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

Plaintiff filed suit alleging sex and race discrimination, retaliation, and sex and race harassment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and retaliation in violation of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court concluded that the district court properly granted summary judgment for the state on plaintiff's race and sex discrimination and retaliation claims where plaintiff did not establish a prima facie case because she could not show, as a matter of law, that she suffered an adverse employment action. The court also concluded that summary judgment was appropriately granted on the harassment claim where the conduct described did not affect a term, condition, or privilege of employment because this conduct was not severe or pervasive enough to constitute actionable discrimination. Accordingly, the court affirmed the district court's judgment. View "Jackman v. Fifth Judicial District, et al." on Justia Law

Plaintiff filed suit against his employer (Nichols) for breach of the Collective Bargaining Agreement (CBA) and against his union for breach of its duty of fair representation. Plaintiff alleged that Nichols breached the CBA by failing to establish rest periods for workers on the continuously operating lines as required by Section 17.1 of the CBA. In this case, the union had a duty not to pursue a grievance to arbitration that it believed did not warrant such action. The court concluded that plaintiff had not raised a genuine issue of material fact on whether the union failed in its duty of fair representation on the issue before the court. Accordingly, the court affirmed the district court's grant of summary judgment for the union and the employer. View "Inechien v. Nichols Aluminum, LLC, et al." on Justia Law

Defendant was convicted of conspiracy to distribute methamphetamine and distribution of methamphetamine. Defendant appealed her conviction and sentence. The court concluded that the evidence was sufficient to convict defendant. The court also concluded that the district court did not clearly err in denying defendant safety valve relief where the district court appropriately viewed the trial testimony, the evidence, and arguments presented at sentencing concerning defendant's and her families' participation in drug trafficking, in light of defendant's denial of involvement. Accordingly, the court affirmed the judgment of the district court. View "United States v. Hinojosa" on Justia Law

Defendant appealed his conviction of four counts of making false claims against the United States. The court concluded that the district court did not err by not conducting a third Faretta inquiry where defendant had the benefit of two prior hearings and the district court was satisfied that his election to proceed pro se was knowing and voluntary under all the circumstances, and the court rejected defendant's claims of error. The court also concluded that there was sufficient evidence to convict defendant. Accordingly, the court affirmed the judgment of the district court. View "United States v. Miller" on Justia Law

Defendant was convicted of wire fraud, money laundering, and making false statements to the United States Probation Office. On appeal, defendant argued that the district court erred at trial in admitting certain evidence and that he was denied his right to "conflict-free" counsel and a fair trial. The court concluded, inter alia, that defendant's plea-statement waiver was knowing and voluntary and thus the district court did not err in allowing the government to successfully offer the plea agreement factual stipulation as evidence against defendant; the court affirmed the district court's admission of the factual stipulation under Federal Rule of Evidence 403; the court affirmed the denial of defendant's motion to sever because the district court did not abuse its discretion in its determination that defendant's prior conviction for wire fraud and money laundering would be admissible on all charges and would not be unduly prejudicial; the court dismissed plaintiff's Sixth Amendment challenge without prejudice because the record was not fully developed enough to hold that a plain miscarriage of justice occurred; and the court affirmed the district court's decision to continue with trial despite defendant's brief absence. View "United States v. Washburn" on Justia Law

Defendant appealed his conviction for being a felon in possession of a firearm. The court concluded that even if the district court abused its discretion in restricting the cross-examination of a witness, any error was harmless beyond a reasonable doubt because additional evidence would have been cumulative; the district court did not err in refusing to admit any evidence regarding the magistrate judge's finding that the witness lacked credibility where the evidence was hearsay, irrelevant, and cumulative; and the district court did not clearly abuse its discretion in denying a new trial where the record did not clearly demonstrate a compromise verdict. Accordingly, the court affirmed the judgment of the district court. View "United States v. Jones" on Justia Law

Defendant appealed his sentence stemming from his conviction for conspiring to manufacture and distribute at least 50 grams of actual methamphetamine and 500 grams of meth mixture or substance. The court concluded that the district court did not err in applying a sentencing enhancement under U.S.S.G. 2D1.1(b)(13)(C)(ii) for creating a substantial risk of harm to human life or the environment because of the meth farm's rural location; the district court did not clearly err in attributing to defendant his girlfriend's pseudoephedrine purchases where, in light of their extensive joint meth use and pseudoephedrine distribution, it was reasonably foreseeable to defendant that his girlfriend would purchase pseudoephedrine from pharmacies; and the district court did not err in using information in the proffer agreement to determine his guideline range. Accordingly, the court affirmed the judgment of the district court. View "United States v. Loesel" on Justia Law

Plaintiff, aged 76, filed suit under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq, and state law, contending that Securitas fired him because of his age. Plaintiff cited evidence that prior to his termination, Securitas supervisors showed age animus through negative comments regarding plaintiff's age. Plaintiff adduced enough evidence to raise genuine doubt as to the legitimacy of Securitas's motive, even if that evidence did not directly contradict or disprove Securitas's articulated reasons for its actions. Accordingly, the court reversed the district court's grant of summary judgment in favor of Securitas, concluding that there were genuine issues of material fact concerning pretext. View "Johnson v. Securitas Security Services" on Justia Law

Plaintiff appealed the denial of his application for Social Security disability benefits and supplemental security income. The court concluded that the ALJ erred in determining plaintiff's residual functional capacity as "frequent to occasional" handling and fingering, because "frequent" and "occasional" were separate terms of art with distinct meanings. Accordingly, the court reversed and remanded to the district court with directions to remand the case to the Commissioner for clarification of plaintiff's residual functioning capacity and for further proceedings. View "Owens v. Astrue" on Justia Law

WFC challenged the district court's holding that WFC was not entitled to a tax refund for a capital loss it claimed as a result of a complex transaction involving the transfer of leases and the sale of stock. WFC argued that the district court erred in finding that the lease restructuring transaction (LRT)/stock transfer constituted a sham transaction. The court concluded that the district court did not err in finding that the LRT/stock transaction lacked objective economic substance; in finding that WFC failed to meet its burden of proving by a preponderance of the evidence that avoiding the Office of the Comptroller of the Currency (OCC) regulations was its business purpose for the LRT/stock transfer; and in finding that WFC failed to prove by a preponderance of the evidence that the LRT/stock transfer was motivated by a purpose to strengthen its hand with good bank customers or to create management efficiencies. Accordingly, the court affirmed the judgment of the district court. View "WFC Holdings Corp. v. United States" on Justia Law