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

This case involves allegations that a teacher restrained, secluded, and abused her students as a teacher in a special education classroom. The students’ parents sued the teacher, along with Aberdeen School District (“ASD”) and a host of its administrative officials, on their children’s behalf under 42 U.S.C. Section 1983. The district court denied the teacher’s assertion of qualified immunity from claims for infringing the Fourth and Fourteenth Amendment rights of three students, identified as A.A., B.B., and C.C.   The Eighth Circuit affirmed the denial of qualified immunity for the teacher on the students’ Fourth Amendment claims to the extent held above. In all other respects, the court reversed the denial of qualified immunity for the teacher and the remaining ASD officials. The court explained that it found four violations of clearly established Fourth Amendment rights: (1) secluding A.A. in the little room before February 4, 2016; (2) secluding B.B. in the calm-down corner using dividers; (3) grabbing B.B.’s arms to push him into the swimming pool; and (4) pinning C.C. down to strip his clothes off. The teacher is not entitled to qualified immunity for those violations but is for all other unreasonable seizure allegations. However, the court wrote, the remaining generalized assertions of physical and verbal abuse fail to meet the high bar required for a substantive due process violation. View "Jane Doe v. Becky Guffin" on Justia Law

A jury convicted Defendant of possession with intent to distribute methamphetamine and conspiracy to distribute methamphetamine in violation of 21 U.S.C. Sections  841(a)(1) and 846. He appealed the district court’s denials of his motion to suppress evidence, his motion to strike a juror for cause, and his motion to admit a portion of a video recording.   The Eighth Circuit affirmed Defendant’s convictions. Defendant argued that the seizure and detention of the lockboxes was unreasonable under United States v. Place, 462 U.S. 696 (1983). But “Place had nothing to do with the automobile exception and is inapposite.” See Acevedo, 500 U.S. at 578 (noting that the Supreme Court has consistently “explained that automobile searches differ from other searches” and has denied the applicability of cases that “do not concern automobiles or the automobile exception” to cases involving the automobile exception). Therefore, the district court did not err in denying Defendant’s motion to suppress. Further, the court wrote there was no abuse of discretion because the juror stated that she could remain fair and would listen to the detective’s testimony before deciding if she believed it. Finally, Defendant claimed that the “partial recording and the Government’s characterization of it . . . gave a misleading and unfair understanding of the meaning of Defendant’s statement to the jury.” But he offers no explanation of how the recording was misleading. View "United States v. Shaun Farrington" on Justia Law

Plaintiff worked at the University of Arkansas-Pulaski Technical College (“UAPTC”). In April 2018, Plaintiff requested and received leave under the Family and Medical Leave Act (“FMLA”) to care for her mother who had cancer. After being notified that her position would be eliminated in an upcoming reorganization she applied for a different position. The hiring committee led by Defendant interviewed Plaintiff and five other candidates. After the interview, the committee hired another applicant to whom Defendant had given a more favorable interview score.   Plaintiff sued the Board of Trustees of the University of Arkansas, members of the Board of the Trustees in their official capacities, the hiring committee director in his official and individual capacities, and UAPTC. Among other claims, she alleged that the hiring committee director violated the FMLA by discriminating and retaliating against her.   The district court denied the summary-judgment motion in relevant part, rejecting the hiring director’s qualified immunity defense on the ground that “qualified immunity is not available to defendants on an FMLA claim.” The Eighth Circuit remanded the case to the district court for consideration of the motion for summary judgment on the basis of qualified immunity. The court explained that the district court’s rejection of the hiring director’s qualified-immunity defense was based on a misreading of our statement in Darby v. Bratch. The court construed the statement in Darby about qualified immunity to mean that the FMLA clearly established the violative nature of the particular conduct in that case, not that qualified immunity can never be available on an FMLA claim. View "Rebecca Sterling v. Board of Trustees" on Justia Law

Plaintiff, a woman with severe autism, and her mother, filed an employment discrimination lawsuit against Menards. Plaintiff's mother, who was also a plaintiff in the suit, arranged to have a job coach help Plaintiff obtain employment. However, despite the coach being willing to help Plaintiff through her orientation, Menards did not allow the coach to be present. After orientation, Plaintiff signed an arbitration agreement without the opportunity to show it to her job coach. Ultimately, Plaintiff was terminated and filed this case.Menards moved to compel arbitration. The district court denied Menards' request, resulting in this appeal.On appeal, the Eighth Circuit held that the fact Plaintiff's mother was appointed as Plaintiff's conservator did not necessarily mean that Plaintiff lacked the ability to enter into the contract. However, the court held that the record was not sufficiently developed to determine whether the facially valid contract was revocable under the void contract defense. Thus, the Eighth Circuit vacated the district court's order denying the motion to compel arbitration, and remanded to the district court for further proceedings. View "Mary Triplet v. Menard, Inc." on Justia Law

Defendant pleaded guilty to possession with intent to distribute crack cocaine in 2006. While on bail awaiting sentencing, Defendant and his brother were involved in a bar fight, during which Defendant shot and killed one man and assaulted another. Defendant was charged with murder, assault, and armed criminal action in state court.The following year Defendant was sentenced on the federal drug charges. The district court calculated a total offense level of 34 and a criminal history category II, resulting in a Sentencing Guidelines range of 168 to 210 months of imprisonment. The government moved for an upward departure under USSG Secs. 4A1.3 and 5K2.0(a)(2). The district court heard evidence about the bar fight, including a video of the altercation and testimony from a police detective, and granted the motion. The court sentenced Defendant to 480 months of imprisonment, the then-applicable statutory maximum. Defendant was subsequently acquitted of the charges related to the bar fight.In 2013, Defendant moved for a sentencing reduction pursuant to 18 U.S.C. Sec 3582(c). The district court granted the motion, but only reduced Defendant's sentence to 240 months. The court denied Defendant's subsequent sentencing reduction under Section 404 of the First Step Act. Defendant appealed. The Eighth Circuit affirmed the district court's denial of Defendant's s motion, finding that the district court conducted a complete review of Defendant's motion and provided a reasonable basis for its decision. View "United States v. Anthony Sisco" on Justia Law

Defendant was indicted on charges of possession with intent to distribute methamphetamine and possession with intent to distribute marijuana. Pursuant to a written plea agreement, Defendant pled guilty to the charge of possession with intent to distribute marijuana and was sentenced to 80 months imprisonment plus 4 years supervised release. The government dropped the charges related to possession with intent to distribute methamphetamine.The district court calculated Defendant's total offense level as 34 with a criminal history category of II, resulting in a Guidelines range of 168 to 210 months. The district court varied downward, sentencing Defendant to 80 months imprisonment to be followed by a term of 4 years supervised release.Defendant appealed, claiming that the district court erred in using the methamphetamine to calculate her guideline sentence. The district court did not err in determining that quantities of methamphetamine were attributable to Defendant based on its credibility findings and the district court's credibility findings are virtually unassailable on appeal and were not clearly erroneous. View "United States v. Jennifer Buford" on Justia Law

Defendant was arrested and charged with firearm and drug charges after an officer claimed to see a bag of drugs in Defendant's car that was in plain view. In a motion to suppress, the officer testified inconsistently with the radio call. However, the district court found the officer credible and denied Defendant's motion. On appeal, Defendant claimed that the district court should not have credited the officer's testimony.The Eighth Circuit affirmed the district court's denial of Defendant's motion to suppress, finding that the district court was entitled to credit the police officer's testimony over Defendant's. In finding that the drugs were in plain view, the district court implicitly credited the officer's testimony over his radio call. While the two statements were at odds, the court’s credibility determination did not amount to clear error. View "United States v. Lamont White" on Justia Law

Defendant was convicted of second-degree sexual assault in Arkansas state court in February 2003, an offense requiring him to register under the Arkansas Sex Offender Registration Act of 1997. One of Defendant's registration requirements was that he notify his probation officer of intended international travel 21 days in advance. However, after registering in 2020, Defendant left the country without informing his probation officer. Upon his return, Defendant was charged with knowingly failing to provide information and then engaging in intended travel in foreign commerce.Defendant's guidelines were 18 to 24 months, but the government successfully sought an upward variance, resulting in a sentence of 36 months of imprisonment. The court also imposed a term of 15 years of supervised release with up to 36 months of home detention as a special condition of supervised release. Defendant appealed his sentence.The Fifth Circuit affirmed Defendant's sentence, finding that any error by the district court did not affect Defendant's substantial rights because the court indicated it would have imposed the same term as an upward variance. View "United States v. Brian Floss" on Justia Law

A child, through his parents, brought a due process challenge under the Individuals with Disabilities Education Act (IDEA), claiming that the School District failed to provide him a free appropriate public education (FAPE). An administrative law judge agreed and ordered compensatory education. The district court affirmed but reduced the compensatory education award based on the statute of limitations. The parties cross-appealed. On appeal, the Eighth Circuit found that the school provided the child with a FAPE and reversed the district court's order. View "Minnetonka Public Schools v. M.L.K." on Justia Law

Defendant was convicted on seven counts of forging or counterfeiting postage meter stamps and three counts of smuggling the district court sentenced Defendant to 36 months’ imprisonment and ordered him to pay $256,441.78 in restitution to the United States Postal Service (“USPS”). Defendant appealed challenging the sufficiency of the evidence supporting his convictions, the district court’s estimate of the face value of the counterfeit stamps for purposes of calculating his advisory sentencing guidelines range, the amount of restitution ordered, and the substantive reasonableness of his prison sentence.   The Eighth Circuit affirmed Defendant’s convictions, but vacated the district court’s restitution order and remanded for the district court to limit the restitution award to the loss due to forgery, and otherwise affirmed Defendant’s sentence. The court held that Defendant’s sufficiency-of-the-evidence challenge fails as to all counts if it is construed as a request for a judgment of acquittal. And it fares no better if construed as a request for a new trial. To prevail on this claim, even assuming he did not forfeit it, Defendant would need to show that “the evidence weigh[ed] heavily” against the verdict. Here, the evidence did not weigh heavily against the verdict but rather provided ample support for it. Moreover, the court found that neither statute of conviction lists as an element a scheme, conspiracy, or pattern of criminal activity. Therefore, restitution to the USPS should have been limited to “the loss caused by the specific conduct that is the basis of” Defendant’s forgery convictions. View "United States v. Bradley Matheny" on Justia Law