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

A debtor filed for Chapter 7 bankruptcy and sought to discharge student loan debts owed to both the Department of Education and a private lender, the Bank of North Dakota. The debtor, a 50-year-old woman with degrees in physics, education, communication, and mechanical engineering, had a history of mental health challenges and an unconventional work history, including periods of unemployment and underemployment. She consistently sought employment in her fields of study but often had to accept lower-paying or unrelated jobs. At the time of the proceedings, she was employed as an engineer earning $78,000 annually, with modest assets, minimal retirement savings, and reasonable living expenses.The United States Bankruptcy Court for the Northern District of Iowa held a trial and a supplemental evidentiary hearing. The court found that the debtor’s federal student loan debt was not dischargeable, but the private student loan debt owed to the Bank of North Dakota was dischargeable under 11 U.S.C. § 523(a)(8), concluding that repayment of the Bank’s loan would impose an undue hardship. The court based its decision on the debtor’s financial resources, reasonable expenses, lack of significant assets, ongoing mental health needs, and the inflexibility of the Bank’s repayment terms. The Bank of North Dakota appealed the dischargeability determination.The United States Bankruptcy Appellate Panel for the Eighth Circuit reviewed the bankruptcy court’s legal conclusions de novo and its factual findings for clear error. The panel affirmed the bankruptcy court’s decision, holding that the debtor met her burden of proving undue hardship under the totality-of-the-circumstances test. The panel agreed that the Bank’s student loan was dischargeable, while the Department of Education loan was not, and found no error in the bankruptcy court’s analysis or application of the law. View "Duncanson v. Bank of North Dakota" on Justia Law

Twelve days before filing for bankruptcy, the debtors purchased a new property in New Hampton, Iowa, but did not list this property in their bankruptcy schedules. Instead, they listed their Waucoma property, consisting of three contiguous parcels totaling just under 30 acres, as their residence and claimed it as fully exempt under Iowa’s homestead laws. No objections were filed to this exemption. The debtors later sold two of the three Waucoma parcels, retaining only a vacant lot (Parcel A). After their bankruptcy discharge, a creditor, AgVantage, sought to execute a pre-petition judgment lien against Parcel A, ultimately acquiring it at a sheriff’s sale.The United States Bankruptcy Court for the Northern District of Iowa denied the debtors’ motion to avoid AgVantage’s judicial lien, finding that the debtors had abandoned the Waucoma property as their homestead by purchasing and using the New Hampton property. The court also dismissed the debtors’ adversary complaint seeking contempt sanctions against AgVantage for violating the discharge injunction, concluding that AgVantage held a valid lien and was enforcing in rem rights, not collecting a discharged debt. The bankruptcy court further denied the debtors’ motion to amend the judgment.On appeal, the United States Bankruptcy Appellate Panel for the Eighth Circuit found that the bankruptcy court’s factual findings regarding the debtors’ homestead status on the petition date were not supported by the record. The panel held that the debtors’ exemption claim was presumptively valid and that AgVantage had not met its burden to rebut this presumption. The panel also determined that the bankruptcy court erred in granting a motion to dismiss the adversary proceeding without affording the debtors the procedural presumptions required at that stage. The panel reversed the bankruptcy court’s decision and remanded for further proceedings, including an evidentiary hearing. View "Jencks v. AgVantage FS" on Justia Law

Sammie Smith, Jr. and Elizabeth Smith filed for Chapter 13 bankruptcy three times within approximately two and a half years. Their first case was voluntarily dismissed. In their second case, they changed attorneys multiple times, filed several amended plans, and ultimately had their case dismissed for failure to make plan payments. Shortly after, they filed a third Chapter 13 case, again changing attorneys and submitting multiple amended plans and schedules. The Smiths also filed objections to creditor claims and requested several continuances. They failed to appear at a scheduled hearing on one of their objections, leading the bankruptcy court to issue an order to show cause regarding dismissal for failure to appear.The United States Bankruptcy Court for the Eastern District of Arkansas dismissed the Smiths’ third bankruptcy case, citing unreasonable delay prejudicial to creditors under 11 U.S.C. § 1307. The court also barred the Smiths from filing another bankruptcy case in any jurisdiction for one year. The Smiths appealed, arguing they were denied due process and a fair hearing, particularly objecting to the lack of notice regarding the possibility of a refiling bar.The United States Bankruptcy Appellate Panel for the Eighth Circuit reviewed the case. It held that the bankruptcy court did not abuse its discretion in dismissing the Smiths’ case, as the record supported dismissal for unreasonable delay and failure to appear. However, the appellate panel found that imposing a one-year bar on refiling without prior notice or an opportunity for the Smiths to be heard on that sanction was an abuse of discretion and violated due process. The panel affirmed the dismissal of the bankruptcy case but reversed and vacated the one-year refiling bar. View "Smith v. Gooding" on Justia Law

Arkansas enacted a law in 2021 that prohibits healthcare professionals from providing or referring minors for gender transition procedures, which include certain medical and surgical interventions intended to alter a minor’s physical characteristics to those of a different sex. Four minors, their parents, and two healthcare professionals challenged the law, arguing it violated their constitutional rights. The law was passed over the governor’s veto and defined violations as unprofessional conduct subject to disciplinary action.The United States District Court for the Eastern District of Arkansas initially granted a preliminary injunction, and a panel of the Eighth Circuit affirmed, finding a likelihood of success on the Equal Protection claim. After a bench trial, the district court permanently enjoined enforcement of the law, holding that it violated the Equal Protection Clause, the Due Process Clause, and the First Amendment.The United States Court of Appeals for the Eighth Circuit, sitting en banc, reversed the district court’s decision. The appellate court held that the law does not classify based on sex or transgender status, but rather on age and medical procedure, and is therefore subject to rational basis review. The court found that the state’s interest in protecting the health and safety of minors provided a rational basis for the law. The court also concluded that there is no deeply rooted constitutional right for parents to obtain gender transition procedures for their children over a state prohibition. Regarding the First Amendment, the court determined that the law’s restriction on referrals regulates professional conduct with only incidental effects on speech and survives intermediate scrutiny. The permanent injunction was reversed and the case remanded. View "Brandt v. Griffin" on Justia Law

Three residents and taxpayers of a Minnesota school district challenged a provision in the collective bargaining agreement between the district and its teachers’ union. The agreement allowed teachers to take up to 100 days per year of paid leave to work for the union, with the union reimbursing the district for the cost of substitute teachers but not for the full salaries and benefits of the teachers on leave. The residents objected to the alleged political and campaign activities conducted by teachers during this leave and filed suit, claiming violations of the First Amendment, the Minnesota Constitution, and state labor law.Previously, the United States District Court for the District of Minnesota dismissed the case, finding that the residents lacked Article III standing. On an earlier appeal, the United States Court of Appeals for the Eighth Circuit held that the residents had adequately alleged municipal taxpayer standing at the motion to dismiss stage and remanded the case. On remand, the district court again granted summary judgment for lack of standing, concluding that the residents had not shown a sufficient injury in fact. The residents appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and held that two of the residents, as current municipal taxpayers, had Article III standing because they demonstrated that district funds were expended solely due to the challenged union leave policy. The court found that the expenditure of funds, even if partially reimbursed, constituted a direct injury to municipal taxpayers. The court also held that the intermingling of local, state, and federal funds in the district’s general fund did not defeat standing. The judgment of the district court was reversed, and the case was remanded for further proceedings. View "Huizenga v. ISD No. 11" on Justia Law

During a protest in Minneapolis following the murder of George Floyd, Montez Lee, Jr. set fire to a pawn shop that had already been looted. Law enforcement later discovered the body of a man, O.L.S., in the remains of the building. Lee was charged with arson of property used in interstate commerce and pleaded guilty. At sentencing, the parties initially prepared to contest whether Lee’s actions caused O.L.S.’s death, which would have resulted in a significant sentencing enhancement. However, Lee’s attorney ultimately stipulated to the enhancement, and Lee was sentenced to 120 months in prison. The district court deferred a determination of restitution, as no victim had yet requested it, and entered an initial judgment reflecting this deferral.Subsequently, the parties agreed that Lee would pay $842 in restitution, and the district court amended the judgment several months later to include this obligation. Lee did not appeal either the initial or amended judgment. Over a year after the amended judgment, Lee filed a motion under 28 U.S.C. § 2255 to vacate his sentence, alleging ineffective assistance of counsel. The United States District Court for the District of Minnesota dismissed the motion as untimely, holding that the one-year limitations period began with the initial judgment, not the amended judgment that added restitution.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that, for purposes of § 2255(f)(1), a judgment of conviction does not become final until all components of the sentence, including restitution, are determined and the time for direct appeal has expired. Therefore, the limitations period for Lee’s § 2255 motion began after the amended judgment was entered. The Eighth Circuit reversed the district court’s dismissal and remanded the case, concluding that Lee’s motion was timely. View "Lee v. United States" on Justia Law

A 93-year-old woman with dysphagia was discharged from the hospital with a recommendation to consume puree-based meals and liquid additives produced by a food company. For about a month, her caretakers provided her with six of these meals and four servings of the additive daily. The product labels disclosed their sodium content. The woman suffered multiple cardiac arrests and was diagnosed with hypernatremia before passing away. Her estate, represented by her daughter, alleged that the company’s products caused her death and brought claims including strict products liability, breach of implied warranty, negligence, and wrongful death.The United States District Court for the Eastern District of Arkansas excluded one of the estate’s expert reports for failing to comply with Federal Rule of Civil Procedure 26(a)(2)(B), finding it lacked an opinion and was merely a recitation of facts. The court denied the estate’s motion for summary judgment and granted summary judgment to the company on all claims, concluding that the estate failed to provide sufficient evidence or expert testimony to support its claims.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s exclusion of the expert report for abuse of discretion and its grant of summary judgment de novo. The appellate court held that the district court did not abuse its discretion in excluding the expert report, as the estate failed to comply with disclosure requirements and did not show the failure was justified or harmless. The court also affirmed summary judgment for the company, finding the estate did not present evidence that the products were defective or unreasonably dangerous, nor did it provide necessary expert testimony for its claims. The court affirmed the district court’s judgment in full. View "Howard v. Hormel Foods Corporation" on Justia Law

After pleading guilty in 2018 to conspiracy to distribute heroin, the defendant served a 48-month sentence and began supervised release in 2023. During his initial term of supervision, he was charged with sex trafficking offenses, which he argued violated a “No Further Prosecution” clause in his plea agreement. Although the district court initially denied his motion to dismiss those charges, the United States Court of Appeals for the Eighth Circuit later held that the plea agreement barred the new charges, vacated his sex trafficking convictions, and ordered his release. Upon release, the district court imposed modified and additional special conditions of supervised release, citing evidence of prior sex trafficking and violent conduct.Following his release, the defendant repeatedly violated the terms of his supervised release. The United States District Court for the Southern District of Iowa revoked his supervision twice, each time imposing new terms of incarceration and supervised release, and reimposing or adding special conditions, including GPS monitoring, a curfew, and restrictions on contact with minors. The defendant did not appeal the first revocation judgment, but after the second revocation and reimposition of conditions, he objected to certain conditions and appealed.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s imposition of the challenged conditions for abuse of discretion. The appellate court held that the district court did not abuse its discretion in imposing GPS monitoring and curfew, given the defendant’s extensive violations and history of evading supervision. The court also upheld the restriction on unapproved contact with minors, finding it reasonably tailored in light of evidence of past conduct and allowing for contact with prior approval. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Thomas" on Justia Law

On July 2, 2022, Antonio Mashawn Airhart and his girlfriend discovered her borrowed car had been vandalized. Suspecting a neighbor’s involvement, a confrontation ensued later that day between Airhart and the neighbor’s brother, Martin Diaz, outside the neighbor’s apartment. During the altercation, Airhart was seen with a firearm, and Diaz testified that Airhart shot him in the face. Diaz returned fire with his own weapon. Law enforcement recovered shell casings from two types of ammunition at the scene and found an empty ammunition box and loose rounds in the apartment where Airhart was staying, with a fingerprint matching Airhart on the box.The United States District Court for the Southern District of Iowa denied Airhart’s motion to exclude evidence of the empty ammunition box and loose rounds, and a jury convicted him of unlawful possession of ammunition after a prior felony and misdemeanor crime of violence. The district court sentenced Airhart to 180 months in custody and three years of supervised release.On appeal to the United States Court of Appeals for the Eighth Circuit, Airhart challenged the admission of the ammunition evidence and certain lay opinion testimony by a detective, and argued the evidence was insufficient to support his conviction. The Eighth Circuit found that the district court erred in admitting the ammunition evidence, as it was neither intrinsic to the charged offense nor properly admitted under Rule 404(b), and that the detective’s lay opinion testimony was inadmissible. However, the court held both errors were harmless given the overwhelming evidence of guilt, including eyewitness testimony and corroborating video and physical evidence. The court also found the evidence sufficient to support the conviction. The Eighth Circuit affirmed the conviction and sentence. View "United States v. Airhart" on Justia Law

Marcus Rexrode, a convicted felon, arranged to sell marijuana to a sixteen-year-old, J.M. During the transaction, J.M. attempted to rob Rexrode at gunpoint, and J.M.’s companion also produced a firearm and fired at Rexrode. Rexrode fled while shooting back, fatally wounding J.M. Rexrode subsequently entered a plea agreement with the government, pleading guilty to being a felon in possession of a firearm. In exchange, the government agreed to dismiss a murder charge. The plea agreement included a joint recommendation for a 180-month sentence, acknowledged the possibility of guideline departures, and reserved both parties’ rights to object to any departures.The United States District Court for the District of North Dakota adopted the Presentence Investigation Report, which calculated a guidelines range of 41 to 51 months but identified grounds for upward departures due to the offense resulting in death and uncharged conduct. At sentencing, the court applied these departures, raising the guidelines range to 97 to 121 months, and imposed a 120-month sentence—substantially below the joint recommendation. Rexrode appealed, arguing procedural error in applying the departures and that the sentence was substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that there was no procedural error, as Rexrode had agreed to the possibility of departures and did not object to the Presentence Investigation Report or the departures at sentencing. The court also found that any error would have been harmless, as the district court stated it would have imposed the same sentence regardless. Additionally, the court determined that Rexrode had waived his right to appeal the sentence, as it fell within the adjusted guidelines range. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Rexrode" on Justia Law