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

Defendant was convicted of attempting to persuade, induce, and entice an individual who had not yet attained the age of 18 years old to engage in sexual activity. The district court sentenced Defendant to a mandatory minimum sentence of 120 months imprisonment under 18 U.S.C. Sec 2422(b). Defendant challenged the district court's imposition of the mandatory minimum sentence as a violation of the Eighth Amendment.The Eighth Circuit affirmed Defendant's sentence, finding that it did not violate the Eighth Amendment's prohibition against cruel and unusual punishment. The court explained that the facts of the case show defendant intentionally engaged in dangerous conduct that was exploitive of children, which is exactly the type of conduct contemplated and targeted by the statute. Under these facts, the court determined that there was no inference of gross disproportionality. View "United States v. Raul Rivas" on Justia Law

Appellant petitioned the district court for a writ of habeas corpus in part on the basis that an off-the-record jury selection procedure violated his constitutional rights. Without holding an evidentiary hearing, the district court dismissed Appellant’s petition with prejudice. The Eighth Circuit granted a certificate of appealability as to whether the district court prematurely dismissed Appellant’s claims that the pretrial jury selection procedure violated his right to be present, right to a public trial and right to an appeal and that his trial counsel was ineffective for participating in the procedure.The Eighth Circuit ultimately affirmed the district court’s ruling. The court explained that Appellant has not shown that “fundamental unfairness” resulted from his trial counsel’s participation in the pretrial jury selection procedure. Appellant alleged that his was fundamentally unfair because he was unaware of the pretrial jury selection procedure and any discriminatory strikes made during this procedure.  However, the court wrote, that Appellant’s trial counsel agreed to and participated in the procedure, which effectively gave both parties an additional 15 peremptory strikes; a record was, in fact, made of these strikes, and maintained by and available for review at the Washington County Circuit Court Clerk’s Office; the written submission of strikes that occurred as part of the pretrial jury selection procedure was only a portion of voir dire; and the remainder of voir dire, along with the evidentiary and sentencing phases of the trial, remained open to the public. Thus, Appellant’s trial counsel’s participation in the pretrial jury selection procedure did not render his trial fundamentally unfair. View "Zachariah Marcyniuk v. Dexter Payne" on Justia Law

Monsanto Company and BASF Corporation began developing dicamba-tolerant seed and sued each other over intellectual property. When the USDA deregulated Monsanto’s dicamba-tolerant soybean seed that year, Monsanto began to sell it. BASF’s lower-volatility dicamba herbicide was approved in 2017. Bader Farms, Inc. sued Monsanto and BASF for negligent design and failure to warn, alleging its peach orchards were damaged by dicamba drift. The jury awarded compensatory damages and punitive damages based on Monsanto’s acts.   The district court denied Defendants’ motions for a new trial and judgment as a matter of law but reduced punitive damages to $60 million. The district court’s judgment also held Monsanto and BASF jointly and severally liable for the punitive damages.   Defendants appealed, arguing that Bader failed to prove causation, the measure of actual damages is the value of the land rather than lost profits, Bader’s lost profits estimate was speculative, and the punitive damages award was unwarranted under Missouri law and excessive under the United States Constitution.   The Eighth Circuit held that Bader established causation by showing Defendants' conduct was both the cause in fact and the proximate cause of Bader's injury. Further, the district court properly refused to find intervening cause as a matter of law or to give an affirmative converse on the issue. However, the evidence established different degrees of culpability between BASF and Monsanto, and the district court should have instructed the jury to separately assess punitive damages against each of them; therefore, the court remanded with directions to hold a new trial only on the issue of punitive damages. View "Bader Farms, Inc. v. BASF Corporation" on Justia Law

After Nygard removed his driveway and was about to pour a new one, an Orono inspector told Nygard that he needed a permit. The next day, Nygard finished the driveway and applied for a permit. The new driveway was narrower than the previous one. The city responded with a form, imposing several conditions. Nygard crossed out some conditions, initialed the modified form, and returned it. After several exchanges, the city notified Nygard that he must agree to the conditions or “this matter will be turned over to the prosecuting attorney.” Nygard did not acknowledge the conditions. A police officer drafted a statement of probable cause, alleging that “work had been completed without having first obtained a permit” and listing some alleged deficiencies in its construction. According to the Nygards, the police did not inspect the property and some allegations were not true.Nygard was acquitted of violating the city code. The Eighth Circuit affirmed the dismissal of his suit under 42 U.S.C. 1983, claiming the code was void for vagueness and alleging First Amendment retaliation, abuse of process, and malicious prosecution. Nygard’s prosecution was not based on falsehoods. The report did not claim that the conditions were required by the code but that Nygard had not agreed to the conditions and had replaced a driveway without a permit. Any failure to investigate did not defeat probable cause; the city already knew that he installed a driveway without a permit. View "Nygard v. City of Orono" on Justia Law

Minneapolis police investigated Randle for selling crack cocaine while he was on supervised release for a prior federal offense. After conducting a controlled buy, Officer Hamilton applied for a warrant to search a Brooklyn Park, Minnesota home that Randle listed as his supervised release address. The warrant was executed that day. Randle arrived during the search. Police seized 308 grams of crack cocaine and related evidence from the home and from bags carried by Randle.The district court denied a motion to suppress, applying the good-faith exception while concluding the affidavit did not create a “fair probability that evidence of Randle’s alleged drug trafficking activities would be found at the Residence” because it did not include Hamilton’s statement that in his professional judgment drug traffickers typically keep narcotics in their home and did not state that Hamilton followed Randle to the residence directly after the controlled buy and failed to specify when the officers started following Randle. The Eighth Circuit affirmed. The evidence is admissible because “it was objectively reasonable for the officer executing [the] search warrant to have relied in good faith on the [issuing] judge’s determination that there was probable cause to issue the warrant.” The court also upheld the denial of a “Franks” hearing; Randle failed to make the necessary “substantial preliminary showing” of “deliberate falsehood or of reckless disregard for the truth.” View "United States v. Randle" on Justia Law

The Eighth Circuit affirmed the judgment of the district court convicting Defendant of unlawful possession of a firearm as a previously convicted felon and sentencing him to 105 months in prison, holding that there was no reversible error in the proceedings below.The presentence report in this case recommended a base offense level of 20 and an advisory guideline range of 92 to 115 months' incarceration. The parties subsequently determined that Defendant's base offense level should be 14. The court considered the sentencing factors set forth in 18 U.S.C. 3553(a) and ultimately imposed a sentence of 105 months' imprisonment. The Eighth Circuit affirmed, holding that the sentence was not excessive or unreasonable and that the court did not abuse its discretion by considering an improper sentencing factor. View "United States v. Jones" on Justia Law

Someone shot a St. Louis fire captain and his passenger. The fire captain described the shooter as a “black male,” once on a 911 call right after the shooting, again when responding officers arrived on the scene, and again to an officer at the hospital. He did not give that description to Detective Bowles, who investigated the case. Bowles focused his attention on the Hartman brothers, who are white. Nearby cameras had captured them driving in the area and then stopping shortly before the shooting. Based on this evidence, Detective Bowles requested multiple search and arrest warrants. The paperwork Bowles submitted omitted the fact that the fire captain had described the shooter as black.The brothers were eventually released and sued Bowles, citing the Fourth Amendment, 42 U.S.C. 1983. The Eighth Circuit affirmed the dismissal of the suit. A detective does not violate a clearly established constitutional right by omitting information from a warrant application that he does not actually know, even if the reason is his own reckless investigation. To succeed, the Hartmans had to show that Bowles omitted facts “with the intent to make, or in reckless disregard of whether they make, the affidavit misleading.” Bowles is entitled to qualified immunity. View "Hartman v. Bowles" on Justia Law

A sheriff’s deputy sexually abused J.T.H.’s 15-year-old son. J.T.H., who also worked in law enforcement, threatened to sue for the abuse. Before long, Spring Cook, a child-welfare investigator, showed up at his door after someone had apparently called the child-abuse hotline and accused J.T.H. (and his wife) of neglect. The parents asked for the case to be reassigned to an investigator from another county, but Cook kept it for herself. Cook ultimately issued a preliminary written finding of neglect. Unsatisfied with the outcome, the parents requested a formal administrative review. Cook was the circuit manager, so she reviewed and upheld her own finding. The second step required Cook, the parents, and their attorney to appear before Missouri’s Child Abuse and Neglect Review Board. Following that meeting, the Board concluded that Cook’s findings of “neglect were unsubstantiated.” The parents sued Cook for allegedly retaliating against them for exercising their First Amendment rights. The magistrate judge, acting by consent of the parties, concluded that neither absolute nor qualified immunity applied. The Eighth Circuit reversed: "the availability of absolute immunity depends on 'the nature of the function performed,' not the type of claim brought. ... So even if there is a general right to be free of retaliation, the law is not clearly established enough to cover the 'specific context of the case': retaliatory investigation. Cook is entitled to qualified immunity for both investigative acts." View "J.T.H. v. Cook" on Justia Law

Isaiah Hammett was killed during the St. Louis Metropolitan Police Department’s (SLMPD) execution of a search warrant at his grandfather’s home. Hammett’s surviving mother and grandfather, Gina Torres and Dennis Torres (Dennis), brought Fourth Amendment excessive force and unlawful seizure claims under 42 U.S.C. § 1983, conspiracy claims under 42 U.S.C. §§ 1983 and 1985, and state law wrongful death and infliction of emotional distress claims against the City of St. Louis and multiple SLMPD officers.The district court denied the City and defendant officers’ motion for summary judgment on these claims, and they appealed. The Eighth Circuit determined it lacked jurisdiction to review the denial of qualified immunity "if at the heart of the argument is a dispute of fact." The Court found that in their essence, defendants' arguments were related to the of the sufficiency of the evidence, and whether certain opinion testimony presented at trial created a genuine issue of fact. To the extent that defendants asserted arguments beyond the scope of the Court's jurisdiction, the Eighth Circuit dismissed their appeal. On the few arguments that remained, the Court reversed the district court's denial of the defendant officers' qualified immunity claims: Dennis was not seized for purposes of the Fourth Amendment; (2) the City could not have conspired with itself through the defendant officers acting within the scope of their employment; and (3) the intracorporate conspiracy doctrine did not apply to § 1983 conspiracy claims. Judgment was dismissed in part, reversed in part, and remanded for further proceedings. View "Torres v. Coats" on Justia Law

Defendant-appellant Caesar Vaca lied to detectives when he told them he had never possessed a gun. He had pleaded guilty to a crime more than 20 years earlier that involved the use of one. The issue presented for the Eighth Circuit Court of Appeals was whether evidence of the prior conviction was admissible. The district court said yes, and the Eighth Circuit affirmed. View "United States v. Vaca" on Justia Law