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

Defendant was found incompetent to stand trial after he was indicted on one count of possession of a firearm after having been committed to a mental institution. The district court ordered defendant to be involuntarily medicated to restore him to competency. The court held that the district court did not err in finding that the government had satisfied the second Sell v. United States factor: that involuntary medication would significantly further the government's important interest in prosecuting the case. In the absence of a specific determination by the district court whether administering the medication constituted a medically appropriate treatment for defendant, as required by the fourth Sell factor, there was no finding for the court to review. Therefore, the court remanded with directions that the district court determine whether the government had established by clear and convincing evidence that involuntarily administering the recommended medication regime to defendant was medically appropriate. View "United States v. Curtis" on Justia Law

Claimant appealed the district court's order denying his post-trial motion to suppress evidence obtained as the result of a traffic stop. The government had instituted a civil in rem forfeiture lawsuit against the $45,000.00 found in claimant's vehicle but claimant was not charged with any crime. The arresting officer had pulled claimant's vehicle over for violation of Nebraska Revised Statute Sec., 60-399(2), which provided that license plates be plainly visible, but the officer was clear in his trial testimony that he was able to read "Utah" while still traveling a safe distance behind claimant on the highway. The court concluded that the district court clearly erred in characterizing the facts in its order on claimant's motion for reconsideration; that claimant drove a vehicle with out-of-state license plates and exited from the highway at an unlikely exit for cross-country travelers did not provide the officer with the requisite level of suspicion to stop claimant; and therefore, the initial traffic stop violated claimant's Fourth Amendment rights and any evidence obtained as a result should have been suppressed. Accordingly, the court reversed the judgment of the district court. View "United States v. Martin" on Justia Law

Plaintiff, a prison inmate, filed suit asserting various claims, including 42 U.S.C. 1983 claims alleging violations of the First and Fourteenth Amendments, that prison officials wrongfully censored and confiscated his mail. The court concluded that when an official properly and timely files a motion for dismissal or for summary judgment asserting qualified immunity, the official was entitled to a ruling on the issue of qualified immunity. As such, the district court must issue a reviewable ruling before requiring the officials to progress further in litigation at the district court. Therefore, the court reversed the district court's order converting the officials' motion to dismiss into a motion for summary judgment; vacated the district court's partial denial of the officials' motion for summary judgment; and remanded with instructions for the district court to decide, consistent with this opinion, whether the officials were entitled to qualified immunity on the pleadings under Rule 12(b)(6). View "Payne v. Britten, et al." on Justia Law

Defendant was convicted of conspiracy to launder money and conspiracy to possess with intent to distribute methamphetamine, cocaine and marijuana after two mistrials. The district court denied defendant's motion to dismiss based on double jeopardy and declined to impose sanctions for the government's failure to disclose its GPS surveillance. The court concluded that the district court's factual finding that the government did not intend to goad defendant into requesting a mistrial was not clearly erroneous where the prosecutor's conduct did not reflect an intent to subvert the protections afforded by the Double Jeopardy Clause. Neither of defendant's mistrials resulted from government acts intended to provoke a mistrial and defendant's conviction did not violate double jeopardy. The court also concluded that the district court did not abuse its discretion in declining to impose sanctions where the district court found that the government did not act in bad faith by failing to disclose the GPS surveillance, any prejudice to defendant was modest and had for the most part been remedied, and sanctions were unnecessary to ensure compliance. Accordingly, the court affirmed the judgment of the district court. View "United States v. Amaya" on Justia Law

Plaintiff filed suit against the City, several officers, the State of Iowa, the director of the Iowa Department of Corrections (Baldwin), the Curt Forbes Residential Center, and manager of the Residential Center (McPherson), alleging claims under 42 U.S.C. 1983 and several state-law negligence claims. Plaintiff was shot three times by Angenaldo Bailey. The court concluded that a reasonable jury could not conclude that Officer Mueller acted recklessly or in a conscience-shocking manner by declining to arrest Bailey before the investigation proceeded the next day; plaintiff's claim against Officers Owens, Ropp, and Crippen failed because nothing the officers did - or did not do - established either a state-created danger or special relationship that imposed on them an affirmative duty to protect plaintiff from third-party harm; the evidence did not support a finding that Officers Owens, Ropp, or Crippen were deliberately indifferent to plaintiff's injuries; and because plaintiff cannot establish a constitutional violation by any of the individual City Defendants, the district court properly granted summary judgment to the City. Plaintiff's due process claims against the State Defendants rested on distinct factual allegations about whether those parties exposed her to harm by failing to take steps in response to Bailey's repeated violations of a protective order. Even if the factual record had been fully developed on those claims, plaintiff had no opportunity to make legal arguments in support of her position. Therefore, the court affirmed the district court's grant of summary judgment for the City Defendants, reversed the grant of summary judgment for the State Defendants, and remanded for further proceedings. View "Montgomery v. City of Ames, et al." on Justia Law

The trustee filed an adversary proceeding to recover as voidable preferences two payments that Momar received from debtor during the 90 days prior to filing a bankruptcy petition. On appeal, the trustee challenged the district court's grant of summary judgment excepting the second transfer. The court cautioned district courts and parties in future preferential transfer cases that the Seventh Amendment right to jury trial must be respected and therefore, unless a proper demand for jury trial has been waived, the normal rules limiting the grant of summary judgment applied. On the merits, the district court did not clearly err in finding that the preferential transfer at issue, a payment made to a regular supplier 26 days after the supplier's invoice, was made in the ordinary course of business between debtor and Momar. Accordingly, the court affirmed the judgment of the district court. View "Cox v. Momar Inc." on Justia Law

Relators filed several related qui tam actions against government contractors, including Cisco, alleging that they committed fraud against the government by means of a kickback and defective pricing schemes in violation of the False Claims Act (FCA), 31 U.S.C. 3729-3733, the Anti-Kickback Act, 41 U.S.C. 51-52, and other federal statutes. The government intervened in the action against Cisco, adopted the relators' complaint, and settled the action. Relators' action was dismissed with prejudice as part of the settlement and the district court awarded relators over eight million dollars. The government appealed. Based on the court's decision in Roberts v. Accenture, LLP, the court concluded that the district court did not err by refusing to apply Rule 9(b) pleading standards when determining whether relators were entitled to a statutory share of the government's recovery under section 3730(d)(1). The court also concluded that the district court correctly awarded relators a share of the government's recovery. Finally, the district court correctly awarded relators a share of the settlement funds the government received from both Cisco and its distributor. Accordingly, the court affirmed the judgment of the district court. View "Rille, et al. v. United States" on Justia Law

Plaintiff, through his guardian, sought to recover from an insurance policy of ACE. Plaintiff is developmentally disabled and requires a personal care assistant. Plaintiff, while supervised by an assistant, was blinded in one eye by a BB gun given to him by the assistant. On appeal, plaintiff challenged the district court's grant of summary judgment to ACE, finding that plaintiff's claim was excluded from the policy's general-liability coverage. Plaintiff argued that his injury was within the general-liability coverage because he was not a "patient" within the meaning of the patient exclusion in the policy. The court affirmed the judgment of the district court, concluding that the district court correctly found that the term "patient" was unambiguous. View "Volk v. Ace American Ins. Co." on Justia Law

Plaintiff, convicted of raping his two minor nieces, appealed the district court's denial of his petition for a writ of habeas corpus under 28 U.S.C. 2254. Plaintiff claimed that his counsel was ineffective by failing to object to an expert vouching for a witness and by stating, during opening statements, that plaintiff would only be called to testify if the state had proven its case. The court affirmed the district court's ruling that plaintiff did not suffer from ineffective assistance of counsel where the state court's decision was not an unreasonable application of clearly established federal law or resulted in a decision that was based on an unreasonable determination of the facts. Accordingly, the court affirmed the judgment of the district court. View "Abernathy v. Hobbs" on Justia Law

Defendant appealed his conviction for unlawful possession of marijuana as a previously convicted felon. The court concluded that the district court did not abuse its discretion by admitting evidence of the firearm-purchasing scheme as context for defendant's unlawful possession of the ammunition; the disputed evidence in this case demonstrated the circumstances surrounding the offense and tended logically to prove one or more elements of defendant's unlawful possession of ammunition; evidence of the firearm-purchasing scheme was probative of defendant's knowledge and explained how and why he used another individual to acquire prohibited ammunition; and recent straw purchases by the individual arguably played an integral role in the offense of conviction. Accordingly, the court affirmed the district court's judgment. View "United States v. Morrison, Jr." on Justia Law