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

Officer Mason Roth shot and killed Bobby Jo Klum, who was walking through a residential neighborhood with a gun to his head, evading arrest, and ignoring officer commands to drop the weapon. Klum’s spouse and mother sued Officer Roth and the City of Davenport under 42 U.S.C. § 1983, alleging a violation of Klum’s Fourth Amendment right against unreasonable seizure. The district court granted qualified immunity to Officer Roth and concluded the City of Davenport was not liable under Monell v. Department of Social Services.The United States District Court for the Southern District of Iowa granted summary judgment to Officer Roth and the City of Davenport on all claims. The court concluded that Klum’s Fourth Amendment right against unreasonable seizure was not violated and that Klum did not possess a clearly established right against seizure by deadly force under the circumstances. Plaintiffs appealed the district court’s grant of summary judgment based on qualified immunity as to their excessive force claim against Officer Roth and the City of Davenport.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that any right was not clearly established at the time, and therefore, Officer Roth was entitled to qualified immunity. The court found that the totality of the circumstances, including Klum’s non-compliance, evasion, and proximity to bystanders, justified the use of deadly force. The court also upheld the district court’s grant of summary judgment on the Monell claim, concluding that Plaintiffs failed to raise a genuine issue as to whether the City of Davenport had a policy that directly caused the use of deadly force. View "Klum v. City of Davenport" on Justia Law

A law firm, Sutter & Gillham PLLC, and its partners were involved in a contentious wrongful-death lawsuit in Arkansas, representing the family of a teenage boy who died from a gunshot wound. The family suspected foul play, while the boy's friends claimed it was suicide. The state court dismissed the case with prejudice, citing misconduct by the family and its attorneys. Although the firm had withdrawn from the case, it felt unfairly maligned by the court's order. One partner's attempt to intervene and seek recusal of the judge was denied, and no appeal was filed. The family successfully overturned the dismissal, and the case remains pending.The firm faced related litigation, including a state court lawsuit by the wrongful-death defendants against the firm and its partners for alleged misconduct. The firm also filed a federal lawsuit alleging constitutional violations by the wrongful-death defendants and their attorneys, claiming they conspired with the state trial judge. The United States District Court for the Eastern District of Arkansas dismissed the case under the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court concluded that the Rooker-Feldman doctrine did not apply because the federal lawsuit did not seek to overturn the state court judgment but rather targeted the actions of the defendants and their attorneys. The court emphasized that the doctrine only applies when a federal action is essentially an appeal of a state court decision. The Eighth Circuit vacated the district court's dismissal and remanded the case for further proceedings, allowing the plaintiffs to pursue their claims. View "Sutter & Gillham PLLC v. Henry" on Justia Law

The Minnesota Legislature amended its statutes to impose stricter regulations on white-tailed deer farming, including prohibiting new registrations and limiting transfers to immediate family members. The Minnesota Deer Farmers Association and individual deer farmers challenged these amendments, claiming violations of their substantive due process, equal protection, and procedural due process rights.The United States District Court for the District of Minnesota dismissed their complaint. The Deer Farmers appealed, arguing that the amendments deprived them of their fundamental right to pursue their chosen profession and unfairly advantaged those with immediate family members.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court first addressed the standing of the plaintiffs, finding that Udovich, an unregistered former deer farmer desiring a registration, had standing to challenge the amendments. The court then considered the substantive due process claim, concluding that the right to pursue white-tailed deer farming is not a fundamental right deeply rooted in the nation’s history and traditions. Therefore, the amendments were subject to rational basis review, not strict scrutiny.The court also addressed the equal protection claim, determining that the classification based on having immediate family members was not suspect and thus also subject to rational basis review. The court found that the amendments were rationally related to the legitimate government interest of containing Chronic Wasting Disease.Finally, the court dismissed the procedural due process claim due to a lack of standing, as the complaint did not adequately allege that any particular plaintiff had been cited or intended to engage in noncompliant conduct.The Eighth Circuit affirmed the district court’s dismissal of the Deer Farmers' claims. View "MN Deer Farmers Assoc. v. Strommen" on Justia Law

Markhel D’John Harris-Franklin was charged with being an armed career criminal in possession of ammunition, violating 18 U.S.C. §§ 922(g)(1) and 924(e). He moved to dismiss the indictment, alleging a violation of the Speedy Trial Act and that 18 U.S.C. § 922(g)(1) is unconstitutional under the Second Amendment. The district court denied his motions, and he was found guilty by a jury.The United States District Court for the District of Minnesota initially handled the case. Harris-Franklin made multiple motions to extend the time for filing pretrial motions, which the court granted, finding that the ends of justice served by the continuances outweighed the best interests of the public and Harris-Franklin in a speedy trial. After a competency evaluation and the appointment of new counsel, Harris-Franklin moved to dismiss the indictment for violation of the Speedy Trial Act and challenged the constitutionality of 18 U.S.C. § 922(g)(1). The magistrate judge recommended denying the motions, and the district court adopted this recommendation. Harris-Franklin did not renew his motion to dismiss before trial, and he was convicted.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Harris-Franklin’s rights under the Speedy Trial Act were not violated, as the district court properly excluded certain periods of delay from the 70-day calculation. The court also found that circuit precedent foreclosed Harris-Franklin’s Second Amendment argument, affirming the district court’s denial of his motions to dismiss. The court concluded that the ends-of-justice continuances granted by the district court were reasonable and necessary to allow new counsel time to prepare for trial. View "United States v. Harris-Franklin" on Justia Law

Raymond Antonio Lewis was convicted by a jury of being a felon in possession of a firearm and possession of methamphetamine with intent to distribute. The incident occurred on December 20, 2018, when Officer John Buford responded to a report of shots fired and encountered Lewis, who was found with firearms and methamphetamine. Lewis was identified as a felon and arrested.The United States District Court for the Eastern District of Arkansas handled the case. Lewis was indicted in May 2021, with a superseding indictment in November 2022. His trial was delayed multiple times due to continuance requests by his counsel and other procedural matters. Lewis filed motions to suppress Officer Buford’s testimony and to sever the trial, both of which were denied by the district court. The jury found Lewis guilty on two counts but acquitted him on a third count of possessing firearms in furtherance of drug distribution. He was sentenced to 156 months’ imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. Lewis argued that the district court erred in denying his pretrial motions, that the preindictment delay violated his Fifth Amendment rights, that the delay between indictment and trial violated his Sixth Amendment rights, and that the evidence was insufficient to support his conviction. The Eighth Circuit affirmed the district court’s decisions, holding that the exclusionary rule did not apply to the officer’s testimony despite the policy violation, that the denial of the motion to sever was not an abuse of discretion, that the preindictment delay did not violate due process, and that the delay in trial did not violate the Sixth Amendment. The court also found the evidence sufficient to support the convictions. View "United States v. Lewis" on Justia Law

In 2020, Mujera Benjamin Lung’aho threw Molotov cocktails that damaged or destroyed three police cars belonging to state and municipal police departments. He was indicted under 18 U.S.C. § 844(f)(1) for maliciously destroying law enforcement vehicles possessed by local police departments receiving federal financial assistance. Lung’aho moved to dismiss the indictment, arguing that the statute was unconstitutional as applied to him.The United States District Court for the Eastern District of Arkansas denied Lung’aho’s motion to dismiss. The court held that while the Property Clause did not apply because the police cars were not federal property and were not bought with federal financial assistance, the prosecution was constitutional under the Spending Clause coupled with the Necessary and Proper Clause.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to dismiss de novo. The court held that Lung’aho’s conduct fell within the plain meaning of 18 U.S.C. § 844(f)(1) and that the statute was constitutional as applied to him. The court reasoned that under the Spending Clause and the Necessary and Proper Clause, Congress has the authority to ensure that federal funds are spent for the general welfare, and criminalizing the arson of police cars from departments receiving federal funding is a rational means of safeguarding federal dollars. The court affirmed the district court’s judgment, concluding that § 844(f)(1) was constitutionally applied to Lung’aho. View "United States v. Lung'aho" on Justia Law

Two students alleged that an Arkansas law violates their First Amendment rights by prohibiting their teachers from providing classroom materials and instruction about Critical Race Theory (CRT). The district court concluded that the law likely violated the students' right to receive information and entered a preliminary injunction. Arkansas officials appealed, arguing that the Free Speech Clause does not allow students to compel the government to provide certain classroom materials or instruction in public schools.The United States District Court for the Eastern District of Arkansas granted a preliminary injunction to the students but denied one to the teachers. The court determined that the teachers' speech was government speech, not their own, and thus any chill on their speech did not harm their rights. The court concluded that the students demonstrated that the law blocked their receipt of information previously provided before its enactment and that the Arkansas officials did not show a legitimate pedagogical reason for withholding teaching about CRT.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the Arkansas officials. The court held that the students conceded the classroom materials and instruction they sought to receive constituted government speech. Since the government's own speech is not restricted by the Free Speech Clause, the government is free to choose what to say and what not to say. The court concluded that the students could not show a likelihood of success on their claim and vacated the preliminary injunction. The court also declined to uphold the preliminary injunction based on the teachers' vagueness claim, as the teachers did not file a cross-appeal. The case was remanded for further proceedings. View "Walls v. Oliva" on Justia Law

In several Minnesota cities, only members of a pre-approved union can work on municipal construction jobs. Multiple contractors, a carpenter, and a union objected to this requirement, alleging it violated the First Amendment. The contractors, Kaski, Inc.; Nordic Group, Inc.; and Roen Salvage Co., claimed they missed out on lucrative work due to these project-labor agreements. Luke Krhin, a carpenter, and the Christian Labor Association, which has a local chapter in Minnesota, also joined the lawsuit.The United States District Court for the District of Minnesota determined that none of the plaintiffs had standing to sue. The court found that the contractors, Krhin, and the Christian Labor Association could not succeed on their First Amendment claim. The plaintiffs appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on the issue of standing, a jurisdictional requirement. The court found that the contractors did not have standing because the relevant constitutional claims belonged to their employees, not to them. The court also found that Krhin, who opposed joining a pre-approved union, was exempt from the requirement as a supervisor, thus lacking standing. The Christian Labor Association also lacked standing because it failed to identify any members who would have standing to sue in their own right.The Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss based on a lack of standing. View "Christian Labor Association v. City of Duluth" on Justia Law

Law enforcement officers suspected Bandak Wiyual Deng of involvement in a shooting at a park on February 10, 2022. Surveillance video showed an individual matching his characteristics exiting a car with what appeared to be a gun. The car, a black Ford Taurus, lacked a license plate or paper registration tag. A confidential informant recorded a conversation with Deng, where Deng mentioned needing a gun for a funeral and a previous shooting. On the day of the funeral, officers stopped Deng, found marijuana and a gun in his car, and Deng admitted to using drugs and touching the gun.The United States District Court for the Southern District of Iowa upheld the government's peremptory strikes of two prospective jurors and refused to admit parts of Deng's interview with law enforcement. Deng's motion for a judgment of acquittal, arguing that 18 U.S.C. § 922(g)(3) violated the Second Amendment, was denied. The jury convicted Deng.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not clearly err in overruling Deng’s objections to the peremptory strikes, as the government provided race-neutral explanations. The court also found that any potential error in the district court's evidentiary rulings was harmless, given the ample evidence supporting Deng’s conviction. Finally, the court affirmed the denial of Deng’s motion for a judgment of acquittal, rejecting his facial challenge to the constitutionality of 18 U.S.C. § 922(g)(3). The judgment was affirmed. View "United States v. Deng" on Justia Law

Dimaryn Ware was indicted on multiple firearms-related charges. He moved to dismiss the indictment, arguing that the statutes violated the Second Amendment both on their face and as applied to him. The district court denied his motion, and Ware pled guilty while preserving his right to appeal the denial. He now appeals the denial and several sentencing decisions.The district court, the United States District Court for the Southern District of Iowa, denied Ware's motion to dismiss the indictment. Ware pled guilty to two counts, and the remaining counts were dismissed on the government's motion. At sentencing, the court applied the Base Offense Level from the United States Sentencing Guideline (USSG) § 2K2.1(a)(3), concluding that the offense involved a firearm capable of accepting a large capacity magazine. The court calculated a Guidelines range of 84 to 105 months but varied upward to 144 months' imprisonment, ordering the sentence to run concurrently with a state sentence for a related shooting but consecutively to other state sentences for unrelated offenses.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Ware's arguments against the constitutionality of 18 U.S.C. § 922(g)(1) and § 932(b)(1) were foreclosed by precedent, specifically citing United States v. Jackson and United States v. Sharkey. The court also held that the district court did not err in considering conduct underlying an acquitted charge when determining Ware's sentence, as permitted by precedent. Additionally, the court found no clear error in the district court's application of USSG § 2K2.1(a)(3) based on the evidence of the firearm's capability to accept a large capacity magazine. Finally, the court upheld the district court's decision to impose Ware's federal sentence consecutively to his unrelated state sentences and to not reduce his federal sentence based on time served for those unrelated state sentences.The judgment of the district court was affirmed. View "United States v. Ware" on Justia Law