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

Joshua Vogt died of a drug overdose while detained in a county jail. His daughter, Molly Vogt, filed a lawsuit under 42 U.S.C. § 1983, alleging that three officers deliberately disregarded his medical condition. The magistrate judge recommended summary judgment in favor of the officers, and the district court agreed. Molly Vogt appealed, arguing that a pending adverse-inference instruction against the officers created a material factual dispute regarding their deliberate indifference to Mr. Vogt’s medical condition.The United States District Court for the District of Minnesota initially reviewed the case. The magistrate judge found that the county had intentionally destroyed footage from Camera 18, which could have shown Mr. Vogt’s condition. Despite this, the magistrate judge recommended summary judgment for the officers, concluding that even with the adverse inference, the available evidence did not support a finding of deliberate indifference. The district court adopted these recommendations, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that to establish a § 1983 medical indifference claim, the plaintiff must show that officers acted with deliberate indifference to a pretrial detainee’s objectively serious medical needs. The court found that the officers repeatedly checked on Mr. Vogt, questioned him about his condition, and called for emergency medical help when his condition worsened. The court concluded that the adverse inference regarding the missing footage did not create a genuine issue of material fact sufficient to preclude summary judgment. The court affirmed the district court’s decision, granting summary judgment to the officers. View "Vogt v. Crow Wing County" on Justia Law

A Columbia County resident, Roderick McDaniel, was shot and killed by Deputy Charles McClinton outside an apartment complex in Magnolia, Arkansas. McDaniel was a suspect in a first-degree murder case, and an arrest warrant had been issued for him. Deputy McClinton encountered McDaniel in a white SUV, which matched the description of the vehicle used in the crime. When McDaniel attempted to flee by reversing into McClinton's patrol car and then accelerating forward, McClinton fired a single shot, killing McDaniel. A loaded handgun, later confirmed to be the murder weapon, was found near McDaniel.The United States District Court for the Western District of Arkansas denied Deputy McClinton's motion for summary judgment based on qualified immunity. The court found that there were material factual disputes, particularly regarding whether McDaniel was driving the SUV forward toward McClinton when he was shot. The court concluded that McClinton was not entitled to qualified immunity because it was clearly established that using deadly force against a suspect merely for fleeing, even in a vehicle, was unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that Deputy McClinton was entitled to qualified immunity. The court reasoned that McClinton had probable cause to believe McDaniel was a dangerous felon who had committed first-degree murder and was still armed. Therefore, using deadly force to prevent McDaniel's escape was constitutionally permissible. The court also noted that McClinton's conduct did not violate McDaniel's clearly established rights, as existing precedent did not clearly prohibit the use of deadly force in such circumstances. The case was remanded with instructions to enter summary judgment in favor of Deputy McClinton and dismiss the case. View "Arnold v. McClinton" on Justia Law

David Burke died after falling down retractable steps attached to his motorhome. His estate, wife, and children filed product liability claims against Lippert Components, Inc., and LCI Industries, who had purchased the product brand after the Burkes bought the vehicle. The plaintiffs alleged negligence, design defects, manufacturing defects, and inadequate instructions and warnings. They later sought to add the previous owners of the product brand as defendants and amend the scheduling order, but the district court denied these motions and granted summary judgment in favor of Lippert and LCI.The United States District Court for the Northern District of Iowa denied the plaintiffs' motions to amend the complaint and the scheduling order, citing unreasonable delay. The court then granted summary judgment for Lippert and LCI, finding that they did not manufacture, distribute, or sell the steps in question, and thus were not liable under Iowa law. The plaintiffs appealed these decisions.The United States Court of Appeals for the Eighth Circuit affirmed the district court's rulings. The appellate court held that Lippert and LCI were not required to plead an affirmative defense regarding successor liability, as their defense negated an essential element of the plaintiffs' claims. The court also found that Lippert and LCI did not assume liability through the purchase agreement and that expert testimony was necessary to support the claim of inadequate post-sale warnings. Finally, the court agreed that the plaintiffs failed to show good cause for their delayed motions to amend the complaint and scheduling order. The judgment of the district court was affirmed. View "Burke v. Lippert Components, Inc." on Justia Law

Henry Stursberg, a financial consultant, sued Morrison Sund PLLC, a Minnesota law firm, for allegedly running up legal fees without achieving results. After Stursberg decided to change counsel, Morrison Sund filed an involuntary bankruptcy petition against him. Stursberg sought to dismiss the petition, which the bankruptcy court granted under 11 U.S.C. § 305(a)(1), noting the petition was used improperly to collect fees. Stursberg then filed a diversity action in Pennsylvania, asserting state law tort claims against Morrison Sund.The Eastern District of Pennsylvania dismissed Stursberg’s claims due to lack of personal jurisdiction and improper venue, transferring the case to the District of Minnesota. The Minnesota district court dismissed the state law claims, ruling they were preempted by the Bankruptcy Code, specifically 11 U.S.C. § 303(i), which provides remedies for bad faith filings of involuntary bankruptcy petitions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s dismissal, holding that the federal court that dismisses an involuntary bankruptcy case has exclusive jurisdiction to enforce debtor remedies under § 303(i). The court concluded that Stursberg’s state law claims were preempted by the federal statute, and his failure to appeal the bankruptcy court’s denial of his motion for attorney’s fees and costs under § 303(i)(1) precluded him from seeking further damages. The court emphasized that § 303(i) provides an exclusive remedy for bad faith filings, precluding state law tort claims in this context. View "Stursberg v. Morrison Sund PLLC" on Justia Law

In May 2023, Iowa's Governor signed Senate File 496 (SF496) into law, which introduced new regulations for public school libraries, classrooms, and curriculum, and required parental notification for certain gender identity accommodations. Two groups of plaintiffs, including students, authors, and educators, filed lawsuits to enjoin SF496, arguing it violated the First Amendment, the Fourteenth Amendment, and the Equal Access Act. The plaintiffs sought a preliminary injunction to prevent the law's enforcement.The United States District Court for the Southern District of Iowa granted the preliminary injunction, enjoining the enforcement of SF496's provisions related to the removal of books from school libraries and the prohibition of instruction on gender identity and sexual orientation for students in kindergarten through grade six. The court found that the plaintiffs had standing and that the law's enforcement would likely cause irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the district court's analysis was flawed. The appellate court held that the district court did not properly apply the legal standards for facial challenges and failed to consider the law's legitimate applications. The Eighth Circuit also noted that the district court did not adequately address the as-applied challenges raised by the plaintiffs. Consequently, the appellate court reversed the district court's decision, vacated the preliminary injunction, and remanded the case for further proceedings consistent with its opinion. The plaintiffs were allowed to pursue injunctive relief under the correct legal framework and address the unconsidered as-applied challenges. View "GLBT Youth in Iowa Schools Task Force v. Reynolds" on Justia Law

An Arkansas inmate, Steven Pinder, filed a lawsuit under 42 U.S.C. § 1983, alleging that various defendants, including Wellpath, LLC, and its employees, were deliberately indifferent to his serious medical needs, violating his Eighth Amendment rights. Pinder sought declaratory and injunctive relief and substantial damages for several medical issues, including severe glaucoma, peptic ulcers, acid reflux, diabetes, and an orthopedic condition in his right shoulder. The district court granted summary judgment to two defendants on the shoulder claim and dismissed other claims for failure to establish in forma pauperis (IFP) status.The United States District Court for the Eastern District of Arkansas initially denied Pinder's IFP status due to his "three strikes" under the Prison Litigation Reform Act (PLRA), which bars prisoners with three prior dismissals for frivolous or malicious claims from proceeding IFP unless they are in imminent danger of serious physical injury. Pinder filed a declaration asserting imminent danger, which the magistrate judge partially accepted, allowing some claims to proceed. The district court adopted these recommendations but later revoked IFP status for most claims based on new evidence, ultimately granting summary judgment on the remaining shoulder claim.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court remanded the motion to revoke Pinder's IFP status to the district court for further consideration, particularly in light of new medical evidence. The appellate court also remanded the issue of whether the interlocutory dismissals were proper, given a recent Eighth Circuit opinion. The court did not rule on the summary judgment at this time, vacating the district court's judgment and remanding for further proceedings consistent with its opinion. View "Pinder v. WellPath" on Justia Law

Devon Arseneau and her ex-husband were involved in a child custody dispute in the St. Louis County Circuit Court. The court appointed Elaine Pudlowski and Brian Dunlop as guardians ad litem to represent the child's best interests and James Reid to conduct psychological evaluations. Following their testimonies, the court awarded sole legal custody to Arseneau’s ex-husband and joint physical custody to both parents. Arseneau subsequently filed a lawsuit under 42 U.S.C. § 1983 against Pudlowski, Dunlop, and Reid, alleging that their actions during the custody proceedings violated her constitutional rights.The United States District Court for the Eastern District of Missouri dismissed Arseneau’s complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The court concluded that the defendants were entitled to absolute immunity and had not acted under color of state law. The district court did not address the defendants' arguments regarding Younger abstention or the Rooker-Feldman doctrine.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s dismissal. The appellate court determined that Younger abstention did not apply because there were no ongoing state proceedings. It also bypassed the Rooker-Feldman issue, finding that the merits of the case warranted dismissal. The court held that the defendants, as guardians ad litem and a court-appointed psychologist, were entitled to absolute immunity for actions within the scope of their judicial duties, even if those actions were alleged to be wrongful or illegal. Consequently, the court affirmed the dismissal of Arseneau’s § 1983 claims. View "Arseneau v. Pudlowski" on Justia Law

Antonio Webb, a former state inmate in Missouri, filed a lawsuit against several prison officials, alleging violations of his Eighth Amendment rights. Webb claimed he was subjected to sexual harassment and abuse, that officials failed to protect him from this abuse, and that he faced retaliation for reporting the misconduct. The district court granted summary judgment in favor of the officials, leading to Webb's appeal.The United States District Court for the Western District of Missouri initially handled the case. The officials asserted qualified immunity as a defense in their answer to Webb's complaint but did not file a motion to address it. The case moved forward through discovery, and at a pretrial conference, the officials indicated they had not moved for summary judgment on qualified immunity due to a lack of grounds. However, four days before the trial, the court ordered the officials to file a motion discussing qualified immunity, extended the deadline for dispositive motions, and continued the trial. The officials complied, and the court granted summary judgment, concluding Webb failed to present sufficient evidence of any constitutional violation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court's decision to address qualified immunity before trial was a reasonable exercise of case management, aimed at conserving judicial resources and ensuring fairness. Webb had adequate notice and an opportunity to respond to the motion. On the retaliation claim, the court determined Webb did not provide competent evidence to support his allegations. His declaration was inadmissible as it was not signed under penalty of perjury, and his grievance records did not meet the requirements of Federal Rule of Civil Procedure 56. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Webb v. Lakey" on Justia Law

An inmate in the Arkansas Department of Corrections (ADC) filed a pro se 42 U.S.C. § 1983 action, alleging that several ADC employees retaliated against him for exercising his First Amendment rights. The inmate claimed retaliation occurred after he filed a grievance, circulated a memorandum encouraging other inmates to file grievances against a new administrative directive, and threatened a lawsuit. The directive in question imposed a three-page limit on non-privileged correspondence between inmates and non-incarcerated individuals. The inmate was charged with rule violations, placed in isolation, and later moved to administrative segregation.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants, concluding that they had valid, non-retaliatory reasons for their actions, as the inmate had violated prison rules. The district court also denied the inmate's request for an extension of time to file his own summary judgment motion, citing a lack of good cause and the age of the case. The inmate appealed both decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court’s grant of summary judgment, finding that the inmate’s circulation of the memorandum was protected conduct under the First Amendment and that there was insufficient evidence to demonstrate a security concern justifying the disciplinary actions. The court also found that the district court erred in relying on a written charge of a rule violation that was dismissed on procedural grounds and on the inmate’s deposition testimony given years later. However, the court affirmed the district court’s denial of the inmate’s request for an extension of time to file a summary judgment motion, finding no abuse of discretion. View "Lamar v. Payne" on Justia Law

In the 1950s, the U.S. Army Corps of Engineers purchased land from the Meltons and the Paines, using traditional surveying descriptions. A 1962 subdivision plat map indicated a stone (Peter’s Stone) that appeared to mark the boundary, but a 1974 Corps survey found the stone was not at the true centerline. This discrepancy led to a land dispute over a strip of land between the true centerline and the stone.In 1977, the United States filed quiet title actions against the owners of Lot 8 and adjacent landowners. The court consolidated the cases and found that the Meltons and the Corps likely believed the stone marked the true centerline. In 1979, the court awarded a small portion of Lot 8 to the Highfills but did not resolve the boundary for other lots. The judgment was recorded in 1989.In 2019, the Gambrells purchased several lots in the subdivision and, in 2020, were informed by the Corps that the true centerline was marked by the Corps’ monument, not Peter’s Stone. The Gambrells filed a quiet title action in 2021. The United States moved for summary judgment, arguing the 1979 judgment and the 1974 monument provided notice of a potential dispute. The district court granted summary judgment for the United States, citing the Quiet Title Act’s 12-year statute of limitations.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The court held that the 1979 judgment and the 1974 monument provided constructive notice of the United States’ claim, triggering the statute of limitations. The court also rejected the Gambrells’ collateral estoppel argument, noting that nonmutual offensive collateral estoppel does not apply against the United States. The court emphasized that the statute of limitations ruling does not resolve the underlying boundary dispute, leaving the parties free to pursue further legal actions. View "Gambrell v. United States" on Justia Law