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

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

A law firm, Sutter & Gillham PLLC, and its partners were involved in a contentious wrongful-death lawsuit in Arkansas, representing the family of a teenage boy who died from a gunshot wound. The family suspected foul play, while the boy's friends claimed it was suicide. The state court dismissed the case with prejudice, citing misconduct by the family and its attorneys. Although the firm had withdrawn from the case, it felt unfairly maligned by the court's order. One partner's attempt to intervene and seek recusal of the judge was denied, and no appeal was filed. The family successfully overturned the dismissal, and the case remains pending.The firm faced related litigation, including a state court lawsuit by the wrongful-death defendants against the firm and its partners for alleged misconduct. The firm also filed a federal lawsuit alleging constitutional violations by the wrongful-death defendants and their attorneys, claiming they conspired with the state trial judge. The United States District Court for the Eastern District of Arkansas dismissed the case under the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court concluded that the Rooker-Feldman doctrine did not apply because the federal lawsuit did not seek to overturn the state court judgment but rather targeted the actions of the defendants and their attorneys. The court emphasized that the doctrine only applies when a federal action is essentially an appeal of a state court decision. The Eighth Circuit vacated the district court's dismissal and remanded the case for further proceedings, allowing the plaintiffs to pursue their claims. View "Sutter & Gillham PLLC v. Henry" on Justia Law

Absolute Pediatric Therapy, owned by Anthony Christopher, hired LaDonna Humphrey in May 2018 but terminated her four months later. In October 2018, Absolute and Christopher sued Humphrey in Arkansas state court, alleging various tort claims and accusing her of stealing information and making false accusations. Humphrey counterclaimed under the False Claims Act, alleging her termination was for reporting illegal activities. The litigation was contentious, and in August 2019, the state court found Humphrey in contempt and liable on all counts, awarding $3.57 million in damages to the plaintiffs.Following the state court's decision, Humphrey filed for Chapter 7 bankruptcy in September 2019. The Trustee of her bankruptcy estate proposed selling her claims, including her counterclaim and defensive appellate rights, to Absolute for $12,500. Humphrey objected to the sale of her defensive appellate rights. The bankruptcy court approved the sale, finding it reasonable and negotiated at arm's length. Humphrey did not obtain a stay of the sale but did secure a stay of the state court appeal.Humphrey appealed the bankruptcy court's order to the United States District Court for the Western District of Arkansas, which reversed the bankruptcy court's decision. The district court held that defensive appellate rights are not property of the estate under Arkansas law and found the sale not in the best interest of the estate. The district court also rejected the argument that the appeal was moot under 11 U.S.C. § 363(m) because Humphrey had obtained a stay of the state court proceedings.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the absence of a stay of the sale itself rendered the appeal statutorily moot under 11 U.S.C. § 363(m). The court vacated the district court's order and dismissed Humphrey's appeal from the bankruptcy court. View "Humphrey v. Christopher" on Justia Law

Jefferson County, Missouri, filed a lawsuit against several pharmacy benefit managers (PBMs), including Express Scripts and OptumRX, alleging that their distribution practices facilitated prescription opioid abuse, resulting in numerous deaths and emergency room visits. The County sought relief under Missouri public nuisance law. The case was initially filed in the Twenty-Second Judicial Circuit Court of Missouri and later amended multiple times. On December 1, 2023, the PBMs filed a notice of removal to federal court, citing the federal officer removal statute and other federal statutes.The case was previously part of the federal Opioid Multidistrict Litigation (MDL) but was severed and remanded to Missouri state court in July 2019. During discovery, the County provided a "Red Flag Analysis" identifying prescription claims, including federal claims. The PBMs argued that this analysis indicated the case was removable to federal court. However, the County later disclaimed reliance on federal claims in a joint stipulation.The United States District Court for the Eastern District of Missouri granted the County's motion to remand the case to state court. The district court found that the PBMs' removal was untimely, as they were required to file a notice of removal within 30 days of the February 14, 2022, Red Flag Analysis. The court also determined that removal was not substantively proper under the federal officer removal statute because the County had disclaimed any reliance on federal claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the PBMs had unambiguously ascertained that the February 14, 2022, Red Flag Analysis allowed for removal but failed to act within the required 30-day period. Consequently, the district court's order to remand the case to state court was upheld. View "Jefferson County v. Express Scripts, Inc." on Justia Law