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

Plaintiff filed suit under 42 U.S.C. 1983, alleging, inter alia, excessive use of force by officers and a failure to train or supervise by the county jail administrator. The court concluded that it has appellate jurisdiction under 28 U.S.C. 1291 and the collateral-order doctrine to review the district court's denial of qualified immunity; the court declined to review the district court's order denying summary judgment to the county and to the individual defendants in their official capacities; the court concluded that the first use of the taser was reasonable where plaintiff purposefully kicked the officer and was aggressive; as to the second taser strike, a jury could find that plaintiff was nonviolent and an objectively reasonable officer would not use a taser on him as corporal inducement; plaintiff's constitutional right to be free from being tased for non-compliance was clearly established at the time; therefore, the officers were not entitled to qualified immunity where the officers violated plaintiff's constitutional right to be free from excessive force; and the county jail administrator was not entitled to qualified immunity on the failure to train or supervise claim. Accordingly, the court affirmed the judgment of the district court. View "Smith v. Conway County, Arkansas, et al." on Justia Law

Respondent, in his official capacity as superintendent of the Potosi Correctional Center, moved to vacate the district court's order staying the execution of petitioner. The court concluded that the district court abused its discretion in granting an indefinite stay of execution where petitioner has not shown a substantial likelihood of success on the merits of his federal habeas petition. The Missouri courts are the proper forum in the first instance for petitioner's claim of incompetency, under Ford v. Wainwright, to be executed. Accordingly, the court vacated the stay of execution. View "Middleton v. Roper" on Justia Law

Respondent, in his official capacity as superintendent of the Potosi Correctional Center, moved to vacate the district court's order staying the execution of petitioner. Petitioner filed a "second-in-time federal habeas corpus petition and supplemental petition to first habeas corpus application," alleging that the state does not provide adequate procedures by which he could raise a claim that he is mentally incompetent to be executed under the Eighth Amendment as interpreted in Ford v. Wainwright. The court concluded that the district court abused its discretion by staying petitioner's execution for the purpose of holding a hearing on a Ford claim that was never presented to the Missouri state courts. Accordingly, the court vacated the stay of execution. View "Middleton v. Roper" on Justia Law

Plaintiff filed suit against Midland, contending that the plain language of an annuity contract dictates that the term is zero or that, at minimum, Midland's proffered term is unreasonable. Completely absent from the annuity contract was any indication about the interest rate to be applied in the event that Midland was no longer offering new certificates of the annuity. The court concluded that the district court did not err in this case where Restatement (Second) of Contracts section 204 permitted the district court to supply a term for the missing value that is reasonable under the circumstances of this case. Accordingly, the court affirmed the district court's grant of summary judgment to Midland. View "Murr v. Midland National Life Ins. Co." on Justia Law

Defendant appealed her conviction for knowingly trafficking in contraband cigarettes in violation of 18 U.S.C. 2342(a). The court concluded that the government failed to prove a knowing violation of section 2342(a); there was sufficient evidence that defendant knowingly received the packages but not that she knowingly received "contraband cigarettes" hidden inside the packages; and the Double Jeopardy Clause required entry of judgment of acquittal. Accordingly, the court reversed the judgment of the district court. View "United States v. Nguyen" on Justia Law

Defendant appealed his conviction and sentence for possession of cocaine base with intent to distribute. The court concluded that the evidence was sufficient to convict defendant; the district court adequately considered the 18 U.S.C. 3553(a) factors and did not commit procedural error; and the sentence was substantively reasonable. Accordingly, the court affirmed the conviction and sentence. View "United States v. Jenkins" on Justia Law

Plaintiff filed suit against defendant, alleging claims related to her candidacy as a legal writing instructor at the Iowa College of Law. On appeal, plaintiff challenged the district court's denial of her motion for a new trial. The court held that where a court declares a mistrial and discharges the jury which then disperses from the confines of the courtroom, the jury can no longer render, reconsider, amend, or clarify a verdict on the mistrial counts. In this case, the court concluded that the magistrate judge erred in recalling the jury to question and re-poll them as to the mistried, or not, counts. Accordingly, the court reversed and remanded. View "Wagner v. Jones, et al." on Justia Law

Plaintiffs filed suit against police officers under 42 U.S.C. 1983, alleging false arrest and retaliation. The court concluded that plaintiffs failed to preserve the issue of whether the district court erred when it vacated the partial grant of summary judgment on the issue of liability in the false arrest claim; whether plaintiff made a Rule 50(a) motion is moot because they failed to preserve the issue by making a post-judgment Rule 50(b) motion; and the district court did not abuse its consideration discretion in denying plaintiffs' motion for a new trial. Accordingly, the court affirmed the judgment of the district court. View "Hoffmeyer, et al. v. Porter, et al." on Justia Law

MHFS filed suit against the County, the Commission, and others for interfering with its business operations at the Baxter County Airport. The court concluded that the district court did not err in dismissing MHFS's claims for breach of contract where MHFS did not allege any breach of contract distinct from the breach of the duty to act in good faith; Arkansas law does not recognize a "continuing tort" theory; even if the court were to assume such acts were intentional, MHFS failed to state a claim for intentional interference with its business relationship; the district court correctly dismissed MHFS's civil rights claims for denial of procedural due process where MHFS was not deprived of any property or liberty interest; the district court did not abuse its discretion by declining to exercise supplemental jurisdiction over state law claims; and the district court did not abuse its discretion in denying the motion to amend following its dismissal of the action. Accordingly, the court affirmed the judgment of the district court. View "Mountain Home Flight Service v. Baxter County, et al." on Justia Law

After the company it hired to compile research on the greeting cards market, Monitor, transmitted confidential market research it had prepared for Hallmark to a private equity firm, Clipper, Hallmark filed suit against Monitor and Clipper. Hallmark settled with Monitor and a jury awarded Hallmark compensatory and punitive damages in the case against Clipper. The court concluded that the jury had sufficient evidence to find that Hallmark's PowerPoint presentations constituted trade secrets under the Missouri Uniform Trade Secrets Act, Mo. Rev. Stat. 417.450 et seq; the jury verdict did not give Hallmark a double recovery where Hallmark's settlement with Monitor and its jury verdict against Clipper compensated Hallmark for independent injuries and no reduction of the jury award was necessary; and the punitive damages against Clipper were permissible under Missouri law where defendant acted with reckless disregard for Hallmark's rights and the Due Process Clause where it was not grossly excessive. Accordingly, the court affirmed the district court's denial of Clipper's motion for judgment as a matter of law and, alternatively, to alter or amend the judgment. View "Hallmark Cards v. Monitor Clipper Partners" on Justia Law