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

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to conspiracy to distribute 50 grams or more of actual methamphetamine. The court concluded that there was no error in the district court's denial of defendant's request for safety valve sentencing because the record supports the district court's determination that defendant was not credible in his safety valve interview. View "United States v. Trujillo-Linares" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute a controlled substance. The court concluded that the evidence was sufficient to support defendant's conviction and that there was no error in the district court's calculation of methamphetamine attributable to him. After reviewing the evidence presented at trial and the arguments set forth at sentencing, the court found that there is nothing in the record which definitely and firmly illustrates that the lower court made a mistake. View "United States v. Orlando Ramirez" on Justia Law

After the termination of disability benefits under a long-term disability plan governed by the Employee Retirement Income Security Act (ERISA), plaintiff filed suit against the plan administrator, Sun Life, seeking reinstatement of long-term disability (LTD) benefits.The Eighth Circuit reversed the district court's grant of Sun Life's motion for judgment on the record, concluding that there is no substantial evidence in the joint administrative record to support Sun Life's termination decision. In this case, the plan relied on virtually the same medical records for a decade while it paid the benefits, and has pointed to no information available to it that altered in some significant way its decision to pay benefits. The court explained that Sun Life's about-face requires "relevant evidence" that a "reasonable mind might accept as adequate to support" its change in decision, which the evidence does not in this record. Accordingly, the court directed the district court to order the reinstatement of plaintiff's LTD benefits. View "Roehr v. Sun Life Assurance Co. of Canada" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence seized through execution of a search warrant of his motel room, his statements to police during an interrogation, and an eyewitness identification. The court concluded that the information in the affidavit was stale where one of the charges against defendant was for a continuing offense, and there was a substantial basis for finding probable cause to search the motel room for firearms. The court also concluded that the district court did not not err in denying defendant's request for a Franks hearing where, even if the affidavit were supplemented by facts defendant contends were improperly omitted, a judge could reasonably conclude that probable cause existed for finding firearms in Room 220. The court further concluded that, it need not decide whether officers had consent to enter, because even if consent was lacking, the challenged evidence was admissible under the inevitable discovery doctrine. Finally, the court concluded that defendant knowingly and intelligently waived his Miranda rights, and rejected defendant's challenge to the witness's identification from a mug shot. View "United States v. Smith" on Justia Law

After Tyler S. Halsey suffered a heat stroke while working for Townsend Tree Service, his parents filed suit for wrongful death and negligence. The district court dismissed the claims against the supervisor with prejudice, dismissed the claims against Townsend Tree without prejudice, and granted summary judgment to the parent company, The Townsend Corporation of Indiana.The Eighth Circuit affirmed, concluding that plaintiffs failed to allege that the supervisor breached a duty separate and distinct from the nondelegable duties of Townsend Tree. In this case, plaintiffs stress two allegations: (1) that the supervisor directed Halsey to continue working despite indications of heat exhaustion, and (2) that the supervisor disabled the air conditioning in the work trucks so Halsey could not escape the heat. Under Missouri law, the court concluded that both plaintiffs' allegations are within Townsend Tree's nondelegable duties to provide a safe workplace and equipment. Because plaintiffs' claims against the supervisor have no reasonable basis in fact or law, the case was properly removed to federal court.The court further concluded that the district court properly dismissed Townsend Tree without prejudice and the district court did not err in applying the primary jurisdiction doctrine where the question of the cause of death was within the special competence of the Missouri Labor Industrial Relations Commission. Finally, the court concluded that the district court did not err in granting summary judgment to Townsend Corporation where it did not incur liability under either Restatement(Second) of Torts Sec. 324A(b) or 324A(c). View "Halsey v. The Townsend Corporation of Indiana" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to attempted coercion or enticement of a minor in violation of 18 U.S.C. 2422(a). Defendant was sentenced to time served and 120 months' supervised release, including one year of home confinement. The government acknowledges that there was no procedural error, but contends that the sentence was substantively unreasonable. The court concluded that the district court did not abuse its discretion by imposing the below-Guidelines sentence where the district court considered the 18 U.S.C. 3553(a) factors, including his lack of a criminal history and his honorable military service. The court explained that the district court has wide latitude to weigh the sentencing factors, including the need to afford adequate deterrence to criminal conduct and the Post Conviction Risk Assessment. The court rejected the government's remaining contentions to the contrary. View "United States v. Davis" on Justia Law

The Eighth Circuit denied the petition for review of the BIA's decision upholding the IJ's denial of petitioner's application for cancellation of removal. Petitioner testified regarding his daughter's suicide attempt and cited it as evidence that his removal would result in exceptional and extremely unusual hardship to her.The court concluded that the BIA did not misapply the standard for exceptional and extremely unusual hardship by focusing on the daughter's current conditions. The court explained that the BIA's future-oriented analysis shows that the BIA applied the correct legal standard. Furthermore, the court lacks jurisdiction to review the IJ's findings. In this case, the cause of the daughter's declining mental health is a factual matter involving credibility assessments—precisely the sort of discretionary, fact-finding exercise that Congress has shielded from judicial review in cancellation disputes. The court also concluded that the BIA's decision not to address the IJ's misstatement about petitioner's eligibility for reentry is also outside the court's jurisdiction. View "Garcia-Ortiz v. Garland" on Justia Law

Plaintiffs Irvin and Bates filed 42 U.S.C. 1983 actions against police officers, the police chief, and the city, alleging violations of their Fourth Amendment rights and claims under Iowa law when Officers Richardson and Jupin stopped Irvin and Bates while responding to a 911 call.The Eighth Circuit consolidated the appeals and affirmed the district court's grant of summary judgment dismissing Irvin's claims, as well as Bates's parallel state and federal claims. However, the court reversed the district court's grant of summary judgment dismissing Bates's federal and state law claims of false arrest after the initial encounter. The court concluded that the district court did not err by concluding that Officer Richardson had reasonable suspicion to stop and detain Irvin and Bates to determine whether they were involved in an unlawful firearm display during a public disturbance minutes earlier at a location they were walking away from. Because the officers had, at a minimum, arguable reasonable suspicion, they are entitled to qualified immunity on the investigative stop claims. The court affirmed the district court's grant of qualified immunity dismissing the Fourth Amendment claims where, under the circumstances, the force used by the officers did not turn the lawful Terry stop into an arrest. The court's conclusion that plaintiffs were not arrested defeats the false arrest claims.However, the court concluded that under Iowa law the district court erred in granting defendants summary judgment on Bates's claim regarding his subsequent arrest for interference with official acts. Likewise, summary judgment was not appropriate as to Bates's section 1983 false arrest claim where the relevant facts are too confused and contested to conclude, as a matter of law, that Officer Richardson is entitled to qualified immunity. Finally, the court declined to resolve these Monell issues as a matter of law on this summary judgment record and therefore included these issues in reversing the grant of summary judgment dismissing Bates's separate false arrest claims. View "Irvin v. Richardson" on Justia Law

The Eighth Circuit affirmed defendant's 360 month sentence imposed after he pleaded guilty to production of child pornography. The court concluded that there was no error in the district court's application of a two-level enhancement for an offense involving "the commission of a sexual act or sexual contact," pursuant to USSG 2G2.1(b)(2)(A). The court also concluded that there was no error in the district court's application of a two-level enhancement for use of a computer to "solicit participation with a minor in sexually explicit conduct," USSG 2G2.1(b)(6)(B)(ii). View "United States v. Raiburn" on Justia Law

The Eighth Circuit affirmed in part and reversed in part in an action challenging the district court's award of attorney's fees and costs. The court concluded that the district court did not abuse its discretion in setting the attorneys' rates or in excluding the managing partner's hours as unwarranted. However, the district court abused its discretion by excluding all hours related to plaintiff's three summary judgment motions and 1.6 hours for two oppositions: to a successful motion for extension of time to file the answer, and to a successful motion to continue the trial. Finally, the court need not appoint a new judge for remand where judicial rulings alone almost never constitute a valid basis for a bias or partiality motion, and judicial remarks that are critical or disapproving of, or even hostile to a party ordinarily do not support a bias or partiality challenge. The court remanded for further proceedings. View "Burton v. Nilkanth Pizza Inc." on Justia Law