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

After Defendant pleaded guilty to conspiring to distribute 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, the district court at sentencing found that the methamphetamine Defendant possessed was pure, leading to a higher Sentencing Guidelines range than Defendant believed was appropriate. Defendant takes issue with the court's finding and also says that the government breached an agreement not to seek a Guidelines range that was based on pure methamphetamine.   The Eighth Circuit affirmed. The court explained that to obtain a conviction, the government had to prove merely that Defendant’s conspiracy involved a mixture or substance containing methamphetamine, so it makes sense that the government charged him that way. But for sentencing purposes, the Guidelines consider whether that substance was pure methamphetamine or not. The government did not rest merely on Defendant’s guilty plea to demonstrate that the methamphetamine was pure; it had the methamphetamine tested to confirm that it was pure, and Defendant has expressly disavowed any challenge to the accuracy of the laboratory testing. The district court, therefore, did not err. View "United States v. Jason Russell" on Justia Law

Olmsted Medical Center (“Olmsted”) provides preventive, primary, and specialty healthcare in southeastern Minnesota. Olmsted purchased a business property insurance policy from Continental Casualty Company (“Continental”) for the period from January 1, 2020, to January 1, 2021. The “Coverage” section of the policy states that it “insures against risks of direct physical loss of or damage to property and/or interests described herein at” Olmsted’s premises. Olmsted submitted a claim for losses it sustained due to the COVID-19 pandemic under the insurance policy it held with Continental. Continental denied the claim two days later. Olmsted filed suit in Minnesota state court, alleging Continental breached the insurance contract when it refused to pay the claim. Olmsted requested damages and declaratory relief. After Olmsted filed its amended complaint, Continental filed a motion to dismiss. Continental argued, among other things, that Olmsted’s allegations did not implicate a “direct physical loss of or damage to” property; therefore, its claim for coverage did not fall within the policy’s language under any of the above provisions.   The Eighth Circuit affirmed. The court explained that although SARS-CoV-2 may have a “physical” element, it does not have a physical effect on real or personal property. Moreover, the business-interruption provision, however, expressly limits coverage to the “length of time as would be required . . . to rebuild, repair or replace” the affected property. Due to the fact that SARS-CoV-2 does not have an effect on the underlying property, the court did not see how to square Olmsted’s broader interpretation of the provision with the express time limitation. View "Olmsted Medical Center v. Continental Casualty Company" on Justia Law

In 2002, a jury convicted Defendant of drug-related crimes, including conspiracy to distribute 500 grams or more of methamphetamine. Based on prior felony drug convictions, the district court imposed a mandatory life sentence on the conspiracy count. In the First Step Act, Congress eliminated mandatory life sentences for this offense. However, Congress did not make Section 401(a) sentence reductions retroactively available to persons who were convicted and sentenced before the First Step Act’s enactment. Defendant moved to reduce his sentence through a motion for compassionate release. The district court denied the motion, concluding that Section 3582(c)(1)(A) relief is foreclosed by United States v. Crandall, 25 F.4th 582 (8th Cir. 2022). The issue on this appeal is whether Defendant is eligible for a sentence reduction under Section 3582(c)(1)(A).   The Eighth Circuit affirmed. The court reasoned that in Crandall, the court held that a non-retroactive change in law regarding sentencing, such as Section 401(a)(2) of the First Step Act, “whether offered alone or in combination with other factors, cannot contribute to a finding of ‘extraordinary and compelling reasons’ for a reduction in sentence under Section 3582(c)(1)(A).” The court explained that the Court’s reasoning in Conception would apply when a motion for compassionate release establishes an extraordinary and compelling reason for relief other than a nonretroactive change in the law, such as the defendant’s medical condition, age, or family circumstances, and the court is exercising its discretion to grant relief. But “Concepcion is irrelevant to the threshold question” of whether Defendant has shown an “extraordinary and compelling reason” for Section 3582(c)(1)(A) relief. View "United States v. Rodrigo Rodriguez-Mendez" on Justia Law

A jury convicted Defendant of rioting and aiding and abetting arson for his participation in civil unrest in downtown Minneapolis. The district court sentenced Defendant to concurrent sentences of 60 months of imprisonment for rioting and 100 months of imprisonment for aiding and abetting arson, followed by two years of supervised release. Defendant appealed, challenging the admission of certain surveillance video and the substantive reasonableness of the sentence.   The Eighth Circuit affirmed. The court explained that here, the district court decided the challenged surveillance video was not so unfairly prejudicial, misleading, or confusing so as to substantially outweigh its probative value. The court reasoned that the district court’s explanation belies Defendant’s contention that the district court neglected to conduct the balancing test required by Rule 403. The court wrote it convicted the court the district court did not abuse its discretion by admitting the challenged video. Further, here, the district court provided extensive reasoning, much of which expressly addressed Defendant’s mitigation arguments. The court explained that this explanation is sufficient to satisfy the court that the district court considered Defendant’s arguments and had a reasoned basis for imposing the 100-month sentence. Accordingly, the court found that as to his claim the sentence is substantively unreasonable, Defendant has not articulated any reason for the court to reach such a conclusion in light of the presumption of reasonableness that attaches to the bottom-of-the-Guidelines sentence. View "United States v. Victor Edwards" on Justia Law

Louis DeGidio, the father of Plaintiffs, began purchasing, distributing, and servicing Industrial Combustion, LLC’s (“IC”) burners for institutional boiler systems in a sales area including most of Minnesota. IC’s non-exclusive distributors are responsible for installing and servicing the IC burners they sell. In 1996, the family incorporated Louis DeGidio, Inc. (“LDI”) and Louis DeGidio Services, Inc. (“LDSI”). LDI continued purchasing burners from IC. LDSI installed and serviced the burners LDI sold, purchasing replacement parts from IC. The two corporations shared the same location, officers, and shareholders. Plaintiffs were joint 50% shareholders and key officers of both. Whatever written agreement was then in effect is not in the record, but it is undisputed that LDI was the distributor. At issue is whether a manufacturer collects an indirect “franchise fee” within the meaning of the Minnesota Franchise Act if it charges the distributor a price based on the retail price the manufacturer paid a third-party vendor for the parts.   The Eighth Circuit affirmed and agreed with the district court the answer is clearly no, and therefore, the distributorship agreement here at issue was not a franchise. The court further agreed that the manufacturer did not breach an oral implied-in-fact contract and was not barred by promissory estoppel when it terminated the DeGidio sales representative without cause. Applying Minnesota law and reviewing de novo, the court affirmed the grant of summary judgment in favor of IC and its parent company, Cleaver-Brooks, Inc. View "Louis DeGidio, Inc. v. Industrial Combustion, LLC" on Justia Law

Police went to arrest Defendant for an incident that happened the day before. Defendant fled first on an ATV and then in a car. Once stopped, Defendant was sent to the hospital to receive medical attention. Meanwhile, officers searched Defendant’s car, finding guns and ammunition. A grand jury indicted Defendant for being a prohibited person in possession of a firearm. Defendant moved to suppress his statements, arguing that his Miranda waiver was invalid. The district court denied the motion. Defendant then moved in limine to exclude testimony that he had or used a gun in connection with the incident that led police to confront him on April 22. The district court granted the motion in part, prohibiting the Government from presenting hearsay testimony about the gun. Defendant also moved in limine to exclude evidence of his second flight from police, which was denied.   The Eighth Circuit affirmed. The court explained that here, the totality of the circumstances suggests that Defendant voluntarily, knowingly, and intelligently waived his rights. He was not intimidated, coerced, or deceived. On the contrary, officers ensured Defendant appreciated the rights he was waiving, told him that it was his decision to talk, and advised him that he could end the interview at any time. The evidence at trial showed that on the day the guns were discovered, police watched Defendant get in a car and drive off. When the pursuit ended, police found two guns in the passenger seat. View "United States v. Patrick Medearis" on Justia Law

Plaintiff sued Missouri prison officials under 42 U.S.C. Section 1983, alleging deprivations of his constitutional rights while incarcerated. The officials moved for summary judgment based on qualified immunity, and the district court denied the motion on two sets of claims. The officials appealed a portion of the order.   The Eighth Circuit reversed. The court explained that even assuming for the sake of analysis that Plaintiff enjoyed a clearly established liberty interest in avoiding assignment to administrative segregation, it was not clearly established that he was entitled to the procedures set forth in Wolff v. McDonnell, 418 U.S. 539. Further, the court explained that a reasonable official could have believed that the procedures applied in Plaintiff’s case were constitutionally sufficient. Informal due process requires only “some notice of the reasons for the inmate’s placement . . . and enough time to prepare adequately for the administrative review.” The procedures applied here meet the informal due process standard. The officials gave Plaintiff adequate notice of the reasons for his placement. The notice informed Plaintiff of his rights and identified the alleged victim, the date of the sexual assault, and the prison rule that he allegedly violated. View "James Spann v. George Lombardi" on Justia Law

Defendant moved to suppress evidence from a traffic stop, claiming that the officers unconstitutionally delayed it to conduct a drug-dog search and that the dog’s alert did not provide probable cause to search. The district court denied most of the motion. A jury convicted Defendant for possession of 50 grams or more of methamphetamine with intent to distribute and conspiracy to distribute 500 grams or more of a mixture and substance containing meth. Defendant appealed the denial of the motion to suppress.   The Eighth Circuit affirmed. The court held that the Troopers here had reasonable suspicion before stopping Defendant, which existed throughout the stop. Only 27 minutes passed from the stop until the dog’s alert. This delay did not violate the Fourth Amendment because the Troopers acted diligently to pursue the mission of the stop: to assist with the investigation of Defendant’s drug-related activity. Further, the court held that based on the totality of the circumstances at the scene of the stop, the dog’s alert provided probable cause to search the vehicles. View "United States v. Larry Rederick" on Justia Law

Plaintiff filed a Section 1983 lawsuit against several defendants, including agents of the Grand Forks Narcotics Task Force (“GFNTF”). Plaintiff alleged two Fourth Amendment violations: (I) the warrant was based upon deliberate falsehood or reckless disregard for the truth -- the use of the informant to develop and generate false evidence incorporated in an affidavit; and (ii) Defendants deprived Plaintiff of a preliminary hearing at which Plaintiff would have been discharged because the warrant was not supported by probable cause. Plaintiff appealed the grant of summary judgment dismissing these claims.   The Eighth Circuit affirmed. The court agreed with the district court that the affidavit provided probable cause to arrest Plaintiff, even if corrected to include the information Plaintiff alleged was recklessly omitted. The court explained that there is no evidence any of the defendants knew about the false “murder-for-hire” allegations when the warrant affidavit was submitted. An agent does not “violate a clearly established constitutional right by omitting information from a warrant application that he does not actually know, even if the reason is his own reckless investigation.” As Plaintiff’s subsequent, lengthy investigation of the informant makes clear, minimal further investigation into the informant’s criminal history would not have exonerated Plaintiff. View "Henry Howe v. Steven Gilpin" on Justia Law

This case started more than fifty years ago when Minnie Liddell sued to desegregate the St. Louis public school system. The NAACP joined the lawsuit, and the State of Missouri (among others) became a defendant. The parties struck a deal that lasted until 1999 when they agreed to end Missouri’s remedial obligations. The Missouri Legislature ratified the parties’ settlement agreement and created a charter-school option. A group of charter schools complained to the Missouri Legislature, which altered the funding formula in 2006. The revised formula, part of Senate Bill 287, is what has led to the current dispute. The St. Louis Public School District and one of the plaintiffs asked the district court to enforce the settlement agreement by having Missouri reimburse it for the special-sales-tax revenue it had lost under the new funding formula. The district court sided with Missouri, and both sides appealed. Plaintiffs continued to believe that the St. Louis Public School District should receive all the special-sales-tax revenue. And Missouri argued that the desegregation-spending condition finds no support in the settlement agreement.   The Eighth Circuit affirmed the district court’s judgment but vacated the part requiring charter schools to spend those funds on “desegregation measures.” The court explained that there has been no “disproportionate adverse financial impact” on the St. Louis Public School District because it never had a right to keep all the special-sales-tax revenue for itself. Moreover, the court rejected the argument that allowing charter schools to spend their money as they see fit is inconsistent with the “purpose” of the settlement agreement. View "Deric Liddell v. State of Missouri" on Justia Law