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

Plaintiff filed suit under 42 U.S.C. 1983 and Minnesota state law, alleging that officers violated her Constitutional rights when they arrested her. The court concluded that the officer's decision to arrest plaintiff for violating Minnesota's open-container law was reasonable, even if the flask found under her seat was empty. The officer was reasonable in viewing the time of day, plaintiff being non-cooperative, and plaintiff repeatedly asking to urinate as additional factors sufficient for probable cause to arrest for constructive possession. The officer's conduct did not show plain incompetence or a knowing violation of the law. Therefore, the officer was entitled to qualified immunity and the court affirmed the judgment of the district court. View "Branch v. Gorman, et al." on Justia Law

Block appealed a district court order denying its motion for a preliminary injunction requiring defendant to comply with post-termination covenants in a Puerto Rican franchise agreement. The district court denied the preliminary injunction, concluding that Block had not demonstrated that it would suffer irreparable harm if the court did not issue an injunction. The court vacated and remanded, concluding that the district court failed to make specific findings and explain its ruling. Even if the record permitted the court to infer why the district court concluded that Block's initial showing of irreparable injury was inadequate, without adequate Rule 52(a) findings and reasons, the court could not evaluate whether summary denial of Block's motion without an evidentiary hearing was an abuse of discretion, when other procedural alternatives were clearly available. The court declined to direct the district court to enter the requested injunction on remand. View "H&R Block Tax Services, LLC v. Acevedo-Lopez" on Justia Law

Debtor appealed the bankruptcy court's order dismissing his adversary complaint for failure to state a claim. The bankruptcy appellate panel concluded that the bankruptcy court correctly dismissed debtor's adversary complaint where he did not challenge the validity, priority, or extent of the government's lien on any grounds other than his contention that the government's criminal action violated the district court's stay of actions and proceedings against him; debtor did not specifically identify or quantity under 11 U.S.C. 362(k) any damages arising from the government's alleged violation of the automatic stay for the bankruptcy court to consider; and a bankruptcy proceeding may not be used as a forum to mount a collateral attack on a final criminal judgment. Accordingly, the panel affirmed the judgment. View "Behrens v. United States" on Justia Law

Loftness filed suit against defendants seeking a declaratory judgment that it had fulfilled its duties under the Non-Disclosure Agreement (NDA) and the May 2008 Agreement. Defendants asserted counterclaims against Loftness for, as relevant here, unjust enrichment and breach of two contracts. The court concluded that, instead of applying the test for the tort of misappropriation of trade secrets and confidential information, the district court should have interpreted and applied the terms of the NDA; the parties did not comprehensively brief or argue whether Loftness's actions in connection with the Brandt deal constituted a breach of the non-compete provision of the NDA; and the court remanded this counterclaim for further proceedings because it would be beneficial for the district court to consider the issue in the first instance. The court also concluded that the May 2008 Agreement was unenforceable under the statute of frauds; the court declined to read the NDA as a writing that extended the terms of the May 2008 Agreement; even if the court accepted defendant's position that the parties orally extended the May 2008 Agreement for seventeen years, such an extension was unenforceable under the statute of frauds because it could not be performed within one year; and there was no implied-in-fact contract. Accordingly, the court affirmed the grant of summary judgment on this counterclaim. Because the rights and the obligations of the parties were governed by the NDA and the May 2008 Agreement, the court affirmed the dismissal of the unjust enrichment counterclaim. View "Loftness Specialized Farm v. Twiestmeyer, et al." on Justia Law

Petitioners were convicted of drug-related charges. On appeal, petitioners challenged the district court's denial of 28 U.S.C. 2255 relief on the issue of whether they were entitled to relief based on their absence during the answer of jury questions. Petitioners did not raise the issue of their absence on direct appeal. Because petitioners did not establish a cause for the procedural default, the court need not reach the question of prejudice. The court also concluded that the government's letter at issue did not properly fall under Rule 28(j) and the court disregarded the government's Rule 28(j) letter insofar as it included material outside the 28(j) limitations. Any request to supplement the record was moot. Accordingly, the court affirmed the judgment of the district court. View "Meeks v. United States" on Justia Law

Defendant was convicted of possession with intent to distribute and conspiracy to distribute 50 grams or more of methamphetamine and illegal reentry of an alien. On appeal, defendant challenged the district court's denial of his motion to suppress evidence elicited while agents conducted a "knock and talk" at defendant's residence. The court concluded that there was no evidence of misrepresentation in the agent's request to enter the apartment and the boyfriend and roommate of one of the lessees had actual authority to consent; the agents conducted a lawful protective sweep of the apartment where facts were sufficient to alert the agents as to the possibility that the apartment harbored dangerous individuals; defendant's statement about the location of the gun was a volunteered, spontaneous admission; the circumstances surrounding defendant's consent to search his bedroom was void of even the slightest evidence of coercion; and defendant's post-Miranda statements were lawfully obtained. Accordingly, the court affirmed the district court's denial of the motion to suppress. View "United States v. Crisolis-Gonzalez" on Justia Law

Defendant was convicted of conspiracy to distribute at least 50 grams of cocaine base and distribution of at least five grams of cocaine base. On appeal, defendant challenged the district court's denial of his motion for a new trial, arguing that a new trial was warranted because a government witness committed perjury. The court concluded that the district court did not abuse its discretion in denying defendant's motion for a new trial where defendant failed to demonstrate that the newly discovered evidence was material and would result in an acquittal upon retrial. The evidence of defendant's participation in the controlled buy was overwhelming and the value of the additional impeachment material would be negligible at best. View "United States v. Meeks" on Justia Law

Defendant appealed the revocation of his supervised release and the sentence imposed by the district court. The court concluded that the district court did not abuse its discretion in relying on the certified copy of defendant's theft conviction as proof of a state law violation; the district court did not err in finding that defendant failed to notify his probation officer within 72 hours of contact with law enforcement officers, as required by a condition of his supervised release; and the sentence was substantively reasonable. Accordingly, the court affirmed the judgment of the district court. View "United States v. Goodon" on Justia Law

Plaintiff appealed the district court's entry of summary judgment in favor of Open Harvest on plaintiff's claim alleging a violation of section 510 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1140. Because plaintiff has not identified direct evidence of a specific intent to interfere with her ERISA benefits, the court must analyze her claim under the McDonnell Douglas burden-shifting framework. In this case, Open Harvest articulated a legitimate, non-discriminatory justification for its failure to pay the August policy premium. Under the McDonnell Douglas framework, the burden shifted back to plaintiff to show a genuine dispute whether Open Harvest's justification was pretextual. Plaintiff failed to show a genuine dispute whether Open Harvest terminated her employment with a specific intent to interfere with her ERISA benefits. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Open Harvest. View "Barnhardt v. Open Harvest Cooperative" on Justia Law

Defendant appealed his conviction of four counts of aggravated sexual abuse. The court concluded that there was little possibility that the jury was confused over which evidence related to which count and the court was satisfied that the denial of severance did not deprive defendant of a fair trial; even if relevant, the district court did not abuse its discretion in finding that the evidence at issue, the videotaped interview of a victim, had the potential of confusing or misleading the jury since the content of the evidence related to the dismissed count; the district court did not err in striking defendant's former wife's testimony; in regards to allegations of prosecutorial misconduct, because defendant could not show that any possible threats by the Government prejudiced him or denied him a fair trial, there was no error in the district court not hearing the extent of the threats at issue; there was no err in sustaining relevancy objections to evidence that the victims had been sexually abused in the past by others; there was no error in limiting evidence of defendant's strained relationship with the victims' fathers; and the court rejected defendant's claim that the cumulative effect of the errors deprived him of a fair trial. Accordingly, the court affirmed the judgment of the district court. View "United States v. Wilkens" on Justia Law