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

After being convicted of second-degree sexual assault in Garland County, Arkansas, Harl Garrett was sentenced to 20 years in prison. Garrett requested his attorney, Ben Hooten, to file an appeal, but instead, Hooten moved to withdraw as counsel without filing the notice of appeal. Garrett was not informed of the withdrawal order until after the 30-day window for filing a direct appeal had expired. Garrett attempted to file a pro se notice of appeal and later submitted motions for a belated appeal and to proceed in forma pauperis, but these were denied by both the Garland County Circuit Court and the Arkansas Supreme Court. Garrett subsequently filed a state postconviction petition, which was also denied as untimely.Garrett then filed a federal habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the Eastern District of Arkansas, raising the claim that he was denied his constitutional right to a direct appeal due to counsel and court failures. The district court denied the petition as time-barred under the one-year statute of limitations set by the Antiterrorism and Effective Death Penalty Act (AEDPA), finding that the limitations period began when Garrett learned of his attorney’s abandonment and expired before the federal petition was filed. However, the district court granted a certificate of appealability on whether Garrett’s motion for a belated appeal tolled the AEDPA limitations period under 28 U.S.C. § 2244(d)(2).The United States Court of Appeals for the Eighth Circuit reviewed the case and held that a motion for belated appeal in Arkansas constitutes “collateral review” under AEDPA, thus tolling the statute of limitations while the motion is pending. The court reversed the district court’s judgment and remanded the case for further proceedings, concluding that Garrett’s federal habeas petition was timely. View "Garrett v. Payne" on Justia Law

Muhammad Arif, the owner of convenience stores in Arkansas, was accused of soliciting a fifteen-year-old girl, the daughter of his handyman, to engage in sexual acts in exchange for money on two occasions in 2019. Both incidents occurred while Arif was driving the girl home in his vehicle. The girl declined his advances, recorded the conversations, and later reported the incidents to her parents and the police. Arif was initially prosecuted under Arkansas state law, but the federal government took over, charging him under 18 U.S.C. § 1591(a)(1), which criminalizes commercial sex trafficking of a minor “in or affecting interstate or foreign commerce.”The United States District Court for the Eastern District of Arkansas presided over the trial. After the jury found Arif guilty, he moved for a judgment of acquittal, arguing that the government failed to prove the required element that his conduct affected interstate commerce. The district court agreed, granting the motion and concluding that merely driving a car manufactured out of state and giving money to the victim did not constitute an actual effect on interstate commerce as required by precedent.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo, considering whether the evidence was sufficient to establish the interstate commerce element of the federal statute. The appellate court held that the government’s evidence—Arif’s use of a car manufactured in another state, the transfer of $20, and the use of local roadways—was insufficient to show an actual effect on interstate commerce. The court distinguished this case from others where use of the internet, interstate travel, or communications had a clear impact on commerce. The Eighth Circuit affirmed the district court’s judgment of acquittal. View "United States v. Arif" on Justia Law

During an oil pipeline protest in Hubbard County, Minnesota, Matthew Locke and another protestor locked themselves to construction equipment using a device known as a “sleeping dragon,” which made removal difficult. Law enforcement officers, including Sheriff Cory Aukes and Chief Deputy Scott Parks, responded to the scene. In their efforts to remove Locke, the officers used several pain compliance techniques, applying pressure to various nerves on Locke’s head and neck. Locke alleges that as a result, he suffered facial paralysis, tinnitus, and emotional distress. After being removed from the device by extraction teams, Locke was evaluated by EMTs, taken to the hospital, and then jailed.The United States District Court for the District of Minnesota dismissed Locke’s claims under 42 U.S.C. § 1983 and Minnesota law. The court held that Sheriff Aukes and Deputy Parks were entitled to qualified and official immunity, and that Locke’s complaint did not state a claim for municipal liability against Hubbard County. The district court also dismissed Locke’s state law claims for assault and battery.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The Eighth Circuit held that, accepting the complaint’s allegations as true, Locke plausibly alleged a violation of his clearly established Fourth Amendment right to be free from excessive force, as the officers’ use of pain compliance techniques on a nonviolent, passively resisting misdemeanant was not objectively reasonable. The court also found that the district court erred in dismissing the official capacity claim without considering whether the sheriff was a final policymaker for the county. Additionally, the Eighth Circuit reversed the grant of official immunity on the state law claims, finding that the complaint sufficiently alleged willful violation of a known right. The court reversed and remanded for further proceedings. View "Locke v. County of Hubbard" on Justia Law

Philip Myers, a native and citizen of Liberia, was adopted by a U.S. citizen and entered the United States as a child. He later sustained several criminal convictions, including for aggravated felonies. In 2021, the Department of Homeland Security initiated removal proceedings against him. Myers claimed derivative citizenship through his adoptive mother, who had become a naturalized U.S. citizen, and also alleged that he had been abused by her. The United States Citizenship and Immigration Services (USCIS) had previously denied his derivative citizenship application, finding insufficient evidence that he was in his adoptive mother’s legal and physical custody at the relevant time. During removal proceedings, Myers, sometimes represented by counsel and sometimes pro se, was found competent to proceed without safeguards. He applied for various forms of relief, including asylum and protection under the Convention Against Torture, but these were denied.The Immigration Judge ordered Myers removed to Liberia. Myers appealed to the Board of Immigration Appeals (BIA), arguing that the competency determination was flawed and that he should have been found incompetent to proceed pro se. The BIA found no clear error in the Immigration Judge’s competency finding and dismissed the appeal. Myers then moved to reopen the proceedings, citing a pending motion with USCIS regarding derivative citizenship, alleged errors in the competency determination, a new asylum claim based on his sexual orientation, and a pending T-visa application as a victim of sex trafficking. The BIA denied the motion to reopen, and Myers was removed to Liberia.The United States Court of Appeals for the Eighth Circuit reviewed the BIA’s denial of the motion to reopen for abuse of discretion and found none. The court also rejected Myers’s constitutional challenge to the statutory requirements for derivative citizenship and found no genuine issue of material fact regarding his nationality claim. The petition for review was denied. View "Myers v. Bondi" on Justia Law

Anthony Browne was convicted in Iowa in 1991 of willful injury causing serious injury, a Class C forcible felony, and criminal gang participation, a Class D felony. After completing his sentence in 1998 and maintaining a law-abiding life, Browne sought to possess firearms for hunting, target shooting, and home defense. Iowa law prohibits felons, especially those convicted of forcible felonies, from possessing firearms or obtaining a permit to acquire a handgun, and does not allow restoration of firearms rights for such individuals except through a gubernatorial pardon.Browne filed suit in state court against the Governor of Iowa and the Sheriff of Johnson County, arguing that the statutory prohibition on restoration of firearms rights for forcible felons violates the Second Amendment as applied to him. The defendants removed the case to the United States District Court for the Southern District of Iowa. Browne requested a declaratory judgment that the statute is unconstitutional, and injunctions against enforcement and denial of a handgun permit without an individualized determination of dangerousness. The district court dismissed Browne’s federal claim for failure to state a claim, finding the statute constitutional, and remanded his state constitutional claim to state court.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The appellate court held that Browne had standing because applying for restoration or a permit would be futile under current law. On the merits, the court affirmed the district court’s dismissal, holding that Iowa’s lifetime prohibition on firearm possession by forcible felons, subject to the possibility of a gubernatorial pardon, is consistent with the Nation’s historical tradition of firearms regulation and does not violate the Second Amendment. The judgment of the district court was affirmed. View "Browne v. Reynolds" on Justia Law

The plaintiff, a Nebraska resident, received Medicaid benefits administered by the Nebraska Department of Health and Human Services (NDHHS). In April 2024, she was sent a notice stating her Medicaid eligibility was ending due to income exceeding program standards. The notice informed her of her rights to request a conference or appeal and outlined the process for a fair hearing. She did not appeal the termination, and her coverage ended on May 1, 2024. Subsequently, she filed a federal lawsuit on behalf of herself and similarly situated individuals, alleging that the termination notices failed to meet due process requirements and seeking class certification, declaratory and injunctive relief, including reinstatement of benefits until proper notice was provided.The United States District Court for the District of Nebraska considered only her individual claims, as she did not challenge the court’s decision to exclude class claims on appeal. The district court denied her request for a temporary restraining order, finding she was unlikely to succeed because her claims sought retroactive relief barred by sovereign immunity and because the notices likely satisfied due process. The court then dismissed her complaint for lack of subject matter jurisdiction, concluding she had not alleged an ongoing violation of federal law and was not seeking prospective relief, as required to invoke the Ex parte Young exception to Eleventh Amendment immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s dismissal. The Eighth Circuit held that the plaintiff’s alleged due process violation was a discrete past event—the issuance of the notice and termination of benefits—not an ongoing violation. The court further held that the relief sought was retrospective, not prospective, and thus barred by the Eleventh Amendment. The court concluded that the Ex parte Young exception did not apply, and affirmed the dismissal. View "Filyaw v. Corsi" on Justia Law

A certified nurse midwife in Nebraska sought to provide home birth services but was prevented from doing so by state law. The Nebraska Certified Nurse Midwifery Practice Act requires midwives to work under a supervising physician through a practice agreement and prohibits them from attending home births outside authorized medical facilities. The midwife alleged that these restrictions forced her to turn away women seeking home births and sued state officials, claiming the law violated her constitutional rights and the rights of her prospective patients.The United States District Court for the District of Nebraska dismissed the midwife’s claims. The court found that she failed to state a claim for violation of her own rights under the Due Process Clause and lacked standing to assert claims on behalf of her prospective patients. The district court concluded that the statutory requirements were rationally related to legitimate state interests in health and safety and that the midwife did not have a sufficiently close relationship with prospective patients nor could she show that those patients were hindered from bringing their own suits.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the Nebraska law regulating midwifery is subject to rational basis review and that the legislature could rationally believe the restrictions serve legitimate interests in public health and safety. The court also held that the midwife lacked third-party standing to assert the rights of prospective patients because she did not have a close relationship with them and they were not hindered from bringing their own claims. The Eighth Circuit affirmed the district court’s judgment, upholding the dismissal of all claims. View "Swanson v. Hilgers" on Justia Law

Marcus D. Evans, an inmate at the Varner Supermax Unit in Arkansas, was placed in full restraints to attend a prison program. After returning to his cell, officers removed his hand restraints but refused to remove his leg restraints, despite his repeated requests. Evans remained in leg restraints for approximately 15 hours, during which he experienced pain, had difficulty sleeping, and was forced to cut off his clothing to shower. Medical records indicated he reported significant pain but showed no serious physical injury. Evans alleged that the officers’ refusal to remove the restraints was intentional and stemmed from prior altercations and threats.Evans filed suit in the United States District Court for the Eastern District of Arkansas, asserting an excessive force claim under 42 U.S.C. § 1983 against the officers. The officers moved for summary judgment, arguing qualified immunity. A magistrate judge recommended granting summary judgment, finding that while a jury could find a constitutional violation, the right was not clearly established. The district court declined to adopt this recommendation, holding that existing precedent clearly established that prolonged restraints without penological justification could constitute excessive force, and denied qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo. The court held that the officers’ refusal to remove the leg restraints constituted a use of force, and that Evans’s pain and discomfort, even absent serious injury, were sufficient to support an excessive force claim. The court further found that existing case law clearly established that subjecting an inmate to prolonged restraints without penological justification could violate the Eighth Amendment. Therefore, the Eighth Circuit affirmed the district court’s denial of qualified immunity to the officers. View "Evans v. Smith" on Justia Law

The plaintiff, a former police officer in Dermott, Arkansas, alleged that he was forced to resign in retaliation for reporting a fellow officer’s excessive use of force. The incident in question involved the other officer grabbing an arrestee by the neck while the arrestee was restrained. Subsequently, the officer accused the plaintiff of taking money from a parolee, which the parolee confirmed in a statement. The police chief referred the matter to a prosecutor, who initiated a state police investigation. During this period, the plaintiff’s employment status became unclear, with conflicting statements about whether he was fired or resigned. The plaintiff ultimately resigned after a job offer from another police department was rescinded due to the ongoing investigation. He was later charged with abuse of office and witness bribery, but the charges were dismissed when the parolee could not be located.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants on all claims. The court found that the plaintiff had voluntarily resigned and had not suffered an adverse employment action, which was necessary for his First Amendment retaliation claim. The court also determined that the plaintiff was not “seized” within the meaning of the Fourth Amendment for his malicious prosecution claim, as a summons to appear in court did not constitute a seizure. The court exercised supplemental jurisdiction over the state law claims and found that they failed on the merits, including claims under the Arkansas Whistle Blower Act, malicious prosecution, abuse of process, and defamation.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the plaintiff’s voluntary resignation did not amount to an adverse employment action, and that he was not seized under the Fourth Amendment. The court also agreed that the state law claims failed as a matter of law. View "Brown v. City of Dermott Arkansas" on Justia Law

Anthony Schmitt, a Christian volunteer, taught a program called “The Quest for Authentic Manhood” at the Minnesota Correctional Facility from 2012 until 2020, when all religious programming was suspended due to the COVID-19 pandemic. The Quest program, which is based on biblical teachings about manhood, was popular among inmates and had been offered voluntarily. In 2023, after religious programming resumed, the Minnesota Department of Corrections (MDOC) decided to discontinue Quest, citing concerns that its content conflicted with the department’s diversity, equity, and inclusivity values. The MDOC specifically objected to the program’s biblical perspective on masculinity, its treatment of sexual orientation, and its portrayal of gender roles.Schmitt filed suit in the United States District Court for the District of Minnesota, alleging that the MDOC’s decision violated his First Amendment rights to free speech and free exercise of religion, and constituted a denominational preference in violation of the Establishment Clause. He sought a preliminary injunction to reinstate the Quest program. The district court denied the motion, applying the standard from Turner v. Safley, and found that the MDOC’s decision was rationally related to legitimate penological interests, was neutral, and did not violate Schmitt’s constitutional rights.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the preliminary injunction. The court held that, even assuming the Turner standard applied, the MDOC’s action was not neutral because it targeted Schmitt’s religious viewpoint. The court found that Schmitt was likely to succeed on the merits of his First Amendment claims and that the other factors for a preliminary injunction also favored him. The Eighth Circuit reversed the district court’s denial of the preliminary injunction and remanded with instructions to reinstate the Quest program pending further proceedings. View "Schmitt v. Rebertus" on Justia Law