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

Parolees sued the Missouri Department of Corrections (MDOC), claiming that its parole revocation system violated the Due Process Clause. Recognizing the system’s flaws, MDOC rewrote its policies and consented to summary judgment. Later, MDOC moved to dismiss for failure to join a required party—the Missouri Public Defender Commission (Commission). The district court denied MDOC’s motion and held a hearing to determine whether MDOC’s revised policies satisfied due process. Finding additional problems, the district court issued a remedy order instructing MDOC to make changes.   The Eighth Circuit affirmed in part, reversed in part, and remanded. The court explained that the state must hold a revocation hearing “within a reasonable time after the parolee is taken into custody.” The court wrote that MDOC has a policy requiring a revocation hearing within 30 days, but it does not always follow that policy. The district court ordered MDOC to follow its 30-day policy. The court wrote that because it has held that longer delays may be reasonable in some cases, the remedy is not tailored to the violation and was an abuse of discretion. View "Stephanie Gasca v. Anne Precythe" on Justia Law

Parents Defending Education, an association of parents, brought this action to challenge a policy adopted by the Linn Mar Community School District in Iowa. The disputed policy is entitled “Administrative Regulations Regarding Transgender and Students Nonconforming to Gender Role Stereotypes.” The policy sets forth regulations for the District that “address the needs of transgender students, gender-expansive students, nonbinary, gender nonconforming students, and students questioning their gender to ensure a safe, affirming, and healthy school environment where every student can learn effectively.” The parents who seek to participate in this case are anonymous; the pleadings identify them by a letter of the alphabet. The district court determined that Parents Defending failed to establish Article III standing because the organization did not show injury, causation, or redressability on its claims.   The Eighth Circuit dismissed the appeal in part as moot and reversed on one claim. The court concluded that at least Parent G has alleged an injury in fact sufficient to confer Article III standing. Parent G asserts that her son wants to “state his belief that biological sex is immutable.” Because of the policy, however, Parent G states that her son remains silent in school “when gender identity topics arise” to avoid violating the policy. This student’s proposed activity “concerns political speech” and is “arguably affected with a constitutional interest.” Thus, Parent G has standing to bring a claim challenging the policy based on the First Amendment. Therefore, Parents Defending has standing as an association to pursue the claim on behalf of a member. View "Parents Defending Education v. LinnMar Community School Dist., et al" on Justia Law

MyPillow, Inc. and Chief Executive Officer Michael Lindell (collectively, “Lindell”) appealed the district court’s denial of their motions for a preliminary injunction and for the return of property—Lindell’s cell phone that was seized by federal agents on September 13, 2022. The basis of Lindell’s action arises from an ongoing federal investigation into the individuals responsible for publishing forensic images of election software used in the 2020 election in Mesa County, Colorado. He argued on appeal that the federal investigation violates his First Amendment rights of freedom of speech, freedom of association, freedom of the press, and the right to petition for the redress of grievances. He also contended the search warrant for his phone violates the Fourth Amendment’s prohibition against general warrants.   The Eighth Circuit affirmed the district court’s denial of Lindell’s motion for a preliminary injunction. The court reversed the district court’s decision not to exercise equitable jurisdiction over Lindell’s motion for the return of property as it relates to the continued retention of the cell phone itself and all its data. The court explained that it is unable to determine from the record whether the government can reasonably justify its continued refusal to return Lindell’s cell phone, which at this point was seized nearly a year ago, or the data on it, which is entirely unrelated to the offenses the government is investigating. Accordingly, the court remanded for the district court to hold a prompt hearing and balance the government’s interest in retaining Lindell’s cell phone and all its data against Lindell’s right to get the property back. View "Michael Lindell v. United States" on Justia Law

Kenneth Kraemer and Kraemer Farms, LLC (collectively, “Plaintiffs”) commenced this qui tam action under the False Claims Act (“FCA”), against United Dairies, other dairy farms, and their partners and agents (“Defendants”) alleging that they knowingly filed false crop insurance claims. Plaintiffs’ FCA Complaint alleged that Defendants (1) fraudulently obtained crop insurance payments by falsely reporting a silage-use-only variety of corn as grain and using that false statement to obtain the payments, and (2) were unjustly enriched by receiving the payments. The district court held that Defendants submitted materially false claims but denied Plaintiffs FCA relief because they failed to prove that Defendants knowingly defrauded the United States. However, the court found that certain Defendants had been unjustly enriched and awarded damages to the United States. The United States then filed a post-trial motion urging the district court to vacate or amend its judgment because Plaintiffs do not have standing to seek common law unjust enrichment relief on behalf of the United States. The district court granted the motion and vacated its judgment for lack of subject matter jurisdiction.   The Eighth Circuit affirmed. The court explained that the dismissal of Plaintiffs’ FCA claims must be affirmed even if Plaintiffs are correct that the district court erred in ruling that any violations were not knowing. The court wrote that because it concludes that Defendants in submitting Acreage Reporting Forms supporting their crop insurance applications did not submit materially false claims for crop insurance payments, Plaintiffs contention -the district court applied the wrong legal standard in denying FCA relief on other grounds is of no moment. View "United States ex rel. Kenneth Kraemer v. United Dairies, L.L.P." on Justia Law

Creighton Preparatory School expelled Plaintiff after he made lewd remarks about a teacher. Plaintiff sued Creighton under Title IX of the Education Amendments of 1972 on the theory that the school had discriminated against him by failing to perform an “adequate and impartial investigation.” The district court granted Creighton’s motion to dismiss. It first dismissed the Title IX claim because Plaintiff had failed to “allege [that] his sex played any part in the disciplinary process at all.” Then, with the federal question gone, it declined to exercise supplemental jurisdiction over Plaintiff’s breach-of-contract claim.The Eighth Circuit affirmed. The court explained that Plaintiff does not allege that Creighton faced external pressure to punish male students, much less gave in by expelling him. The court reasoned that without an allegation of that kind, the complaint fails to plausibly allege the sort of “causal connection between the flawed outcome and gender bias” required to make an erroneous outcome theory work.Further, the court wrote that treating men and women differently can support an inference of sex discrimination, but it requires identifying a similarly situated member of the opposite sex who has been “treated more favorably.” For Plaintiff, he had to find “a female accused of sexual harassment” who received better treatment. There are no female students at Creighton, an all-boys school, let alone any who have faced sexual-misconduct allegations. The court explained that to the extent that Plaintiff argues that believing them over him raises an inference of discrimination, there is nothing alleged that the school did so because of his sex. View "Elijah Wells v. Creighton Preparatory School" on Justia Law

Plaintiff was hired as a Law Enforcement Officer by the Sisseton, South Dakota, Police Department. Plaintiff and the City signed a Sisseton Police Department Employment Contract (the “Contract”) requiring Plaintiff to reimburse the City for the cost of her training if she left the Department before completing 36 months of employment. In January 2022, Defendant, the City’s Chief of Police, informed Plaintiff that the Police Commission had lost confidence in her, and Defendant asked Plaintiff to resign, which she did. Plaintiff filed this 42 U.S.C. Section 1983 action, asserting, along with other claims, that the City and numerous individual defendants violated her Fourteenth Amendment procedural and substantive due process rights. The district court granted Defendants’ motion. Plaintiff appealed only the dismissal of her due process claims.   The Eighth Circuit affirmed. The court agreed with the district court the Supreme Court of South Dakota would rule that the Contract did not change an at-will employment relationship. The court explained that for Plaintiff’s claim against the City to survive a motion to dismiss, her complaint must contain “enough facts to state a claim to relief that is plausible on its face.” The court agreed with the district court that the Complaint “failed to allege any unconstitutional policy or custom that enabled” Defendants to deprive Plaintiff of her alleged federal due process rights. Counsel for Plaintiff could only respond that the Complaint plausibly alleged the practice of violating the three-year term in the City’s employee reimbursement contracts. That practice was not alleged in the Complaint and, in any event, is nothing more than a “facially lawful municipal action.” View "Samantha LaCoe v. City of Sisseton" on Justia Law

The University of Iowa expelled graduate student John Doe after investigating two accusations of sexual misconduct brought against him by different complainants. The Iowa Board of Regents affirmed the decision. Doe sued the University and University officials, claiming, in part, discrimination on the basis of sex under Title IX, 20 U.S.C. Section 1681(a), and procedural due process violations, 42 U.S.C. Section 1983. The district court granted qualified immunity to the University officials, dismissed the procedural due process claims against them, and granted the University summary judgment on the remaining claims.   The Eighth Circuit affirmed. The court explained that it is not convinced that institutional efforts to prevent sexual misconduct on campus, including educational programs that challenge students to evaluate the impact of gender norms on rape culture, amount to evidence of external pressure on the University that supports an inference of bias. The court held that Doe failed to provide “sufficient evidence to allow a reasonable jury to find that [the University] disciplined him on the basis of sex.” Accordingly, the court affirmed the district court’s grant of summary judgment on Doe’s Title IX claim. Further, the court explained that the University provided adequate notice of the charges. Therefore, the court wrote that because Doe failed to show the University officials’ conduct violated his federal rights, it affirmed the district court’s dismissal of Doe’s claims against the University officials. View "John Doe v. University of Iowa" on Justia Law

Great River Entertainment, LLC sought coverage from Zurich American Insurance for losses related to the COVID-19 pandemic. The district court granted Zurich’s motion to dismiss for failure to state a claim. Great River appealed and moved to remand because there was not complete diversity of citizenship.   The Eighth Circuit remanded to the district court to consider whether there is federal diversity jurisdiction. The court explained that it cannot proceed without subject matter jurisdiction. The court wrote that based on Great River’s new affidavit, it is unable to conclude that its members were diverse. While Great River’s carelessness has clearly wasted judicial resources, the court explained that it cannot address the merits before determining federal jurisdiction. This is a task better suited for the district court. The court wrote that on remand, the court may also take additional action it deems appropriate. View "Great River Entertainment, LLC v. Zurich American Insurance Co." on Justia Law

Plaintiff sued under 42 U.S.C. Section 1983 on behalf of her son, who died in a vehicle accident while fleeing Defendants, St. Louis County police officers. Plaintiff claimed the officers failed to provide medical aid in violation of the Due Process Clause of the Fourteenth Amendment of the U.S. Constitution, and the officers filed a motion for summary judgment based on qualified immunity. The district court denied the motion, concluding there were genuine disputes of material facts that prevented it from holding the officers were entitled to immunity at this stage of the proceedings.   The Eighth Circuit affirmed. The court explained that Plaintiff does not argue that the officers simply delayed calling for medical assistance. Instead, she argues the officers never called for medical assistance—thus denying medical aid altogether. The court explained that in such cases where no medical aid was provided, there is no need to provide evidence demonstrating the detrimental effect of the lack of aid. The court wrote that because the officers failed to render any aid, rather than simply delaying in providing it, precedent does not require Plaintiff to demonstrate the detrimental effect of the lack of aid. Thus, we agree with the district court that, viewed in the light most favorable to Plaintiff, she has shown a clearly established constitutional violation. View "Clara Cheeks v. Mark Jakob" on Justia Law

EEE Minerals, LLC, and a Trustee for The Vohs Family Revocable Living Trust, sued the State of North Dakota, the Board of University and School Lands, and the Board’s commissioner in a dispute over mineral interests in McKenzie County, North Dakota. Plaintiffs alleged that state law related to mineral ownership was preempted by federal law and that the defendants had engaged in an unconstitutional taking of the plaintiffs’ mineral interests. Plaintiffs sought damages, an injunction, and declaratory relief. The district court dismissed the action.   The Eighth Circuit affirmed. Plaintiffs contend that the Flood Control Act impliedly preempts the North Dakota statute because the state law “stands as an obstacle to the accomplishment and execution of the full purposes and objectives of Congress.” The court explained that it is not convinced that the State’s determination of a high-water mark, and the attendant settling of property rights under state law, stands as an obstacle to accomplishing the objectives of the Flood Control Act. The court wrote that the interests of the United States and the goals of the Flood Control Act are unaffected by a dispute between the State and a private party over mineral rights that were not acquired by the federal government.   Further, the court explained that Plaintiffs have not established that the United States will be prevented from flooding or inundating any land covered by the 1957 deed in which the State claims ownership of mineral interests under state law. The Flood Control Act would not dictate that property rights be assigned to Plaintiffs. View "EEE Minerals, LLC v. State of North Dakota" on Justia Law