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

Appellants (the “Bullion Traders”) are a collection of in-state and out-of-state precious metal traders or representatives thereof challenging the constitutionality of Minnesota Statutes Chapter 80G, which regulates bullion transactions. The Bullion Traders argue the statute violates the dormant Commerce Clause.   The Eighth Circuit reversed the district court’s partial grant of the Commissioner’s motion to dismiss and the district court’s partial denial of the Bullion Traders’ motion for summary judgment. On remand, the court left to the district court to decide in the first instance whether the extraterritorial provisions of Chapter 80G, as amended, are severable from the remainder of the statute.   The court explained that certain in-state obligations, such as a registration fee for traders doing business in Minnesota, even when calculated considering out-of-state transactions, do not control out-of-state commerce. However, Chapter 80G does not merely burden in-state dealers with a monetary obligation that considers both in-state and out-of-state transactions. Rather, it prohibits an in-state dealer who meets the $25,000 threshold from conducting any bullion transaction, including out-of-state transactions, without first registering with the Commissioner. View "Thomas Styczinski v. Grace Arnold" on Justia Law

A jury convicted Defendant of conspiracy to distribute tetrahydrocannabinol (THC), in violation of 21 U.S.C. Sections 841(a)(1), 841(b)(1)(C), and 846. Defendant appealed, arguing that the district court (1) abused its discretion by denying his motion for a continuance; (2) erred by admitting into evidence portions of recordings of phone calls that Defendant made from jail; (3) permitted trial delays that violated Defendant’s Sixth Amendment right to a speedy trial, and (4) erred at sentencing by declining to vary downward.   The Eighth Circuit affirmed. The court explained that Defendant has not established that the court abused its discretion. The trial occurred nearly a year after Defendant’s arrest and arraignment. Defendant replaced his attorney in August of 2020, but he still had more than five months to prepare for trial with his trial counsel’s assistance. Five months falls within a range found in cases where the court has concluded that there was adequate time.   Further, the court explained the delays, in this case, are not attributable to the government as they resulted from delays requested by codefendants or ordered by the court in which Defendant acquiesced. This means that the relevant period is between October 19, 2020, and January 11, 2021, the date Defendant’s trial began. Thus, the court held that the period of delay does not trigger presumptive prejudice. View "United States v. Muzammil Ali" on Justia Law

A class of inmates who were juvenile offenders sued the state officials responsible for administering the parole process. The inmates alleged that the policies and practices of the parole officials violated their rights to be free from cruel and unusual punishment and to due process of law under the federal and Missouri constitutions. The district court determined that the parole review practices were constitutionally deficient, and ordered the State to implement an elaborate remedial plan.   The State appealed, and the Eighth Circuit concluded that there is no constitutional violation. The court explained that the Supreme Court’s juvenile-specific jurisprudence under the Eighth Amendment does not warrant declaring a constitutional violation and imposing on the State the elaborate set of parole procedures endorsed by the district court. A requirement to allow “some meaningful opportunity” for release, even if applicable to these juvenile homicide offenders, is satisfied here. The juvenile homicide offenders in Missouri received more process than offenders under the regular parole process: they presented more documentary evidence than adult offenders, received longer hearings than the average parole hearing, and were entitled to consideration of statutory factors that apply only to juveniles who were formerly sentenced to life without parole. View "Norman Brown v. Anne Precythe" on Justia Law

Plaintiffs, a transgender youth, their parents, and two healthcare professionals, sought to enjoin Arkansas Act 626, which prohibits healthcare professionals from providing gender transition procedures to any individual under the age of 18 or from referring any such individual to any healthcare professional for gender transition procedures. The district court enjoined the Act, and the State appealed.The Eighth Circuit held that because a minor's sex at birth determines whether or not the minor can receive certain types of medical care under the law, Act 626 discriminates on the basis of sex. Thus, to be valid, the Act must be supported by an exceedingly persuasive justification. The Eighth Circuit determined that the Act prohibits medical treatment that conforms with the recognized standard of care for adolescent gender dysphoria and that the purpose of the Act is not to ban a treatment but to ban an outcome the State deems undesirable. Thus, the district court did not err in granting an injunction. View "Dylan Brandt v. Leslie Rutledge" on Justia Law

Defendant was convicted by an Arkansas jury on two counts of capital murder and sentenced to death. After the district court denied his second amended petition for a writ of habeas corpus, the Eighth Circuit vacated the dismissal of two claims and remanded for further proceedings. On remand, the district court denied Defendant's petition with respect to his conviction but granted relief with respect to his sentence of death, imposing a sentence of life imprisonment. Both sides appealed.On appeal, the Eighth Circuit affirmed the district court's order affirming Defendant's conviction; however, the court reversed the district court's grant of relief. The Eighth Circuit explained that the Arkansas Supreme Court's decision concerning the scope of cross-examination of a government witness did not contravene or unreasonably apply Supreme Court precedent by concluding that the balance struck by the trial court was permissible under the Sixth Amendment, and his Confrontation Clause claim did not merit relief. Defendant's other claims were procedurally barred and Defendant did not show cause of prejudice to overcome the default. View "Ray Dansby v. Dexter Payne" on Justia Law

Plaintiff resigned from his employment as a surgeon with Mayo Clinic (“Mayo”) after an internal committee recommended his termination following an investigation into allegations of his misconduct. Plaintiff sued Mayo and his supervisor, alleging discrimination and reprisal. The district court granted summary judgment in favor of Mayo and the supervisor.   The Eighth Circuit affirmed the district court’s ruling. The court explained that Plaintiff argues Mayo’s recommendation to terminate his employment was based on his race, religion, and national origin. Because Said does not offer direct evidence of discrimination, Plaintiff must create a sufficient inference of discrimination under the McDonnell Douglas framework to survive summary judgment.   Here, Plaintiff claims another similarly situated former employee, who also received complaints, from Mayo received preferential treatment. The court concluded that even if Plaintiff was similarly situated to the other employee, the court concluded that Plaintiff does not present sufficient evidence for a reasonable jury to conclude he received disparate treatment from the other employee. The court further explained that the record overwhelmingly demonstrates that Mayo believed Plaintiff was guilty of making unwelcomed advances toward female coworkers and of other misconduct. Said fails to “create a real issue as to the genuineness of” Mayo’s perceptions. Finally, regarding Mayo’s reporting of Plaintiff’s resignation to the State Board, as already discussed, the record demonstrates Mayo believed it was required to report Plaintiff’s termination to the State Board because Plaintiff resigned during an open investigation into his misconduct. Thus, Plaintiff fails to present sufficient evidence showing this was a pretext for retaliatory intent. View "Sameh Said v. Mayo Clinic" on Justia Law

Defendant was convicted by a jury of possession of a firearm by a prohibited person, in violation of 18 U.S.C. Section 922(g)(9), and possession of a firearm with an obliterated serial number, in violation of 18 U.S.C. Section 922(k). The district court sentenced him to 125 months’ imprisonment. On appeal, Defendant makes several arguments: first, that the district court erred in denying his request for an entrapment instruction; second, he raises a Brady claim; and third, he argues ineffective assistance of counsel.   The Eighth Circuit affirmed. The court explained that factual record establishes law enforcement and its informant merely provided Defendant an opportunity to make a sale, which revealed Defendant’s unlawful possession of the firearm that he sold to the agent.  As there is no evidence of inducement, the court was not required to give entrapment instruction.   Further, Defendant’s assertions are too speculative to support a Brady claim. The jury heard the relevant testimony and was thus aware of the conflicting recollections of the agent and the confidential informant about the events leading to the sale. Furthermore, considering the weight of evidence against Defendant on the two counts of conviction, the failure to disclose the identity of the informant’s brother did not prejudice him. Finally, the court declined to hear Defendant’s ineffective-assistance claim. The court held that it only reviews such claims on direct appeal in “exceptional cases”, and this case is not such an instance. View "United States v. Brandon Hayes" on Justia Law

Plaintiff sued, now retired, police officer, after an encounter that led to Klein’s arrest and a truncated prosecution. The district court granted Defendant’s motion for summary judgment, and Plaintiff appealed the dismissal of his claims alleging unlawful seizure, false arrest, and malicious prosecution.The Eighth Circuit affirmed, concluding that the seizure and arrest claims were untimely and that the malicious prosecution claim fails on the merits. The court explained that Plaintiff’s false arrest claim accrued when he was bound over for trial on June 20, 2017, and his unlawful seizure claim accrued at the time of the seizure, on June 19, 2017. The action filed on November 6, 2019, was therefore untimely as to these claims as well. The district court properly granted Defendant’s motion for summary judgment on Plaintiff’s claims alleging false arrest and unlawful seizure under both federal law and Iowa law.Moreover, the court concluded that Defendant had probable cause to arrest Plaintiff or possession with intent to deliver more than five grams of methamphetamine, and failure to possess a tax stamp for seven grams of methamphetamine. Plaintiff argues that Defendant lacked probable cause because his search for the evidence violated the Fourth Amendment and the Iowa Constitution. The existence of probable cause in a civil action, however, is measured based on all evidence known to the arresting officer, whether or not it would have been admissible at trial. View "Michael Klein v. Warren Steinkamp" on Justia Law

Plaintiff and other death-row prisoners in Arkansas sued the governor and a corrections official, arguing that Arkansas’s three-drug execution protocol violates the Eighth Amendment. After a bench trial, the district court found that the prisoners failed to establish a violation, and denied a motion for new trial.   The prisoners argue that the district court clearly erred in finding that they failed to demonstrate that the Arkansas execution protocol creates a substantial risk of severe pain. The Eighth Circuit affirmed. The prisoners cite expert testimony from Dr. Craig Stevens and Dr. Gail Van Norman that midazolam has a ceiling effect that occurs at a dose between 0.2 to 0.4 mg/kg. These experts relied on two medical studies, which are known by the names of their principal authors as the Inagaki study and the Miyake study. The court wrote that with no scientific consensus and a paucity of reliable scientific evidence concerning the effect of large doses of midazolam on humans, the district court did not clearly err in finding that the prisoners failed to demonstrate that the Arkansas execution protocol is sure or very likely to cause severe pain. Accordingly, the district court properly dismissed the claim under the Eighth Amendment.   Further, the prisoners failed to establish that the State’s existing method was sure or very likely to cause needless suffering, so the State was not required to consider alternative methods. The district court did not abuse its discretion in denying the motion. View "Stacey Johnson v. Asa Hutchinson" on Justia Law

In 2020, Kansas City began restricting participation in its Minority Business Enterprises and Women’s Business Enterprises Program to those entities whose owners satisfied a personal net worth limitation. Mark One Electric Co., a woman-owned business whose owner’s personal net worth exceeds the limit, appeals the dismissal of its lawsuit challenging the Kansas City Program as unconstitutional because of the personal net worth limitation.The Eighth Circuit affirmed. The court explained that to survive strict scrutiny, the government must first articulate a legislative goal that is properly considered a compelling government interest, such as stopping the perpetuation of racial discrimination and remediating the effects of past discrimination in government contracting. Here, Mark One does not dispute that the City has a compelling interest in remedying the effects of race and gender discrimination on City contract opportunities for minority- and women-owned businesses. And Mark One has conceded the 2016 Disparity Study provides a strong basis in evidence for the MBE/WBE Program to further that interest.The City’s program must be narrowly tailored, which requires that “the means chosen to accomplish the government’s asserted purpose are specifically and narrowly framed to accomplish that purpose. Mark One claims that its exclusion from the Program despite its status as a woman-owned business shows that the Program is unlawful Indeed, Mark One has declared that it has suffered past discrimination, as the Program requires for certification. But the City does not have a constitutional obligation to make its Program as broad as may be legally permissible, so long as it directs its resources in a rational manner not motivated by a discriminatory purpose. View "Mark One Electric Company v. City of Kansas City, Missouri" on Justia Law