a statement. The police chief referred the matter to a prosecutor, who initiated a state police investigation. During this period, the plaintiff’s employment status became unclear, with conflicting statements about whether he was fired or resigned. The plaintiff ultimately resigned after a job offer from another police department was rescinded due to the ongoing investigation. He was later charged with abuse of office and witness bribery, but the charges were dismissed when the parolee could not be located.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants on all claims. The court found that the plaintiff had voluntarily resigned and had not suffered an adverse employment action, which was necessary for his First Amendment retaliation claim. The court also determined that the plaintiff was not “seized” within the meaning of the Fourth Amendment for his malicious prosecution claim, as a summons to appear in court did not constitute a seizure. The court exercised supplemental jurisdiction over the state law claims and found that they failed on the merits, including claims under the Arkansas Whistle Blower Act, malicious prosecution, abuse of process, and defamation.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the plaintiff’s voluntary resignation did not amount to an adverse employment action, and that he was not seized under the Fourth Amendment. The court also agreed that the state law claims failed as a matter of law. View "Brown v. City of Dermott Arkansas" on Justia Law

Anthony Schmitt, a Christian volunteer, taught a program called “The Quest for Authentic Manhood” at the Minnesota Correctional Facility from 2012 until 2020, when all religious programming was suspended due to the COVID-19 pandemic. The Quest program, which is based on biblical teachings about manhood, was popular among inmates and had been offered voluntarily. In 2023, after religious programming resumed, the Minnesota Department of Corrections (MDOC) decided to discontinue Quest, citing concerns that its content conflicted with the department’s diversity, equity, and inclusivity values. The MDOC specifically objected to the program’s biblical perspective on masculinity, its treatment of sexual orientation, and its portrayal of gender roles.Schmitt filed suit in the United States District Court for the District of Minnesota, alleging that the MDOC’s decision violated his First Amendment rights to free speech and free exercise of religion, and constituted a denominational preference in violation of the Establishment Clause. He sought a preliminary injunction to reinstate the Quest program. The district court denied the motion, applying the standard from Turner v. Safley, and found that the MDOC’s decision was rationally related to legitimate penological interests, was neutral, and did not violate Schmitt’s constitutional rights.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the preliminary injunction. The court held that, even assuming the Turner standard applied, the MDOC’s action was not neutral because it targeted Schmitt’s religious viewpoint. The court found that Schmitt was likely to succeed on the merits of his First Amendment claims and that the other factors for a preliminary injunction also favored him. The Eighth Circuit reversed the district court’s denial of the preliminary injunction and remanded with instructions to reinstate the Quest program pending further proceedings. View "Schmitt v. Rebertus" on Justia Law

A citizen of the United Kingdom, who currently resides in Japan, underwent surgery in the United Kingdom to have a medical device implanted. The device was manufactured by a Minnesota-based company, which is a subsidiary of a New Jersey-based parent company. After the device allegedly failed, the plaintiff traveled to Colorado for removal and replacement of the device, but continued to experience problems. He later received additional medical care in Thailand. Dissatisfied with the device’s performance, he filed a lawsuit in the United States District Court for the District of Minnesota, asserting negligence and strict liability claims against both the manufacturer and its parent company.The defendants did not contest jurisdiction or venue in Minnesota, but moved to dismiss the case on the grounds of forum non conveniens, arguing that the United Kingdom was a more appropriate forum. The district court agreed, reasoning that most relevant events and evidence were outside Minnesota, and dismissed the case with prejudice. The court also denied the plaintiff’s request to amend his complaint to add more facts connecting the case to Minnesota, concluding that such an amendment would be futile. The plaintiff’s subsequent request to file a motion for reconsideration was also denied.The United States Court of Appeals for the Eighth Circuit reviewed the case and determined that the district court abused its discretion. The appellate court held that the district court failed to properly hold the defendants to their burden of persuasion on all elements of the forum non conveniens analysis and erred by automatically weighing all contacts outside Minnesota in favor of the United Kingdom, rather than considering contacts with the entire United States. The Eighth Circuit reversed the dismissal and remanded the case for a new forum non conveniens analysis, instructing the district court to apply the correct legal standards and properly weigh the relevant factors. View "Dibble v. Torax Medical, Inc." on Justia Law

John Baldwin sued Union Pacific Railroad Company under the Americans with Disabilities Act (ADA) and the Age Discrimination in Employment Act (ADEA), alleging he was unlawfully removed from his position following a fitness-for-duty evaluation. Baldwin, who had degenerative arthritis and underwent a double hip replacement, experienced a bursitis flare-up while working, leading to a fitness-for-duty evaluation. Despite being cleared by his orthopedic surgeon and a physical exam, Union Pacific's Chief Medical Officer imposed work restrictions based on Baldwin's exercise tolerance test results, which showed low aerobic capacity and mild hypertension. Baldwin was ultimately prevented from returning to his job.The United States District Court for the District of Nebraska denied both parties' summary judgment motions. Baldwin voluntarily dismissed his disparate impact and ADEA claims, proceeding to trial on the ADA claims for disparate treatment and failure to accommodate. The jury found that Union Pacific discriminated against Baldwin based on a perceived disability but concluded he posed a direct threat to himself. The district court entered judgment for Union Pacific and denied Baldwin’s motion for a new trial, which challenged the jury instructions.The United States Court of Appeals for the Eighth Circuit reviewed the case. Baldwin argued that the jury instructions misallocated the burden of proof and omitted essential elements of the direct threat defense. The court found that while the direct threat instruction was incomplete, it did not affect the trial's outcome. The business judgment instruction was deemed appropriate and did not mislead the jury. The court affirmed the district court's judgment, concluding that the instructions, taken as a whole, did not mislead the jury or affect Baldwin's substantial rights. View "Baldwin v. Union Pacific Railroad Co." on Justia Law