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

In 2012, Arkansas inmate Jones filed suit under the Religious Land Use and Institutionalized Persons Act, challenging the Department of Correction’s (ADC’s) grooming policy. The district court granted summary judgment for defendants, relying on an Eighth Circuit decision, Holt. While appeal was pending, the Supreme Court granted certiorari in Holt, and reversed, holding that ADC’s grooming policy substantially burdened the plaintiff inmate’s exercise of religion. The Eighth Circuit granted a motion to supplement the record on appeal with ADC’s new grooming policy, effective 2015. After holding that Jones’s appeal has not been plainly mooted by the new grooming policy, the court declined to reach the merits and remanded to the district court to consider Jones’s complaint in light of the new grooming policy and the Supreme Court’s decision. View "Jones v. Meinzer" on Justia Law

Davis was arrested for driving while intoxicated and was transported to the crowded Ferguson jail. Officers escorted Davis to a cell, which Davis refused to enter. Three officers responded as backup. White pushed Davis into the cell and a short, bloody fight ensued. Later, White was treated at a hospital and required surgery for a broken nose that had bled profusely. Davis was taken to the emergency room; scalp bleeding was noted but he refused treatment. After his release, Davis went to another hospital where he was diagnosed with a concussion and a scalp laceration. There was testimony that three officers each beat or kicked Davis after he was handcuffed and subdued on the cell floor. Davis was charged with “Property Damage” for transferring blood onto four uniforms and eventually pleaded guilty to careless driving, speeding, non-moving violations, and two counts of Destruction of City Property. Davis filed suit under 42 U.S.C. 1983, alleging excessive force, municipal liability, substantive due process violations by filing false complaints, and assault and battery against the officers individually under Missouri law. White filed an assault and battery counterclaim. The district court rejected all claims. The Eighth Circuit reversed summary judgment on the excessive force and assault and battery claims, vacated the dismissal of White’s counterclaim, and remanded. View "Davis v. White" on Justia Law

The Robbinses provide towing and wrecker services along the I-44 corridor in eastern Missouri. State Highway Patrol (MSHP) Troops C and I, pursuant to MSHP policy, used a “rotation list” of approved towing and wrecking companies to determine which company to call to the scene of a disabled vehicle if the vehicle owner had no preference. The Robbinses were on both lists until they were removed, reportedly because Robbins had been charged with shooting at a competitor’s truck in 1999. The Robbinses alleged the criminal charge resulted from a “sham investigation” and that their competitor used a friendship with an MSHP officer, with whom Robbins had had a confrontation, to harm the Robbinses’ business. A jury acquitted Robbins, but they were never reinstated to either list. In 2005, the Robbinses sued the MSHP. The state court determined the MSHP lacked statutory authority to create a rotation list. In 2010, the Robbinses sued officers in their individual capacities, alleging due process and equal protection violations and conspiracy to violate those rights under 42 U.S.C. 1983 and violations of the Sherman Act, 15 U.S.C. 1, 2, claiming that the officers conspired to deny them work and disparaged their business. The Eighth Circuit affirmed summary judgment in favor of the officers. View "Robbins v. Becker," on Justia Law

Mead, committed to Iowa's Civil Commitment Unit for Sex Offenders filed a 42 U.S.C. 1983 complaint alleging that defendants deprived him of "extensive dental care that he is unable to afford" and were "deliberately indifferent to [his] need for dental care." He alleged that he had many teeth pulled while in custody, was unable to chew food properly, suffered from acid reflux, and had become diabetic. The defendants moved for summary judgment arguing that Mead had sufficient funds to pay for a partial denture plate and failed to demonstrate a serious medical need because he had not requested and did not want a soft diet, had not lost weight, had complained of discomfort but not pain, had stated that he was satisfied with his medical care, and no dentist had concluded that Mead had a serious medical need for dentures. The defendants argued that they were entitled to qualified immunity, not personally responsible for Mead's alleged damages, and immune from money damages. The district court denied summary judgment, concluding that Mead had established genuine issues of material fact. The Eighth Circuit reversed, finding the defendants entitled to qualified immunity from damages on Mead's claim regarding the denial of partial dentures View "Mead v. Palmer" on Justia Law

North Dakota prohibited abortion “[a]fter the point in pregnancy when the unborn child may reasonably be expected to have reached viability,” except when necessary to preserve the life or health of the mother, N.D. Code 14-02.1-04(3), and defined “viable” as “the ability of an unborn child to live outside the mother’s womb, albeit with artificial aid.” In 2013, North Dakota passed House Bill 1456, extendng the general prohibition on abortion by requiring a physician performing an abortion to “determin[e], in accordance with standard medical practice, if the unborn child the pregnant woman is carrying has a detectable heartbeat” except “when a medical emergency exists that prevents compliance.” Another provision prohibited a physician from performing an abortion if the unborn child had a “heartbeat [that] has been detected according to the requirements of section 1.” There were exceptions for the life or health of the pregnant woman. A physician who violated the provision committed a felony, but the pregnant woman was not subject to liability. Plaintiff, the sole North Dakota abortion provider, challenged the law. The district court granted an injunction. The Eighth Circuit affirmed, stating the continued application of the Supreme Court’s viability standard discounts the legislative branch’s recognized interest in protecting unborn children. View "MKB Mgmt. Corp. v. Stenehjem" on Justia Law

Deputy Russeth stopped Wall for a traffic violation. Exiting her vehicle, Wall smelled of alcohol, exhibited poor balance, failed field sobriety tests, and in a preliminary breath test, produced a blood-alcohol concentration (BAC) of .109—beyond the .08 legal threshold. Russeth arrested Wall. At headquarters, Russeth sought Wall’s consent to conduct a urine or blood test to determine BAC. In compliance with Minn. Stat. 169A.51, Russeth read aloud the “implied consent advisory,” informing Wall that “[r]efusal to take a test [wa]s a crime,” and before making a decision about testing, she had the right to consult an attorney. Affirming her understanding of her rights and disclaiming her right to an attorney, Wall agreed to urinalysis. After 45 minutes, Wall had not produced a urine sample. Russeth transported Wall to a medical center where Wall agreed to blood analysis. A registered nurse took a blood sample. Wall pled guilty to a petty misdemeanor traffic violation; her DWI charge was dismissed. Wall sued, alleging the county had a policy or custom of conducting warrantless, nonconsensual blood-alcohol tests in violation of the Fourth Amendment. Following the reasoning of the Minnesota Supreme Court, the court agreed that Wall’s consent made the blood draw constitutional. The Eighth Circuit affirmed. Wall’s dilemma, alone, does not satisfy her burden of nullifying her otherwise uninhibited consent. View "Wall v. Stanek" on Justia Law

Wieland is a member of the Missouri House of Representatives and obtains healthcare coverage for his family through the Missouri Consolidated Health Care Plan (MCHCP), a plan made available to him by his employer, the state. Until August 1, 2013, MCHCP offered an opportunity to opt out of contraceptive coverage under state law. The state and MCHCP discontinued offering that opportunity when the state opt-out was found to be preempted by the Patient Protection and Affordable Care Act (ACA), 42 U.S.C. 300gg, and its implementing regulation. The Wielands sued the U.S. Departments of Health and Human Services, Treasury, and Labor, challenging the ACA, as requiring them to obtain, and provide to their daughters, healthcare coverage for contraceptives, sterilization, and abortifacients in violation of their sincerely held religious beliefs. The district court dismissed for lack of standing. The Eighth Circuit reversed, stating that it is more than merely speculative that the Wielands’ injury would be redressed if they were granted the injunctive relief they seek. If the Supreme Court’s decision in Hobby Lobby overruled the case under which the opt-out was eliminated, the state law opt-out provision would likely again be available. View "Wieland v. Dep't of Health & Human Servs." on Justia Law

Williams was arrested at a motel, following a sting operation to locate a missing minor female, who police believed was being prostituted online. In Williams' motel room, police found the missing girl, a second girl, condoms, and the cellular phone that an undercover officer called earlier to arrange a paid "date" with the girls. After Williams was in handcuffs, detective Slaughter read his Miranda rights. Detective Slaughter testified that Williams stated he understood the admonitions and agreed to waive his right not to speak. Williams asked Slaughter whether he could remove belongings from his rental car. Slaughter asked whether there was anything illegal in the vehicle. Williams responded that he had a registered firearm and gave verbal consent to search. Williams watched the search, and did not withdraw consent. Police found a firearm, condoms, and electronic devices. Later, during a recorded interview, Slaughter summarized his contact with Williams and stated that Williams had been read his Miranda rights. Williams acknowledged and agreed with Slaughter's statements. Williams voluntarily consented and officers began searching the electronic devices. Almost six hours later, officers asked Williams for written consent. Williams refused and requested a lawyer. The officers stopped questioning Williams and secured warrants for the devices. The Eighth Circuit upheld denial of a motion to suppress and rejected a claim of vindictive prosecution. View "United States v. Williams" on Justia Law

Witthar pleaded guilty to conspiracy against rights, obstruction of justice, and interference with fair housing rights, 18 U.S.C. 241, 1512(b)(1); 42 U.S.C. 3631 waiving her right to appeal or collaterally attack a finding of guilt and her sentence on any ground except: ineffective assistance of counsel, prosecutorial misconduct, a sentence imposed in excess of the statutory maximum, or an illegal sentence. The prosecution advocated for a sentence at the bottom of her advisory guidelines range, dismissed four other counts, and agreed to not bring additional charges related to her crimes. The district court sentenced Witthar to 63 months’ imprisonment, at the bottom of her advisory guidelines range. No appeal followed. Eleven months later, Witthar filed a pro se petition under 28 U.S.C. 2255, alleging that her attorney failed to file a requested notice of appeal. The government submitted an affidavit from Witthar’s attorney stating that Witthar had not asked him to file an appeal. The district court denied Witthar’s claim without conducting an evidentiary hearing, finding that Witthar’s “bare, conclusory allegations” did not entitle her to relief. The Eighth Circuit reversed. Because Witthar’s allegations, if true, amounted to ineffective assistance of counsel, there was a factual dispute on a critical issue View "Witthar v. United States" on Justia Law

In 2009, a jury found Thompson guilty of two counts of first-degree premeditated murder and two counts of first-degree murder while committing aggravated robbery. Thompson was 17 when he committed the crimes. Pursuant to Minnesota law, he received two consecutive mandatory sentences of life imprisonment without the possibility of release. The Minnesota Supreme Court affirmed Thompson’s convictions and sentences on direct appeal. In 2012, the U.S. Supreme Court (Miller decision) held that the Eighth Amendment forbids a sentencing scheme that mandates a sentence of life in prison without the possibility of parole for juvenile offenders. Thompson sought relief under 28 U.S.C. 2254. The district court dismissed with prejudice, finding that Miller’s rule was not retroactively applicable. The Eighth Circuit affirmed. Miller did not announce a new substantive rule because it neither categorically barred a punishment nor placed a group of persons beyond the state’s power to punish. After Miller, as before, a court retains the power to impose a life sentence without the possibility of parole. That the sentence now must be discretionary does not alter its substance. View "Thompson v. Roy" on Justia Law