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

Articles Posted in U.S. 8th Circuit Court of Appeals
by
Defendant appealed his conviction for assault resulting in serious bodily injury. The court concluded that the evidence was sufficient to support the verdict where defendant was entitled to attack the credibility of witnesses based on alleged inconsistencies during the trial, but the jury was convinced that defendant committed the assault and that conclusion was reasonable based on the evidence. View "United States v. Conklin" on Justia Law

by
Defendants Randy and Paul Irlmeier each pleaded guilty to one count of conspiracy to manufacture at least 100 marijuana plants. On appeal, defendants challenged their sentences. The court affirmed, concluding that the district court did not err in applying an aggravating role enhancement under U.S.S.G. 3B1.1 to each sentence based on Paul's recruitment of four individuals and his directions to them and based on Randy's instruction to Paul to water the marijuana plants while he was out of town and Randy's instructions to another individual. View "United States v. Irlmeier" on Justia Law

by
After debtors filed for Chapter 7 bankruptcy protection, GMAC filed this adversary proceeding claiming that it was entitled to a first-priority lien on a home and surrounding twenty-two acres of land by operation of the Arkansas doctrine of equitable subrogation, or to reformation correcting the mutual mistake in its mortgage. The court concluded that, at the time Summit and Southern State made their new loans, knowledge that GMAC made a mistake by describing the wrong property on its earlier mortgage was not knowledge that GMAC had or even claimed to have a superior unrecorded interest, because GMAC had for many months made no attempt to correct the known error, or to reform its mortgage; the principle of Killam v. Tex. Oil & Gas Corp. did not apply to mortgage priority disputes; and the blame for the uncertainty regarding GMAC's lien position lies with GMAC. Had GMAC taken timely action, it would have held the senior recorded lien. Accordingly, the court affirmed the district court's denial of relief for GMAC. View "Owcen Loan Servicing, LLC v. Summit Bank, et al." on Justia Law

by
South Dakota Native American inmates filed suit against defendants claiming that a tobacco ban substantially burdened the exercise of their religious beliefs in violation of the Religious Land Use and Institutionalized Persons Act of 2000 (RLUIPA), 42 U.S.C. 2000cc-1(a). The court concluded that the record amply showed that the inmates have satisfied their burden. That some Native Americans practicing the Lakota religion would consider red willow bark a sufficient alternative to tobacco did not undermine the decision of the district court. Even assuming that defendants' ban on tobacco furthered compelling government interests in security and order, the ban was not the least restrictive means of achieving that interest. The court concluded that the scope of the district court's remedial orders extended no further than necessary to remedy the violation of inmates' rights under RLUIPA. Accordingly, the court affirmed the district court's grant of injunctive relief in all respects. View "Native American Council, etc., et al. v. Weber, et al." on Justia Law

by
Petitioner appealed the district court's denial of his petition to vacate, set aside, or correct his sentence under 28 U.S.C. 2255. The court concluded that it need not discuss whether trial counsel's conduct was deficient because the court found overwhelming evidence of petitioner's guilt on Count 5, which is the count on which trial counsel conceded petitioner's guilt. The court declined to address petitioner's claim that counsel was ineffective for conceding that he possessed the firearm to raise the claim that counsel was ineffective for not objecting to the jury instruction on Count 4 because petitioner was not granted a certificate of appealability on that claim. Accordingly, the court affirmed the judgment of the district court. View "Coleman v. United States" on Justia Law

by
Defendant appealed his sentence after pleading guilty to using interstate commerce facilities in the commission of murder-for-hire. Defendant had posted a classified ad on Craigslist.com offering to pay for the murder of police officers. The court affirmed, concluding that the district court gave great weight to defendant's mental illness, departing downward from his guidelines sentence by 48 months despite finding that his history of inappropriate behavior, combined with his access to firearms, created a "potentially explosive situation." Accordingly, defendant's sentence was substantively reasonable where the district court was within its discretion to consider defendant's capacity to cause harm in the future. View "United States v. Lawrence" on Justia Law

by
Plaintiffs, pretrial detainees at a detention center, filed suit under 42 U.S.C. 1983 against prison guards and the Sheriff, alleging a variety of constitutional violations. The court concluded that the district court correctly denied summary judgment on the basis of qualified immunity where the record supported a claim of excessive force in violation of the Eighth Amendment. The record also supported a claim for failure to protect plaintiffs from harm in violation of the Due Process Clause and the district court correctly denied the guards qualified immunity on this claim. Given the fact that the Sheriff was not at the detention center, he could not have used excessive force against plaintiffs, nor could he have an opportunity to intervene to prevent the guards from employing excessive force. Accordingly, the court reversed the district court's denial of summary judgment based on qualified immunity with respect to the Sheriff. The court affirmed in all other respects. View "Edwards, Jr., et al. v. Byrd, et al." on Justia Law

by
The Trustee appealed from the bankruptcy court's holding that a property tax refund was exempt under Minn. Stat. 550.37, subd. 14, as "government assistance based on need." The property tax refund at issue is authorized by the State of Minnesota Property Tax Refund Act, Minn. Stat. 290A.01-290A.27. The bankruptcy appellate panel concluded that the property tax refund at issue here was not government assistance based on need and was therefore not exempt under section 550.37, subd. 14. Accordingly, the panel reversed the bankruptcy court's order. View "Manty v. Johnson" on Justia Law

by
Creditor appealed from the bankruptcy court's order directing the clerk to reject the filing of his dischargeability complaint based on creditor's failure to make a motion to reopen the underlying bankruptcy case. The bankruptcy appellate panel reversed, holding that reopening a case is not a prerequisite to filing a dischargeability complaint. View "Goldstein v. Diamond" on Justia Law

by
Petitioner, an insanity acquitee committed to the custody of the Missouri Department of Mental Health, filed a petition under 28 U.S.C. 2254, challenging the denial of his state-court application for unconditional release. As a preliminary matter, the court concluded that the district court did not exceed the scope of the court's mandate by considering the Warren County Circuit Court's 2011 findings and decisions. The court concluded that petitioner failed to rebut the presumption that the circuit court's implicit finding of current mental illness is correct. Petitioner also failed to rebut the presumption of correctness of the Warrant County Circuit Court's express finding that he currently presented a danger to others. Accordingly, the court affirmed the district court's denial of the petition for habeas corpus. View "Grass v. Reitz" on Justia Law