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

The Eighth Circuit affirmed defendant's 300 month sentence imposed after he was convicted of conspiracy to distribute and possess with intent to distribute five kilograms or more of cocaine. The court concluded that, because the phones had evidentiary value independent of the data on the phones, the eight-month seizure of the devices before they were searched was not unreasonable. The court also concluded that the district court did not err in rejecting defendant's proposed instruction on multiple conspiracies where the evidence substantially pointed to a single conspiracy; there was no error in admitting evidence of defendant's drug trafficking activity in California when the activity was undertaken as part of the charged conspiracy; and there was no error in calculating the quantity of drugs. The court further concluded that the district court did not err by imposing sentencing enhancements under USSG 2D1.1(b)(1) for possession of a firearm and USSG 3C1.2 for reckless endangerment during flight. View "United States v. Burris" on Justia Law

The Eighth Circuit affirmed the denial of supplemental security income benefits to claimant, concluding that substantial evidence supported the ALJ's determination that claimant was capable of performing certain work available in the national economy. In this case, the ALJ provided good reasons for giving little weight to claimant's testimony regarding his limitations and to his treating physician's opinion on the subject. Furthermore, perhaps the most persuasive medical reason the ALJ offered in support of his finding as to claimant's residual functional capacity is the relatively conservative course of treatment that he undertook to deal with the pain. Finally, the ALJ did not accept the consulting physician's opinion in its entirety. View "Pierce v. Kijakazi" on Justia Law

Plaintiff filed suit against MasterCard for life insurance benefits under MasterCard's employee benefits plan, alleging breach of fiduciary duty under the Employee Retirement and Income Security Act (ERISA), breach of contract, and fraud.The Eighth Circuit reversed the district court's grant of summary judgment in favor of MasterCard on plaintiff's breach of fiduciary claim, concluding that plaintiff plausibly alleged that his wife elected a total amount of three times her salary in life insurance, for which MasterCard promised to pay premiums. The court explained that, if that proves true, MasterCard's failure to pay premiums would constitute a breach of the fiduciary duty it owed its employees participating in its ERISA-governed benefit plan. Furthermore, plaintiff plausibly alleged that, if his wife's election was in fact deficient for any reason, MasterCard's materially misleading statements caused her to reasonably believe that she had elected three times her salary in life insurance, premiums paid by her employer, and to rely upon that belief in declining to purchase additional life insurance as she was entitled to do. The court affirmed as to the remaining claims and concluded that amendment would be futile. View "Delker v. Mastercard International, Inc." on Justia Law

Plaintiff, the owner of TLDI, filed suit against MultiPlan and PHCS, alleging numerous causes of action, including those relevant to this appeal—breach of contract and a right to an award of attorneys' fees. The Eighth Circuit affirmed the district court's denial of attorneys' fees, concluding that the Network Agreement's indemnity clause does not permit recovery of attorneys' fees in this dispute between the contracting parties.However, the court reversed the district court's holding that plaintiff's conduct waived the contractual amendment-in-writing requirement, concluding that waiver and modification have been pleaded adequately. Furthermore, even assuming arguendo that Multiplan presented evidence sufficient to establish the presumption of receipt, plaintiffs countered with evidence that it was not received. Finally, the court concluded that alterations in position suffice as to consideration. In this case, the revised fee schedule together with the increased potential patient pool changed the obligations of both parties. View "Crutcher v. MultiPlan, Inc." on Justia Law

The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm (Count 1) and two counts of being an unlawful user of a controlled substance in possession of a firearm (Counts 2 and 3). Viewing the evidence in the light most favorable to the verdict and accepting all reasonable inferences that support the verdict, the court concluded that the government presented sufficient evidence that defendant was actively engaged in the use of a controlled substance during the time he possessed firearms in 2013 and 2016, thereby satisfying the requisite temporal nexus between gun possession and regular drug use required under 18 U.S.C. 922(g)(3). Therefore, the evidence was sufficient to support defendant's convictions for being an unlawful user of a controlled substance in possession of a firearm. The court also concluded that the government presented sufficient evidence that defendant knew his use of controlled substances (notably, marijuana) was unlawful.The court further concluded that the district court correctly merged Counts 1 and 2 for purposes of sentencing; the court remanded for the district court to amend its written judgment to conform to its oral pronouncement of one 120-month sentence for Counts 1 and 2; and vacated the district court's imposition of a third term of supervised release because the district court plainly erred when it imposed three terms of supervised release. Having examined the record, the court concluded that the district court did not abuse its discretion by varying upward from the Guidelines range and did not impose a substantively unreasonable sentence where the district court properly considered the 18 U.S.C. 3553(a) sentencing factors. View "United States v. Carnes" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Allstate and dismissal of plaintiff's bad faith claim. The court concluded that the district court's discovery and progression rulings, even if erroneous, did not prejudice plaintiff because her jury award establishes that Allstate acted reasonably in its valuation and negotiation of her insurance claim. In this case, it cannot be said Allstate was unreasonable in its valuation or unjustified in its refusal to pay policy limits, and thus Allstate did not act in bad faith as a matter of law. View "Tilghman v. Allstate Property & Casualty Insurance Co." on Justia Law

Plaintiffs, relatives of individuals who worked at the Tyson Foods pork processing facility that contracted COVID-19 and later died, filed suit alleging claims for fraudulent misrepresentation and gross negligence. Plaintiffs contend that Tyson's actions in March and April of 2020 caused their relatives' deaths. Tyson removed the cases to federal court and then the district court remanded to state court.The Eighth Circuit affirmed and concluded that Tyson has failed to show that it was performing a basic governmental task or operating pursuant to a federal directive in March and April of 2020. Therefore, Tyson was not acting under a federal officer at the time that plaintiffs' relatives contracted COVID-19 and is not eligible for removal under the federal officer removal statute. The court also concluded that Tyson has abandoned the federal question argument concerning removal by failing to brief it, either in its initial brief or by supplemental brief, after the Supreme Court decided BP P.L.C. v. Mayor and City Council of Baltimore, 141 S.Ct. 1532 (2021), permitting alternative arguments against remand to be raised. View "Buljic v. Tyson Foods, Inc." on Justia Law

After Midwest failed to meet its sales quota for two or more consecutive quarters, Exactech terminated its Agency Agreement with Midwest. The Agreement contained a non-compete provision entitling Midwest to Restricted Period Compensation (RPC) after termination. Midwest filed suit seeking, among other things, a declaratory judgment as to the amount of RPC.The Eighth Circuit reversed the district court's judgment, concluding that the district court did not apply the plain and ordinary meaning of Paragraph 5.D.ii as required by Minnesota law. Furthermore, nothing in the remainder of the Agreement contradicts the plain meaning of Paragraph 5.D.ii. There is no claim of unilateral or mutual mistake and the court remanded for further proceedings. View "Midwest Medical Solutions, LLC v. Exactech U.S., Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Tyson on plaintiff's interference claim under the Family and Medical Leave Act (FMLA). The court concluded that Tyson's request for recertification was reasonable as a matter of law under 29 U.S.C. 2613(e) and did not interfere with defendant's FMLA rights. The court explained that it was reasonable as a matter of law to require recertification based on a significant change in the circumstances of plaintiff's absences. View "Whittington v. Tyson Foods, Inc." on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence. Defendant conditionally pleaded guilty to one count of being a felon and drug user in possession of a firearm. The court concluded that the district court's factual finding that the officers credibly testified to smelling burnt marijuana while driving behind defendant is not clearly erroneous. In this case, the district court's credibility finding was based on the consistency of the officers' testimony, the corroborating evidence, and the expert testimony. Furthermore, the district court also sufficiently explained its rejection of defendant's counterarguments. In the alternative, the court concluded that, based on the totality of the circumstances, it was reasonable for the officers to conclude that the odor of burnt marijuana was coming from defendant's vehicle, rather than any other vehicle. View "United States v. Shumaker" on Justia Law