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

This case involves a qui tam action under the False Claims Act (FCA) and the Iowa False Claims Act (IFCA) brought by Stephen Grant, a sleep medicine practitioner, against Steven Zorn, Iowa Sleep Disorders Center, and Iowa CPAP. Grant alleged that the defendants had knowingly overbilled the government for initial and established patient visits and violated the Anti-Kickback Statute and the Stark Law by knowingly soliciting and directing referrals from Iowa Sleep to Iowa CPAP. The district court found the defendants liable for submitting 1,050 false claims to the United States and the State of Iowa and imposed a total award of $7,598,991.50.The district court had rejected the defendants' public disclosure defense and awarded summary judgment to the defendants on the Anti-Kickback Statute and Stark Law claim. After a bench trial, the district court found the defendants liable on several claims, including that Iowa Sleep had violated the anti-retaliation provisions of the FCA and IFCA by firing Grant. The district court also concluded that the defendants had overbilled on initial patient visits but not on established patient visits.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed in part, vacated in part, and remanded for further proceedings. The court held that the public disclosure bar was inapplicable because Grant’s complaint did not allege “substantially the same allegations” contained in the AdvanceMed letters. The court also held that the district court did not abuse its discretion in admitting expert testimony on extrapolation and overbilling. However, the court found that the district court erred in its determination of damages and civil penalties, violating the Eighth Amendment’s Excessive Fines Clause. The court vacated the punitive sanction and remanded the case for further proceedings. View "Grant v. Zorn" on Justia Law

In April 2018, Benjamin Evans was shot and killed by Police Deputy Brian Krook in Lake Elmo, Minnesota, after Evans knelt in a crosswalk with a loaded gun pointed at his own head. Following a criminal trial, Krook was acquitted of a second-degree manslaughter charge. Subsequently, Evans' father, William O. Evans, Jr., filed a civil lawsuit against Krook under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment. Krook sought summary judgment based on qualified immunity, a defense unavailable when an officer uses deadly force against someone who does not pose an immediate threat of serious physical harm to another.The District Court for the District of Minnesota denied Krook's motion for summary judgment, citing genuine factual disputes over whether Evans' gun was ever pointed at the officers and whether Evans posed an immediate threat to them. Krook appealed this decision, challenging the denial of qualified immunity.The United States Court of Appeals for the Eighth Circuit, in reviewing the case, first addressed the question of jurisdiction. The court noted that it did not have jurisdiction to review the district court's determination regarding evidence sufficiency, i.e., what facts a party may or may not be able to prove at trial. The court's jurisdiction was limited to the purely legal question of whether the conduct that the district court found was adequately supported in the record violated a clearly established federal right.The court found that the availability of qualified immunity in this case hinged on whether Krook acted reasonably under the circumstances by shooting Evans because Evans either pointed his gun at another or otherwise wielded his gun in a menacing fashion. The court concluded that the inconclusive nighttime videos of Evans' actions did not clearly contradict the district court's factual determinations. Therefore, resolving the underlying factual dispute was beyond the court's limited review. As such, the court dismissed the appeal, stating it lacked the jurisdiction to resolve it. View "Evans v. Krook" on Justia Law

The case revolves around a request for disclosure of certain redacted contents of the Internal Revenue Manual under the Freedom of Information Act (FOIA) by T. Keith Fogg. The redacted contents pertain to the IRS's unique authentication procedures used in special situations to prevent unauthorized disclosure of sensitive taxpayer information, identity theft, and criminal fraud. The IRS claimed these redacted contents were exempt from FOIA disclosure under Exemption 7(E) as they were records or information compiled for law enforcement purposes.The District Court for the District of Minnesota initially granted summary judgment to the IRS, holding that Exemption 7(E) applied to the redacted contents. Fogg appealed to the United States Court of Appeals for the Eighth Circuit, which reversed the grant of summary judgment and remanded the case to the district court for an in-camera inspection of the redacted contents.Upon inspection, the district court again concluded that Exemption 7(E) applied to the redacted contents as they served a law enforcement purpose and involved exceptional situations of a heightened risk of fraud or identity theft. The court granted summary judgment to the IRS once more.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that the redacted contents were techniques and procedures used for law enforcement investigations, akin to background checks. The court also concluded that the IRS had met its burden under the foreseeable harm requirement, showing that disclosure of the redacted contents would foreseeably harm the IRS's interest in preventing circumvention of the law. View "Fogg v. IRS" on Justia Law

Catherine Bradford applied for Social Security disability insurance benefits and supplemental security income, claiming she became unable to work due to multiple ailments. Her disability insurance coverage expired on September 30, 2018, and to receive benefits, she had to establish that her period of disability began between April 24, 2015, and September 30, 2018. Bradford also sought supplemental security income payments for the period between April 24, 2015, and April 8, 2020. Bradford's medical records included opinions from a nurse practitioner, three state-agency physicians, and a family medicine practitioner.The administrative law judge (ALJ) determined that Bradford had not performed substantial gainful activity since the date of her alleged disability and that she was severely impaired by multiple ailments. However, the ALJ found that none of these impairments, either individually or in combination, met or medically equaled the severity of any impairment listed in the relevant regulation. The ALJ assessed Bradford’s residual functional capacity before April 9, 2020, and concluded that she was capable of performing light work, subject to certain limitations. The ALJ determined that Bradford’s limitations did not preclude her from performing her past work as a housekeeper, laundry aide, or factory cleaner. The ALJ gave Nurse Ash’s opinion little weight and gave great weight to the opinions of the state-agency physicians and Dr. Keown.The Appeals Council denied review, and the district court granted judgment for the Commissioner. Bradford appealed, arguing that the ALJ committed legal error by disregarding a prior remand order of the district court and disputing the ALJ’s conclusion that she could perform light work. The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision, concluding that the ALJ permissibly weighed the evidence and committed no legal error. The court found that the ALJ's determination that Bradford could stand for six hours and perform light work was supported by substantial evidence. View "Bradford v. Kijakazi" on Justia Law

The case involves two defendants, Raekwon Patton and Austin Mallory, who were found guilty of their roles in a drive-by shooting following an encounter with a rival gang member. The shooting occurred after the defendants and their gang members spotted Raysean Nelson, a rival gang member, in a parking lot and followed him. The defendants were charged with attempted murder in aid of racketeering and discharging a firearm during a crime of violence.The district court overruled multiple objections raised by the defendants. Patton argued that the jury instructions were missing and that the evidence presented by the government was excessive and portrayed him negatively. He also claimed that his decision to return fire was justified as the other side shot first. However, the court found that Patton had not attempted to retreat before using force, which was required by Iowa law. The court also rejected Patton's argument that the instructions set the bar too low on the racketeering element.Mallory challenged the verdict based on two evidentiary decisions and questioned whether the government established that he was a knowing accomplice. The court excluded a hearsay statement that Mallory hoped would prove he was not the driver during the shooting. The court also did not admit evidence showing Mallory's involvement in non-gang activities, considering it as inadmissible character evidence.The United States Court of Appeals for the Eighth Circuit affirmed the judgments of the district court, finding sufficient evidence for the jury to conclude that Mallory was guilty as an accomplice and rejecting Patton's arguments about the jury instructions and the evidence presented by the government. View "United States v. Mallory" on Justia Law

James and Levi Garrett, a father and son farming duo in South Dakota, were found guilty by a jury of making false statements in connection with federal crop insurance. The Garretts had participated in a federal crop insurance program, administrated by Crop Risk Services (CRS) and backed by the Risk Management Agency of the United States Department of Agriculture (USDA). They had obtained insurance for sunflower crops in 2018, and James had obtained insurance for a corn crop in 2019. The Garretts were accused of falsely certifying the number of acres of sunflowers and corn they planted in 2018 and 2019 respectively, and subsequently reporting harvest losses to CRS.The case went to trial in October 2022. The jury heard from several witnesses and examined dozens of exhibits. At the conclusion of the trial, James was convicted on two counts of making a false statement in connection with insurance for sunflower and corn crops, and Levi was convicted on one count of making a false statement in connection with insurance for a sunflower crop. The Garretts moved for judgment of acquittal, and in the alternative, a new trial, arguing there was insufficient evidence to support their convictions. The district court denied their motion.The Garretts appealed to the United States Court of Appeals for the Eighth Circuit, challenging the district court’s evidentiary rulings and its denial of their post-trial motions. They argued that the district court erred in admitting certain evidence and excluding others, and that there was insufficient evidence to support their convictions. The Court of Appeals affirmed the judgment of the district court, concluding that the trial record supported the jury verdict and that the district court did not err in its evidentiary rulings or in denying the Garretts' post-trial motions. View "United States v. Garrett" on Justia Law

Sarah Watkins filed a lawsuit against the City of St. Louis, Missouri, and six individual police officers under 42 U.S.C. § 1983, alleging that the officers used excessive force during a routine traffic stop. Watkins was stopped for a traffic violation near St. Louis Lambert International Airport. After she was asked to step out of her car, she was handcuffed and allegedly subjected to verbal abuse, forced into a vehicle, pepper-sprayed, and repeatedly hit on the leg with a baton. Watkins was later treated for injuries to her legs, face, and body.The district court dismissed Watkins's claims, ruling that the officers were entitled to qualified immunity on her Fourth Amendment excessive force claims. The court also dismissed the claims against the City, stating that Watkins failed to provide sufficient facts to state a claim for municipal liability under § 1983 and Monell v. Department of Social Services.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal of Watkins's claims. The court found that Watkins had sufficiently alleged a violation of her Fourth Amendment right to be free from unreasonable seizures. The court also determined that this right was clearly established at the time of the traffic stop. Therefore, the court reversed the district court's dismissal of Watkins's Fourth Amendment excessive force claims against the individual officers. However, the court affirmed the dismissal of Watkins's § 1983 claims against the City, as she had not alleged sufficient facts to support the existence of an unconstitutional policy or custom. View "Watkins v. City of St. Louis, Missouri" on Justia Law

The case involves Noah’s Ark Processors, LLC, and the United Food and Commercial Workers’ Union. After the expiration of their previous collective-bargaining agreement, the parties began negotiations for a new one. The company's representative, however, had no decision-making authority, and the negotiations were brief and ineffective. Frustrated, the union filed charges with the National Labor Relations Board (NLRB). The NLRB filed a petition against Noah’s Ark in federal district court for injunctive relief, which was granted, ordering the company to return to the negotiating table. However, the company declared it was unwilling to negotiate and presented another final offer. The district court issued a contempt finding, and the NLRB determined that Noah’s Ark had failed to bargain in good faith.The parties met seven more times over the next two months, but the negotiations were unsuccessful. Noah’s Ark extended another final offer, which included terms the union had already rejected. The company declared another impasse and made changes unilaterally. The union filed another complaint, and an administrative-law judge found that Noah’s Ark had both bargained in bad faith and prematurely declared an impasse. The NLRB ordered Noah’s Ark to continue negotiating, provide backpay to its employees, reimburse the union for its bargaining expenses, and have its CEO read a remedial notice at an all-employee meeting.The United States Court of Appeals for the Eighth Circuit ruled that substantial evidence supported the NLRB's order and granted enforcement. The court found that Noah’s Ark did not take the negotiations seriously and did not approach the renewed negotiations with an open mind and sincere intention to reach an agreement. The court also agreed with the NLRB's finding that there was no good-faith impasse. The court did not consider Noah’s Ark's objections to the remedies imposed by the NLRB, as the company had not raised these specific objections before the NLRB. View "National Labor Relations Board v. Noah's Ark Processors, LLC" on Justia Law

In the case, Sease Beard, a transgender inmate, alleges mistreatment and retaliation by prison officials. Beard, who identifies as a transgender woman, has been provided hormone-replacement therapy by the Missouri Department of Corrections since 2019. The issue in the case centers on whether the prison officials are shielded by qualified immunity.Beard was involved in multiple incidents with guards. In one particular incident, when a guard expressed disapproval of Beard's attire, Beard refused to change. Subsequently, several guards physically restrained Beard, used pepper spray, removed Beard's clothes, and carried Beard through the prison's hallways in view of other inmates. Following this incident, Beard filed a lawsuit against nearly everyone involved, claiming violations of state law and the First, Fourth, Eighth, and Fourteenth Amendments to the United States Constitution.The lower court, the United States District Court for the Western District of Missouri, denied the officials' motion to dismiss the case, asserting their claim to qualified immunity.The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision in part and reversed in part. The court found that certain prison officials were not entitled to qualified immunity for some of Beard's claims, including a Fourth Amendment claim regarding a strip search and First Amendment retaliation claims related to denial of a promotion, restriction of shower access, and confiscation of personal property. However, the court found that other officials were entitled to qualified immunity for claims related to the denial of mental health treatment and the supervisors' inaction. The case was sent back to the district court for further proceedings. View "Beard v. Falkenrath" on Justia Law

The case involves the death of Andrew Dawson Bell, who committed suicide while detained at the Washington County Detention Center (WCDC) in Fayetteville, Arkansas. Bell's mother, Judy Lynn Smith-Dandridge, filed a lawsuit against several Fayetteville Police Department officers, WCDC employees, nurses, and Washington County itself, alleging that they were deliberately indifferent to Bell's serious medical needs, in violation of 42 U.S.C. § 1983 and the Arkansas Civil Rights Act, Arkansas Code Ann. § 16-123-105. The district court granted summary judgment in favor of all defendants, and Smith-Dandridge appealed to the United States Court of Appeals for the Eighth Circuit.Bell had a history of mental illness and substance abuse. On the day he died, Bell had called the police several times, reporting hallucinations of people trying to break into his apartment. Officers responded but found no evidence of a break-in. They arrested Bell for terroristic threats, disorderly conduct, and carrying a weapon. When Bell was processed into WCDC, he informed the intake officers of his mental health history, including a history of suicidal ideation. Despite this, he was placed in the general population.The main issue on appeal was whether the police officers and WCDC personnel had knowledge of Bell's substantial risk of suicide and deliberately disregarded it. Smith-Dandridge argued that the officers’ interactions with Bell and their review of his arrest history established they had the requisite knowledge to establish deliberate indifference. However, the court found that while Bell's behavior put the officers on notice of signs of mental illness, it did not make it obvious to them that Bell had a substantial risk of suicide. Similarly, the court found that the WCDC personnel's inaction to prevent Bell's suicide did not constitute criminal recklessness.The court also dismissed Smith-Dandridge's claim that Washington County was deliberately indifferent in its failure to train jail staff. The court found that Smith-Dandridge failed to show that the alleged deficient training caused WCDC personnel to be deliberately indifferent to Bell's substantial risk of suicide. As such, the court affirmed the district court's grant of summary judgment in favor of all defendants. View "Smith-Dandridge v. Geanolous" on Justia Law