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

The Departments of Health and Human Services (HHS), Labor (DOL), and Treasury appealed a preliminary injunction that enjoins the government from enforcing the contraceptive mandate provisions of the Patient Protection and Affordable Care Act (ACA), 42 U.S.C. 300gg-13(a)(4), and its implementing regulations against nonprofit religious organizations that offer healthcare coverage to their employees. The district court’s order also enjoined the government from enforcing the challenged provisions against “any insurance provider (including insurance issuers and third-party administrators) offering health insurance to” the organizations. The Eighth Circuit affirmed, stating that by coercing the organizations to participate in the contraceptive mandate and accommodation process under threat ofsevere monetary penalty, the government has substantially burdened their exercise of religion. Even assuming that the government’s interests in safeguarding public health and ensuring equal access to health care for women are compelling,the contraceptive mandate and accommodation process likely are not the least restrictive means of furthering those interests. View "Dordt College v. Burwell" on Justia Law

Hall, smelling strongly of alcohol, crashed a bicycle into a garage. Police sent Hall to Ramsey County Detox Center. Cameras captured some of what followed. Around 5:20 a.m., Hall complained of leg pain to Leifeld, a registered nurse, who observed that Hall could walk, but could not put full weight on his leg. Leifeld told Hall to wait until the processing of patients set for discharge. About 10 minutes later, Hall called 911 from a pay phone. The dispatcher notified the Center. A staff member told Hall he would be placed in seclusion if he called 911 again. Hall, visibly upset, placed another call. Hall claims he called his lawyer. Leifeld believed the call violated the restriction and summoned aides, who led Hall toward the seclusion room. Hall was uncooperative. The aides pushed Hall against a wall and twisted Hall’s arm behind his back. In the seclusion room, they performed a take-down. Hall fell asleep until 7:30 a.m. He was taken to the hospital around 11:30 a.m. A doctor placed Hall’s arm in a sling and immobilized his leg. The Eighth Circuit affirmed rejection of Hall’s suit under 42 U.S.C. 1983 on summary judgment, based on qualified immunity; Hall could not demonstrate any violation of his constitutional rights. View "Hall v. Ramsey County" on Justia Law

Defendant appealed his sentence of 180 months, the mandatory minimum under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1), after pleading guilty to illegally possessing a firearm. Applying the categorical approach, the court concluded that, by the plain language of the Iowa Code, defendant's terrorism conviction was a violent felony requiring the use of force, threat, or intimidation, and was, therefore, a violent felony under ACCA, which applies when a defendant has three prior convictions for violent felonies or serious drug offenses. Defendant's conviction of going armed with intent under Iowa Code section 708.8 was also a predicate violent felony where under ACCA’s residual clause. There was no Sixth Amendment violation under Alleyne v. United States; the challenged enhancement was based solely on defendant's prior conviction and fell under the recidivism exception to the jury presentation requirement.. On remand for reconsideration in light of Johnson v. United States, (2015), the Eighth Circuit again affirmed the sentence, but subsequently granted rehearing and vacated.. In light of Johnson, Langston’s going-armed-with-intent conviction is not a qualifying violent felony, nor is Langston’s theft conviction. View "United States v. Langston" on Justia Law

In 2002 Brown began working for Diversified. She was promoted and received excellent reviews. In 2009 Brown became an account executive. Brown struggled in the position, repeatedly making serious record-keeping errors. Brown took 12 weeks of leave under the Family and Medical Leave Act, 29 U.S.C. 2601, after receiving a breast cancer diagnosis. Diversified provided Brown with additional training after she returned, and her 2011 reviews noted improvement, but still identified needed improvement. Diversified was purchased by a new owner, who told Brown’s new manager to rank employees and discharge the lowest performers. After determining that Brown was underperforming, management decided to move Brown to a different position. Diversified accommodated Brown’s high risk pregnancy and did not immediately change her job, but then lost a major account. Diversified accommodated Brown’s request to work from home for several weeks. Brown was fired five days after complaining about her reassignment .The district court granted Diversified summary judgment on all FMLA and state law claims. The Eighth Circuit reversed in part: where an employer has known its stated reason for taking adverse action against an employee for an extended period of time, but only acts after the employee engages in protected activity, the employer's earlier inaction supports an inference of pretext. View "Brown v. Diversified Distrib. Sys., LLC" on Justia Law

Defendant pleaded guilty to one count of possessing with intent to distribute 50 grams or more of a mixture or substance containing a detectable amount of methamphetamine. On appeal, defendant challenged the district court's denial of his motion to suppress evidence. The court concluded that the traffic stop was not unreasonably prolonged by a dog sniff where seven or eight minutes had passed from the time the officer issued a written warning until the dog indicated the presence of drugs. Following remand from the Supreme Court, the Eighth Circuit again affirmed. When Rodriguez’s vehicle was stopped in March 2012, the law of the Circuit provided that a brief delay to employ a drug dog did not constitute an unconstitutional seizure, as long as the traffic stop was not unreasonably prolonged. View "United States v. Rodriguez" on Justia Law

Hollingsworth was detained for booking at the police station in St. Ann, Missouri, after an arrest for stealing wine coolers from a convenience store at a gas station. When she refused a directive from police and corrections officers to change from her street clothes into an orange jumpsuit, a police officer stunned her with a Taser device to encourage compliance. Hollingsworth later sued the police officer, two corrections officers, and the City of St. Ann, under 42 U.S.C. 1983, alleging excessive force in stunning her with the Taser, and that corrections officers violated her constitutional rights by failing to intervene. She asserted that the city was liable because its policy regarding the use of Tasers was unconstitutional. The district court granted summary judgment for defendants on all claims, concluding that the officers were entitled to qualified immunity, and that the city’s Taser policy did not cause any potential violation of Hollingsworth’s rights. The Eighth Circuit affirmed, stating that although the actions of one or more officers might have been unreasonable, their conduct did not violate clearly established law at the time of the incident. View "Hollingsworth v. City of St. Ann" on Justia Law

Following a police pursuit, Murray shot Jermell through the windshield and side window of Jermell’s vehicle. Jermell died from the gunshot wounds. Jermell’s mother sued Murray, another officer (Caudell), Chief of Police Gunderman, and the City of Morrilton, alleging excessive force, supervisory liability, and municipal liability under the federal Civil Rights Act, 42 U.S.C. 1983, and claims under Arkansas law. Murray, Caudell, Gunderman, and the city moved for summary judgment. The district court granted Caudell’s motion, denied the city’s motion, granted Defendants’ motion as it pertained to Thompson’s duplicative official-capacity claims against Murray and Gunderman, and denied Murray’s motion for summary judgment based on qualified immunity. Murray and Gunderman filed an interlocutory appeal. The Eighth Circuit dismissed Murray’s appeal for lack of jurisdiction, and dismissed Gunderman’s claim for want of a reviewable order because the district court did not address or rule on Thompson’s claims against Gunderman in his individual capacity. View "Thompson v. Murray" on Justia Law

In 1989 White was convicted of rape and murder. The prosecution used testimony and confessions from White’s five co-defendants, all of whom pled guilty to related charges. After DNA testing in 2008, all convictions were pardoned or overturned. They sued Gage County and the officers involved in their case. On earlier appeals from separate summary judgments, the Eighth Circuit determined: “evidence is sufficient to support Plaintiffs’ claims that their rights to fair criminal proceedings were violated as the result of a reckless investigation and Defendants’ manufacturing of false evidence”; evidence was sufficient to support a conspiracy claim; evidence was not sufficient to support a coercion claim; members of the sheriff’s office were not protected by qualified immunity; and the county attorney was protected by absolute immunity. After trial of the consolidated claims, the court dismissed plaintiffs’ conspiracy claim and all claims against Gage County, but denied qualified immunity to the officers. The Eighth Circuit reversed as to the County and affirmed the denial of qualified immunity. Plaintiffs “produced proof of questionable procedures” and “hasty condemnation” by officers in charge of policy-making. There was ample evidence that the sheriff created policies, supervised other officers, specifically directed, endorsed, and encouraged their activities, and was a final policymaker for the County. View "Dean v. Cnty. of Gage" on Justia Law

The 2013 General Public School Choice Act, Ark. Code 6–18–1901 provided that "[a] school district annually may declare an exemption under this section if the school district is subject to the desegregation order or mandate of a federal court or agency remedying the effects of past racial segregation." Plaintiffs have minor children who reside within the Blytheville School District and applied to transfer their children to neighboring school districts. The Blytheville District subsequently adopted a resolution to exempt the District from the Act. Plaintiffs sued, alleging that the District violated their due process and equal protection rights under 42 U.S.C. 1983 and for violations of the Arkansas Civil Rights Act. The district court granted the District summary judgment. The Eighth Circuit affirmed, rejecting arguments that the District violated due process by abusing its power under state law and failing to provide pre-deprivation process, and violated equal protection by using race as the reason for its exemption and nullifying the 2013 Act within its borders on the pretense that it was subject to a desegregation order. The District at least had a rational basis for believing that it "is subject to the . . . mandate of a federal court or agency." View "Adkisson v. Blytheville Sch. Dist. #5" on Justia Law

Simmons and Gyurica were fishing on a bridge near Bowden’s property. Bowden shouted to the men to identify themselves; he fired a shotgun from his deck when they failed to respond. Bowden and Simmons then had a verbal altercation, with Bowden holding his shotgun. Each called the police. Deputy Martin first spoke with Simmons and Gyurica at the residence of Simmons’s grandmother, Voyles. They reported that Bowden shot at them. Bowden said that he shot away from the men. Martin relayed these circumstances to his supervisor, who ordered Martin to seize the shotgun and to draft a probable cause statement averring that there was probable cause that Bowden had unlawfully used a weapon. The parties dispute involvement by the circuit clerk, a friend of Voyles. Martin later admitted that he did not think that Bowden had violated Missouri law. The Jefferson County prosecutor obtained an arrest warrant. A Missouri court held a preliminary hearing and determined that there was probable cause. Bowden was acquitted. In Bowden’s suit alleging violation of his Fourth Amendment rights, the court denied the defendants summary judgment based on qualified immunity. The Eighth Circuit reversed, finding that the facts, in the light most favorable to Bowden do not show violation of his constitutional rights. View "Bowden v. Martin" on Justia Law