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

After her husband died of a heroin overdose, Plaintiff sought accidental death benefits under an employer-sponsored benefit plan governed by the Employee Retirement Income Security Act of 1974 (ERISA). The plan’s insurer, Symetra Life Insurance Company, denied her claim, and Plaintiff sued. The district court granted summary judgment in Plaintiff’s favor. Symetra appealed, arguing that Plaintiff’s suit is barred by her failure to exhaust internal review procedures and that her husband’s death otherwise falls under an exclusion to coverage.   The Eighth Circuit affirmed. Symetra contends that the exclusion applies to Plaintiff’s husband’s death because he “purposely” used heroin. But just because the act of using an illegal substance is purposeful does not mean that an injury stemming from that act, including a fatal overdose, was too. Symetra also maintains that Plaintiff’s husband, as a “longtime drug user,” was surely aware of the risks of using heroin and that his “generalized knowledge” of such risks is sufficient for his death to fall under the “intentionally self-inflicted injury” exclusion. The court reasoned that even assuming Symetra’s characterization of Plaintiff’s husband’s drug use is accurate, the argument attempts to replace an exclusion that applies only to “intentionally self-inflicted” injuries with one that also includes injuries resulting from reckless, or even negligent, conduct. The court wrote that the plain language of Symetra’s “intentionally self-inflicted injury” exclusion does not apply to unintended injuries like Plaintiff’s husband’s heroin overdose. Thus, Symetra’s denial of Plaintiff’s claim for accidental death benefits based on that exclusion was erroneous. View "Terri Yates v. Symetra Life Insurance Company" on Justia Law

Plaintiff fled when Defendant police officer stopped him based on an outstanding warrant for fifth-degree theft. At the nearby police station, Plaintiff briefly refused to obey Defendant’s command to exit the squad car and proceed to the station for booking. When the handcuffed Plaintiff finally exited the car and stood up, Defendant struck him with his fist on the back of the head and neck. Plaintiff brought this action for excessive force under 42 U.S.C. Section 1983 and asserted pendent Iowa state law claims for tortious assault and battery. The district court granted summary judgment dismissing both claims on the ground that the force used was objectively reasonable. Alternatively, the court ruled that Church was entitled to qualified immunity on the federal Section 1983 claim because any constitutional violation was not clearly established. Plaintiff appealed.   The Eighth Circuit concluded that genuine issues of disputed facts preclude a determination, on this summary judgment record, of whether the alleged unlawful use of excessive force was objectively reasonable and, if not, whether the violation was clearly established at the time of the incident in question. Accordingly, the court reversed the dismissal of all claims, including Plaintiff’s pendent state law claims. View "Derek Westwater v. Kevin Church" on Justia Law

A jury convicted Defendant of being a felon in possession of a firearm and possessing a firearm in furtherance of a drug trafficking crime. The district court denied his motion for a new trial in a thirty-page Order and sentenced Defendant as an armed career criminal to 360 months imprisonment. The court also revoked Defendant’s supervised release and imposed a consecutive fifty-four-month sentence. Defendant appealed his conviction and sentence, arguing there was insufficient evidence to convict him of the firearm offenses; the district court committed evidentiary errors and improperly instructed the jury; the government committed Brady violations; his trial counsel was ineffective; and the district court erred in sentencing him as an armed career criminal and abused its discretion in revoking supervised release.   The Eighth Circuit affirmed the conviction but, based on an intervening armed-career-criminal decision, remanded for resentencing.  The court explained that at oral argument, without conceding the merits of these issues, government counsel conceded that United States v. Perez, 46 F.4th 691 (8th Cir. 2022), would require a different outcome and, therefore, the court should remand for further proceedings on whether Defendant was properly sentenced under the ACCA. The court agreed that is the proper course of action. As the district court may decide that the Iowa convictions are no longer proper ACCA predicate offenses, an issue the court did not decide, that would moot the question of whether the Georgia conviction is a qualifying ACCA predicate, absent a second appeal. View "United States v. Kenny Smart" on Justia Law

Defendant pleaded guilty to possession of a firearm by a felon in violation of 18 U.S.C Section 922(g)(1) pursuant to a written plea agreement. He later moved to withdraw his guilty plea when the probation office determined that he had three or more prior convictions “for a violent felony or a serious drug offense,” which qualified him for a mandatory minimum sentence of 15 years imprisonment under the Armed Career Criminal Act (“ACCA”). At sentencing, the district court denied Defendant’s motion, reasoning that the plea agreement expressly stated that Defendant may be subject to a mandatory minimum sentence under the ACCA and that this would not be grounds for withdrawal of his plea. The district court then concluded that Defendant’s prior convictions indeed qualified him for a 15-year sentence under the ACCA and sentenced him accordingly. Defendant argued that the district court erred by not allowing him to withdraw his guilty plea and by finding that his criminal history included three ACCA predicate offenses.   The Eighth Circuit affirmed. The court consulted the indictment to which Defendant pleaded guilty. The court explained that the language makes clear that Defendant pleaded guilty to the Section 571.030.1(9) offense of shooting at other persons from a motor vehicle. The final step, then, is to determine whether this offense has a physical-force element. The court concluded that it does because there is no “non-fanciful, non-theoretical manner” to knowingly shoot at other persons from a motor vehicle “without so much as the threatened use of physical force.” View "United States v. Clarence Harris" on Justia Law

A jury convicted Defendant of aggravated sexual abuse, and the district court sentenced him to 440 months in prison. Defendant appealed his conviction. The Eighth Circuit affirmed. The court explained that Defendant claims the district court erred “by failing to instruct the jury that it had to agree on the specific act of sexual abuse in order to convict.” However, Defendant cites no authority that failure to give a specific unanimity instruction. To the contrary, the Eighth Circuit has held that jurors need not agree on a specific sexual act to reach a unanimous verdict.   Further, Defendant contends the district court erred in admitting hearsay statements regarding the reports of abuse. The court wrote that the statement was limited in scope to the victim’s disclosure of the abuse, not the specifics of it. But even if the statements were inadmissible hearsay, their admission would be harmless given the other evidence against Defendant.   Moreover, Defendant maintains he was deprived of his Fifth Amendment right to a fair trial because the government’s closing argument “distorted its burden of proof and unfairly mischaracterized Defendant’s theory of the case.” Even if the closing were improper, under plain error review, the Eighth Circuit wrote it will “reverse only under exceptional circumstances,” which requires that Defendant show “a reasonable probability that the outcome would have been different absent the alleged error.” The evidence and the district court’s instructions show this is not an exceptional case where the conviction is overturned based solely on a prosecutor’s statements during closing argument. View "United States v. Adam Poitra" on Justia Law

Following a six-week trial in 1998, a federal jury convicted Defendant of twelve crimes he committed as part of the 6-0 Tres Crips, including the five murders (Counts 51-55) and conspiracy to distribute cocaine and crack cocaine (Count 2). Under the mandatory sentencing guidelines then in effect, the district court imposed statutory maximum life imprisonment sentences on those counts. Defendant sought Section 2255 relief under Section 404 of the First Step Act of 2018, which made relief under Sections 2 and 3 of the Fair Sentencing Act of 2010 available to eligible defendants sentenced prior to 2010. Invoking the concurrent sentence doctrine, the district court denied First Step Act relief. On appeal, Defendant argued that the district court abused its discretion by employing the concurrent sentence doctrine to avoid resentencing Defendant.   The Eighth Circuit affirmed. The court wrote that in reviewing the district court’s use of the concurrent sentence doctrine for an abuse of discretion, the district court applied the doctrine consistent with controlling Eighth Circuit decisions. The court explained that when, as here, the district court ruling on a First Step Act motion initially sentenced the defendant and later granted a sentence reduction, the court’s “plain statement” that it declined to exercise its discretion to grant a further reduction “closes the matter.” The district court properly treated the concurrent sentence doctrine as “a species of harmless-error review.” As it applied the proper analysis in invoking the doctrine, and its analysis is consistent with our First Step Act precedents, there was no abuse of its broad First Step Act discretion. View "United States v. Robert Jefferson" on Justia Law

Appellees raised a First Amendment challenge to South Dakota’s statutory deadlines to submit petitions to initiate South Dakota statutes and to amend the South Dakota Constitution. After a bench trial, the district court agreed the filing deadline for petitions to initiate statutes violates the First Amendment to the United States Constitution, but the filing deadline for petitions to amend the state Constitution does not. The district court then permanently enjoined three South Dakota officials from enforcing the unconstitutional deadline and crafted a new filing deadline.   The Eighth Circuit affirmed the district court’s holding that the filing deadline in South Dakota Codified Laws Section 2-1-1.2 violates the First Amendment, reversed the holding that the filing deadline in South Dakota Codified Laws Section 2-1-1.1 does not violate the First Amendment, and remanded with instructions to modify the permanent injunction. Further, the court denied the dueling motions to strike party submissions. The court explained that South Dakota’s filing deadline of one year before a general election “imposes a burden on political expression that the State has failed to justify.” In other words, South Dakota failed to provide evidence connecting the one-year deadline to its asserted interests. Further, in applying the same legal framework and record available for the filing deadline under South Dakota Codified Laws Section 2-1-1.2, the court concluded that the filing deadline under South Dakota Codified Laws Section 2-1- -15- 1.1 also violates the First Amendment. Finally, the court found that prescribing a new filing deadline is outside the scope of the district court’s authority. View "SD VOICE v. Kristi Noem" on Justia Law

The United States Department of Agriculture (“USDA”) permanently disqualified Euclid Market Inc. (“Euclid Market”) from the Supplemental Nutrition Assistance Program (“SNAP”) after it determined Euclid Market had unlawfully trafficked SNAP benefits. After the USDA issued its final decision, Euclid Market filed an action in federal court under 7 U.S.C. Section 2023, requesting the district court set aside the USDA’s final decision. The district court found Euclid Market did not meet its burden to show the USDA’s action was invalid and entered judgment in favor of the government. Euclid Market appealed. Euclid Market argued that the district court erred by requiring it to produce transaction-specific evidence for every transaction raised by the USDA to meet its burden of proof.   The Eighth Circuit vacated the judgment and remanded. The court agreed with Euclid Market that the transaction-specific standard is erroneous and that the district court applied such a standard in this case. A store’s failure to provide transaction-specific evidence for every transaction does not inherently doom its case. Concluding otherwise would create unnecessary tension with the fundamental principles of evidence. Further, a hardline rule that a store cannot prevail without transaction-specific evidence for each transaction raised by the USDA is inconsistent with the district court’s rightful discretion in weighing all of the relevant, admissible evidence to determine the validity of the disqualification by a preponderance of the evidence. View "Euclid Market Inc. v. United States" on Justia Law

After Plaintiff prevailed at trial and was awarded $58,240 in damages, plus post-judgment interest, Plaintiff sought attorneys’ fees in the amount of $701,706, litigation costs in the amount of $43,089.48, and additional filing and transcript-preparation fees in the amount of $1,620.45. The district court ultimately awarded attorneys’ fees in the amount of $570,771 and filing and transcript-preparation fees in the amount of $1,620.45 but denied the request for litigation costs. Defendant BNSF Railway Company (BNSF) appealed, asserting that the district court abused its discretion with respect to the award of attorneys’ fees.   The Eighth Circuit affirmed in part, reversed in part, and reduced the award of fees by $103,642.50. BNSF first argued that the award of fees is unreasonable because Plaintiff only achieved limited success. The court reasoned that Plaintiff undisputedly prevailed at trial on his FRSA claim. As this claim was at the heart of Plaintiff’s case, his degree of success is significant, regardless of the fate of his FELA claim or another theory of liability underlying his FRSA claim.   However, the court found that BNSF’s request for the reduction of fees related to the first trial, however, has merit. The court wrote that Plaintiff undisputedly offered the jury instruction that contained a legal error based on Eighth Circuit precedent, which required vacatur of the judgment. The court agreed with BNSF that Plaintiff is not entitled to fees that were unreasonably caused by his own legal error. View "Edward Blackorby v. BNSF Railway Company" on Justia Law

After a jury convicted Defendant, former Sheriff of Franklin County, Arkansas, of depriving two jail detainees of their constitutional rights by subjecting them to unreasonable force that resulted in bodily injury, the district court sentenced Defendant to 48 months imprisonment, followed by 2 years of supervised release. Defendant challenged both his conviction and his sentence.   The Eighth Circuit affirmed. The court held that the district court’s finding that Defendant attempted to influence Ball’s testimony was not clearly erroneous and sufficiently supports the district court’s application of the obstruction-of-justice enhancement. The district court sentenced Defendant to a within-Guidelines sentence of 48 months’ imprisonment. Defendant argued in a cursory fashion that his sentence is “greater than necessary,” given the alleged de minimis nature of his victims’ injuries and the purported bias of the witnesses at trial. However, the district court discussed Section 3553(a) factors in-depth and considered the proffered mitigating and aggravating circumstances in crafting the sentence. View "United States v. Anthony Boen" on Justia Law