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

Plaintiff, an orthopedic surgeon and former consultant at Stryker, filed suit alleging that Stryker and I-Flow violated the False Claims Act (FCA), 31 U.S.C. 3729-3733, by marketing their pain pumps to encourage the placement of pain pumps directly into patients' joint spaces after orthopedic procedures. The court concluded that the district court did not err in concluding that plaintiff's allegations had been publicly disclosed and that plaintiff was not excepted under section 3730(e)(4)(B) as an "original source" of the information. The court rejected plaintiff's claim of procedural error and affirmed the district court's dismissal of the claims under section 3730(e)(4)(A). View "Paulos v. Stryker Corp., et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the City, challenging the state's vehicle forfeiture proceeding under Minnesota Stat. 169A.63, Subdiv. 8(b). After looking at the three Mathews v. Eldridge factors, the court concluded that the City's current process - allowing those affected by vehicle forfeiture to request a judicial determination if they believe the forfeiture was erroneous - was sufficient to satisfy due process. In regards to plaintiff's Fourth Amendment claim, his vehicle was lawfully subject to forfeiture, and given his conviction for a fourth DWI, he was not entitled to get it back. Therefore, even if there hypothetically could have been a prolonged seizure had plaintiff requested a judicial determination within thirty days, he cannot show that he suffered any harm from the City's retention of his vehicle because the City was then the rightful owner. Accordingly, the court affirmed the district court's grant of summary judgment to the City. View "Booker v. The City of Saint Paul" on Justia Law

Defendant appealed his conviction for conspiracy to commit bank robbery, possession of a firearm in furtherance of a crime of violence, and being a felon in possession of a firearm. The court concluded that the evidence was sufficient to convict defendant of the conspiracy and possession charges; the district court did not err by denying defendant's motion in limine to exclude Rule 404(b) evidence where he confessed to a prior armed bank robbery because it was probative of his intent and was not unduly prejudicial; and, therefore, the court affirmed the judgment of the district court. View "United States v. Bassett" on Justia Law

Plaintiff filed suit against Officers Santiago and Roth, the City, and the State, alleging constitutional violations under 42 U.S.C. 1983 and state-law violations when the officers unlawfully seized him and used excessive force. On appeal, the officers challenged the district court's denial of their motion for summary judgment. The court agreed with the district court that a reasonable jury could find a violation of the Fourth Amendment when the officers "jerked" plaintiff up by the arms, when he was already under control and handcuffed, with sufficient force to cause serious injury to his shoulder area. Further, the law was sufficiently developed to show that such a violation - allegedly involving unnecessary violence against a handcuffed and compliant detainee - would contravene clearly established law at the time. Accordingly, the court affirmed the judgment of the district court. The court lacked jurisdiction to resolve plaintiff's state-law claims against Officer Roth and the City. View "Blazek v. Santiago" on Justia Law

Plaintiffs, who guaranteed loans for their husbands' company, appealed the district court's grant of summary judgment in favor of Community on their claim under the Equal Credit Opportunity Act (ECOA), 15 U.S.C. 1691 et seq. The court concluded that the text of the ECOA clearly provides that a person does not qualify as an applicant under the statute solely by virtue of executing a guaranty to secure the debt of another. Therefore, a guarantor does request credit and therefore cannot qualify as an applicant under the unambiguous text of the ECOA. Consequently, the court concluded that a guarantor is not protected from marital-status discrimination by the ECOA. The district court did not err in granting summary judgment to Community on plaintiffs' ECOA claim or their ECOA-based affirmative defense. Plaintiffs' argument that the district court erred in striking their demand for a jury trial is moot. View "Hawkins, et al. v. Community Bank of Raymore" on Justia Law

Defendant appealed his sentence after pleading guilty to being a felon in possession of a firearm. The court concluded that defendant and his counsel were not entitled to advance notice before the district court imposed a sentence outside his advisory-Guidelines range. Accordingly, the court affirmed the judgment of the district court. View "United States v. Omoware" on Justia Law

Defendant appealed her sentence after pleading guilty to one count of making a false statement to the government in connection with her receipt of Supplemental Security Income (SSI) benefits from the SSA. The court concluded that the district court properly determined that it could calculate defendant's offense level using intended rather than actual loss. Accordingly, the court affirmed the judgment of the district court. View "United States v. Killen" on Justia Law

Plaintiff appealed the denial of her applications for disability insurance benefits (DIB) and supplemental security income (SSI). Plaintiff argued that the ALJ failed to give adequate weight to her treating physician's opinions regarding her disability. The court concluded that the ALJ had reason to discredit the physician's evaluation given the conclusory nature of his opinion and the court affirmed the judgment. View "Toland v. Colvin" on Justia Law

Defendant appealed his conviction for possessing and distributing child pornography. The court concluded that the district court did not misapply Rule 414 in admitting into evidence defendant's prior conviction for trafficking in child pornography; the district court did not err in denying defendant's motion for mistrial where defendant failed to show that there were premature jury deliberations; and the district court did not err in denying a motion for a new trial where none of the evidence defendant described as "newly discovered" was unknown or unavailable to the defense at the time of trial. Accordingly, the court affirmed the judgment of the district court. View "United States v. Axsom, II" on Justia Law

Defendant appealed his conviction and sentence for charges related to his coercion of several women to travel interstate to perform commercial sex acts for defendant's pecuniary gain. The court concluded that the evidence was sufficient to support his convictions for conspiracy to commit sex trafficking, sex trafficking, and coercion and enticement to travel in interstate commerce for prostitution; the district court did not abuse its discretion in refusing to grant defendant's motion for new trial based on the weight of the evidence; the district court did not abuse its discretion in denying defendant's motion for new trial based on newly discovered evidence; the district court did not abuse its discretion in admitting Rule 403 evidence regarding the victim's background to demonstrate that they were vulnerable victims because the evidence was probative and not unfairly prejudicial; and defendant's sentence did not violate the Eighth Amendment. Accordingly, the court affirmed the judgment of the district court. View "United States v. Bell" on Justia Law