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

This case concerned the 2011 NFL lockout. Active NFL players filed a class action suit (Brady suit) against the NFL, alleging violations of the federal antitrust laws and other claims. Retired NFL players also filed suit against the NFL and its teams, alleging antitrust violations (Eller I suit). After both actions were consolidated, the Brady suit was settled, the players re-designated the NFLPA as their collective bargaining agent, the NFL and NFLPA signed a new collective bargaining agreement (CBA) incorporating the settlement terms, the Brady plaintiffs dismissed their action, the lockout ended, and the 2011 NFL season commenced. Carl Eller and other retired NFL players (plaintiffs) then filed this class action (Eller II) against the NFLPA and others. The district court granted defendants' motion to dismiss and plaintiffs appealed, alleging claims for intentional interference with prospective economic advantage under Minnesota law. The court concluded that no reasonable jury could find that plaintiffs had a reasonable expectation of a prospective separate contractual relation with the NFL that would provide more than the increased benefits provided in the 2011 CBA. Even if plaintiffs alleged a reasonable expectation of prospective contractual relations or economic advantage with the NFL, plaintiffs failed to allege facts proving that defendants improperly or wrongfully interfered with these advantageous prospects. Accordingly, the court affirmed the judgment of the district court. View "Eller, et al. v. NFL Players Assoc., et al." on Justia Law

Plaintiff filed suit against the County and others after her son Johnny died from multiple drug intoxication while in the county jail. At issue on appeal was the district court's denial of qualified immunity on summary judgment for the law enforcement officials. The court concluded that Officer Furr did not have subjective knowledge that Johnny required medical attention and that Officer Furr was not deliberately indifferent to Johnny's medical needs. Accordingly, Officer Furr was entitled to qualified immunity. In regards to Officer King, the court concluded that a reasonable officer would have known that a constitutional violation occurred by deliberately disregarding Johnny's serious medical needs in the circumstances Officer King confronted. Accordingly, the district court properly denied Officer King qualified immunity because this constitutional right was clearly established. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Thompson v. King, et al." on Justia Law

Debtor appealed from the order of the bankruptcy court finding his debt to Bank of America nondischargeable under 11 U.S.C. 523(a)(2) for fraud and section 523(a)(4) for embezzlement. Under section 523(a)(4), Southwest Bank established that debtor was not lawfully entitled to use the insurance proceeds at issue for the purposes for which he used them and debtor produced nothing to the contrary. Accordingly, the bankruptcy appellate panel (BAP) affirmed the bankruptcy court's finding under section 523(a)(4). Because the BAP concluded that the bankruptcy court did not err in finding the debt to be nondischargeable under 523(a)(4) for embezzlement, the court limited its analysis to that basis for nondischargeability and did not reach the section 523(a)(2) fraud issue. View "Bank of America, N.A. v. Armstrong" on Justia Law

Plaintiff, a surgical technologist, filed suit against the hospital alleging racial discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981. The court concluded that the district court did not clearly err in concluding that plaintiff failed to prove the hospital terminated her in retaliation for complaining of racial discrimination; in finding that plaintiff failed to prove that race was the motivating factor behind her termination, rather the district court believed that plaintiff was terminated for being insubordinate; and in finding that plaintiff was not subject to disparate terms and conditions of her employment based on race. Accordingly, the court affirmed the judgment of the district court. View "Wright v. St. Vincent Health System" on Justia Law

The Government appealed the bankruptcy court's order denying its motion to approve its superpriority administrative expense claim under section 507(b) of Title 11 of the Bankruptcy Code; its motion for evidentiary hearing; and its motion to alter or amend the bankruptcy court's denial of its motion for a section 507(b) administrative expense claim. The bankruptcy appellate panel concluded that the bankruptcy court abused its discretion when it denied the Government the opportunity to conduct discovery and produce evidence. Accordingly, the court reversed and remanded for the bankruptcy court to determine the amount, if any, of the Government's section 507(b) claim. View "United States v. Lange, et al." on Justia Law

Defendant appealed his conviction for using and maintaining a premises for the purpose of distributing and using a controlled substance. The court concluded that the evidence was sufficient to convict defendant and the district court did not err in denying defendant's motion for judgment of acquittal, nor did it abuse its discretion in denying his motion for a new trial. View "United States v. Rhodes" on Justia Law

Plaintiff, a self-described "professing Evangelical Christian," distributed Bibles at the Twin Cities Pride Festival for many years in an exhibitor's booth but in 2009, Twin Cities Pride denied plaintiff's application for a booth. On appeal, plaintiff challenged the district court's denial of his motion for a preliminary injunction against enforcement of a local regulation that restricted literature distribution in a public park during the Festival. The court concluded that plaintiff has shown a likelihood of success on his claim that the literature distribution regulation was not narrowly tailored to serve a significant governmental interest; plaintiff satisfied the irreparable harm requirement; the balance of the equities favored granting the injunction; and the injunction was in the public interest. Accordingly, the court reversed the district court's denial of plaintiff's motion for a preliminary injunction and remanded for further proceedings. View "Johnson v. Minneapolis Park and Rec. Bd." on Justia Law

Defendant was indicted for possession with intent to distribute five grams or more of methamphetamine. On appeal, the government challenged the district court's grant of defendant's motion to suppress evidence seized from his person and vehicle. The court concluded that police officers had reasonable suspicion to believe that defendant was engaged in criminal activity and a reasonable belief that defendant was dangerous; defendant's furtive gestures under his seat as the officers approached the vehicle gave them reason to believe that there was a weapon in the vehicle that defendant might access when the Terry stop ended and he was permitted to return to the vehicle; this objectively reasonable concern for officer safety justified the officer's immediate protective sweep under the driver's seat of the vehicle; because reasonable suspicion was established, the officer's search of the vehicle's interior was permitted even though the occupants had been removed from the vehicle; the officer was also authorized to search the lockbox he found in the vehicle, which was large enough to conceal a weapon; the limits of the Terry stop were not exceeded when defendant was removed from the vehicle and handcuffed; and consequently, because there was no unlawful arrest, the district court's rationale did not justify suppression of the evidence and statements. Accordingly, the court reversed and remanded. View "United States v. Morgan" on Justia Law

Mortgagors appealed the district court's grant of judgment on the pleadings to their lenders in a dispute regarding a home loan. At issue on appeal was whether mailing a notice of rescission within three years of consummating a loan was sufficient to "exercise" the right to rescind a loan transaction under 15 U.S.C. 1635(a) or, alternatively, whether a party seeking to rescind the transaction was required to file a lawsuit within the three-year statutory period. The court held that a party seeking to rescind a loan transaction must file suit within three years of consummating the loan. Accordingly, the court affirmed the district court's judgment on the pleadings in favor of the lenders. View "Jesinoski, et al. v. Countrywide Home Loans, Inc., et al." on Justia Law

Plaintiff and his wife appealed the denial of his application for Medicaid benefits, arguing that the Department wrongfully denied the application because it had improperly counted against the wife's eligibility an annuity owned by the wife. The district court ruled in favor of plaintiffs and the Department appealed. The court concluded that, because the wife had no right, authority, or power to liquidate the annuity, the annuity benefits were not a resource, but rather was income indicated by the federal statute defining "unearned income." Therefore, the Department applied a more restrictive methodology under state law by classifying the annuity benefits as a resource that counted against plaintiff's eligibility for Medicaid benefits. The court rejected the Department's counter-arguments and the remaining arguments, and affirmed the judgment of the district court. View "Geston, et al. v. Anderson" on Justia Law