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

Plaintiffs filed suit against the District alleging violations of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 706 and 794a. Plaintiffs' claims involved disputes with the District over the manner in which the District implemented individualized education programs. The court concluded that plaintiffs were required to exhaust their administrative remedies under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400-1491, before filing their ADA and Rehabilitation Act claims in the district court. Further, the futility, inadequate remedy, and contrary to law exceptions were not applicable in this case. Accordingly, the court affirmed the district court's grant summary judgment in favor of the District. View "J.B., et al. v. Avilla R-XIII School District" on Justia Law

Plaintiff challenged the district court's denial of his motion for judgment as a matter of law, or in the alternative, for a new trial. Plaintiff sued defendant for the injuries he sustained during a traffic accident. After a mistrial, the jury returned a verdict for defendant. The court concluded that the district court did not abuse its discretion in denying a new trial where a violation of an in limine order was not prejudicial; there was sufficient evidence to support the jury's verdict; Federal Rule of Evidence 606(b) precluded jurors from testifying in regards to jury deliberations for the purpose of challenging a verdict; and the district court did not abuse its discretion by not allowing plaintiff's reconstruction expert to testify as to whether either of the drivers' conduct violated South Dakota law. Accordingly, the court affirmed the judgment of the district court. View "Warger v. Shauers" on Justia Law

In an insurance coverage dispute with a policyholder, Cincinnati appealed the district court's adverse summary judgment rulings. The policyholder sought a claim of total loss for a vertical lathe that it purchased from a manufacturer in Taiwan and that was destroyed in Los Angeles. Cincinnati denied coverage, claiming that the coverage extension for newly acquired property did not apply. The court concluded that the extension of coverage to "any location you acquire" was ambiguous and, under Iowa law, the court construed that ambiguity in the policyholder's favor. The court also concluded that the district court did not err in awarding prejudgment interest under Iowa law. Accordingly, the court affirmed the judgment of the district court. View "Amera-Seiki Corp. v. The Cincinnati Ins. Co." on Justia Law

Defendant appealed his conviction of 65 counts of mail fraud for collecting proceeds from the milling of pine saw logs that he diverted from their intended mill. The court affirmed the judgment, concluding that the evidence was sufficient to support his conviction; defendant failed to show that the district court erred in allowing an Assistant United States Attorney to introduce defendant's proffered statements under Federal Rule of Evidence 410(a)(4); and the district court did not err in denying defendant a setoff against the restitution amount. View "United States v. Clemons" on Justia Law

A jury found defendant guilty of the crime of using a firearm during and in relation to a drug trafficking crime. The district court sentenced defendant to 300 months' imprisonment, to be served consecutively to a sentence already imposed in a previous case. Defendant raised numerous challenges regarding the procedural and substantive reasonableness of his sentence. While this case was pending before the court on appeal, the Supreme Court issued Alleyne v. United States which overruled Harris v. United States, noting that it could not be reconciled with Apprendi v. New Jersey. Given the new Alleyne precedent, the court concluded that it was clear that there was an error in the proceedings and the error was plain. Accordingly, the court remanded for resentencing consistent with the jury's verdict. View "United States v. Lara-Ruiz" on Justia Law

Petitioner, a native and citizen of Guinea, petitioned for review of the BIA's denial of his claim for asylum based on the untimeliness of his application. The court concluded that the BIA did not commit legal error because it did not require petitioner to show both "changed circumstances" and "extraordinary circumstances" to excuse his untimeliness. Instead, the BIA independently analyzed both exceptions and agreed with the IJ that petitioner met neither of them. Further, the issue of whether a "material" change in circumstances affected petitioner's eligibility for asylum was not a reviewable question of law. Accordingly, the court dismissed the petition because it lacked jurisdiction to review the BIA's determination that the application for asylum was untimely. View "Goromou v. Holder, Jr." on Justia Law

Plaintiff filed suit against the OHA after she was terminated. At issue on appeal was whether plaintiff's appeal must be dismissed for failure to order the necessary portions of a trial transcript. Plaintiff ordered the portion of the trial transcript that contained her testimony and the remaining portions of the transcript were not transcribed and were not available. The court could not properly review the issues in the case based on the record plaintiff provided and, therefore, the court did not address the merits of plaintiff's First Amendment retaliation claim. Accordingly, the court granted the OHA's motion to dismiss plaintiff's appeal based on Federal Rule of Appellate Procedure 10(b). View "Kelly v. Omaha Housing Authority, et al." on Justia Law

Defendants appealed their convictions for conspiring to distribute five kilograms or more of cocaine. Defendants Dunn, Westbrook, and Moore also appealed their convictions for using a communication facility to facilitate cocaine distribution. Defendants raised numerous issues on appeal. The court concluded that the evidence was sufficient to support the cocaine conspiracy convictions; the district court did not abuse its discretion in denying the motions in limine to exclude late-disclosed witnesses where defendants made no showing of prejudice; the district court did not abuse its discretion in denying a mistrial where a witness's testimony incriminating Defendant Dunn was not disclosed in the proffer statement produced to defense counsel because any prejudice to defendants or benefit to the government was small; the district court did not plainly err when it authorized the extension of the wiretap; Dunn had actual notice of the recorded calls within 90 days of the wiretap's termination and failed to show prejudice; and the district court did not err in denying Dunn's motion to suppress or his motion in limine regarding a special agent's failure to properly identify Dunn as the speaker on the recorded calls. The court disposed of defendants' remaining arguments and affirmed the judgment of the district court. View "United States v. Dunn" on Justia Law

Plaintiff sued her former employer alleging violations of her rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The employer believed that plaintiff suffered from a serious health condition and placed her on involuntary FMLA leave. After plaintiff submitted certifications of her fitness to return to work, the employer informed her that she had exhausted her FMLA leave and terminated her employment. The court affirmed the district court's grant of the employer's motion to dismiss where the statute entitled plaintiff to a certain amount of leave and her employer did not interfere with that entitlement. Further, the court concluded that plaintiff had no right to FMLA benefits where she admitted that she never suffered a serious health condition within the meaning of the Act. The court rejected defendant's claim of equitable estoppel where she did not establish a submissible case of detrimental reliance; and the employer's mistaken belief that plaintiff suffered a serious health condition could not entitle her to FMLA benefits. View "Walker v. Trinity Marine Products, et al." on Justia Law

Plaintiffs filed suit against their former employer alleging retaliatory termination after plaintiffs filed grievances against their supervisor. A jury found that the employer did retaliate against plaintiffs and awarded backpay and damages for emotional distress to each plaintiff. Both parties appealed. The court concluded that the evidence of discriminatory animus was sufficient to submit plaintiffs' retaliation claims to the jury; the employer's proffered non-discriminatory explanation for the terminations failed to address the discriminatory motivation; and the employer's argument that the discriminatory motivation was cured was unavailing. Accordingly, the district court properly denied the employer's motion for judgment as a matter of law on the retaliation claims. The court agreed with the district court's decision to instruct the jury that it could award damages for emotional distress; the district court did not clearly abuse its discretion in denying the employer's motion for new trial or remittitur; and the court affirmed the district court's decision to refuse an instruction on punitive damages. Accordingly, the court affirmed the judgment. View "Bennett, et al. v. Riceland Foods, Inc." on Justia Law