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

The Northwest Arkansas Conservation Authority is a public corporation created to handle wastewater treatment for municipalities in northwest Arkansas. After a series of pipeline failures, the Authority sued the pipeline contractor and its surety, alleging deficient construction. The Authority sued outside the time periods specified in the relevant statutes of limitations and repose, but asserted that the time did not run against its claims, because the Authority was suing as a public entity seeking to vindicate public rights. The district court concluded that the rights the Authority sought to enforce were merely proprietary and that its claims were therefore time-barred.   The Eighth Circuit affirmed. The court explained that the relevant proprietary interests are not transformed into public rights just because the Authority spent public money to repair the pipeline. Every action by a public entity impacts the public fisc to some degree. But if financial implications alone were enough to invoke nullum tempus, then the public-rights exception would swallow the general rule that statutes of limitations and repose run against municipal entities. Here, the damages sought would replenish the public entity’s coffers, but the relief would not vindicate a distinct public right. The Authority therefore cannot invoke nullum tempus to avoid the statutes of limitations or repose. View "NW AR Conservation Authority v. Crossland Heavy Contractors" on Justia Law

Plaintiffs, independent contractors of American Family Life Insurance Company of Columbus (Aflac), alleged that an Aflac employee, sexually assaulted Plaintiff in her hotel room during a work conference in St. Louis, Missouri. Plaintiffs filed suit against Defendant, asserting tort claims for battery, assault, false imprisonment, and loss of consortium, among others. the beneficiary under Plaintiffs’ Arbitration Agreements with Aflac. The district court denied the motion as to the aforementioned claims, holding that they did not arise under or relate in any way to the arbitration agreements. Defendant appealed, arguing that the claims fall within the scope of the arbitration agreements.   The Eighth Circuit affirmed. The court held that Plaintiffs’ tort claims do not fall within the scope of the Arbitration Agreements. The facts underlying Plaintiffs’ tort claims do not touch matters covered by Plaintiffs’ Arbitration Agreements in light of the Agreements’ limiting language requiring the “dispute arise under or relate in any way to the Associate’s Agreements. As a result, the district court did not err in denying Defendant’s motion to compel arbitration. View "Katherine Anderson v. Jeffrey Hansen" on Justia Law

Defendant pleaded guilty to conspiracy to distribute methamphetamine and possession with intent to distribute methamphetamine. He appealed the district court’s application of the career-offender sentencing enhancement and the substantive reasonableness of his sentence.   The Eighth Circuit affirmed. At sentencing, the Government agreed with Defendant that assault on a police officer under Iowa Code section 708.3A(3) is indivisible. Now, Defendant and the Government agree that section 708.3A(3) is divisible. Nevertheless, the court concluded that the statute is indivisible. The court explained that here, the crime of assault against a peace officer is not divisible on the ground that assault has alternatives, some of which lack a force element. The assault alternatives in section 708.1(2) are merely different means of satisfying the assault element of section 708.3A(3). Nor is section 708.3A(3) divisible on the ground that it can be committed by causing bodily injury or mental illness.   Thus, because section 708.3A(3) is indivisible, the court applied the categorical approach. The court wrote that Defendant does not identify any Iowa cases or his own case where section 708.3A(3) was applied in a way that did not involve at least the threatened use of physical force. Thus, Defendant’s conviction of assault on a peace officer qualifies as a crime of violence under Section 4B1.2.   Further, Defendant’s sentence is not substantively unreasonable. The advisory guidelines range was 262 to 327 months imprisonment, and Defendant was sentenced to 262 months imprisonment. Therefore, the court presumed that Defendant’s sentence is substantively reasonable View "United States v. Levi Hamilton" on Justia Law

A class of inmates who were juvenile offenders sued the state officials responsible for administering the parole process. The inmates alleged that the policies and practices of the parole officials violated their rights to be free from cruel and unusual punishment and to due process of law under the federal and Missouri constitutions. The district court determined that the parole review practices were constitutionally deficient, and ordered the State to implement an elaborate remedial plan.   The State appealed, and the Eighth Circuit concluded that there is no constitutional violation. The court explained that the Supreme Court’s juvenile-specific jurisprudence under the Eighth Amendment does not warrant declaring a constitutional violation and imposing on the State the elaborate set of parole procedures endorsed by the district court. A requirement to allow “some meaningful opportunity” for release, even if applicable to these juvenile homicide offenders, is satisfied here. The juvenile homicide offenders in Missouri received more process than offenders under the regular parole process: they presented more documentary evidence than adult offenders, received longer hearings than the average parole hearing, and were entitled to consideration of statutory factors that apply only to juveniles who were formerly sentenced to life without parole. View "Norman Brown v. Anne Precythe" on Justia Law

A jury convicted Defendant of conspiracy to distribute tetrahydrocannabinol (THC), in violation of 21 U.S.C. Sections 841(a)(1), 841(b)(1)(C), and 846. Defendant appealed, arguing that the district court (1) abused its discretion by denying his motion for a continuance; (2) erred by admitting into evidence portions of recordings of phone calls that Defendant made from jail; (3) permitted trial delays that violated Defendant’s Sixth Amendment right to a speedy trial, and (4) erred at sentencing by declining to vary downward.   The Eighth Circuit affirmed. The court explained that Defendant has not established that the court abused its discretion. The trial occurred nearly a year after Defendant’s arrest and arraignment. Defendant replaced his attorney in August of 2020, but he still had more than five months to prepare for trial with his trial counsel’s assistance. Five months falls within a range found in cases where the court has concluded that there was adequate time.   Further, the court explained the delays, in this case, are not attributable to the government as they resulted from delays requested by codefendants or ordered by the court in which Defendant acquiesced. This means that the relevant period is between October 19, 2020, and January 11, 2021, the date Defendant’s trial began. Thus, the court held that the period of delay does not trigger presumptive prejudice. View "United States v. Muzammil Ali" on Justia Law

Plaintiff made contributions to a 401(k) plan during her employment at Honeywell International Inc. She originally designated her husband, Defendant, as the sole beneficiary in the event of her death. The parties later divorced and in the marital termination agreement (MTA), they agreed that Plaintiff will be awarded, free and clear of any claim on the part of Defendant’s, all of the parties’ right, title, and interest in and to the Honeywell 401(k) Savings and Ownership Plan. Plaintiff submitted a change-of-beneficiary form to Honeywell. She, however, did not comply with a requirement.   Plaintiff died in 2019 and Honeywell paid the benefits to Defendant. The personal representative of Plaintiff’s estate sued Honeywell for breach of fiduciary duty, and Defendant for breach of contract, unjust enrichment, conversion, and civil theft. The Eighth Circuit affirmed summary judgment for Honeywell and reversed summary judgment for Defendant on the breach of contract and unjust enrichment claims.   The court explained that even if the Plan gave the administrator discretion to accept Plaintiff’s defective Form, it is not an abuse of discretion to act in accordance with plan documents. ERISA directs administrators to “discharge [their] duties . . . in accordance with the documents and instruments governing the plan.” Thus, because Honeywell followed plan documents in rejecting Plaintiff’s defective change-of-beneficiary form and distributing benefits, the breach of fiduciary duty claim fails. Further, even if the MTA were ambiguous, a reasonable jury could find that Plaintiff and Defendant intended for the MTA to waive his beneficiary interest in the 401(k). View "Robert Gelschus v. Clifford Hogen" on Justia Law

Plaintiff was severely injured in a crash while he was driving a Peterbilt semi-truck. He sued the truck’s manufacturer, PACCAR, Inc. (PACCAR), alleging that the truck’s defective design caused his injuries. A jury returned a verdict in PACCAR’s favor. His estate appeals, arguing that the district court committed several evidentiary errors at trial.The Eighth Circuit affirmed. The court held, 1.) Plaintiff's expert's second report was untimely under the discovery orders in the case, and the district court did not abuse its discretion by excluding it; 2.) the district court did not abuse its discretion by concluding that plaintiff had failed to show the good cause required under Fed. R. Civ. P. 16(b)(4) to modify the scheduling order after the court declared a mistrial; 3.) Plaintiff failed to preserve his challenge to Defendant's "state-of-the-art" defense.Applying plain error review to Plaintiff's challenge to Defendant's "state-of-the-art" defense, the court held the district court did not plainly err in admitting the testimony as the witnesses were testifying based on their extensive industry experience, and noted that Iowa law permits industry custom as evidence of the state of the art. View "Elizabeth Zick v. Paccar, Inc." on Justia Law

Defendant was convicted of conspiracy to distribute cocaine base in 1997 and sentenced to 240 months imprisonment followed by 10 years’ supervised release, which, at the time, were minimum terms. The Eighth Circuit affirmed the conviction and sentence in 1998. After being released, Defendant violated the terms of his supervised release and was sentenced to 37 months imprisonment.In Many 2020, Defendant sought relief under the First Step Act. The government conceded First Step Act eligibility but opposed a reduction, arguing Defendant did not merit discretionary relief. The district court agreed Defendant was eligible but denied a First Step Act reduction. Defendant appealed. However, during the pendency of the appeal, Defendant was released from custody. Thus, the Eighth Circuit concluded that the matter was moot. View "United States v. Eugene Saunders" on Justia Law

Plaintiffs, a transgender youth, their parents, and two healthcare professionals, sought to enjoin Arkansas Act 626, which prohibits healthcare professionals from providing gender transition procedures to any individual under the age of 18 or from referring any such individual to any healthcare professional for gender transition procedures. The district court enjoined the Act, and the State appealed.The Eighth Circuit held that because a minor's sex at birth determines whether or not the minor can receive certain types of medical care under the law, Act 626 discriminates on the basis of sex. Thus, to be valid, the Act must be supported by an exceedingly persuasive justification. The Eighth Circuit determined that the Act prohibits medical treatment that conforms with the recognized standard of care for adolescent gender dysphoria and that the purpose of the Act is not to ban a treatment but to ban an outcome the State deems undesirable. Thus, the district court did not err in granting an injunction. View "Dylan Brandt v. Leslie Rutledge" on Justia Law

In this class action, participants in a drug and alcohol recovery program alleged the program assigned them to work for defendant Hendren, a private company that paid the program for their services. Plaintiffs alleged the defendants failed to pay them the required minimum wage. The district court held that plaintiffs were employees and granted them relief. Defendant appealed.On appeal, the Eighth Circuit reversed, finding that the fact that the work Plaintiffs performed as participants in a court-ordered recovery program benefited Hendren did not make the program participants employees of either the program or Hendren. Thus, because Plaintiffs were not employees, they were not entitled to relief. View "Mark Fochtman v. Hendren Plastics, Inc." on Justia Law