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

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

The case involves Billings County and its commissioners, who appealed a district court's decision to grant a preliminary injunction preventing them from entering the property of Sandra Short, David Short, Donald Short, and Sarah Sarbacker. The dispute centers on the County's attempt to use eminent domain to construct a bridge over the Little Missouri River, known as the Little Missouri River Crossing (LMRC). The Shorts had previously settled a lawsuit with the County in 2021, where the County agreed not to pursue eminent domain for the LMRC project. Despite this, a newly elected Board of Commissioners decided to proceed with the project in 2023, leading the Shorts to file a new lawsuit.The United States District Court for the District of North Dakota granted a preliminary injunction in favor of the Shorts, finding that they were likely to succeed on their breach-of-contract claim based on the Settlement Agreement. The court refrained from deciding on the validity of the Settlement Agreement, leaving that issue for the state court to address. The district court also stayed its proceedings, pending the outcome of the state court case, and denied the County's motion to dismiss without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the case and vacated the preliminary injunction. The appellate court held that the County could not lawfully contract away its power of eminent domain, as it is an essential attribute of sovereignty. The court concluded that the Settlement Agreement was contrary to law and that the Shorts were not likely to succeed on their breach-of-contract claim. The case was remanded for further proceedings consistent with this opinion. View "Short v. Billings County" on Justia Law

Zackaria Dahir Mohamed, a native of Somalia, entered the United States as a child refugee in 1998. He was later convicted of several offenses, including theft and assault with a dangerous weapon. In 2013, the Department of Homeland Security initiated removal proceedings against him due to these convictions. An Immigration Judge (IJ) ordered his removal in 2018, and the Board of Immigration Appeals (BIA) dismissed his appeal. Mohamed then petitioned for review.The IJ initially found Mohamed removable for aggravated felony theft and crimes of violence. In 2020, the IJ ordered his removal to Somalia. Mohamed appealed to the BIA, which remanded the case to the IJ to assess Mohamed’s competency. On remand, Mohamed presented evidence of his mental health history, including a psychological evaluation by Dr. Jerry Kroll. The IJ ruled in 2021 that Mohamed was competent during the 2020 merits hearing, based on Dr. Kroll’s testimony and the IJ’s observations. The BIA dismissed Mohamed’s appeal on de novo review, leading to the current petition.The United States Court of Appeals for the Eighth Circuit reviewed the case. Mohamed argued that the BIA’s affirmation of the IJ’s competency finding was unsupported by the record. The court noted that it has jurisdiction to review final agency removal orders but not factual findings related to criminal offenses. The court found that Mohamed’s competency determination was a factual finding, which is generally affirmed unless clearly erroneous. Mohamed’s claims were barred by 8 U.S.C. § 1252(a)(2)(C).Even if Mohamed presented a legal or constitutional claim, the court found no fundamental procedural error or resulting prejudice. The IJ had considered all appropriate evidence, including Dr. Kroll’s testimony and Mohamed’s behavior during proceedings. The court concluded that there was no procedural error in holding a retroactive competency hearing. The petition for review was denied. View "Mohamed v. Bondi" on Justia Law

Continental Resources, Inc., an oil and gas production company, leases minerals from both the North Dakota Board of University and School Lands (Land Board) and the United States. The dispute centers on the entitlement to royalties from minerals extracted from the bed of Lake Sakakawea in North Dakota, which depends on the location of the Ordinary High Water Mark (OHWM). If North Dakota law and the state survey govern the OHWM, the Land Board is entitled to a larger percentage of the royalties; if the federal survey controls, the United States is entitled to a larger percentage.The United States removed the interpleader action to federal court and moved to dismiss based on sovereign immunity. The United States District Court for the District of North Dakota denied the motion, holding that under 28 U.S.C. § 2410(a)(5), the United States waived sovereign immunity because North Dakota law created a lien in favor of the United States upon Continental severing the minerals. The district court granted summary judgment in favor of the United States for lands retained since North Dakota's admission to the Union, applying federal law and the Corps Survey. It granted summary judgment in favor of the Land Board for lands reacquired by the United States, applying North Dakota law and the Wenck survey.The United States Court of Appeals for the Eighth Circuit reviewed the case. It affirmed the district court's denial of the motion to dismiss, agreeing that the United States had a lien on the disputed minerals under North Dakota law. The court also affirmed the summary judgment in favor of the Land Board, holding that North Dakota law governs the current location of the OHWM for lands reacquired by the United States. The court denied the United States' motion for judicial notice of additional documents. View "Continental Resources, Inc. v. United States" on Justia Law

Tayvin Galanakis sued Officers Nathan Winters and Christopher Wing under 42 U.S.C. § 1983 and Iowa law, alleging they arrested him without probable cause. He also brought federal and state claims against the City of Newton, Iowa. The district court denied summary judgment in part, determining that the officers were not entitled to qualified immunity or state statutory immunity, and the City was subject to vicarious liability on a surviving state-law claim.The United States District Court for the Southern District of Iowa denied summary judgment with respect to the § 1983 and false arrest claims against Winters and Wing, as well as the respondeat superior claim against the City predicated on Galanakis’s false arrest claim. The defendants appealed, arguing that qualified immunity and state statutory immunity protected the officers—and, as to the false arrest claim, the City—from suit.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s denial of qualified immunity on Galanakis’s Fourth Amendment claim, concluding that no objectively reasonable officer could have concluded that there was a substantial chance Galanakis had driven while under the influence of marijuana. The court found that Galanakis evinced almost no indicia of intoxication and that his behavior during the stop did not suggest impairment. The court also dismissed the interlocutory appeal as to the state-law claims, noting that without clarification that resolution of the qualified immunity claim necessarily resolves the pendent claims, it declined to exercise jurisdiction. View "Galanakis v. City of Newton, Iowa" on Justia Law

An off-duty St. Louis Police Officer, Milton Green, was mistakenly shot by Officer Christopher Tanner during a pursuit of a suspect who had fired at police officers. Green filed a lawsuit under 42 U.S.C. § 1983 against Tanner and the City of St. Louis, alleging Fourth and Fourteenth Amendment violations and state law claims. The district court granted summary judgment in favor of the defendants, concluding that Tanner did not violate Green’s constitutional rights and that official immunity barred the state-law claims. The court also denied Green’s motions to alter or amend the judgment and to submit newly discovered evidence.The United States District Court for the Eastern District of Missouri granted summary judgment to the defendants, finding that Tanner’s actions were reasonable under the circumstances and that there was no constitutional violation. The court also ruled that Green’s Monell claim against the City failed due to the lack of an underlying constitutional violation and that official immunity protected Tanner from the state-law claims. Green’s motions to alter or amend the judgment and to reopen discovery were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that Tanner’s use of force was objectively reasonable given the circumstances, which involved a rapidly evolving and dangerous situation. The court also upheld the dismissal of the Monell claims against the City, as there was no constitutional violation by Tanner. Additionally, the court affirmed the denial of Green’s post-judgment motions and the dismissal of the state-law battery claims, agreeing that official immunity applied. View "Green v. City of St. Louis" on Justia Law

McKenzie County, North Dakota, sued the United States and the Department of the Interior, claiming ownership of mineral royalties under certain lands. The County argued that previous litigation had settled the matter in its favor. The United States contended that the prior litigation involved different lands and that the County’s claim was untimely. The district court ruled in favor of the County, and the United States appealed.The United States District Court for the District of North Dakota had previously granted judgment for the County, concluding that the 1930’s Condemnation Judgments and a 1991 Judgment quieted title to the disputed minerals in favor of the County. The district court held that the County’s claim was not barred by the Quiet Title Act’s statute of limitations and that the All Writs Act and Rule 70 empowered it to enforce its prior judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court’s decision. The Eighth Circuit held that the All Writs Act could not be used to circumvent the Quiet Title Act’s requirements. The court determined that the 1991 Judgment did not include the tracts listed in the 2019 Complaint and that the County’s claim under the Quiet Title Act was untimely. The court concluded that the County knew or should have known of the United States’ adverse claim to the mineral royalties by December 2003, thus triggering the Quiet Title Act’s 12-year statute of limitations. The Eighth Circuit instructed the district court to enter judgment in favor of the United States. View "McKenzie County, ND v. United States" on Justia Law

The Human Rights Defense Center (HRDC) sought to mail its publications to inmates at the Baxter County Jail and Detention Center. HRDC's materials, which include books and magazines about prisoners' legal rights and criminal justice news, were rejected due to the jail's policy limiting non-legal mail to postcards. HRDC filed a lawsuit against Baxter County, claiming the policy violated its First and Fourteenth Amendment rights.The United States District Court for the Western District of Arkansas awarded partial summary judgment to HRDC on the due process claim, finding a technical violation of HRDC's right to notice. However, after a bench trial, the court held that the postcard-only policy did not violate HRDC's free speech rights. The Eighth Circuit Court of Appeals vacated and remanded the decision, requiring additional fact-finding on whether HRDC had alternative means to exercise its First Amendment rights.Upon remand, the district court found that the jail's policies effectively banned HRDC's publications and that allowing these publications would have a de minimis impact on jail operations. The court concluded that the policy was not reasonably related to legitimate penological objectives and violated HRDC's rights. It awarded HRDC nominal damages, a permanent injunction against the postcard-only policy as applied to publisher mail, and attorney fees and costs.The United States Court of Appeals for the Eighth Circuit affirmed the district court's judgment. The court held that the jail's postcard-only policy was not reasonably related to its penological goals and constituted an exaggerated response, effectively banning HRDC's publications. The court also upheld the award of attorney fees and costs to HRDC, finding no abuse of discretion in the district court's decisions. View "Human Rights Defense Center v. Baxter County Arkansas" on Justia Law

Tennessee and sixteen other states challenged a regulation by the Equal Employment Opportunity Commission (EEOC) under the Pregnant Workers Fairness Act, which mandates reasonable accommodations for pregnancy-related conditions, including abortion. The states argued that the regulation unlawfully required them to accommodate employees seeking abortions, conflicting with their policies. They sought an injunction and a declaratory judgment against the rule, claiming it was arbitrary, exceeded EEOC's authority, violated the First Amendment and federalism principles, and was unconstitutional under Article II.The United States District Court for the Eastern District of Arkansas dismissed the case, ruling that the states lacked standing as they did not demonstrate an imminent injury or that the alleged injuries were redressable. The court found the risk of enforcement speculative and compliance costs not directly traceable to the rule. The court also dismissed the states' motion for a preliminary injunction as moot and for failing to show irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that the states had standing as they were the direct objects of the EEOC's regulation, which imposed new obligations on them. The court found that the states were injured by the regulatory burden itself and that setting aside the rule would remedy this injury. The court concluded that the states' need to comply with the rule constituted an injury in fact, caused by the EEOC's action, and redressable by a favorable judicial decision. The case was remanded for further proceedings without addressing the merits of the claims. View "State of Tennessee v. EEOC" on Justia Law

Seven states challenged a rule by the Department of Education that modified an existing income contingent repayment (ICR) plan for federal student loans, known as the Saving on a Valuable Education (SAVE) plan. This plan altered payment thresholds, stopped interest accrual, and forgave loan balances after as little as ten years of repayment. The states argued that the Secretary of Education exceeded statutory authority by forgiving loans through an ICR plan.The United States District Court for the Eastern District of Missouri found that the states were likely to succeed on their claim and issued a preliminary injunction against the rule’s early loan forgiveness provisions. Both parties appealed: the federal officials sought to vacate the preliminary injunction, while the states requested a broader injunction.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the states were likely to succeed in their claim that the Secretary’s authority to promulgate ICR plans does not include loan forgiveness at the end of the payment period. The court held that the statute requires ICR plans to be designed for borrowers to repay their loan balances in full through payments that can fluctuate based on income during the payment term. The court determined that the Secretary had exceeded this authority by designing a plan where loans are largely forgiven rather than repaid.The Eighth Circuit affirmed the entry of the preliminary injunction but concluded that the district court erred by not enjoining the entire rule. The court remanded the case with instructions to modify the injunction to cover the entire SAVE Rule and the revived forgiveness provisions under the previous REPAYE plan. View "State of Missouri v. Trump" on Justia Law