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

Argus filed suit under the Freedom of Information Act (FOIA), 5 U.S.C. 552 et seq., seeking information regarding how much money individual retailers received from taxpayers each year through the Supplemental Nutrition Assistance Program (SNAP). On appeal, Argus challenged the district court's grant of summary judgment to the USDA. The district court found that the spending information was exempt from disclosure and granted the USDA's motion. The court reversed, concluding that the statutory text plainly precluded the USDA from shielding the spending information under Exemption 3. View "Argus Leader Media v. USDA" on Justia Law

Defendant pleaded guilty to a drug offense and subsequently appealed his sentence. The district court sentenced defendant as a career offender under U.S.S.G. 4B1.1. The court concluded that defendant's conviction for first-degree battery under Arkansas Code Annotated 5-1-201(a)(3) was not a crime of violence under the force clause because the crime can be violated by reckless driving and defendant's conviction was also not a crime of violence under the residual clause because subsection (3) was not similar in kind or degree of risk to the enumerated crimes. Accordingly, defendant lacked the two predicate crimes of violence needed to qualify as a career offender. The court vacated and remanded for resentencing. There was no reason to allow the government to expand the record on remand because the government had a full and fair opportunity to present its evidence. View "United States v. Boose" on Justia Law

Defendant appealed his conviction for possessing crack cocaine with intent to distribute. The court affirmed the district court's denial of defendant's motion to suppress the evidence seized from his residence where the search had not occurred until after the warrant had been executed; affirmed the district court's denial of defendant's motion for a judgment of acquittal where a reasonable jury could have concluded that defendant was the sole occupant of the residence and his dominion over the premises was sufficient to establish constructive possession, and that defendant intended to distribute the crack cocaine found in his residence; and the admission into evidence of an out-of-court statement did not violate defendant's Confrontation Clause rights where the statement was not hearsay. View "United States v. Wright" on Justia Law

Defendant appealed his conviction for being a felon in possession of a firearm and possession of an unregistered firearm. Because defendant was unable to establish that there was any government involvement or inducement relevant to the instant charge, the court need not address whether defendant was predisposed to engage in the relevant conduct. Accordingly, the court affirmed the district court's denial of defendant's request to instruct the jury on an entrapment defense. View "United States v. Ardrey" on Justia Law

Plaintiff, the surviving spouse of an Acxiom employee, filed suit for accidental death benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. On appeal, Unicare appealed the district court's grant of summary judgment in favor of plaintiff. The court held that the district court correctly applied an abuse-of-discretion standard of review; the district court correctly found that UniCare erred in denying coverage for accidental death benefits where all of the evidence indicated that the spouse's death was the unexpected result of ingested prescribed medications; the district court correctly found that UniCare had not proven that the exclusion should be used to deny coverage; and the fee award was reasonable. Accordingly, the court affirmed the judgment of the district court. View "Nichols v. Acxiom Corp." on Justia Law

Maverick petitioned for review of the ARB's affirmance of an ALJ's finding that Maverick was liable for taking retaliatory action against an employee in violation of the Surface Transportation Assistance Act (STAA), 49 U.S.C. 31105. The court applied Chevron deference in regards to the agency's interpretation that the limitations period in the STAA began to run when the employee received notice of the employer's adverse action; the court also agreed with the ARB that the ALJ's finding that the employee received such notice within 180 days of filing his claim was supported by substantial evidence; and, therefore, the ARB's determination that the employee timely filed his claim was not contrary to law. The court also concluded that all of the facts found by the ALJ, including those pertaining to the retaliation claim, were supported by substantial evidence. Finally, the ALJ's decision not to reduce the back pay award on the basis that the employee failed to mitigate damages by voluntarily leaving his position was not contrary to law and the court found no abuse of discretion in the ALJ's award of compensatory damages for the employee's emotional distress. Accordingly, the court denied the petition for review. View "Maverick Transp., LLC v. U.S. Dept. of Labor" on Justia Law

Plaintiff filed suit against Safeco seeking to stack the underinsured motorist coverage from various policies she and her husband had taken out with Safeco for their five vehicles. On appeal, plaintiff appealed the district court's grant of summary judgment for Safeco. The court rejected Safeco's argument that the Missouri Supreme Court in Ritchie v. Allied Property & Casualty Insurance Co. limited its holding to situations where the insured was occupying a non-owned vehicle at the time the injury was suffered and was not applicable to plaintiff because she was a pedestrian at the time of the accident. The court concluded that whether the policy in Ritchie required occupancy of a non-owned vehicle was not specifically decided by the Missouri Supreme Court. From the Missouri Supreme Court's holding in Ritchie, the court believed it would reject the Missouri Court of Appeals decision in Kennedy v. Safeco Insurance Co. of Illinois. Accordingly, the court reversed and remanded with instructions to grant plaintiff's motion for partial summary judgment and to conduct further proceedings. View "Jordan, et al. v. Safeco Ins. Co. of IL" on Justia Law

Plaintiff appealed the district court's adverse grant of summary judgment respecting the timeliness of his lawsuit against Nationwide seeking coverage under plaintiff's employer's underinsured motorist (UIM) policy with Nationwide. In Minnesota, the plain language of an unambiguous insurance policy controls its legal effect, whereas an ambiguous policy term is construed strictly against the insurer. In this instance, the policy plainly required plaintiff to have filed his action in a court of competent jurisdiction within two years of the underlying accident, a condition which was not satisfied here. Accordingly, the court affirmed the judgment of the district court. View "Larson v. Nationwide Agribusiness Ins." on Justia Law

After BIVI discharged an employee for falsifying work records, the Union grieved the discharge. BIVI and the Union submitted the dispute to arbitration, the arbitrator ordered that the employee be reinstated without back pay, and BIVI commenced this action to vacate the arbitration award. The district court granted summary judgment to the Union and BIVI appealed. The court concluded that the arbitrator's award drew its essence from the collective bargaining agreement (CBA) where BIVI's Article VIII, Section 3(d) argument was waived and where the arbitrator conducted a straightforward balancing of the management rights and just cause provisions. The court also concluded that BIVI has not made the factual and legal showing that would be required for the court to invoke the narrow public policy exemption and vacate an arbitration award that fully acknowledged the employee's misconduct, denied her back pay as a result of that misconduct, but reinstated her to her former position. Accordingly, the court affirmed the judgment of the district court. View "Boehringer Ingelheim Vetmedica v. UFCW" on Justia Law

Debtor appealed the bankruptcy court's order, affirmed by the bankruptcy appellate panel, granting summary judgment in favor of the trustee regarding debtor's homestead exemption. The court affirmed, concluding that debtor never asserted an intention to move back into the property at issue nor had he refuted his statement at the 11 U.S.C. 341 meeting that he did not expect to live at the property at any point in the future. Further, denying the homestead exemption did not violate Article XXI, section 4 of the South Dakota Constitution where debtor removed himself from the property with no fixed or actual intent to return. View "Paul, Jr. v. Allred" on Justia Law