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

Verlynin Buckley pleaded guilty to being a felon in possession of a firearm. The district court determined that he was an armed career criminal and sentenced him to 180 months in prison. Buckley appealed, arguing that the court erred in deeming him an armed career criminal under the Armed Career Criminal Act (ACCA), which mandates a minimum of fifteen years in prison for defendants with three or more prior convictions for a violent felony or a serious drug offense.The United States District Court for the Eastern District of Arkansas held that Buckley’s prior Arkansas convictions for possessing cocaine with the intent to deliver and for delivering cocaine were serious drug offenses under the ACCA. Buckley conceded that his prior convictions involved prohibited activity subjecting him to ten or more years in prison but contended that his prior convictions did not involve a controlled substance as defined by federal law.The United States Court of Appeals for the Eighth Circuit reviewed the case and rejected Buckley’s argument. The court held that the Arkansas statutes under which Buckley was convicted did not incorporate the state’s drug schedules but instead referred to cocaine in its ordinary sense. The court found no reason to believe that Arkansas intended to define cocaine more broadly than federal law. Consequently, Buckley’s prior cocaine convictions were deemed serious drug offenses under the ACCA. The Eighth Circuit affirmed the district court’s decision, upholding Buckley’s sentence as an armed career criminal. View "United States v. Buckley" on Justia Law

Justin Johnson, a pretrial detainee at Jefferson County Jail, was attacked by two other inmates while in protective custody. Johnson sued correctional officers Jacob Schurman and Christopher Taylor under 42 U.S.C. § 1983 for failure to protect him and for negligence under Missouri law. The district court granted summary judgment in favor of the officers, finding that qualified immunity barred the § 1983 claims and that official immunity and the public duty doctrine barred the negligence claims.The United States District Court for the Eastern District of Missouri determined that Johnson could not show a constitutional violation necessary to overcome qualified immunity. The court found no evidence that the officers were deliberately indifferent to a substantial risk of serious harm, as the attackers were not known to be violent, and Johnson had no prior relationship with them. The court also dismissed the negligence claims, ruling that the officers were protected by official immunity because their actions were discretionary, not ministerial. Additionally, the court found that the public duty doctrine applied, as the officers owed no particular duty to Johnson beyond that owed to the general prison population.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court agreed that the officers were entitled to qualified immunity, as Johnson failed to show that they were deliberately indifferent to a known risk. The court also upheld the dismissal of the negligence claims, concluding that the officers' actions involved discretionary decisions protected by official immunity. The court did not address the public duty doctrine, as the official immunity finding was sufficient to resolve the negligence claims. View "Johnson v. Schurman" on Justia Law

Absolute Pediatric Therapy, owned by Anthony Christopher, hired LaDonna Humphrey in May 2018 but terminated her four months later. In October 2018, Absolute and Christopher sued Humphrey in Arkansas state court, alleging various tort claims and accusing her of stealing information and making false accusations. Humphrey counterclaimed under the False Claims Act, alleging her termination was for reporting illegal activities. The litigation was contentious, and in August 2019, the state court found Humphrey in contempt and liable on all counts, awarding $3.57 million in damages to the plaintiffs.Following the state court's decision, Humphrey filed for Chapter 7 bankruptcy in September 2019. The Trustee of her bankruptcy estate proposed selling her claims, including her counterclaim and defensive appellate rights, to Absolute for $12,500. Humphrey objected to the sale of her defensive appellate rights. The bankruptcy court approved the sale, finding it reasonable and negotiated at arm's length. Humphrey did not obtain a stay of the sale but did secure a stay of the state court appeal.Humphrey appealed the bankruptcy court's order to the United States District Court for the Western District of Arkansas, which reversed the bankruptcy court's decision. The district court held that defensive appellate rights are not property of the estate under Arkansas law and found the sale not in the best interest of the estate. The district court also rejected the argument that the appeal was moot under 11 U.S.C. § 363(m) because Humphrey had obtained a stay of the state court proceedings.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the absence of a stay of the sale itself rendered the appeal statutorily moot under 11 U.S.C. § 363(m). The court vacated the district court's order and dismissed Humphrey's appeal from the bankruptcy court. View "Humphrey v. Christopher" on Justia Law

The Debtor-Appellant filed a chapter 13 voluntary petition on August 16, 2024, and was allowed to pay the filing fee in installments. The Debtor claimed to have received credit counseling within 180 days before filing, but failed to submit the required credit counseling certificate within the statutory deadline. The bankruptcy court issued an order compelling the Debtor to file the certificate by October 11, 2024, but the Debtor did not comply. Additionally, the Debtor failed to make the required installment payments on September 27 and October 11, 2024.The United States Bankruptcy Court for the District of South Dakota dismissed the Debtor’s case on October 15, 2024, due to the failure to pay the installment payments and the failure to submit the credit counseling certificate. The Debtor appealed the dismissal, arguing that the failure to pay the filing fee installment was due to unintentional delay and that the payment for the September 27 installment was sent but not received. The Debtor also attempted to submit two payments on October 14, which were delivered late.The United States Bankruptcy Appellate Panel for the Eighth Circuit reviewed the case. The court found that the Debtor’s appeal did not comply with Federal Rule of Bankruptcy Procedure 8014, as the brief lacked necessary components such as citations and a proper argument. Additionally, the court held that the bankruptcy court did not abuse its discretion in dismissing the case for failure to file a credit counseling certificate and for failure to make required installment payments. The court emphasized that compliance with the credit counseling requirement is mandatory and that the bankruptcy court had no choice but to dismiss the case. The order of the bankruptcy court was affirmed. View "Rivett v. Carlson" on Justia Law

The Minnesota Legislature amended its statutes to impose stricter regulations on white-tailed deer farming, including prohibiting new registrations and limiting transfers to immediate family members. The Minnesota Deer Farmers Association and individual deer farmers challenged these amendments, claiming violations of their substantive due process, equal protection, and procedural due process rights.The United States District Court for the District of Minnesota dismissed their complaint. The Deer Farmers appealed, arguing that the amendments deprived them of their fundamental right to pursue their chosen profession and unfairly advantaged those with immediate family members.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court first addressed the standing of the plaintiffs, finding that Udovich, an unregistered former deer farmer desiring a registration, had standing to challenge the amendments. The court then considered the substantive due process claim, concluding that the right to pursue white-tailed deer farming is not a fundamental right deeply rooted in the nation’s history and traditions. Therefore, the amendments were subject to rational basis review, not strict scrutiny.The court also addressed the equal protection claim, determining that the classification based on having immediate family members was not suspect and thus also subject to rational basis review. The court found that the amendments were rationally related to the legitimate government interest of containing Chronic Wasting Disease.Finally, the court dismissed the procedural due process claim due to a lack of standing, as the complaint did not adequately allege that any particular plaintiff had been cited or intended to engage in noncompliant conduct.The Eighth Circuit affirmed the district court’s dismissal of the Deer Farmers' claims. View "MN Deer Farmers Assoc. v. Strommen" on Justia Law

The case concerns Erik J. Vivier, who was accused of engaging in sexual acts with J.M., a 15-year-old girl, while she was allegedly incapacitated due to alcohol consumption. J.M. testified that she felt dizzy, nauseous, and not in control of her body after drinking, and described being invited into Vivier’s home, given more alcohol, and then sexually assaulted while in a spare bedroom. Vivier initially denied knowing J.M., then changed his account multiple times, eventually admitting to a sexual act but claiming he was not in the right state of mind. Other witnesses present at the home offered limited observations, and the government’s case relied heavily on J.M.’s testimony and Vivier’s inconsistent statements.The United States District Court for the District of North Dakota presided over the trial, where a jury convicted Vivier of sexual abuse of an incapacitated victim and sexual abuse of a minor. Vivier moved for a judgment of acquittal on the charge of sexual abuse of an incapacitated victim, arguing insufficient evidence of J.M.’s incapacity and his knowledge thereof. The district court denied this motion. During trial, Vivier also objected to the testimony of an FBI agent who opined on Vivier’s truthfulness, arguing it was undisclosed expert testimony. The district court denied the motion to strike but issued a curative instruction, partially adopting Vivier’s proposed language.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the motion for judgment of acquittal de novo, viewing the evidence in the light most favorable to the verdict. The court held that sufficient evidence supported the jury’s finding that J.M. was incapacitated and that Vivier knew of her incapacity. The court also found that, although the district court erred in its curative instruction regarding the agent’s opinion testimony, this did not affect Vivier’s substantial rights. The judgment of the district court was affirmed. View "United States v. Vivier" on Justia Law

Jefferson County, Missouri, filed a lawsuit against several pharmacy benefit managers (PBMs), including Express Scripts and OptumRX, alleging that their distribution practices facilitated prescription opioid abuse, resulting in numerous deaths and emergency room visits. The County sought relief under Missouri public nuisance law. The case was initially filed in the Twenty-Second Judicial Circuit Court of Missouri and later amended multiple times. On December 1, 2023, the PBMs filed a notice of removal to federal court, citing the federal officer removal statute and other federal statutes.The case was previously part of the federal Opioid Multidistrict Litigation (MDL) but was severed and remanded to Missouri state court in July 2019. During discovery, the County provided a "Red Flag Analysis" identifying prescription claims, including federal claims. The PBMs argued that this analysis indicated the case was removable to federal court. However, the County later disclaimed reliance on federal claims in a joint stipulation.The United States District Court for the Eastern District of Missouri granted the County's motion to remand the case to state court. The district court found that the PBMs' removal was untimely, as they were required to file a notice of removal within 30 days of the February 14, 2022, Red Flag Analysis. The court also determined that removal was not substantively proper under the federal officer removal statute because the County had disclaimed any reliance on federal claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the PBMs had unambiguously ascertained that the February 14, 2022, Red Flag Analysis allowed for removal but failed to act within the required 30-day period. Consequently, the district court's order to remand the case to state court was upheld. View "Jefferson County v. Express Scripts, Inc." on Justia Law

In 2009, Arkansas enacted a law limiting the number of voters one person could assist to six, with violations classified as misdemeanors. Arkansas United, a non-profit organization, and its founder, L. Mireya Reith, challenged this law, arguing it conflicted with Section 208 of the Voting Rights Act (VRA), which allows voters needing assistance to choose anyone to help them, except their employer or union representative.The United States District Court for the Western District of Arkansas denied an emergency motion for a temporary restraining order but later granted partial summary judgment for the plaintiffs, enjoining the enforcement of the six-voter limit. The court also awarded attorney fees and costs to the plaintiffs. The State sought and obtained a stay of the injunction from the Eighth Circuit Court of Appeals, allowing the six-voter limit to remain in effect for the 2022 General Election.The United States Court of Appeals for the Eighth Circuit reviewed the case and held that Section 208 of the VRA does not create a private right of action. The court found that enforcement of Section 208 is intended to be carried out by the Attorney General, not private parties. The court also rejected the argument that the Supremacy Clause provided a basis for a private right of action. Consequently, the court reversed the district court's grant of summary judgment for the plaintiffs, vacated the permanent injunction and the award of attorney fees and costs, and remanded the case for further proceedings consistent with its opinion. View "Arkansas United v. Thurston" on Justia Law

In 2013, Royalty Interests Partnership, LP (Royalty) leased oil and gas drilling rights to MBI Oil & Gas, LLC (MBI) for a primary term of three years, with the lease continuing as long as oil and gas production occurred on the leased premises or pooled acreage. By 2016, MBI had not drilled any wells or paid royalties, although one pre-existing well was producing oil and gas. In 2020, Royalty leased the same premises to Ovintiv USA Inc. (Ovintiv), which drilled several wells. In 2022, Royalty requested MBI to release its lease, but MBI refused and initiated litigation, claiming its lease was still valid.The United States District Court for the District of North Dakota granted summary judgment in favor of Royalty and Grayson Mill Bakken, LLC (Grayson Mill), Ovintiv’s successor. The court found that MBI had failed to extend the lease term by not producing oil and gas on the leased premises. MBI appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the reservation clause in the lease unambiguously reserved all rights to the production from the pre-existing well to Royalty, excluding it from perpetuating the lease. The court also found that North Dakota’s pooling statute was inapplicable because it applies to separately owned tracts, not separately owned interests in the same tract. Consequently, the court affirmed the district court’s decision, concluding that MBI’s lease had expired due to its failure to produce oil and gas or contribute to drilling on the leased premises or pooled acreage. View "MBI Oil and Gas, LLC v. Royalty Interests Partnership, LP" on Justia Law

Jimmy Hudson pled guilty to a drug distribution charge after selling fentanyl to a confidential informant. He was indicted and, as part of a plea agreement, pled guilty to one count of distributing fentanyl. The plea agreement noted that Hudson might be labeled a career offender, which would increase his sentencing range under the United States Sentencing Guidelines (USSG). The Presentence Investigation Report (PSR) confirmed Hudson's status as a career offender due to his prior felony convictions for controlled substance offenses, resulting in a sentencing range of 151 to 188 months. The Government recommended a 151-month sentence, which the district court adopted.The United States District Court for the Eastern District of Missouri sentenced Hudson to 151 months’ imprisonment, considering the factors in 18 U.S.C. § 3553(a) and Hudson's status as a career offender. The court noted Hudson's criminal history and the need for a sentence that was sufficient but not greater than necessary. Hudson also received a 24-month sentence for violating supervised release terms, but he did not appeal that sentence.Hudson appealed to the United States Court of Appeals for the Eighth Circuit, arguing that his sentence was substantively unreasonable. He contended that his career offender status unfairly increased his sentencing range because his prior convictions were non-violent drug offenses. The Eighth Circuit reviewed the substantive reasonableness of the sentence under an abuse of discretion standard and found that the district court did not abuse its discretion. The court noted that the district court had considered Hudson's individual characteristics and the dangerousness of fentanyl. The Eighth Circuit affirmed the district court's judgment, concluding that the 151-month sentence was not substantively unreasonable. View "United States v. Hudson" on Justia Law