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

Plaintiffs sell technology that permits computers to identify license-plate numbers in digital photographs taken by cameras mounted on vehicles. The cameras automatically photograph everything the vehicles encounter, with GPS coordinates; software provides notice if a photographed vehicle is subject to repossession. The information is sold to clients, including automobile finance and insurance companies and law enforcement. Arkansas’s Automatic License Plate Reader System Act prohibits use of automatic license plate reader systems and permits any person claiming harm from a violation to seek damages from the violator. Vigilant and its affiliates sued, arguing that “use of [automatic license plate reader] systems to collect and create information” and dissemination of the information constitutes speech and that the Act impermissibly restricts this speech based on content—license-plate data—and on the identity of the speaker, because it exempts some entities, such as law enforcement agencies. The district court dismissed, ruling that state officials were immune from suit under the Eleventh Amendment. The Eighth Circuit affirmed on the ground that the plaintiffs lack standing, so there is no Article III case or controversy. State officials do not have authority to enforce the Act, so they do not cause injury; the Act provides for enforcement only through private actions for damages. View "Digital Recognition Network, Inc. v. Hutchinson" on Justia Law

Taylor pled guilty to possessing a prohibited object in prison and received a sentencing enhancement for committing a "crime of violence" under the career offender guideline, U.S.S.G. 4B1.1(a). While his appeal was pending, the Supreme Court held, in Johnson v. United States, that the residual clause of the Armed Career Criminal Act (ACCA) is unconstitutionally vague. That clause defines a "violent felony" to include any felony that "otherwise involves conduct that presents a serious potential risk of physical injury to another," 18 U.S.C. 924(e)(2)(B)(ii). The residual clause of the sentencing guideline under which Taylor’s sentence was enhanced uses identical language to the ACCA. The Eighth Circuit vacated and remanded for resentencing in light of Johnson, which explained that the Fifth Amendment principles prohibiting vague or standardless criminal laws "apply not only to statutes defining elements of crimes, but also to statutes fixing sentences." View "United States v. Taylor" on Justia Law

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

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

B.S., a 16-year-old with attention deficit hyperactivity disorder, had an individualized education program (IEP). A dispute arose and the parents requested a due process hearing. The parties settled several issues, so the only claim remaining was whether B.S. was entitled to compensatory education services for alleged past denial of a free appropriate public education (FAPE). On the first day of the hearing, B.S.’s counsel spent five hours examining the special education administrator. The district objected, noting the allotted nine hours of time. The ALJ subsequently reminded B.S.'s counsel that the time limit set at the pretrial conference would be enforced, and offered an opportunity to reorder the evidence. B.S. objected to enforcement of the time limits and continued with the lengthy examination of the case manager. B.S's time expired and B.S. was not allowed to question witnesses further or cross-examine district witnesses. B.S. made an informal offer of proof of additional evidence that B.S. had intended to present. After an unfavorable decision, B.S. appealed, also alleging that state defendants established an unpromulgated "best practices" rule restricting the length of testimony in violation of the Due Process Clause. The court dismissed the state defendants, finding that B.S. was challenging only one ALJ's discretionary decision, so the state was not a proper party. The Eighth Circuit affirmed that B.S. did not suffer a legally cognizable injury for which the state could be liable and had not been denied a FAPE. View "B.S. v. Anoka Hennepin Pub. Sch." 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