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

Defendant appealed the district court's order denying her objection to the garnishment of her disability payments. The court concluded that defendant's disability payments were "earnings" within the meaning of the Consumer Credit Protection Act, 15 U.S.C. 1673(a), and were subject to the Act's limitations on garnishment. Accordingly, the court reversed the district court's judgment holding otherwise. View "United States v. Ashcraft" on Justia Law

Petitioner, found guilty of second-degree felony murder and four counts of assaulting injured bystanders, appealed the district court's denial of his petition for a federal writ of habeas corpus. At issue was whether petitioner's Fifth and Sixth Amendment rights were violated when the trial court instructed the jury on the uncharged assault offenses. The court concluded that petitioner's right-to-remain-silent claim was procedurally barred because it was not presented to the state courts. The court also concluded that, given the unusual procedural facts of this case - petitioner had notice of and prepared to defend the assault charges in the trial court and then urged the state appellate courts to apply harmless error review to the resulting error - the court could not conclude that the Minnesota Court of Appeals decision applying harmless error review under state law was contrary to clearly established U.S. Supreme Court precedent. Accordingly, the court affirmed the judgment of the district court. View "Anderson v. King" on Justia Law

Defendant appealed her conviction for possession of methamphetamine with intent to distribute. The court concluded that the record showed that the trooper had probable cause necessary to make the traffic stop for improperly driving in the left lane, a reason the trooper articulated to defendant at the time of the stop; the court assumed, without deciding, that defendant had standing to challenge the search of the vehicle; because the troopers no longer needed defendant's consent to search once they discovered a hidden compartment, any effort to withdraw or limit her consent at that point would have been fruitless; the court affirmed the district court's finding that after the troopers discovered the hidden compartment, they had probable cause to continue the search; because defendant was read her Miranda rights, any statements she made at the garage or later at the Nebraska State Patrol Office were admissible; and, therefore, the court affirmed the judgment of the district court denying defendant's motion to suppress. View "United States v. Guevara" on Justia Law

Southern Wine filed suit challenging the Divisions' denial of its application for a license to sell liquor wholesale in Missouri. The Division denied the application because Southern Wine did not satisfy a residency requirement under Missouri law. The court concluded that Southern Wine had not shown that the residency requirement was unconstitutional on the ground that it was motivated by mere economic protectionism; the Division has established a sufficient basis for its residency requirement, which was meaningfully tied to the aim of the Twenty-first Amendment to allow States to maintain an effective and uniform system for controlling liquor by regulating its transportation, importation, and use; and the requirement had a rational basis and did not deprive Southern Wine of equal protection of the laws under the Fourteenth Amendment. Accordingly, the court affirmed the judgment of the district court upholding the statute. View "Southern Wine & Spirits, et al. v. Division of Alcohol & Tobacco, et al." on Justia Law

After 15-year-old B.K. was barred from showing livestock at 4-H exhibitions, B.K.'s father filed suit under 42 U.S.C. 1983 against the unincorporated 4-H Association and two 4-H officials. The district court granted preliminary injunctive relief from the claimed denial of B.K.'s constitutional right to procedural due process. The court inferred that 4-H membership and participation was a "right or status" open to all South Dakota children interested in a career in agriculture, subject to reasonable, non-discriminatory terms; the record clearly demonstrated that the ban deprived B.K. of the opportunity to participate in a public program that was important to her education and career development and from which she obtained significant personal income; and, therefore, the district court did not abuse its discretion in concluding that B.K. had a fair chance of proving that defendants published a defamatory ruling that deprived her of a right or status conferred by state law and that she was entitled to the constitutional protection of the Due Process Clause. Further, B.K. was not afforded minimal procedural due process protection; there was a sufficient showing of the threat of irreparable injury; and the balance of the equities and the public interest supported the issuance of the injunction. Accordingly, the court affirmed the judgment of the district court. View "Kroupa v. Nielsen, et al." on Justia Law

Plaintiffs filed suit against their former employer and others under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. After the district court adopted the magistrate judge's recommended dispositions, plaintiffs appealed. The court concluded that plaintiffs have failed to set forth sufficient evidence to show that they were due more in benefits and penalties than the amount that the district court determined that they were owed; the district court did not abuse its discretion in denying their requests for nonmonetary relief or in determining the reasonable attorney's fees and costs; and, therefore, the court affirmed the judgment of the district court. View "McDowell, et al. v. Price, et al." on Justia Law

After plaintiff served 24 years in prison for murder, a Missouri court found that plaintiff's trial had been fundamentally unfair and ordered his release. Plaintiff then filed suit against the St. Louis Board of Police Commissioners and others, alleging, inter alia, that defendants recklessly or intentionally manipulated evidence and conducted suggestive identification procedures. The court concluded that the district court did not err in granting summary judgment on plaintiff's claims that defendants manipulated the investigation or evidence against him or deprived him of a fair trial; plaintiff had not adduced evidence to show that the identification procedure in this case was impermissibly suggestive and the circumstances of the photo identification procedure did not create a very substantial likelihood of irreparable misidentification; the court found no evidence to support a reasonable inference that any of the defendants conspired to frame plaintiff or otherwise deprive him of his constitutional rights; and plaintiff's Monell claims against the Board failed where none of the individual defendants were liable on plaintiff's 42 U.S.C. 1983 claims. Accordingly, the court affirmed the judgment of the district court. View "Burton v. St. Louis Board of Police, et al." on Justia Law

The State, in consolidated petitions for review, challenged the EPA's final rule approving in part and disapproving in part two state implementation plans (SIPs) submitted by the State to address its obligations under sections 110 and 169A of the Clean Air Act (CAA), 42 U.S.C. 7401-7671q. The final rule also promulgated a federal implementation plan (FIP) to address those portions of the SIPs that were disapproved. The court concluded that, even assuming that the State's interpretation of section 7607(d)(3) was correct, the State has failed to demonstrate that the EPA's error in this regard was so serious and related to matters of such central relevance to the rule that there was a substantial likelihood that the rule would have been significantly changed if the error had not been made; the EPA's refusal to consider the existing pollution control technology in use at the Coal Creek Station because it had been voluntarily installed was arbitrary and capricious and its FIP promulgating selective non-catalytic reduction (SNCR) as the best available retrofit technology (BART) for the Coal Creek Station was therefore vacated; the State's petition for review of the EPA's disapproval of the State's SIP and promulgating of a FIP was denied because the EPA properly disapproved the State's reasonable progress determination; the Environmental Groups' motion to dismiss their petition for review was moot; and the State's petition for review of the EPA's disapproval of the interstate transport SIP was denied because the EPA properly disapproved portions of the State's regional haze SIP. Accordingly, the court granted the State's and Great River Energy's petitions for review to the extent that they challenged the EPA's BART determination for the Coal Creek Station promulgated in EPA's FIP; vacated and remanded that portion of the final rule to the EPA for further proceedings; and denied the remainder of the State's, Great River Energy's, and the Environmental Groups' petitions for review, as well as the Environmental Groups' motion for voluntary dismissal under Federal Rule of Appellate Procedure 42(b). View "State of North Dakota v. EPA" on Justia Law

The government appealed the district court's grant of defendant's motion for a new trial after he was found guilty of one count of conspiracy to launder money. The district court found that it committed two specific plain errors: (1) it determined that the verdict form for defendant was plainly erroneous because it was obvious that the form should have contained a place for the jury to indicate its verdict but that place was missing on the form, and (2) it substituted polling of the jury for the rendering of a verdict on a properly composed verdict form after private deliberations. The court concluded that the district court did not abuse its discretion in determining that the verdict form error and the substitution of a polling procedure for a return of the verdict constituted plain error. Accordingly, the court affirmed the judgment. View "United States v. Amaya" on Justia Law

Debtor filed a voluntary petition for relief under Chapter 7 of the Bankruptcy Code. On appeal, debtor challenged the bankruptcy court's order sustaining the Bank's objection to her claimed exemption in her 2000 Hyundai Tiburon, and ruling that debtor could avoid the Bank's lien under section 522(f) of Title 11 of the Bankruptcy Code. The bankruptcy appellate panel (BAP) agreed with the bankruptcy court that debtor could not claim an exemption under IOWA Code 627.6 where debtor had no equity and had no interest in the vehicle to exempt, and that the Bankruptcy Code provided for no such avoidance. Accordingly, the BAP affirmed the judgment of the bankruptcy court. View "Goben v. Corydon State Bank" on Justia Law