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

Tad Mayfield, a nonpartisan legislative specialist in the assistant chief clerk’s office of the Missouri House of Representatives, was terminated on August 6, 2020, after sending an email on August 3, 2020, to the Speaker of the House and the President Pro Tem of the Missouri Senate advocating for mandatory face masks in the state capitol building due to COVID-19 concerns. Mayfield filed a lawsuit under 42 U.S.C. § 1983, alleging wrongful termination in retaliation for his email, claiming it violated his First Amendment rights.The case proceeded to a jury trial in the United States District Court for the Western District of Missouri. The jury found in favor of Mayfield, awarding him $15,000 in punitive damages and $14,993.93 in actual damages for lost wages. The district court denied the defendants' motions for judgment as a matter of law and awarded Mayfield attorney’s fees.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Mayfield’s email was protected speech under the First Amendment as it addressed a matter of public concern. The court found that the defendants failed to show that the email had an adverse impact on the efficiency of the House’s operations, which would have necessitated a Pickering balancing test. The court also upheld the jury’s finding that the email was a substantial or motivating factor in Mayfield’s termination and rejected the defendants' claim of qualified immunity, stating that the right to speak on matters of public concern was clearly established.Additionally, the court found sufficient evidence to support the submission of punitive damages to the jury, given the defendants' knowledge that terminating an employee for raising public health concerns could be illegal. The court also upheld the district court’s award of attorney’s fees to Mayfield, finding no abuse of discretion. View "Mayfield v. Miller" on Justia Law

Chapter Kris Jackson, the debtor, appeals the bankruptcy court’s order denying her motion for sanctions, damages, and other relief against Rachel Gosset and Jordan Beswick, co-trustees of the Jackson Family Trust. Jackson sought an evidentiary hearing on these issues, an order requiring the co-trustees to post a bond, an order barring them from filing any involuntary bankruptcy petition without court approval, and a declaration that the case is void ab initio.The United States Bankruptcy Court for the Western District of Missouri initially held a status hearing and decided to bifurcate Jackson’s motion to dismiss from her other motions. The court dismissed the involuntary petition under 11 U.S.C. § 305 but denied Jackson’s requests for sanctions and damages, citing minimal potential damages, lack of authority to award damages under 11 U.S.C. § 303(i) when dismissing under § 305, and Jackson’s litigation tactics.The United States Bankruptcy Appellate Panel for the Eighth Circuit reviewed the case. The panel noted that the Eighth Circuit Court of Appeals in Stursberg v. Morrison Sund PLLC clarified that damages under 11 U.S.C. § 303(i) are available even when a case is dismissed under § 305. The panel found that the bankruptcy court should have held an evidentiary hearing to allow Jackson to present evidence supporting her claims for damages and other relief. The panel remanded the case to the bankruptcy court for such a hearing.The panel also denied Jackson’s various motions, including her motion to strike the appellees' brief and her motion for sanctions, as they were outside the scope of the appeal. The panel emphasized that its role was to review the bankruptcy court’s decisions, not to make initial determinations on issues the bankruptcy court abstained from deciding. View "Jackson v. Gosset" on Justia Law

Matthew Cartia and Autumn Adams were arrested by officers when they attempted to interfere with a police investigation at Cartia's parents' house. The officers claimed that Cartia and Adams were interfering with their work, leading to a confrontation where Cartia was handcuffed and taken down using a "hip-toss" maneuver. Adams was also arrested after she tried to intervene. Both Cartia and Adams alleged that the officers used excessive force during and after their arrests, including claims that Cartia was struck and choked by the officers.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the defendants, including the officers and Lincoln County. The magistrate judge concluded that the officers were entitled to qualified immunity and that Lincoln County was not liable under Monell for the officers' actions.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the grant of summary judgment for some claims but reversed it for others. The court held that the officers were entitled to qualified immunity for most of their actions, including the initial takedown and restraint of Cartia, as well as the force used against Adams. However, the court found that there were genuine issues of material fact regarding the excessive force claims against Officers Beeman and Gugliano for allegedly striking and choking Cartia after he was subdued. These claims were remanded for further proceedings. The court also found that the state law claims of assault and battery and negligence against these officers should proceed to trial, as there was sufficient evidence to suggest they may have acted with malice or bad faith. The court affirmed the dismissal of the remaining claims. View "Cartia v. Beeman" on Justia Law

Dr. Tara Gustilo, an Asian American obstetrician-gynecologist of Filipino descent, was demoted from her position as Chair of the OBGYN Department at Hennepin Healthcare System, Inc. (HHS) in April 2021. Following her demotion, she filed charges with the Equal Employment Opportunity Commission (EEOC) and subsequently sued HHS, alleging race discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA), as well as a First Amendment retaliation claim under 42 U.S.C. § 1983.The United States District Court for the District of Minnesota granted summary judgment in favor of HHS, finding no genuine dispute of material fact regarding the race discrimination, retaliation, and First Amendment claims. The court concluded that Dr. Gustilo failed to establish a prima facie case of race discrimination and that there was no evidence she opposed an unlawful employment practice. Additionally, the court found no material fact dispute regarding whether the HHS Board considered her Facebook posts in its decision to demote her.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court reversed the district court's grant of summary judgment on the First Amendment retaliation claim, finding that there was a material fact dispute regarding whether the HHS Board ratified the MEC's decision and the basis for it, which included consideration of Dr. Gustilo's Facebook posts. The court remanded the case for further proceedings to determine if the posts were protected speech and to apply the Pickering balancing test.The court declined to review the district court's summary judgment rulings on the Title VII and MHRA claims at this time, as they are now interlocutory. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Gustilo v. Hennepin Healthcare System, Inc." on Justia Law

A grand jury indicted Derek Mims, Elmer Mims, David Belton, and Anton Whitney for conspiracy to distribute pure methamphetamine. Whitney was also charged with possession of a firearm by a drug user, and Belton was charged with possession of a firearm by a felon and drug user. Derek, Belton, and Whitney entered conditional guilty pleas, while a jury found Elmer guilty. The defendants appealed the district court's denial of motions to suppress evidence from wiretaps, a motion to recuse, and, in Belton's case, a motion to suppress evidence from a vehicle search. Elmer also appealed the sufficiency of the evidence for his conviction and the length of his sentence, while Derek and Whitney challenged their sentences.The United States District Court for the Northern District of Iowa denied the motions to suppress evidence obtained from wiretaps, finding that the necessity and probable cause requirements were met. The court also denied Belton's motion to suppress evidence from a vehicle search, applying the automobile exception to the Fourth Amendment. The court found probable cause based on the suspicious circumstances and modifications observed on the vehicle. The district court also denied the motion to recuse, stating that a judge's authorization of wiretap warrants does not require recusal from subsequent motions to suppress.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decisions, holding that the wiretap affidavits met the necessity and probable cause requirements, the vehicle search was justified under the automobile exception, and the denial of the motion to recuse was not an abuse of discretion. The court also found sufficient evidence to support Elmer's conviction and upheld the sentences of Derek, Whitney, and Elmer, finding no abuse of discretion in the district court's sentencing decisions. View "United States v. Mims" on Justia Law

A grand jury indicted Derek Mims, Elmer Mims, David Belton, and Anton Whitney for conspiracy to distribute methamphetamine. Whitney was also charged with possession of a firearm by a drug user, and Belton with possession of a firearm by a felon and drug user. Derek, Belton, and Whitney entered conditional guilty pleas, while a jury found Elmer guilty. The defendants appealed the district court's denial of motions to suppress evidence from wiretaps and a vehicle search, and the denial of a motion to recuse. Elmer also challenged the sufficiency of the evidence and the length of his sentence, while Derek and Whitney challenged their sentences.The United States District Court for the Northern District of Iowa denied the motions to suppress evidence obtained from wiretaps, finding that the necessity and probable cause requirements were met. The court also denied Belton's motion to suppress evidence from a vehicle search, applying the automobile exception to the Fourth Amendment. The court found probable cause based on the suspicious circumstances and modifications to the vehicle. The motion to recuse was denied, as the judge's authorization of wiretaps did not require recusal.The United States Court of Appeals for the Eighth Circuit reviewed the case. It affirmed the district court's denial of the motions to suppress, finding no clear error in the necessity and probable cause determinations. The court also upheld the denial of the motion to recuse, citing precedent that a judge's authorization of wiretaps does not necessitate recusal. The court found sufficient evidence to support Elmer's conviction and upheld the sentences of Derek, Whitney, and Elmer, finding no abuse of discretion in the district court's sentencing decisions. The judgments of the district court were affirmed. View "United States v. Mims" on Justia Law

Simon Quito-Guachichulca, a lawful permanent resident, pleaded guilty to third-degree criminal sexual conduct under Minnesota law. Following his conviction, the government initiated removal proceedings, arguing that his crime was an "aggravated felony" under federal law, making him deportable. Initially, the government classified the crime as a "crime of violence," but the Supreme Court's decision in Sessions v. Dimaya rendered that classification impermissibly vague. Consequently, the Eighth Circuit vacated the removal order and remanded the case to the Board of Immigration Appeals (BIA) for reconsideration.On remand, the government reclassified Quito's crime as "rape," another type of "aggravated felony." Both an immigration judge and the BIA agreed with this classification. Quito then petitioned for review, arguing that the government’s change in theory violated the doctrine of res judicata. The Eighth Circuit found that res judicata did not apply because there was no final judgment on the merits due to the vacated order.The United States Court of Appeals for the Eighth Circuit reviewed whether Minnesota’s third-degree criminal sexual conduct statute fits the federal definition of "rape" under immigration law. The court applied the categorical approach, examining the statutory elements rather than Quito's actual conduct. The court determined that the federal definition of "rape" in 1996 did not include digital or mechanical penetration, which is covered under Minnesota’s statute. Therefore, the court concluded that there was a categorical mismatch between the state and federal definitions.The Eighth Circuit granted Quito's petition for review, vacated the BIA's order, and remanded the case for further proceedings, holding that Minnesota’s third-degree criminal sexual conduct does not qualify as "rape" under federal immigration law. View "Quito-Guachichulca v. Garland" on Justia Law

Kathan Daniel Wiley was convicted of conspiracy to distribute fentanyl and possession with intent to distribute fentanyl resulting in serious bodily injury. On October 30, 2021, Wiley's 18-month-old child ingested fentanyl pills, leading to severe health issues but ultimately surviving. Wiley had been distributing fentanyl pills for months, and evidence showed he obtained the pills shortly before the incident. The jury found him guilty on both counts, and the district court sentenced him to 240 months for the conspiracy charge and 324 months for possession with intent to distribute, to be served concurrently.The United States District Court for the Southern District of Iowa denied Wiley's motion for judgment of acquittal. Wiley appealed, arguing insufficient evidence for the conspiracy charge, claiming his possession was to support his addiction rather than for distribution. He also contended that the evidence did not support the conviction for possession with intent to distribute resulting in serious bodily injury, asserting the fentanyl ingested by his child was intended for personal use.The United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence de novo, affirming the district court's decision. The court held that the evidence, including Facebook messages and testimony, supported the jury's finding of a conspiracy and intent to distribute. The court also upheld the district court's application of a four-level enhancement under U.S.S.G. § 2D1.1(b)(13) for misrepresenting the substance as another drug. Additionally, the court found no abuse of discretion in the district court's consideration of the § 3553(a) factors, affirming the 324-month sentence as substantively reasonable. The judgment was affirmed. View "United States v. Wiley" on Justia Law

Wayne Lozier, Jr., a licensed bounty hunter in Louisiana, traveled to Missouri to detain a fugitive, R.C., who had failed to appear for her court date in Louisiana. Lozier entered a residence in Missouri, handcuffed R.C., and transported her towards Mississippi. During this time, the residence owner alerted law enforcement, leading to an investigation by Officer Jeffrey Atkins. Lozier was found to have violated Missouri laws by not being licensed in Missouri and failing to notify local law enforcement before apprehending R.C.A federal grand jury indicted Lozier for kidnapping and conspiracy to kidnap. Lozier moved to dismiss the indictment, arguing his actions were lawful as an agent of a bail bondsman. The United States District Court for the Eastern District of Missouri denied these motions, stating Lozier's arguments were factual challenges. At trial, Lozier admitted to the Missouri law violations but contended his actions were standard fugitive apprehension. He objected to a jury instruction that he claimed deprived the jury of deciding whether his actions were unlawful. The jury found Lozier guilty on both counts, and he was sentenced to 120 months on each count, to run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the jury instruction (Instruction 16) created a conclusive presumption that Lozier acted unlawfully by violating Missouri law, thus removing the jury's ability to consider justification or excuse. This violated Lozier's due process rights. The court held that this error was not harmless and vacated Lozier's convictions, remanding the case for a new trial. View "United States v. Lozier" on Justia Law

Plaintiffs BSI Group LLC and International Business Solutions Group, LLC, financial service companies, contracted with EZBanc Corp for financial services. EZBanc collaborated with Solid Financial Technologies, Inc. and Evolve Bank & Trust to provide these services. Plaintiffs alleged that Defendants mishandled funds, withdrawing nearly $9 million from their accounts and failing to process approximately $300,000 in third-party payments. Defendants sought to compel arbitration, arguing that although EZBanc’s contracts with Plaintiffs lacked an arbitration clause, the contracts referred to other terms that included such a clause.The United States District Court for the Eastern District of Arkansas denied Defendants' motions to compel arbitration. The court found that the language in the contracts was too vague to incorporate the Evolve Agreement by reference and that there was a factual dispute regarding whether the terms of the Evolve Agreement were known or easily available to Plaintiffs.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court erred in its interpretation of the contract and its denial of the motion to compel arbitration. The appellate court found that there were material disputes of fact regarding whether the Evolve Agreement was effectively communicated to Plaintiffs, which necessitated a trial. Consequently, the Eighth Circuit reversed the district court’s decision and remanded the case for trial to determine if Plaintiffs agreed to be bound by the terms in the Evolve Agreement through the “pop-up” or other aspects of EZBanc’s website. View "BSI Group LLC v. Solid Financial Technologies Inc." on Justia Law