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

The Association for Accessible Medicines (AAM), representing generic drug manufacturers, challenged a Minnesota law regulating drug prices, Minn. Stat. § 62J.842, arguing it violated the dormant Commerce Clause. The law prohibits manufacturers from imposing excessive price increases on generic or off-patent drugs sold in Minnesota. The district court granted AAM's motion for a preliminary injunction, finding the law likely violated the dormant Commerce Clause.The United States District Court for the District of Minnesota concluded that AAM was likely to succeed on the merits of its claim, faced a threat of irreparable harm, and that the balance of harms and public interest factors were neutral. Minnesota appealed, contesting the likelihood of success on the merits and the balance of harms/public interest.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s ruling for abuse of discretion and its legal conclusions de novo. The court found that the Minnesota law had the impermissible extraterritorial effect of controlling prices outside the state, similar to laws previously struck down by the Supreme Court. The court rejected Minnesota's argument that the law did not control out-of-state prices, noting that it effectively regulated out-of-state transactions if the drugs ended up in Minnesota.The Eighth Circuit affirmed the district court’s decision, agreeing that AAM was likely to succeed on the merits of its dormant Commerce Clause claim. The court also found no abuse of discretion in the district court’s assessment of the balance of harms and public interest, noting that protecting constitutional rights is always in the public interest. The preliminary injunction against the Minnesota law was upheld. View "Ass'n for Accessible Medicines v. Ellison" on Justia Law

Nathan Rinne sued Camden County and two of its commissioners, Greg Hasty and Donald Williams, Jr., alleging violations of his First and Fourteenth Amendment rights after Hasty and Williams voted to ban him from all County property for one year. The defendants sought summary judgment on the defenses of qualified and legislative immunity and on the merits of the issue of punitive damages. The district court denied these motions in full.The United States District Court for the Western District of Missouri denied the defendants' motions for summary judgment. The defendants then appealed the denial of legislative immunity, qualified immunity, and the issue of punitive damages.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the denial of legislative immunity, holding that the commissioners' decision to ban Rinne from county property was administrative, not legislative, in nature. The court found that the act of banning Rinne did not concern the enactment or promulgation of public policy but was an effort to monitor and discipline his presence and conduct at future commission meetings. Consequently, the commissioners were not entitled to legislative immunity. The court dismissed the remainder of the appeal, including the issues of qualified immunity and punitive damages, for lack of jurisdiction, as these involved genuine disputes of fact that could not be resolved at the appellate level. View "Rinne v. Hasty" on Justia Law

Booker Deon McKinney pleaded guilty to possession of ammunition as an unlawful drug user, violating 18 U.S.C. §§ 922(g)(3) and 924(a)(2). He was sentenced to 120 months in prison followed by three years of supervised release. McKinney later moved to withdraw his guilty plea and dismiss his indictment, arguing that § 922(g)(3) violated the Second Amendment. The district court denied his motion.The United States District Court for the Northern District of Iowa initially reviewed the case. McKinney was indicted in January 2023 and pleaded guilty in June 2023. In January 2024, he filed a motion to withdraw his plea and dismiss the indictment, which the district court denied. McKinney was sentenced on January 26, 2024, and subsequently appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. McKinney argued that the district court erred in denying his motion to withdraw his guilty plea and dismiss the indictment, miscalculated his base offense level, relied on inadmissible hearsay evidence, and improperly weighed the § 3553(a) factors at sentencing. The Eighth Circuit found no abuse of discretion in the district court's decisions. The court held that there was no intervening change in the law that justified McKinney's belated request to withdraw his plea. The court also upheld the district court's calculation of the base offense level and its reliance on hearsay evidence, finding it sufficiently reliable. Finally, the court found McKinney's sentence substantively reasonable, noting that the district court had appropriately considered the § 3553(a) factors. The Eighth Circuit affirmed the district court's judgment. View "United States v. McKinney" on Justia Law

Clayton Stewart was involved in a police incident where Officer Victor Garcia of the Jonesboro, Arkansas police department tased him while he was climbing a fence. Stewart fell and was paralyzed as a result. Stewart filed a 42 U.S.C. § 1983 action against Garcia, Jonesboro Chief of Police Rick Elliot, and the City of Jonesboro, alleging violations of his Fourth and Fourteenth Amendment rights. The district court granted summary judgment in favor of the defendants on all claims, and Stewart appealed.The United States District Court for the Eastern District of Arkansas granted summary judgment to the defendants, finding no genuine disputes of material fact that would preclude summary judgment. Stewart argued that Garcia lacked probable cause to arrest him, used excessive force, and was deliberately indifferent to his medical needs. He also claimed that Elliot was liable as Garcia’s supervisor and that the police department’s policies were unconstitutional.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Garcia had at least arguable probable cause to arrest Stewart for misdemeanor assault and fleeing. Regarding the excessive force claim, the court found that while tasing Stewart in an elevated position could be considered deadly force, Stewart’s right to be free from such force was not clearly established at the time of the incident, entitling Garcia to qualified immunity. On the deliberate indifference claim, the court concluded that although a reasonable jury could find Garcia was aware of Stewart’s serious medical needs, Stewart failed to show that the right was clearly established, granting Garcia qualified immunity. The court also affirmed the dismissal of the supervisory liability claim against Elliot and the municipal liability claim against the City of Jonesboro, finding no evidence of a pattern of unconstitutional acts or inadequate policies. The Eighth Circuit affirmed the district court’s judgment in full. View "Stewart v. Garcia" on Justia Law

Leslie Torgerson filed a lawsuit in federal district court against Roberts County, South Dakota, and several individuals, including County Sheriff Tyler Appel, County Deputies Zachary Angerhofer and Wesley Bowsher, his adopted son Ross Torgerson, and his ex-wife Terri Torgerson. Torgerson alleged violations of his substantive and procedural due process rights under the Fourteenth Amendment and civil conspiracy. He also asserted a Monell claim against the County, a state-law claim for common law battery against Ross, and a state-law intentional-infliction-of-emotional distress claim against Deputy Angerhofer, Deputy Bowsher, Ross, and Terri. These claims stemmed from a domestic dispute involving Torgerson, Ross, and Terri.The defendants moved for summary judgment on Torgerson’s claims. The United States District Court for the District of South Dakota granted the defendants' motions for summary judgment and declined to exercise jurisdiction over the remaining state-law claims. The court concluded that Torgerson failed to state a claim for a Fourteenth Amendment violation, as he did not plead that he possessed a constitutional interest that had been violated. The court also determined that Torgerson’s civil conspiracy claim failed due to the lack of a stated constitutional interest and insufficient facts showing a conspiracy. Consequently, Torgerson’s Monell claim against the County also failed. The court declined to exercise supplemental jurisdiction over the state-law claims, considering them to be purely state-related issues.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Torgerson did not suffer a deprivation of liberty as he was not charged or prosecuted for any crime, thus failing to establish a Fourteenth Amendment violation. The court also upheld the summary judgment on the civil conspiracy and Monell claims, as there was no underlying constitutional violation. Finally, the court found no abuse of discretion in the district court’s decision to decline supplemental jurisdiction over the state-law claims. View "Torgerson v. Roberts County of South Dakota" on Justia Law

Karla Smith and Holly Bladel sued Iowa state officials and the State of Iowa after Iowa opted out of federal unemployment programs established during the Covid-19 pandemic. These programs, created under the CARES Act, provided various unemployment benefits. Iowa initially participated in these programs but decided to end its participation in June 2021. Smith and Bladel claimed that this decision violated the U.S. Constitution, the Iowa Constitution, and Iowa state law.The United States District Court for the Southern District of Iowa dismissed the case, ruling that the defendants were immune from suit under the Eleventh Amendment and that the plaintiffs lacked a constitutionally protected property interest in the CARES Act benefits. Smith and Bladel appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The court held that the Eleventh Amendment barred Smith's official-capacity claims against Iowa and its officials, as the claims did not fall under the Ex parte Young exception for ongoing violations of federal law. The court also found that Smith lacked a protected property interest in the CARES Act benefits because Iowa had the discretion to opt out of the programs. Consequently, Smith's due process claim against the Governor and Director in their individual capacities failed. Additionally, the court ruled that Smith's state law claim was barred by the Eleventh Amendment, and her request for declaratory relief was inappropriate as it sought to address past actions rather than future conduct. The court concluded that the district court correctly dismissed all of Smith's claims. View "Smith v. Reynolds" on Justia Law

In this case, Jae Michael Bernard was convicted of unlawful possession of a firearm by a person convicted of a misdemeanor crime of domestic violence. Bernard had a prior conviction in 2002 for domestic abuse assault causing injury. In September 2021, investigators found firearms and ammunition at his residence. Bernard pleaded guilty in June 2022 but later moved to withdraw his plea and dismiss the indictment, arguing that 18 U.S.C. § 922(g)(9) is unconstitutional under the Second Amendment.The United States District Court for the Northern District of Iowa denied Bernard's motion to dismiss the indictment. Bernard then entered a conditional guilty plea, reserving his right to appeal the denial of his motion. The district court sentenced him to thirty-seven months’ imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. Bernard's appeal was based on a facial challenge to the constitutionality of § 922(g)(9). The court noted that a facial challenge requires showing that no set of circumstances exists under which the statute would be valid. The court held that § 922(g)(9) is consistent with the historical tradition of firearm regulation, which allows disarming individuals who present a credible threat to the physical safety of others. The court found that the statute is constitutional in at least some of its applications, as it targets individuals convicted of crimes involving actual or attempted violence or the threatened use of a deadly weapon.The Eighth Circuit affirmed the district court's judgment, concluding that § 922(g)(9) is not unconstitutional on its face. View "United States v. Bernard" on Justia Law

Anthony Unocic, while incarcerated in a Nebraska detention center, told two fellow inmates that he wanted to kill a federal agent named Tubbs who had investigated him. Unocic's threats were taken seriously by the inmates because he bragged about a previous violent standoff with police, demonstrated stabbing techniques, and mentioned using explosives. The inmates reported the threats to federal agents, leading to Unocic being charged with one count of threatening to assault a federal officer under 18 U.S.C. § 115(a)(1)(B) and (c)(1).Unocic pleaded not guilty, and the case went to trial in the United States District Court for the District of Nebraska. The district court instructed the jury on the elements required to convict Unocic, including that he either knew or intended that others would regard his communication as threatening violence, or recklessly disregarded a substantial risk that others could regard his communication as threatening violence. The jury found Unocic guilty, and he was sentenced to thirty-three months' imprisonment.On appeal to the United States Court of Appeals for the Eighth Circuit, Unocic argued that the district court erred by including the term "carelessly" in the definition of "recklessly disregards" in the jury instructions. He claimed this allowed the jury to convict him for speech protected by the First Amendment. The Eighth Circuit reviewed for plain error and concluded that, taken as a whole, the jury instructions did not mislead the jury to convict Unocic based on an incorrect standard. The court found no obvious error and affirmed the district court's judgment. View "United States v. Unocic" on Justia Law

Jacqusyn Grubb was charged with unlawful possession of a firearm as an unlawful user of a controlled substance under 18 U.S.C. § 922(g)(3). Grubb moved to dismiss the indictment, arguing that the statute violated his Second Amendment rights, particularly as he was a user of marijuana, not a more dangerous controlled substance. The government contended that Grubb's challenge was premature due to undeveloped facts.The United States District Court for the Northern District of Iowa denied Grubb's motion to dismiss, ruling that the statute was constitutional on its face but held Grubb's as-applied challenge pending trial. The court rejected Grubb's request for an evidentiary hearing, stating it would amount to unauthorized discovery. Grubb then entered a conditional guilty plea, reserving his right to appeal the denial of his motion to dismiss. The district court later reconsidered and requested supplemental briefing but ultimately denied the motion to dismiss, concluding the statute was constitutional as applied to Grubb.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a trial on the merits was necessary to resolve Grubb's pretrial motion to dismiss the indictment. The court emphasized that there is no summary judgment procedure in federal criminal cases and that the government is not required to present all its evidence before trial. The court concluded that the district court should have deferred ruling on the as-applied challenge until trial. Consequently, the Eighth Circuit reversed the district court's order, vacated the judgment, and remanded the case for further proceedings, allowing Grubb to choose whether to adhere to his guilty plea or proceed to trial. View "United States v. Grubb" on Justia Law

Devin Ledbetter was seriously injured by Springfield, Missouri police officer Brandon Helmers. Ledbetter sued Helmers under 42 U.S.C. § 1983, claiming Helmers used excessive force in violation of the Fourth Amendment. The incident occurred when Helmers and his partner responded to a 911 call about a man holding a woman captive in a tent. Ledbetter, who was in the tent, exited holding a knife. The accounts of what happened next differ, with Helmers claiming Ledbetter was non-compliant and threatening, while Ledbetter claimed he immediately dropped the knife and was compliant. Ledbetter sustained severe injuries, including a fractured hip, during the arrest.The United States District Court for the Western District of Missouri denied Helmers's motion for summary judgment based on qualified immunity, noting disputed facts about the threat Ledbetter posed and the amount of force used. The case proceeded to trial, but the jury could not reach a verdict on liability. However, they answered special interrogatories, finding Helmers reasonably believed Ledbetter posed an immediate threat but did not believe Ledbetter was resisting arrest. The district court then granted Helmers's motion for judgment as a matter of law based on qualified immunity, concluding that Helmers did not use excessive force and that his conduct did not violate clearly established law.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a reasonable jury could find Helmers used excessive force, given the evidence and the jury's special findings. However, the court also held that it was not clearly established that Helmers's use of force was excessive under the circumstances, as existing case law did not provide sufficient guidance for the specific situation Helmers faced. Therefore, the court affirmed the district court's judgment granting Helmers qualified immunity. View "Ledbetter v. Helmers" on Justia Law