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

Pollyann Sorcan, a member of the Rock Ridge School District board, was excluded from committee assignments and meetings by the board. The board alleged that Sorcan undermined the District’s mission and violated policies and data privacy laws. Sorcan filed a 42 U.S.C. § 1983 action against the District and Bill Addy, the board chair, claiming retaliation for her protected speech under the First Amendment.The United States District Court for the District of Minnesota dismissed Sorcan’s case. The court concluded that Addy was entitled to legislative immunity and that Sorcan failed to state a claim against the District under Monell v. Department of Social Services, 436 U.S. 658 (1978). The court found that Sorcan did not identify a persistent pattern of unconstitutional behavior by the District.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Addy, sued in his official capacity, was not entitled to legislative immunity because such immunity does not extend to local officials in their official capacities. The court also found that the district court erred in requiring Sorcan to identify a persistent pattern of unconstitutional misconduct. Instead, a single decision by authorized decisionmakers can represent an official policy under Monell. The court reversed the district court’s dismissal and remanded the case for further proceedings. View "Sorcan v. Rock Ridge School District" on Justia Law

Dontavius R. Sharkey was convicted by a jury of two counts of felon in possession of a firearm and two counts of a straw-purchasing conspiracy. The district court sentenced him to 360 months in prison. Sharkey appealed his conviction and sentence, arguing that the statutes under which he was convicted were unconstitutional and that the district court improperly used acquitted conduct to enhance his sentence.The United States District Court for the Southern District of Iowa found Sharkey's acquitted conduct proven by a preponderance of the evidence and used it to increase his Guidelines range. Sharkey's arguments against the constitutionality of 18 U.S.C. § 922(g)(1) and the use of acquitted conduct were rejected based on existing precedent. The district court also applied enhancements for using a firearm in connection with another felony and for his role as an organizer in the criminal activity.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The court held that Sharkey's constitutional challenges were foreclosed by precedent, specifically citing United States v. Jackson. The court also upheld the use of acquitted conduct in sentencing, referencing United States v. Watts and United States v. Bullock. Additionally, the court found no procedural error in the application of the Guidelines enhancements and determined that the district court did not abuse its discretion in imposing an above-Guidelines sentence. The court concluded that the district court properly considered the relevant factors and did not give undue weight to any improper or irrelevant factors. View "United States v. Sharkey" on Justia Law

The Human Rights Defense Center (HRDC) sought to mail its publications to inmates at the Baxter County Jail and Detention Center. HRDC's materials, which include books and magazines about prisoners' legal rights and criminal justice news, were rejected due to the jail's policy limiting non-legal mail to postcards. HRDC filed a lawsuit against Baxter County, claiming the policy violated its First and Fourteenth Amendment rights.The United States District Court for the Western District of Arkansas awarded partial summary judgment to HRDC on the due process claim, finding a technical violation of HRDC's right to notice. However, after a bench trial, the court held that the postcard-only policy did not violate HRDC's free speech rights. The Eighth Circuit Court of Appeals vacated and remanded the decision, requiring additional fact-finding on whether HRDC had alternative means to exercise its First Amendment rights.Upon remand, the district court found that the jail's policies effectively banned HRDC's publications and that allowing these publications would have a de minimis impact on jail operations. The court concluded that the policy was not reasonably related to legitimate penological objectives and violated HRDC's rights. It awarded HRDC nominal damages, a permanent injunction against the postcard-only policy as applied to publisher mail, and attorney fees and costs.The United States Court of Appeals for the Eighth Circuit affirmed the district court's judgment. The court held that the jail's postcard-only policy was not reasonably related to its penological goals and constituted an exaggerated response, effectively banning HRDC's publications. The court also upheld the award of attorney fees and costs to HRDC, finding no abuse of discretion in the district court's decisions. View "Human Rights Defense Center v. Baxter County Arkansas" on Justia Law

Tennessee and sixteen other states challenged a regulation by the Equal Employment Opportunity Commission (EEOC) under the Pregnant Workers Fairness Act, which mandates reasonable accommodations for pregnancy-related conditions, including abortion. The states argued that the regulation unlawfully required them to accommodate employees seeking abortions, conflicting with their policies. They sought an injunction and a declaratory judgment against the rule, claiming it was arbitrary, exceeded EEOC's authority, violated the First Amendment and federalism principles, and was unconstitutional under Article II.The United States District Court for the Eastern District of Arkansas dismissed the case, ruling that the states lacked standing as they did not demonstrate an imminent injury or that the alleged injuries were redressable. The court found the risk of enforcement speculative and compliance costs not directly traceable to the rule. The court also dismissed the states' motion for a preliminary injunction as moot and for failing to show irreparable harm.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 the states had standing as they were the direct objects of the EEOC's regulation, which imposed new obligations on them. The court found that the states were injured by the regulatory burden itself and that setting aside the rule would remedy this injury. The court concluded that the states' need to comply with the rule constituted an injury in fact, caused by the EEOC's action, and redressable by a favorable judicial decision. The case was remanded for further proceedings without addressing the merits of the claims. View "State of Tennessee v. EEOC" on Justia Law

LaVance LeMarr Cooper was found guilty of being a drug user in possession of a firearm after officers discovered a Glock 20 pistol in his car during a traffic stop. Cooper admitted to smoking marijuana three to four times a week, including two days before the traffic stop. He was sentenced to 37 months in prison by the United States District Court for the Northern District of Iowa.The district court, referencing the case United States v. Veasley, acknowledged that as-applied challenges to the drug-user-in-possession statute are available but concluded that Congress's decision to disarm drug users as a class left no room for individual assessments. Cooper argued that his prosecution under 18 U.S.C. § 922(g)(3) violated the Second Amendment, but the district court disagreed, maintaining that the statute applied categorically to all drug users.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that while keeping firearms out of the hands of drug users does not always violate the Second Amendment, it can in certain circumstances. The court emphasized that historical analogues, such as the confinement of the mentally ill and going-armed laws, support disarmament only when the individual poses a danger to others. The court found that the district court erred in not considering whether Cooper's marijuana use made him dangerous or induced terror.The Eighth Circuit vacated the district court's judgment and remanded the case for a reexamination of Cooper's motion to dismiss the indictment, instructing the lower court to determine whether Cooper's specific circumstances justified disarmament under the Second Amendment. View "United States v. Cooper" on Justia Law

Keshon Baxter was charged with being an unlawful user of a controlled substance in possession of a firearm. In May 2023, police encountered Baxter in Des Moines, Iowa, and found a loaded pistol and a baggie of marijuana on him. Baxter moved to dismiss the charge, arguing that the statute under which he was charged, 18 U.S.C. § 922(g)(3), violated the Second Amendment as applied to him and was unconstitutionally vague. The district court denied his motion without a hearing, and Baxter entered a conditional guilty plea, preserving his right to appeal.The United States District Court for the Southern District of Iowa rejected Baxter's arguments. The court found that the government had shown adequate historical analogues to reject the Second Amendment challenge and that Baxter had not demonstrated that the statute was vague as applied to his conduct. Baxter then appealed these rulings.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court did not make sufficient factual findings regarding Baxter's drug use and its overlap with his firearm possession to properly address the as-applied Second Amendment challenge. Therefore, the appellate court remanded the case to the district court for the necessary factual findings. The appellate court affirmed the district court's rejection of Baxter's vagueness challenge, noting that Baxter had not shown that the term "unlawful user" was vague as applied to his conduct. The court also affirmed the rejection of any facial Second Amendment challenge, as it was foreclosed by precedent.In conclusion, the Eighth Circuit affirmed the district court's decision on the vagueness and facial Second Amendment challenges, reversed the ruling on the as-applied Second Amendment challenge, and remanded for further proceedings. View "United States v. Baxter" on Justia Law

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law

Iowa enacted Senate File 2340, which criminalizes the presence of aliens who have illegally reentered the United States within its boundaries. The Act mandates that aliens violating it must return to the country they reentered from and prohibits judges from abating state prosecutions due to pending or possible federal determinations of the alien’s immigration status. The United States sought a preliminary injunction against the enforcement of the Act, which the district court granted. Iowa appealed the decision.The United States District Court for the Southern District of Iowa ruled that the United States had standing to sue and could state a cause of action to enjoin the Act. The court found that the United States established a likelihood of success on the merits, showing that federal immigration law preempts the Act under both conflict and field preemption. The court also found that irreparable harm would occur if the Act went into effect and that the balance of equities and public interest favored granting the injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion, examining factual findings for clear error and legal conclusions de novo. The appellate court affirmed the district court’s decision, holding that the United States had standing and an equitable cause of action to enjoin the Act. The court found that the Act likely conflicts with federal immigration law, as it obstructs the discretion of federal officials and creates a parallel enforcement scheme. The court also agreed that the United States demonstrated irreparable harm and that the balance of equities and public interest favored the injunction. The preliminary injunction against the enforcement of the Act was affirmed. View "United States v. State of Iowa" on Justia Law

Marcus Todd, a state employee in Minnesota, alleged that a union violated his First and Fourteenth Amendment rights by deducting union dues from his paycheck without his consent. Todd joined the American Federation of State, County, and Municipal Employees in 2014 and authorized dues deductions. In 2018, a new authorization card was allegedly signed electronically with Todd's name, which he claims was forged. After the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, Todd attempted to resign from the union and stop dues deductions, but the union continued until May 2021, citing an annual opt-out period.The United States District Court for the District of Minnesota dismissed Todd's federal claims, stating that he voluntarily agreed to the dues deductions before Janus and was contractually bound to the opt-out period. The court also found that the union did not act under color of state law regarding the alleged forgery and dismissed Todd's claims for prospective relief as moot. The court declined to exercise jurisdiction over Todd's state law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Todd's claims failed due to the lack of state action, as the union's actions were based on private agreements, not state statutes. The court referenced Hoekman v. Education Minnesota and Burns v. School Service Employees Union Local 284, which established that private agreements for dues deductions do not constitute state action. The court also found that the alleged forgery did not establish state action, as it was a private misuse of state law. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Todd v. AFSCME" on Justia Law

The City of Hillsboro, Missouri, enacted ordinances prohibiting new private wells within city limits and requiring residences to connect to the city water system. The Antoinette Ogilvy Trust, owning a 156-acre property within Hillsboro, claimed these ordinances constituted an uncompensated regulatory taking under the Fifth and Fourteenth Amendments. The trustees, William Becker and Darcy Lynch, argued that the regulations made developing the property financially unfeasible due to the high costs of connecting to the city water system.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the City, rejecting the trustees' claims. The court found that the regulations did not constitute a per se taking, as they did not involve a physical invasion of the property or deprive it of all economic value. The court also determined that the regulations did not fail the Penn Central balancing test for regulatory takings.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the regulations did not mandate a permanent physical invasion of the property, as the trustees were not compelled to build structures or dedicate land to the City. The court also found that the property retained substantial value, thus not constituting a taking under Lucas v. South Carolina Coastal Council. Additionally, the court declined to consider the trustees' exaction claim, as it was not sufficiently raised in the lower court.Under the Penn Central test, the court concluded that the economic impact on the trustees was not significant enough to constitute a taking, and the regulations did not interfere with reasonable investment-backed expectations. The character of the governmental action was deemed a legitimate exercise of the City's police powers to prevent water contamination and protect the aquifer. Therefore, the court affirmed the district court's summary judgment in favor of the City. View "Becker v. City of Hillsboro" on Justia Law