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

Michael Lindell, a Minnesota entrepreneur, challenged the legitimacy of the 2020 presidential election, claiming to have data proving Chinese interference. Lindell Management LLC (LMC) hosted a "Cyber Symposium" in August 2021, offering a $5 million reward to anyone who could prove the data provided was not from the November 2020 election. Robert Zeidman, a software developer, participated in the challenge, reviewed the data, and concluded it did not contain any information related to the election. The challenge judges disagreed and denied his claim.Zeidman filed for arbitration, and the arbitration panel unanimously found in his favor, ordering LMC to pay the $5 million reward. The panel determined that the contract required participants to prove the data was not related to the election and that Zeidman had met this burden. Zeidman then moved to confirm the arbitration award in the United States District Court for the District of Minnesota, while LMC sought to vacate it. The district court confirmed the panel's decision, finding that the panel had arguably interpreted and applied the contract.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the arbitration panel had exceeded its authority by using extrinsic evidence to interpret the unambiguous contract terms. The court held that the panel effectively amended the contract by requiring the data to be packet capture data, which violated Minnesota contract law and arbitration precedents. Consequently, the Eighth Circuit reversed the district court's decision and remanded the case with directions to grant LMC's motion to vacate the arbitration award. View "Zeidman v. Lindell Management LLC" on Justia Law

A group of television and radio broadcasters challenged the Federal Communications Commission's (FCC) 2023 Order, which retained all existing media ownership rules and tightened one of them following the 2018 Quadrennial Review. The broadcasters argued that the FCC erred by defining the relevant video and audio markets too narrowly, retaining all parts of the radio and television ownership rules, and tightening Note 11 of the television ownership rule.The FCC's 2023 Order was issued after the 2018 Quadrennial Review, which included a notice of proposed rulemaking and a public comment period. The FCC retained the Local Radio Ownership Rule and the Local Television Ownership Rule, defining the markets narrowly to exclude non-broadcast sources. The FCC justified its decision by emphasizing the unique aspects of broadcast sources and the need to prevent excessive consolidation. The FCC also modified Note 11 to prevent circumvention of the Top-Four Prohibition by including low-power TV stations and multicast streams.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the FCC acted arbitrarily and capriciously in retaining the Top-Four Prohibition part of the television ownership rule and improperly tightened Note 11. The court vacated and remanded the Top-Four Prohibition and the amendment to Note 11 but withheld the issuance of the mandate for 90 days to allow the FCC an opportunity to provide adequate justification. The court denied the remainder of the petition, upholding the FCC's market definitions and retention of the Local Radio Ownership Rule and the Two-Station Limit. View "Zimmer Radio of Mid-Missouri, Inc. v. Federal Communications Commission" on Justia Law

Andrew and Jessie Welsh purchased The Press Bar and Parlor in 2016, managing it through two entities: Horseshoe Club, LLC, which owned the real estate, and Timeless Bar, Inc., which operated the bar. Andrew and Jessie were the sole members and officers of both entities. Illinois Casualty Company (ICC) issued a business owner’s policy covering the bar’s property and operations. Timeless Bar was the named insured, and Horseshoe Club was an additional insured. After their divorce in November 2019, Andrew took sole control of the businesses’ finances. On February 17, 2020, a fire destroyed The Press Bar and Parlor. Andrew and Jessie submitted a claim to ICC, stating the fire was of unknown origin. However, an investigation revealed Andrew had intentionally set the fire, leading to his conviction for arson. ICC denied the claim based on policy exclusions for concealment, misrepresentation, fraud, dishonesty, and intentional acts.The United States District Court for the District of Minnesota dismissed Jessie’s claims due to her lack of standing as a non-insured. On cross-motions for summary judgment, the court ruled in favor of ICC, attributing Andrew’s conduct to both business entities and concluding the policy did not cover the loss. The court also held that Minnesota’s statutory protection for innocent co-insureds did not extend to corporate entities.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The court affirmed the district court’s judgment, holding that Andrew’s misrepresentations were attributable to the business entities, and thus, ICC was justified in denying coverage. The court found no basis in Minnesota law to extend the innocent co-insured doctrine to corporations or limited liability companies. View "Timeless Bar, Inc. v. Illinois Casualty Co." on Justia Law

Ada Martinez-Medina, a Hispanic female of Puerto Rican descent, worked for the United States Department of Agriculture (USDA) and alleged that her supervisor assigned her work above her pay grade and took credit for her work. She filed two Equal Employment Opportunity (EEO) complaints alleging discrimination, retaliation, and a hostile work environment, which were settled in August 2018. After the settlement, she experienced further issues, including a delayed performance review and derogatory comments from her acting supervisor. She filed another EEO complaint in March 2019, which was denied, leading her to file a lawsuit in federal district court.The United States District Court for the Western District of Missouri granted summary judgment in favor of the defendant, the Secretary of the USDA, finding that Martinez-Medina had not presented sufficient evidence to support her claims of disparate treatment, hostile work environment, and retaliation.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Martinez-Medina did not establish a prima facie case of disparate treatment because the alleged adverse employment actions did not affect an identifiable term or condition of her employment. Additionally, the court found that she did not present evidence that the employer's legitimate, nondiscriminatory reason for not granting her reassignment request was pretextual.Regarding the hostile work environment claim, the court concluded that the incidents Martinez-Medina cited were not severe or pervasive enough to alter the conditions of her employment. For the retaliation claim, the court determined that there was no causal link between her protected EEO activity and the alleged retaliatory acts.The Eighth Circuit affirmed the district court's judgment, granting summary judgment to the defendant on all claims. View "Martinez-Medina v. Rollins" on Justia Law

Adan Shamburger pleaded guilty to aiding and abetting the possession with intent to distribute fentanyl. Initially, the district court determined an advisory guideline range of 30 to 37 months’ imprisonment but varied upward and imposed a 48-month sentence, citing the lethality of fentanyl, Shamburger's distribution activities, violent tendencies, high risk of recidivism, and criminal history. Following a retroactive amendment to the United States Sentencing Guidelines, which altered the calculation of criminal history scores, Shamburger's advisory guideline range was reduced to 24-30 months. Consequently, the district court reduced his sentence to 46 months.The United States District Court for the Western District of Arkansas initially sentenced Shamburger to 48 months. After the Sentencing Commission's Amendment 821, which was made retroactive, the district court reduced his sentence to 46 months. Shamburger argued that the reduction was unreasonable and that the court should have shortened his sentence further, given the new advisory guideline range.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 district court did not abuse its discretion in reducing Shamburger's sentence by only two months. The court explained that there is no presumption that a sentence reduction must be proportional to the original sentence within the new advisory range. The district court's decision to impose a sentence close to the original term, despite the lower amended guideline range, was deemed permissible. The appellate court also found no procedural error, as the district court adequately explained its reasoning by referencing its previous discussion of the § 3553(a) factors and the seriousness of the offense conduct. View "United States v. Shamburger" on Justia Law

Two children, a nine-year-old girl and her eight-year-old brother, reported sexual abuse by their stepfather, who lived with them and their mother. After the children disclosed the abuse to a nurse practitioner, law enforcement obtained consent to search the family’s residence, seizing a red iPhone and the children’s bedding. Investigators discovered that the stepfather had shared child pornography via the Mega file-sharing service. Upon questioning, he admitted ownership of the phone, provided its password, and consented to its search. Investigators found videos on the phone and Mega account depicting the children in sexually explicit situations, with the stepfather’s voice directing them. DNA evidence linked him to semen found on the children’s bedding.A grand jury indicted the stepfather on two counts of sexual exploitation of a minor, two counts of committing those offenses while on the sex offender registry, and one count of possession of child pornography. After a bench trial in the United States District Court for the District of Nebraska, the court found him guilty on all counts and sentenced him to 720 months in prison and a life term of supervised release.On appeal to the United States Court of Appeals for the Eighth Circuit, the defendant challenged the sufficiency of the evidence for two counts, the admission of certain evidence, and the reasonableness of his sentence. The Eighth Circuit held that the evidence was sufficient to support the convictions, even though the district court did not explicitly address each of the Dost factors for lascivious exhibition. The court also found no abuse of discretion or plain error in the admission of testimony from a prior victim, the nurse practitioner, or the forensic scientist, nor in the admission of a partially completed Miranda waiver form. The sentence was deemed reasonable. The Eighth Circuit affirmed the judgment of the district court. View "United States v. En Maati" on Justia Law

Ryan Vanicek was killed in a traffic accident when a tractor-trailer driven by Kenneth Kratt, on behalf of Sandair Corporation, collided with his pickup truck. Jessica Vanicek, Ryan's wife, filed a wrongful death and survival action against Kratt and Sandair. Lyman-Richey Corporation, Ryan's employer, intervened under Nebraska's worker's compensation statute. A magistrate judge struck Jessica's claim for punitive damages and denied her leave to amend her complaint. The district court later compelled a settlement over Jessica's objection and ordered the funds to be deposited without post-judgment interest.The United States District Court for the District of Nebraska initially referred the issue of punitive damages to a magistrate judge, who struck the claim, applying Nebraska law. The district court overruled Jessica's objection to this order. The district court also granted summary judgment to the defendants on the claims for negligent infliction of emotional distress and denied a motion for partial summary judgment on pre- and post-impact damages. The district court approved a $5 million settlement proposed by Lyman-Richey, finding it fair and reasonable based on expert reports and the defendants' insurance policy limits. Jessica appealed the denial of her motion to amend and the settlement approval.The United States Court of Appeals for the Eighth Circuit dismissed Jessica's appeal regarding the denial of her motion to amend for lack of jurisdiction, as she failed to object to the magistrate judge's order in the district court. The court affirmed the district court's approval of the settlement, finding no abuse of discretion in its evaluation of damages and the defendants' ability to satisfy the judgment. The court also upheld the district court's decision to deny post-judgment interest, concluding that Jessica was estopped from claiming it due to her attorney's dilatory conduct. View "Vanicek v. Lyman-Richey Corp." on Justia Law

Federal agents conducted a "buy-bust" operation in Des Moines, Iowa, targeting Aldo Ali Cordova Perez, Jr., who was driving a gold Dodge Durango. During the operation, Cordova Perez attempted to flee, leading to a high-speed chase that ended with his arrest. Officers found a large quantity of methamphetamine in his vehicle and a small bag of marijuana in his pocket. Cordova Perez admitted to using marijuana daily and owning a .22-caliber rifle, which was found in his home.The United States District Court for the Southern District of Iowa tried Cordova Perez on multiple charges, including possession with intent to distribute a controlled substance and possessing a firearm as an unlawful drug user. The jury acquitted him of all charges except for the firearm possession under 18 U.S.C. § 922(g)(3). The district court denied his motion for acquittal, finding the statute constitutional both facially and as applied, and sentenced him to 36 months in prison.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court vacated the conviction and remanded for further proceedings, citing the need to reassess the as-applied challenge in light of United States v. Cooper. The court instructed the district court to determine whether Cordova Perez's marijuana use caused him to act dangerously or posed a credible threat to others' safety with a firearm. The court emphasized that the district court should make explicit findings on whether his conduct was consistent with historical firearm regulations. View "United States v. Perez" on Justia Law

William Dahl was charged with production and receipt of child pornography based on two separate incidents. In the first, Dahl, then 36, communicated with a 16-year-old girl, S, via social media, provided her with gifts, and received a nude video from her over Snapchat. In the second incident, Dahl engaged in sexually explicit conversations with the mother of a seven-year-old girl, M, who then produced and sent Dahl images of M’s genitals. Dahl admitted to receiving both the video and the images but claimed he intended to turn the images over to police and believed S was 17.The United States District Court for the Eastern District of Missouri conducted a bench trial and found Dahl guilty of production of child pornography and two counts of receipt of child pornography. At sentencing, the district court ordered Dahl’s federal sentence to run consecutively to sentences in six pending Missouri state cases. However, the record was unclear as to whether the court intended the federal sentence to run consecutively to state sentences involving the same victims or relevant conduct.The United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence and the sentencing order. The court held that, viewing the evidence in the light most favorable to the verdict, a reasonable factfinder could conclude that the materials received by Dahl constituted child pornography under federal law, applying the Dost factors as required by circuit precedent. The court affirmed Dahl’s convictions. However, because of ambiguity regarding whether the federal sentence was intended to run consecutively to all state sentences or only those unrelated to the federal offenses, the Eighth Circuit vacated the sentence and remanded the case for the district court to clarify its sentencing intent. View "United States v. Dahl" on Justia Law

Miguel Alcantar Mercado participated in a drug distribution operation, possessing and distributing over 1,300 grams of heroin and wiring more than $45,000 in drug proceeds. He pled guilty to conspiracy to distribute a controlled substance. The United States Probation Office calculated an advisory Guidelines range of 210 to 262 months’ imprisonment, factoring in his criminal history. The district court sentenced him to 204 months, six months below the Guidelines range, considering both the seriousness of the offense and mitigating factors such as his modest criminal history and family support.Following a retroactive amendment to the Sentencing Guidelines, which revised the calculation of criminal history categories, Alcantar Mercado’s criminal history category was reduced from III to II, making his new Guidelines range 188 to 235 months. This made him eligible for a discretionary sentence reduction. The Probation Office identified him as eligible, noting his good behavior and participation in rehabilitative programs. However, the district court declined to modify his sentence, stating that the variance he received was consistent with the new Guidelines range.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The court found that the district court had considered the relevant factors under 18 U.S.C. § 3553(a) and noted Alcantar Mercado’s good behavior. The appellate court held that the district court was not required to provide a lengthy explanation for its decision and that its consideration of the factors was sufficient. The Eighth Circuit affirmed the district court’s judgment, concluding that the decision was within the permissible range of discretion. View "United States v. Mercado" on Justia Law