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

Plaintiff, a campus police officer, initiated a retaliation action after he was terminated following an incident where he responded to a call for an intoxicated man who had lost consciousness. Employer's reason for Plaintiff's discharge was that he did not properly handle the situation, and it warranted termination. The trial court accepted Employer's reason as non-pretextual and granted Employer's motion for summary judgment.The Eighth Circuit affirmed, finding there are no genuine disputes of material fact that would allow a reasonable jury to find in favor of Plaintiff. Assuming without deciding that Plaintiff established a prima facie case of retaliation, Employer's proffered reason for Plaintiff's termination was legitimate and non-pretextual. View "Christopher Thompson v. University of Arkansas Brd of Trustees" on Justia Law

Dakotans for Health (“DFH”), a South Dakota ballot question committee, sought to place a constitutional amendment measure on South Dakota’s 2022 general election ballot. To get on the ballot, DFH would need to submit nearly 34,000 valid signatures to the South Dakota Secretary of State. When DFH filed its complaint, it employed a paid petition circulator, Pam Cole, to help it obtain these signatures. The district court preliminarily enjoined South Dakota officials from enforcing these requirements. On appeal, the Appellants argued DFH does not have standing to challenge SB 180. Alternatively, they argue the preliminary injunction was unwarranted and improper and thus the district court abused its discretion by entering it.   The Eighth Circuit affirmed. The court concluded DFH is likely to succeed in showing SB 180 is facially invalid as overbroad in that it violates the First Amendment in a substantial number of its applications. It discriminates against paid circulators for reasons unrelated to legitimate state interests, reduces the pool of circulators available to DFH, and restricts the speech of DFH by sweeping too broadly in its requirements. Put another way, SB 180 is not narrowly tailored to serve South Dakota’s important interests.   Further, the court concluded that the balance of harms and the public interest also favor DFH. While South Dakota has important interests in protecting the integrity of the ballot initiative process, it has no interest in enforcing overbroad restrictions that likely violate the Constitution. Thus, the court found that DFH has satisfied the requirements for issuance of a preliminary injunction and that the district court did not abuse its discretion. View "Dakotans for Health v. Kristi Noem" on Justia Law

Defendant appealed the district court’s denial of his motion to dismiss the Government’s petition for civil commitment under 18 U.S.C. Section 4246. Defendant argued that the Middle District of Tennessee violated the time restrictions in Section 4241(d), depriving the Western District of Missouri of subject matter jurisdiction to civilly commit him under Section 4246 because the timing violation he was no longer lawfully “committed to the custody of the Attorney General pursuant to section 4241(d).”   The Eighth Circuit affirmed. The court explained that Defendant did not object to the alleged Section 4241(d) timing violations in the Middle District of Tennessee. Although did he complain to the Middle District of Tennessee in status updates about the delays on the grounds that they violated his rights to a speedy trial and due process. But he never formally requested release, filed an appeal in the Sixth Circuit, or requested a writ of mandamus from the Sixth Circuit. Thus, Defendant waived his right to challenge the alleged Section 4241(d) timing violations. Because the alleged Section 4241(d) timing violations are the basis of Defendant’s Section 4246 challenge, his Section 4246 challenge fails. View "United States v. Andrew Ryan" on Justia Law

The Eighth Circuit reviewed a case for the second time regarding “whether a South Dakota tax on nonmember activity on the Flandreau Indian Reservation (the Reservation) in Moody County, South Dakota is preempted by federal law. On remand, and after a six-day video bench trial, the district court entered judgment in favor of the Tribe, concluding again that federal law preempts the imposition of the tax.   The Eighth Circuit reversed and remanded. The court explained that in light of guideposts from the Supreme Court, even with the evidence that the district court heard at trial, the court cannot conclude that the federal regulation in IGRA regarding casino construction is extensive. The court reasoned that even with a more factually developed record than the court considered on summary judgment, the Bracker balancing test does not weigh in favor of preemption under IGRA because the extent of federal regulation over casino construction on tribal land is minimal, the impact of the excise tax on the tribal interests is minimal, and the State has a strong interest in raising revenue to provide essential government services to its citizens, including tribal members. The district court thus erroneously entered judgment in favor of the Tribe based on IGRA’s preemption of the excise tax. View "Flandreau Santee Sioux Tribe v. Michael Houdyshell" on Justia Law

Plaintiff brought suit in state court against the officers for violation of his rights under the Fourth Amendment to the Federal Constitution and under Article I, Section 8 of the Iowa Constitution and for conspiracy to violate his federal and state constitutional rights. He also brought claims against the chief of police and the City of Des Moines for deliberate indifference under federal and state law. Defendants timely removed the suit to federal court. Plaintiff moved for summary judgment on all counts except for the number of damages; Defendants filed a cross-motion for summary judgment on the basis of federal qualified immunity and state immunity.   On appeal, Defendants argue that the district court erred in denying the individual officers qualified immunity on Plaintiff’s federal law claims, in denying the officers state immunity on his Iowa law claims, and in denying summary judgment to the City on his deliberate indifference claim.   The Eighth Circuit affirmed. The court reasoned that even combined with the fact that the stop occurred in an area known for criminal activity as well as a momentary display of nervousness on the part of a passenger, there is not enough here to justify the stop. The officers argue that there is no clearly established right to drive with a nervous passenger through a high-crime neighborhood with a temporary tag.  These facts, in isolation, do not support a conclusion that Plaintiff’s vehicle was connected to unlawful activity in general, much less to the specific kind of unlawful activity for which the officers pulled him over. View "Jared Clinton v. Ryan Garrett" on Justia Law

Plaintiff Courthouse News is a national “news service that reports on civil litigation in state and federal courts throughout the country.” When Missouri switched to an e-filing system, same-day access became the exception, not the rule. Newly filed petitions remain unavailable until court staff processes them, which can sometimes take “a week or more.” Courthouse News sued the Circuit Clerk for St. Louis County and the Missouri State Courts Administrator, alleging First Amendment violations. In their motion to dismiss Defendants asked the district court to either abstain under Younger v. Harris, 401 U.S. 37 (1971), or rule that Courthouse News’s complaint failed to state a First Amendment claim. The district court decided to abstain and never ruled on the merits.   At issue on appeal is: First, does sovereign immunity protect state-court officials who run an e-filing system that delays public access to newly filed civil petitions? Second, should federal courts abstain from hearing this type of case anyway? The Eighth Circuit reversed concluding that the answer to both is no. The court explained that the case-at-issue does not resemble the classic Younger situation: a litigant runs to federal court to cut off an impending or actual state-court proceeding that is unlikely to go well. Here, the dispute about who gets to see newly filed petitions and when, and neither is the subject of any pending state-court proceeding. The court reasoned that if Courthouse News eventually prevails on its constitutional claim, declaratory relief would mitigate this concern to some degree by giving Missouri courts “the widest latitude in the ‘dispatch of [their] own internal affairs.’” View "Courthouse News Service v. Joan Gilmer" on Justia Law

Plaintiff sued I.C. System, Inc. (ICS) under the Fair Debt Collection Practices Act (FDCPA) for violating 15 U.S.C. Section 1692c(b), which prohibits a debt collector from contacting a third party about the collection of a debt without the prior consent of the consumer. The district court granted ICS’s motion for judgment on the pleadings, finding that Plaintiff, a non-consumer, lacked standing to bring a cause of action under Section 1692c(b).   The Eighth Circuit affirmed. The court explained that it joined the other circuits that have considered this issue in concluding that non-consumers cannot bring a claim under Section 1692c(b). The court further concluded that there was no abuse of discretion because Plaintiff failed to follow the applicable rules, including Eastern District of Missouri Local Rule 4.01(A). Further, the court wrote that Plaintiff confuses Article III standing, which implicates subject matter jurisdiction and is undisputed here, and statutory standing. Thus, because Plaintiff only alleged a violation of Section 1692c(b) and the district court correctly determined that Section 1692c(b) does not provide Plaintiff standing to sue, judgment as a matter of law was appropriate. View "Andrew Magdy v. I.C. System, Inc." on Justia Law

After being hit by an under-insured motorist, Plaintiff experienced worsening symptoms from his Parkinson’s disease. His condition eventually deteriorated to the point that he could no longer work as a doctor. Plaintiff sued Encompass Insurance for $500,000, the maximum available under his automobile policy. The state trial court granted summary judgment to Plaintiff, concluding that Encompass failed to refute that Plaintiff lost at least $500,000 in earning capacity because of the accident. On removal, a federal district court held that it was unable to vacate that judgment.   The Eighth Circuit reversed and remanded. The court interpreted Encompass’s notice of appeal as challenging the Arkansas court’s ruling, as merged into the final judgment of the district court, and held that it constituted an appeal of a “final decision of a district court of the United States” under 28 U.S.C. Section 1291.   The court also rejected the district court’s conclusion that a federal court lacks jurisdiction to vacate the state court’s summary judgment order. The court explained that the Rooker-Feldman doctrine has no application to a properly removed case where, as here, there is no attack on a separate and final state-court judgment. Finally, the court held that the Arkansas court erred by granting summary judgment. The conflict between expert witnesses created a genuine dispute of material fact, so summary judgment was improper. View "Paul Wills v. Encompass Insurance Company" on Justia Law

Plaintiff was severely injured in a crash while he was driving a Peterbilt semi-truck. He sued the truck’s manufacturer, PACCAR, Inc. (PACCAR), alleging that the truck’s defective design caused his injuries. A jury returned a verdict in PACCAR’s favor. His estate appeals, arguing that the district court committed several evidentiary errors at trial.The Eighth Circuit affirmed. The court held, 1.) Plaintiff's expert's second report was untimely under the discovery orders in the case, and the district court did not abuse its discretion by excluding it; 2.) the district court did not abuse its discretion by concluding that plaintiff had failed to show the good cause required under Fed. R. Civ. P. 16(b)(4) to modify the scheduling order after the court declared a mistrial; 3.) Plaintiff failed to preserve his challenge to Defendant's "state-of-the-art" defense.Applying plain error review to Plaintiff's challenge to Defendant's "state-of-the-art" defense, the court held the district court did not plainly err in admitting the testimony as the witnesses were testifying based on their extensive industry experience, and noted that Iowa law permits industry custom as evidence of the state of the art. View "Elizabeth Zick v. Paccar, Inc." on Justia Law

Plaintiffs appealed the district court’s denial of their motion to remand and adverse grant of summary judgment in this diversity action arising out of a slip-and-fall on Ameristar Casino Kansas City, LLC’s property.   The Eighth Circuit affirmed. The court found that the district court properly applied the Massachusetts Rule and granted Ameristar’s motion for summary judgment. There is no dispute that the patch of ice on which Plaintiff slipped and fell had accumulated naturally on the walkway outside the casino’s entrance. There was no dispute that the accumulation was attributable to weather conditions general to the community. Plaintiffs point to no evidence, for example, that the ice on the walkway was an isolated condition unique to Ameristar’s property, rather than the result of weather affecting the entire Kansas City area. Thus, because Ameristar took no steps to remove or treat the ice that accumulated where Plaintiff fell, the district court properly found that Ameristar assumed no duty of care.   Further, Plaintiffs point to no Missouri case where a property owner has been found to have assumed a duty by agreement under similar circumstances. The court wrote that in essence, the Plaintiffs’ implied-agreement theory is an attempt to hold Ameristar liable based on the alleged existence of a company snow-and-ice-removal policy, but Missouri courts do not recognize such an exception to the Massachusetts Rule. View "James Cleek v. Ameristar Casino KC, LLC" on Justia Law