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

The United States Court of Appeals for the Eighth Circuit ruled in a case concerning a law in Iowa that penalized anyone who, while trespassing, knowingly placed or used a camera or surveillance device on the trespassed property. The law was challenged by five animal-welfare groups who argued that it unconstitutionally punished activity protected by the First Amendment. The lower court agreed with the plaintiffs, ruling that the law was unconstitutional on its face because it was not narrowly tailored to achieve the state's substantial interests. On appeal, the Eighth Circuit affirmed in part and reversed in part the lower court's decision. The appellate court found that the plaintiffs had standing to challenge the part of the law that penalized the use of cameras while trespassing (the "Use Provision"), but not the part penalizing the placement of cameras on trespassed property (the "Place Provision"). The court also disagreed with the lower court's conclusion that the law was unconstitutional, holding that it survived intermediate scrutiny against a facial challenge and was not unconstitutionally overbroad, as it did not prohibit a substantial amount of protected speech relative to its plainly legitimate sweep. The court remanded the case for further proceedings consistent with its opinion. View "Animal Legal Defense Fund v. Reynolds" on Justia Law

In this case, UMB Bank, N.A. (UMB) filed a complaint against Jessie Benton and her children, alleging that they violated the Racketeer Influenced and Corrupt Organizations Act (RICO) by committing acts of mail, wire, and bank fraud. The dispute arose from the management of a family trust, which included works of art, real estate, and personal effects. The beneficiaries of the trust accused UMB of mismanagement and sued UMB in a separate Missouri state court case. UMB then filed this federal case, arguing that the beneficiaries and their attorney engaged in fraudulent activities to force UMB to increase trust distributions or resign as trustee.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision to dismiss UMB's complaint for failure to state a civil RICO claim. The court agreed that UMB failed to sufficiently allege a pattern of racketeering activity. Although UMB might be able to prove that three communications to media outlets qualify as predicate acts of mail, wire, or bank fraud, these acts did not show a pattern of racketeering activity because they occurred within a few days and targeted a single victim (UMB). The court also affirmed the district court's denial of UMB's post-judgment motions for leave to amend the complaint, as the proposed amendment was both untimely and futile. View "UMB Bank v. Guerin" on Justia Law

In a case before the United States Court of Appeals For the Eighth Circuit, the plaintiffs, a group of patients, sued BJC Health System (BJC) alleging that BJC had violated their medical privacy rights under Missouri state law. Specifically, the plaintiffs claimed that when they accessed their electronic health records (EHRs) through BJC’s online patient portal, their protected health information was shared with third-party marketing services. BJC removed the case to federal court under the federal officer removal statute, arguing that they acted under the United States Department of Health and Human Services (HHS) when creating and operating the online patient portal. BJC's argument was rejected by the district court which ordered the case to be remanded back to Missouri state court. BJC appealed this decision.The United States Court of Appeals For the Eighth Circuit affirmed the decision of the district court to remand the case to the Missouri state court. The appellate court held that BJC, while receiving federal incentive payments from HHS for creating and operating the online patient portal, was not essentially performing a basic governmental task or duty. Therefore, BJC was not acting under a federal officer in terms of the federal officer removal statute. The court concluded that the creation and operation of an online patient portal was not a basic governmental task, and BJC was not a government contractor or functioning as a federal instrumentality. View "Doe v. BJC Health System" on Justia Law

Guatemalan citizens Miguel Pascual-Miguel and his daughter, Erika Gabriela Pascual-Miguel, sought review of the Board of Immigration Appeals' (BIA) decision affirming the denial of their asylum, withholding of removal, and protection under the Convention Against Torture requests by an immigration judge. They also sought review of the BIA’s denial of motions to reopen for ineffective assistance of counsel and Mendez Rojas class membership. The United States Court of Appeals for the Eighth Circuit denied the petition, affirming the BIA's decisions. The court held that the denial of asylum, withholding of removal, and CAT relief was supported by substantial evidence. Specifically, the court noted that the petitioners failed to show any evidence of persecutory motive related to their home in Guatemala being burned down, as they didn't know who did it or why. The court also held that the BIA's denial of the motions to reopen was not an abuse of discretion. The court noted that the attorney's misconduct did not prejudice the outcome of the removal proceedings and that the petitioners failed to demonstrate a nexus between the harm suffered and any protected ground, even if they were members of the Mendez Rojas class. View "Pascual-Miguel v. Garland" on Justia Law

The United States Court of Appeals for the Eighth Circuit reviewed a case where Deborah Lightner, a former employee of Catalent CTS (Kansas City), LLC, alleged age discrimination and retaliation under Missouri law. Lightner had received multiple promotions during her employment, but after several employees left citing her management style, her performance was rated poorly. After raising concerns about age discrimination in an email, Catalent removed the option of a performance improvement plan (PIP), offering only a demotion or severance. The district court granted summary judgment in favor of Catalent.Upon review, the Eighth Circuit affirmed the district court's decision on the age discrimination claim, as Lightner failed to show that Catalent's justifications were a pretext for discrimination. However, the court reversed the judgment on the retaliation claim. The court found that the timing of Catalent's removal of the PIP option within 48 hours of Lightner's complaint, combined with text messages from Catalent management, created a sufficient inference of retaliation. Here, the close temporal proximity was deemed sufficient to support a reasonable inference of a causal relationship. The case was remanded for further proceedings consistent with this opinion. View "Lightner v. Catalent CTS (Kansas City)" on Justia Law

The case before the United States Court of Appeals for the Eighth Circuit involved Allen Thomas Bloodworth, II, a business owner who operated two towing businesses in Kansas City. Bloodworth alleged that the Kansas City Board of Police Commissioners and fourteen officers of the Kansas City Police Department conspired to stop him from running his businesses and shut down his ability to conduct business in Kansas City. He brought 17 state and federal claims, including defamation, tortious interference with contract and business expectancy, intentional infliction of emotional distress, and negligent hiring, training, supervision, or retention. He also alleged Fourth Amendment violations for an unlawful warrant search and seizure of his residence and business, the shooting of his dog during the search, and the seizure of business records.The district court granted summary judgment in favor of the defendants. On appeal, the Eighth Circuit affirmed the ruling. The appellate court concluded that Bloodworth failed to link the specific conduct of individual defendants to the alleged constitutional violations, and his claims were based on general assertions mostly. It also ruled that Bloodworth failed to establish that the defendants' conduct was extreme and outrageous to support his claim for intentional infliction of emotional distress. The court further found that Bloodworth failed to establish a constitutional violation resulting from the official policy, unlawful practice, custom, or failure to properly train, retain, supervise, or discipline the police officers. Therefore, there was no basis for municipal liability against the Kansas City Board of Police Commissioners. View "Bloodworth v. Kansas City Board of Police Commissioners" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit affirmed the decision of the United States District Court for the Southern District of Iowa to dismiss the lawsuit of Iowa-based livestock feed seller Hawkeye Gold, LLC against China National Materials Industry Import and Export Corporation, also known as Sinoma, for lack of personal jurisdiction. Hawkeye Gold sued Sinoma to recover an unpaid default judgment it obtained against Sinoma's now-defunct wholly owned United States subsidiary, Non-Metals, Inc., for breach of a contract to purchase livestock feed. After six years of litigation, the District Court dismissed the case because it did not have personal jurisdiction over Sinoma, a decision which Hawkeye Gold appealed. The Appeals Court, after reviewing the evidence, agreed with the District Court's conclusion that Sinoma had insufficient minimum contacts with Iowa to support personal jurisdiction. The Court also rejected Hawkeye Gold's argument that Sinoma was a party to the contract or that Non-Metals was the alter-ego of Sinoma. Furthermore, the Court affirmed the District Court's denial of Hawkeye Gold's request for sanctions against Sinoma for alleged discovery violations. View "Hawkeye Gold, LLC v. China National Materials" on Justia Law

In this case, the United States Court of Appeals For the Eighth Circuit examined claims by Colleen M. Johnson against her former employer, Midwest Division-RBH, LLC (Belton Regional Medical Center), her supervisor Patrick Avila, and her replacement Nicole Pasley. Johnson had been on medical leave for nine months due to heart-related issues when she informed Belton Regional that she could not give a return date. The next day, the company terminated her employment. Johnson sued under the Missouri Human Rights Act (MHRA), claiming age and disability discrimination, and also brought common law claims for emotional distress, defamation, and property damage. The district court dismissed the common law claims and granted summary judgment on the MHRA claims.On appeal, the Eighth Circuit affirmed the lower court's decision. The court rejected Johnson’s argument that her common law claims were not preempted by the MHRA, ruling that the MHRA provided the exclusive remedy for claims arising out of an employment relationship and that she had fraudulently joined the Missouri defendants to prevent removal. The court also found that Johnson could not establish a prima facie case of age or disability discrimination under the MHRA because she did not provide evidence that her age or disability was the “determinative influence” on her termination. Instead, the court concluded that Johnson was fired due to her refusal to provide a date when she would return from medical leave, not because of her age or disability. Finally, the court ruled that Johnson had waived her argument of constructive discharge by failing to provide meaningful legal analysis in her opposition to summary judgment. View "Johnson v. Midwest Division - RBH, LLC" on Justia Law

This appeal arises from a protest of the Dakota Access Pipeline at the Backwater Bridge in Morton County, North Dakota. Police officers deployed water, tear gas, rubber bullets, and bean bags to disperse a crowd. Plaintiffs participated in the protest, and they were allegedly injured by the officers’ use of force. The protestors sued Morton County, the City of Mandan, Stutsman County, the law enforcement chiefs for those municipalities, and one hundred unnamed officers. The district court* granted summary judgment for Defendants.   The Eighth Circuit affirmed. The court explained that it was not clearly established in November 2016 that the officers’ use of force to disperse protestors violated a constitutional right under the Fourth Amendment. Thus, the need for training and supervision on dispersal of protestors was not so obvious that it can be characterized as deliberate indifference to the protestors’ rights to be free from unreasonable seizures. Further, the court explained that as with the municipalities, there is insufficient evidence here of deliberate indifference by supervisors where the alleged constitutional right was not clearly established. View "Vanessa Dundon v. Kyle Kirchmeier" on Justia Law

Tod T. Tumey and Tumey, LLP (collectively, “Tumey”) commenced this action in 2021, alleging that Mycroft AI, Inc., engaged in harassment of Tumey, including through “online hacking, phishing, identity theft, and other cyberattacks.” In May 2021, Tumey contacted an M.L. to inquire about employing him as an expert witness in the case. Tumey emailed M.L. a copy of their Complaint against Mycroft, after which Tumey’s counsel and M.L. had a forty-to-sixty-minute conference call to discuss the nature of the case and potential expert work involved. Tumey never executed the engagement letter and did not retain M.L. Mycroft designated M.L. as their expert witness, and Tumey moved to disqualify the expert on grounds of a conflict of interest. The district court denied Tumey’s motion to disqualify M.L. Plaintiffs appealed the district court’s denial of their motion.   The Eighth Circuit affirmed. The court explained that in denying Plaintiff’s motion to disqualify the expert, the district court held that the facts “do not favor a finding that a confidential relationship existed” between Plaintiffs and the expert witness that would give rise to a conflict of interest. The court explained that the district court found that Tumey’s lack of concrete examples failed to show they shared confidential information with M.L. Similarly, the court found that Plaintiffs have failed to show the court that the district court clearly erred in finding that no conflict of interest existed. View "Tumey, LLP v. Mycroft AI, Inc." on Justia Law