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

Debtors filed for Chapter 7 bankruptcy and listed in their bankruptcy schedules a large volume of rice grain and farming equipment owned in connection with a joint venture. The Bank asserted a property interest and the trustee sought an injunction to prevent the Bank from exercising control over the rice and grain equipment. The court concluded that where a joint venture agreement exists, that document would be controlling as to the parties' intention. In this instance, Paragraph 13 of the joint venture agreement supported the bankruptcy court's determination that debtors had not intended to create a separate entity. Therefore, the rice grain was part of debtors' individual bankruptcy estate under 11 U.S.C. 541 and the bankruptcy court had jurisdiction to authorize the trustee to sell the rice grain. Accordingly, the court affirmed. View "Bank of England v. Rice" on Justia Law

Defendant pleaded guilty to being a felon and unlawful drug user in possession of a firearm. The court concluded that the district court did not procedurally err by imposing a four-level enhancement under U.S.S.G. 2K2.1(b)(6)(B) where the district court understood and properly applied the "facilitate" standard of note 14(A) in finding that defendant possessed the firearm "in connection with" his felony drug offense. The court also concluded that the evidence was sufficient to find that defendant used or possessed the firearm in connection with a methamphetamine possession offense where it was "probable" the firearm was connected to defendant's drug offense. Accordingly, the court affirmed the judgment of the district court. View "United States v. Sneed" on Justia Law

Defendant appealed his conviction for conspiracy to distribute various controlled substances and three counts of distribution of a controlled substance. The court concluded that the evidence was sufficient to support each count of his conviction where the evidence presented by the Government at trial established defendant's guilt beyond a reasonable doubt. The court also concluded that the evidence supported the district court's drug quantity calculation for the purposes of calculating his base offense level. Accordingly, the court affirmed the judgment of the district court. View "United States v. Colton" on Justia Law

Defendant appealed his conviction for unlawful possession of a firearm by a previously convicted felon. The court concluded that the evidence was sufficient to convict defendant where the Government presented ample evidence to permit the jury to find beyond a reasonable doubt that defendant knowingly possessed the firearm found in the rental vehicle. The court also concluded that the district court did not abuse its discretion in refusing to give defendant's proposed "mere presence" instruction where the instructions it gave adequately and correctly conveyed the substance of defendant's proposed instruction. Accordingly, the court affirmed the judgment of the district court. View "United States v. Chatmon" on Justia Law

The Trustee and Centris appealed the bankruptcy court's judgment to the extent that it determined certain funds were not property on the bankruptcy estate. Cross-claim Defendants appealed the same judgment to the extent it awarded the Trustee certain fees and expenses and surcharged those fees and expenses against the funds the bankruptcy court determined were not property of the bankruptcy estate. The bankruptcy appellate panel reversed and remanded, concluding that consideration of the issues was premature. The court believed the better course of action was to afford the bankruptcy court an opportunity to consider the arguments and explain its reasoning for accepting or rejecting them. View "Stalnaker v. Allison, et al." on Justia Law

The County filed a putative class action on behalf of similarly situated Minnesota counties seeking a declaratory judgment that Fannie Mae, Freddie Mac, and the FHFA violated state laws by failing to pay a tax on transfers of deeds to real property. The district court granted the federal agencies' motion to dismiss for failure to state a claim. Since Congress exempted the federal agencies from all state taxation except on real property, and Minnesota's deed transfer fell within the broad exemption, the court affirmed the judgment of the district court. View "Hennepin County v. Federal National Mortgage, et al." on Justia Law

Defendant pleaded guilty to one count of illegal reentry subsequent to an aggravated felony conviction. On appeal, defendant challenged his sentence. The court concluded that defendant's sentence was substantively reasonable where his sentence was below the advisory guideline range and where the district court considered all the mitigating circumstances defendant presented. Accordingly, the court affirmed the judgment of the district court. View "United States v. Gonzalez" on Justia Law

Harleysville issued Diamondhead a commercial insurance policy where, although the parties intended for the policy to exclude coverage for law enforcement, Harleysville inadvertently omitted that exclusion from the policy itself. Harleysville subsequently filed suit against Diamondhead and two residents after a Diamondhead police officer got into an altercation with the residents. Harleysville sought a reformation of the insurance contract and a declaration that it had no duty to defend or indemnify the officer. The court concluded that the district court did not err in reforming the policy to reflect the parties' intent and the doctrine of laches was inapplicable in this instance where the officer pointed to no fact that would make it unjust for Harleysville to seek relief in this circumstance. Accordingly, the court affirmed the judgment of the district court. View "Harleysville Worchester Ins. Co. v. Ensminger" on Justia Law

Plaintiff, an involuntarily committed patient at the Iowa Civil Commitment Unit for Sexual Offenders (CCUSO), filed suit under 42 U.S.C. 1983 alleging that defendant, a nurse practitioner at CCUSO, provided him constitutionally deficient medical care. The district court denied defendant's motion for summary judgment on the basis of qualified immunity. The court concluded that the district court erred in analyzing plaintiff's claim under the professional judgment standard. Instead, where a patient's Fourteenth Amendment claims were for constitutionally deficient medical care, the court applied the deliberate indifference standard from the Eighth Amendment. Because the district court applied the wrong constitutional standard in denying qualified immunity, the court remanded to the district court to apply the deliberate indifference standard in the first instance. View "Scott v. Benson, et al." on Justia Law

Plaintiffs, African American officers who worked in a state penitentiary, filed suit under 41 U.S.C. 1981 and 1983 against supervisors for race based harassment and retaliation. On appeal, the officers challenged the district court's dismissal of their claims against Lieutenants Stoner, Haney, and Runge and against Sergeants Miles and Furby. The court concluded that the evidence revealed acts, comments, and inaction by Sergeant Miles sufficient to make out prima facie harassment claims against him, which must be reinstated and remanded; there was insufficient evidence of harassment by the other supervisors and therefore the claims against Lieutenant Stoner, Runge, and Haney, and Sergeant Furby were affirmed; the retaliation claims by supervisors were affirmed; and Sergeant Miles has not shown that he was entitled to qualified immunity on the officers' harassment claims, nor have Lieutenants Stoner and Haney shown they were entitled to qualified immunity on the retaliation claims of Officer Ellis. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Ellis, et al. v. Houston, et al." on Justia Law