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

Defendant, in addition to her full-time position as a St. Paul police officer, was cross-deputized as a federal agent to investigate an interstate sex-trafficking scheme. Many were charged, but none were convicted. The attention soon turned to Defendant, who faced lawsuits from the people she came across during the investigation, including the Plaintiff in this matter.   Plaintiff became involved because of a dangerous encounter with a witness in the federal sex-trafficking investigation. That witness made a call to Defendant, falsely claiming that Plaintiff started the dispute. In Defendant’s affidavit supporting the criminal complaint against Plaintiff, she identified herself as an “FBI Task Force Officer / St Paul MN PD Officer.”  Plaintiff sought to recover on a wrongful-arrest theory against Defendant, whom she has sued in two different capacities: as a St. Paul police officer and as a deputized federal agent.   The district court granted Defendant’s motion for summary judgment on the ground that her actions arose under color of federal law. The Eighth Circuit affirmed, finding that without any actual or purported relationship between Defendant’s conduct and her duties as a police officer no section 1983 action is available.   The court wrote that at issue here is whether Defendant acted under color of state law when she allegedly lied to protect a federal witness while serving on a federal task force. The court explained that state law had nothing to do with “the nature and circumstances” of Defendant’s conduct. The court wrote that Defendant acted within the scope of her federal duties while dealing with the situation, and she referenced her federal-task-force role during her conversations with officers. View "Ifrah Yassin v. Heather Weyker" on Justia Law

Appellant, a black male who was 60 years old at the time his employment was terminated, brought race, sex, and age discrimination claims under Title VII, the Age Discrimination in Employment Act (“ADEA”), and the Minnesota Human Rights Act (“MHRA”) and a retaliation claim under the Minnesota Whistleblower Act ("MWA") after the Minnesota Guardian ad Litem Board (“GALB”) terminated his employment following internal and external investigations into allegations of his misconduct. The district court granted GALB’s motion for summary judgment, finding that Appellant failed to demonstrate a prima facie case of discrimination or retaliation and, even if he had done so, he failed to demonstrate GALB’s reasons for terminating his employment were pretextual.   Appellant appealed and the Eighth Circuit affirmed. The court explained that Appellant failed to point to any direct evidence of discrimination or retaliation; thus, the McDonnell Douglas burden-shifting framework applies. The court concluded that GALB has demonstrated a legitimate, nondiscriminatory and nonretaliatory reason for terminating Appellant in March 2018: the internal and external investigations into Appellant’s alleged misconduct uncovered evidence that Appellant had engaged in gross misconduct. As such, because Appellant failed to show that GALB’s reasons for terminating his employment were pretextual, the district court did not err in granting summary judgment to GALB on his race, sex, and age discrimination claims and his retaliation claim. View "Gregory King v. MN Guardian ad Litem Board" on Justia Law

After Nygard removed his driveway and was about to pour a new one, an Orono inspector told Nygard that he needed a permit. The next day, Nygard finished the driveway and applied for a permit. The new driveway was narrower than the previous one. The city responded with a form, imposing several conditions. Nygard crossed out some conditions, initialed the modified form, and returned it. After several exchanges, the city notified Nygard that he must agree to the conditions or “this matter will be turned over to the prosecuting attorney.” Nygard did not acknowledge the conditions. A police officer drafted a statement of probable cause, alleging that “work had been completed without having first obtained a permit” and listing some alleged deficiencies in its construction. According to the Nygards, the police did not inspect the property and some allegations were not true.Nygard was acquitted of violating the city code. The Eighth Circuit affirmed the dismissal of his suit under 42 U.S.C. 1983, claiming the code was void for vagueness and alleging First Amendment retaliation, abuse of process, and malicious prosecution. Nygard’s prosecution was not based on falsehoods. The report did not claim that the conditions were required by the code but that Nygard had not agreed to the conditions and had replaced a driveway without a permit. Any failure to investigate did not defeat probable cause; the city already knew that he installed a driveway without a permit. View "Nygard v. City of Orono" on Justia Law

Minneapolis police investigated Randle for selling crack cocaine while he was on supervised release for a prior federal offense. After conducting a controlled buy, Officer Hamilton applied for a warrant to search a Brooklyn Park, Minnesota home that Randle listed as his supervised release address. The warrant was executed that day. Randle arrived during the search. Police seized 308 grams of crack cocaine and related evidence from the home and from bags carried by Randle.The district court denied a motion to suppress, applying the good-faith exception while concluding the affidavit did not create a “fair probability that evidence of Randle’s alleged drug trafficking activities would be found at the Residence” because it did not include Hamilton’s statement that in his professional judgment drug traffickers typically keep narcotics in their home and did not state that Hamilton followed Randle to the residence directly after the controlled buy and failed to specify when the officers started following Randle. The Eighth Circuit affirmed. The evidence is admissible because “it was objectively reasonable for the officer executing [the] search warrant to have relied in good faith on the [issuing] judge’s determination that there was probable cause to issue the warrant.” The court also upheld the denial of a “Franks” hearing; Randle failed to make the necessary “substantial preliminary showing” of “deliberate falsehood or of reckless disregard for the truth.” View "United States v. Randle" on Justia Law

The Eighth Circuit affirmed the judgment of the district court convicting Defendant of unlawful possession of a firearm as a previously convicted felon and sentencing him to 105 months in prison, holding that there was no reversible error in the proceedings below.The presentence report in this case recommended a base offense level of 20 and an advisory guideline range of 92 to 115 months' incarceration. The parties subsequently determined that Defendant's base offense level should be 14. The court considered the sentencing factors set forth in 18 U.S.C. 3553(a) and ultimately imposed a sentence of 105 months' imprisonment. The Eighth Circuit affirmed, holding that the sentence was not excessive or unreasonable and that the court did not abuse its discretion by considering an improper sentencing factor. View "United States v. Jones" on Justia Law

Someone shot a St. Louis fire captain and his passenger. The fire captain described the shooter as a “black male,” once on a 911 call right after the shooting, again when responding officers arrived on the scene, and again to an officer at the hospital. He did not give that description to Detective Bowles, who investigated the case. Bowles focused his attention on the Hartman brothers, who are white. Nearby cameras had captured them driving in the area and then stopping shortly before the shooting. Based on this evidence, Detective Bowles requested multiple search and arrest warrants. The paperwork Bowles submitted omitted the fact that the fire captain had described the shooter as black.The brothers were eventually released and sued Bowles, citing the Fourth Amendment, 42 U.S.C. 1983. The Eighth Circuit affirmed the dismissal of the suit. A detective does not violate a clearly established constitutional right by omitting information from a warrant application that he does not actually know, even if the reason is his own reckless investigation. To succeed, the Hartmans had to show that Bowles omitted facts “with the intent to make, or in reckless disregard of whether they make, the affidavit misleading.” Bowles is entitled to qualified immunity. View "Hartman v. Bowles" on Justia Law

Isaiah Hammett was killed during the St. Louis Metropolitan Police Department’s (SLMPD) execution of a search warrant at his grandfather’s home. Hammett’s surviving mother and grandfather, Gina Torres and Dennis Torres (Dennis), brought Fourth Amendment excessive force and unlawful seizure claims under 42 U.S.C. § 1983, conspiracy claims under 42 U.S.C. §§ 1983 and 1985, and state law wrongful death and infliction of emotional distress claims against the City of St. Louis and multiple SLMPD officers.The district court denied the City and defendant officers’ motion for summary judgment on these claims, and they appealed. The Eighth Circuit determined it lacked jurisdiction to review the denial of qualified immunity "if at the heart of the argument is a dispute of fact." The Court found that in their essence, defendants' arguments were related to the of the sufficiency of the evidence, and whether certain opinion testimony presented at trial created a genuine issue of fact. To the extent that defendants asserted arguments beyond the scope of the Court's jurisdiction, the Eighth Circuit dismissed their appeal. On the few arguments that remained, the Court reversed the district court's denial of the defendant officers' qualified immunity claims: Dennis was not seized for purposes of the Fourth Amendment; (2) the City could not have conspired with itself through the defendant officers acting within the scope of their employment; and (3) the intracorporate conspiracy doctrine did not apply to § 1983 conspiracy claims. Judgment was dismissed in part, reversed in part, and remanded for further proceedings. View "Torres v. Coats" on Justia Law

Plaintiff was diagnosed with a reducible ventral hernia while detained awaiting trial at the Greene County Justice Center in Missouri. Although his hernia could be repaired through surgery, Plaintiff was unable to prepay the fee required by the outside surgeon and thus the hernia was not repaired during his detention.   Plaintiff filed suit under 42 U.S.C. Section 1983 against the Greene County Sheriff’s Department and its contract healthcare service provider, Advanced Correctional Healthcare, Inc. (ACH), as well as several individuals employed by those entities (collectively, jail officials). Plaintiff claimed that the jail officials were deliberately indifferent to his serious medical need. The district court granted summary judgment in favor of Defendants.   The Fourth Circuit affirmed the grant of summary judgment. The court explained that to establish deliberate indifference Plaintiff was required to show (1) that he suffered from an objectively serious medical need and (2) that the jail officials had actual knowledge of that need but deliberately disregarded it. The court explained that Plaintiff submitted no medical or expert evidence that any delay in his hernia repair surgery created any excessive risk or harm. Plaintiff argued that his own claims of pain and suffering constitute the verifying medical evidence needed to show harm from the delay. Without corroborating evidence of symptoms, however, self-reported assertions of pain are insufficient to survive summary judgment.   Further, despite Plaintiff’s subjective reports of pain, objective observations did not indicate that he was in severe pain or forced to limit his activities. Thus, the court held that Plaintiff has not demonstrated that jail officials disregarded a known risk to his health. View "Michael Hancock v. Jim Arnott" on Justia Law

The Eighth Circuit affirmed the district court’s approval of a settlement between Defendant Monsanto and Plaintiffs. The court held that the district court did not abuse its discretion in concluding the notice to the class was sufficient or in concluding that payment to class members of 50% of the average weighted retail price of the items they purchased fully compensated the class members.    Plaintiffs filed suit pleading multiple claims arising out of the allegedly deceptive labeling of Roundup products manufactured by Monsanto. The parties agreed to a total Common Fund. They agreed that Monsanto would not object to Plaintiffs’ counsel seeking 25% of that amount as an attorney’s fee. Class members who filed claims were to receive 10% of the average retail price for the product(s) they bought, and any remaining funds after the costs of administration would be distributed cy pres. The parties executed a Second Corrected Class Action Settlement Agreement that made four changes to the initial agreement.   Appellant, a party injured by Roundup, made three objections to the settlement, all of which she renewed on appeal. First, she argued that the district court should have (1) required the parties to take additional steps to identify additional class members and (2) increased the pro-rata portion of the Common Fund up to 100% of the weighted average retail price. The court held the district court did not abuse its discretion in concluding that notice to the class was sufficient in light of the comprehensive notice plan and the estimated results from the claims administrator.Further, the court wrote that cy pres distribution of residual funds pursuant to the settlement agreement neither constitutes speech by any individual class member nor infringes on their First Amendment rights. View "Lisa Jones v. Anna St. John" on Justia Law

Following a traffic stop during which Plaintiff was cited for driving with an open liquor bottle in his car, he filed suit against the Des Moines Police Department officers involved in the stop Officers as well as the City of Des Moines Chief of Police, and the City of Des Moines (collectively “Defendants”), alleging claims under state and federal law for violation of his constitutional rights.   The district court granted summary judgment in favor of Defendants and denied Plaintiff’s request to certify questions to the Iowa Supreme Court and his motion for reconsideration. Plaintiff argued that the district court erred in granting summary judgment to the officers based on qualified immunity on his federal and state claims for an unreasonable seizure.   The Eighth Circuit affirmed the district court’s ruling. The court wrote that because Plaintiff failed to raise a genuine issue of material fact as to whether the officers unreasonably prolonged the stop, the district court did not err in granting summary judgment on the basis of qualified immunity to the officers on this claim.   Next, Plaintiff asserted that the district court erred in granting summary judgment to the officers based on qualified immunity on his federal and state claims for racial profiling. The court affirmed holding that because Plaintiff failed to show that the officers were motivated in any part by Plaintiff’s race, the court need not conclusively resolve this issue to determine that Plaintiff failed to raise a genuine issue of material fact necessary. View "Courtney Saunders v. Kyle Thies" on Justia Law