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

The St. Louis County Police Department (“SLCPD”) in Missouri utilizes what it calls a “Wanteds System.” This system allows officers to issue electronic notices (“Wanteds”) authorizing any other officer to seize a person and take him into custody for questioning without any review by a neutral magistrate before issuance. The Wanteds may pend for days, months, or, in some cases, indefinitely.   The Eighth Circuit affirmed the district court’s grant of qualified immunity to Officers and its dismissal of the municipal liability claim and Count Three. The court reversed the district court’s grant of qualified immunity to the Detective. The court explained that the Wanteds System is broad enough to encompass situations that do not violate the Constitution, including those involving an arrest immediately after an officer has entered a wanted. The court wrote that Plaintiffs’ facial challenge to the Wanteds System fails. Further, the court explained that the SLCPD Wanteds System, although fraught with the risk of violating the Constitution in certain circumstances and/or the danger of evidence being suppressed due to an invalid arrest, is not facially unconstitutional. The burden is then on Plaintiffs to show a persistent pattern of unconstitutional misconduct. The court concluded that the evidence in the record does not show a persistent pattern of unconstitutional arrests so pervasive that it can be said to constitute custom or usage with the force of law. Nor do the proposed classes describe a group of individuals who demonstrate that such a custom or practice exists. The district court did not err in dismissing the Plaintiffs’ municipal liability claim. View "Dwayne Furlow v. Jon Belmar" on Justia Law

Dakotans for Health (“DFH”), a South Dakota ballot question committee, sought to place a constitutional amendment measure on South Dakota’s 2022 general election ballot. To get on the ballot, DFH would need to submit nearly 34,000 valid signatures to the South Dakota Secretary of State. When DFH filed its complaint, it employed a paid petition circulator, Pam Cole, to help it obtain these signatures. The district court preliminarily enjoined South Dakota officials from enforcing these requirements. On appeal, the Appellants argued DFH does not have standing to challenge SB 180. Alternatively, they argue the preliminary injunction was unwarranted and improper and thus the district court abused its discretion by entering it.   The Eighth Circuit affirmed. The court concluded DFH is likely to succeed in showing SB 180 is facially invalid as overbroad in that it violates the First Amendment in a substantial number of its applications. It discriminates against paid circulators for reasons unrelated to legitimate state interests, reduces the pool of circulators available to DFH, and restricts the speech of DFH by sweeping too broadly in its requirements. Put another way, SB 180 is not narrowly tailored to serve South Dakota’s important interests.   Further, the court concluded that the balance of harms and the public interest also favor DFH. While South Dakota has important interests in protecting the integrity of the ballot initiative process, it has no interest in enforcing overbroad restrictions that likely violate the Constitution. Thus, the court found that DFH has satisfied the requirements for issuance of a preliminary injunction and that the district court did not abuse its discretion. View "Dakotans for Health v. Kristi Noem" on Justia Law

An officer initiated a traffic stop of Plaintiff. Plaintiff felt the stop was pretextual, and fled. The officer initiated a PIT maneuver to end the pursuit, causing Plaintiff crashed his vehicle into a light pole and was injured. Plaintiff filed various civil rights claims against the police department. The district court granted summary judgment for the police department.The Eighth Circuit affirmed, finding that the police department guidelines and policies concerning use of a PIT maneuver did not create rights that give rise to a Section 1983 action, and an officer's knowing violation of the guidelines and policies does not transform his actions into unconstitutional behavior. View "Dean Christiansen v. Christopher Eral" on Justia Law

Defendant appealed the district court’s denial of his motion to dismiss the Government’s petition for civil commitment under 18 U.S.C. Section 4246. Defendant argued that the Middle District of Tennessee violated the time restrictions in Section 4241(d), depriving the Western District of Missouri of subject matter jurisdiction to civilly commit him under Section 4246 because the timing violation he was no longer lawfully “committed to the custody of the Attorney General pursuant to section 4241(d).”   The Eighth Circuit affirmed. The court explained that Defendant did not object to the alleged Section 4241(d) timing violations in the Middle District of Tennessee. Although did he complain to the Middle District of Tennessee in status updates about the delays on the grounds that they violated his rights to a speedy trial and due process. But he never formally requested release, filed an appeal in the Sixth Circuit, or requested a writ of mandamus from the Sixth Circuit. Thus, Defendant waived his right to challenge the alleged Section 4241(d) timing violations. Because the alleged Section 4241(d) timing violations are the basis of Defendant’s Section 4246 challenge, his Section 4246 challenge fails. View "United States v. Andrew Ryan" on Justia Law

=Public Water Supply District No. 1 of Greene County, Missouri (“PWSD”) and the City of Springfield, Missouri (the “City”) filed cross motions for summary judgment, and the district court1 granted summary judgment in favor of the City. The district court also denied PWSD’s subsequent motion to alter or amend the judgment under Rule 59(e) of the Federal Rules of Civil Procedure. PWSD appealed these decisions. PWSD asserts its claims are timely under the continuing-violations doctrine because the City continues to provide water to customers within the Disputed Subdivisions.   The Eighth Circuit affirmed the finding that PWSD’s claims are time-barred. Here, it is undisputed that the City began serving each of the Disputed Subdivisions in or before 1994. Based on the principles set forth above, a § 1926(b) violation must occur (and the statute of limitations accrues) when a municipality begins providing service to a new subdivision, and “not when it continues to do so.” Contrary to PWSD’s contention, it is not a continuing violation, and the statute of limitations does not reset when a municipality continues to add and provide service to customers in a subdivision it already serves. View "Public Water Supply District No. 1 of Greene Co v. City of Springfield, Missouri" on Justia Law

In response to President Biden's Executive Order 13990, the State of Missouri and twelve other States ("the States") then filed this action against President Biden, the Interagency Working Group on the Social Cost of Greenhouse Gases and other agencies, asserting four causes of action: (1)“Violation of the Separation of Powers;” (2) “Violation of Agency Statutes;” (3)“Procedural Violation of the APA”; and (4) “Substantive Violation of the APA.”The district court concluded the States lack Article III standing and their claims are not ripe for adjudication, granted Defendants’ motion to dismiss for lack of subject matter jurisdiction, and denied Plaintiffs’ motion for a preliminary injunction as moot. The States appealed.The Eighth Circuit affirmed, finding that the States' request for the court to grant injunctive relief that directs “the current administration to comply with prior administrations’ policies on regulatory analysis [without] a specific agency action to review,” is “outside the authority of the federal courts” under Article III of the Constitution. View "State of Missouri v. Joseph Biden, Jr." on Justia Law

Plaintiff sued police officer under 42 U.S.C. Section 1983 after the police officer deployed pepper spray in Plaintiff’s face. The district court concluded that Plaintiff was engaged in protest activity protected by the First Amendment, and that there was sufficient evidence for a reasonable jury to find that the police officer used force against Plaintiff because she exercised her constitutional right to freedom of speech. Defendant appealed, and argued that he is entitled to qualified immunity from suit.   The Eighth Circuit affirmed finding that there is no reversible error. The court explained that the district court’s determination that a reasonable jury could find that the police officer acted with retaliatory motive is a matter of evidence sufficiency that is not appealable at this juncture. The court further held that the police officer’s argument based on “arguable probable cause” fails for other reasons as well. Probable cause is a constitutional standard under the Fourth does not argue that this case involves a search or seizure, and he does not explain why the asserted existence of “arguable probable cause” would be dispositive as a matter of law on a claim alleging retaliatory use of force in violation of the First Amendment. View "Essence Welch v. Daniel Dempsey" on Justia Law

A jury convicted Defendant n of conspiracy to distribute methamphetamine and possession with intent to distribute methamphetamine. The district court sentenced him to a term of 300 months in prison. Defendant appealed his conviction. Defendant challenged the denial of his motion for judgment of acquittal.   The Eighth Circuit affirmed. The court explained that the evidence presented by the government was sufficient to allow a reasonable jury to find Defendant guilty on both counts. Overall, the evidence, taken in the light most favorable to the verdict, supports the conclusion that Defendant had a role in the drug conspiracy and possessed methamphetamine with the intent to distribute.   Defendant also argued the district court erred in allowing a witness to read a text message from his phone while on the stand when that message had not been disclosed to the defense ahead of trial. The court found that the district court did not abuse its discretion in allowing the witness to read the undisclosed text message on the stand. The court allowed Defendant’s counsel to review the text message over lunch. And Defendant’s counsel did not ask for more time to view the message, ask for a continuance, or even renew his objection following that review. While this process is not what Rule 16 envisions or requires, the defense did have an opportunity to examine the text message and cross-examine the witness about it at trial. View "United States v. Marcus Nelson" on Justia Law

Defendant previously pleaded guilty to selling cocaine in Minnesota on two separate occasions. The district court held that these two convictions were not "serious drug offense[s]" under the Armed Career Criminal Act because Minnesota law defines "cocaine" more broadly than federal law.The Eighth Circuit affirmed, holding that "a drug statute that criminalizes even one additional isomer does not qualify as a 'serious drug felony.'” Here, Minnesota law prohibits all isomers of cocaine, while federal law prohibits only optical and geometric isomers. Thus, because Minnesota law sweeps more broadly than federal law in this regard, Defendant's cocaine convictions do not count as "serious drug offense[s]" under the Armed Career Criminal Act. View "United States v. Maurice Owen" on Justia Law

Plaintiff sought accidental death benefits under an employee benefit plan governed by the Employee Retirement Income and Security Act of 1974 (ERISA) after his wife died from injecting herself with a cocktail of unprescribed narcotics. The district court upheld the Life Insurance Company of North America’s (LINA) decision to deny benefits based on a policy exclusion for the “voluntary ingestion of any narcotic, drug, poison, gas or fumes unless prescribed or taken under the direction of a Physician.” Plaintiff appealed, contending that the district court erred because LINA’s decision was unreasonable and not supported by substantial evidence.   The Eighth Circuit affirmed. The court decided that LINA’s interpretation of “ingestion” was reasonable. The court then turned to whether LINA’s application of its interpretation to the facts is supported by substantial evidence. Here, the wife undisputedly died because she willingly injected herself with a combination of unprescribed narcotics. Therefore, there is sufficient evidence to support LINA’s application of the voluntary ingestion exclusion to the wife’s death. Thus, because the court agreed with the district court’s conclusion that LINA’s denial of benefits was justified in light of the voluntary ingestion exclusion, the court wrote it need not address LINA’s assertion that the wife’s death was not accidental. View "Jay Richmond v. Life Insurance Company" on Justia Law