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

B.J.S., a Native American born in 2004, was charged with multiple acts of aggravated sexual abuse against his younger sister L.S. between August 2019 and June 2022, when he was 15 to 17 years old. The government filed a juvenile information and moved to transfer the proceedings to adult court. The charges included causing L.S. to engage in sexual acts by force, engaging in sexual acts with L.S. under 12, and causing sexual contact with L.S. under 12 with intent to abuse, humiliate, harass, degrade, or arouse sexual desire.The United States District Court for the District of North Dakota granted the government's motion to transfer the case to adult court. B.J.S. moved to dismiss the transfer motion, arguing that the charges did not qualify as "crimes of violence" under 18 U.S.C. § 5032. The district court denied his motion and granted the transfer after an evidentiary hearing. B.J.S. appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the charges under 18 U.S.C. §§ 2241(a), 2241(c), and 2244(a)(5) did not qualify as "crimes of violence" under 18 U.S.C. § 16(a). The court applied the categorical approach, considering only the statutory elements of the offenses. It found that § 2241(a) was overbroad and indivisible, covering more conduct than § 16(a). Similarly, § 2241(c) and § 2244(a)(5) did not require the use, attempted use, or threatened use of physical force against another person. Consequently, the court concluded that none of the charges met the definition of a "crime of violence" for purposes of § 5032 permissive transfer.The Eighth Circuit reversed the district court's decision and remanded the case, determining that the transfer to adult court was not justified. View "United States v. B.J.S." on Justia Law

Laguerre Payen, a federal inmate, was convicted in 2010 of multiple terrorism-related charges and sentenced to 25 years imprisonment. During his incarceration, Payen exhibited disruptive and dangerous behavior, including numerous assaults, threats, and other violations. He was diagnosed with schizophrenia and mild intellectual disability and was committed twice under 18 U.S.C. § 4245 for mental health treatment. Despite some improvement, Payen's behavior remained inconsistent, and he refused medication after his commitments ended.The United States District Court for the Western District of Missouri committed Payen under 18 U.S.C. § 4246, finding by clear and convincing evidence that his release would pose a substantial risk of bodily injury or serious property damage due to his mental illness. Payen appealed, arguing that the district court relied on erroneous facts and that the government failed to prove his dangerousness by clear and convincing evidence.The United States Court of Appeals for the Eighth Circuit reviewed the district court's finding of dangerousness for clear error. The court noted that the district court had relied on the unanimous opinions of experts, including an independent evaluator, who diagnosed Payen with schizophrenia and intellectual disability and concluded that his release would pose a substantial risk. The court also considered Payen's extensive history of violent and disruptive behavior, his refusal to take medication voluntarily, and the lack of a suitable release plan.The Eighth Circuit affirmed the district court's decision, finding no clear error in the determination that Payen's release would create a substantial risk of harm to others or their property. The court emphasized that the district court had properly focused on the expert reports and Payen's history of dangerous behavior in making its decision. View "United States v. Payen" on Justia Law

In 2020, Mujera Benjamin Lung’aho threw Molotov cocktails that damaged or destroyed three police cars belonging to state and municipal police departments. He was indicted under 18 U.S.C. § 844(f)(1) for maliciously destroying law enforcement vehicles possessed by local police departments receiving federal financial assistance. Lung’aho moved to dismiss the indictment, arguing that the statute was unconstitutional as applied to him.The United States District Court for the Eastern District of Arkansas denied Lung’aho’s motion to dismiss. The court held that while the Property Clause did not apply because the police cars were not federal property and were not bought with federal financial assistance, the prosecution was constitutional under the Spending Clause coupled with the Necessary and Proper Clause.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to dismiss de novo. The court held that Lung’aho’s conduct fell within the plain meaning of 18 U.S.C. § 844(f)(1) and that the statute was constitutional as applied to him. The court reasoned that under the Spending Clause and the Necessary and Proper Clause, Congress has the authority to ensure that federal funds are spent for the general welfare, and criminalizing the arson of police cars from departments receiving federal funding is a rational means of safeguarding federal dollars. The court affirmed the district court’s judgment, concluding that § 844(f)(1) was constitutionally applied to Lung’aho. View "United States v. Lung'aho" on Justia Law

Deoman Reeves was convicted by a jury of eleven counts related to narcotics and firearms offenses. The charges stemmed from a series of events in 2019, including a shooting incident in University City, Missouri, and subsequent involvement in drug and firearms trafficking. Reeves was identified as a primary suspect in the shooting and was linked to a narcotics trafficking organization. He was involved in a retaliatory shooting that resulted in the death of a bystander, David Anderson, whom Reeves mistakenly believed to be a rival drug trafficker. Reeves was later involved in several controlled buys of fentanyl and firearms set up by ATF agents.The United States District Court for the Eastern District of Missouri denied several of Reeves's pretrial motions, including a motion to suppress location data obtained from his cellphones and a motion to sever the count charging him with possession of a firearm in furtherance of a drug trafficking crime resulting in death. The district court also denied Reeves's motions for judgment of acquittal and for a new trial. Reeves was sentenced to life imprisonment on one count, 120 months on seven counts to be served concurrently, and 60 months on three counts to be served consecutively.The United States Court of Appeals for the Eighth Circuit reviewed the case and found no reversible error. The court held that the district court did not abuse its discretion or plainly err in denying the motion to sever, as the offenses were connected to the same drug trafficking conspiracy. The court also upheld the denial of the motion to suppress, finding that the warrants were supported by probable cause and sufficiently particular. The court affirmed the denial of the motion for judgment of acquittal, concluding that sufficient evidence supported the convictions. Finally, the court determined that Reeves waived his challenges to the jury instructions by not objecting during the trial. The judgment of the district court was affirmed. View "United States v. Reeves" on Justia Law

Katrina Beran, a certified nursing assistant, was employed at Linden Court, a skilled nursing facility owned by VSL North Platte Court, LLC. In December 2019, Christopher Eugene was hired as another certified nursing assistant. Eugene made derogatory comments about women and engaged in inappropriate physical conduct, including groping Beran and other female staff. Beran reported Eugene's behavior to her supervisors, but they dismissed her concerns and failed to take effective remedial action. Beran continued to experience harassment, leading to severe emotional distress and exacerbation of her post-traumatic stress disorder. She was eventually terminated after reporting Eugene's misconduct.The United States District Court for the District of Nebraska denied Linden Court's motion for summary judgment, and the case proceeded to trial. The jury found in favor of Beran, awarding her $500,000 in compensatory damages and $2,500,000 in punitive damages. The district court reduced the punitive damages to $200,000 due to statutory caps and awarded Beran attorney fees and costs. Linden Court's post-trial motions for judgment as a matter of law and a new trial were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, holding that there was sufficient evidence to support the jury's findings of a hostile work environment and that Linden Court failed to take prompt and effective remedial action. The court also upheld the award of punitive damages, finding that Linden Court acted with reckless indifference to Beran's rights. Additionally, the court found that the compensatory damages awarded for Beran's emotional distress were not excessive and were supported by the evidence. View "Beran v. VSL North Platte Court LLC" on Justia Law

Alexander Laurel-Olea pleaded guilty to unlawful possession of a firearm as an unlawful user of a controlled substance and was sentenced to twenty-four months’ imprisonment and thirty-six months of supervised release. After serving his sentence, he began his supervised release on August 30, 2022. In June 2024, he was arrested for committing fifty-four violations of his supervised release conditions. The district court sentenced him to fourteen months’ imprisonment and a one-year term of supervised release.The United States District Court for the Northern District of Iowa determined that the advisory guideline range for Laurel-Olea’s violations was three to nine months’ imprisonment. The court considered both mitigating and aggravating factors. Mitigating factors included his age, lack of adult criminal history, mental health and substance abuse issues, and acceptance of responsibility. Aggravating factors included his involvement in a dangerous shooting, fifty-four violations of release conditions, becoming a fugitive, and failing to meet his restitution obligation.The United States Court of Appeals for the Eighth Circuit reviewed the case. Laurel-Olea argued that his sentence was unreasonable under 18 U.S.C. § 3583(e), claiming it was disproportionate and did not account for his mental health issues, background, and potential for reintegration. The appellate court applied a deferential abuse-of-discretion standard, noting that it is rare to reverse a district court sentence as substantively unreasonable.The Eighth Circuit found that the district court did not abuse its discretion. The court had considered relevant factors and provided a reasoned explanation for the upward variance from nine to fourteen months, including credit for accepting responsibility. The judgment of the district court was affirmed. View "United States v. Laurel-Olea" on Justia Law

Two students alleged that an Arkansas law violates their First Amendment rights by prohibiting their teachers from providing classroom materials and instruction about Critical Race Theory (CRT). The district court concluded that the law likely violated the students' right to receive information and entered a preliminary injunction. Arkansas officials appealed, arguing that the Free Speech Clause does not allow students to compel the government to provide certain classroom materials or instruction in public schools.The United States District Court for the Eastern District of Arkansas granted a preliminary injunction to the students but denied one to the teachers. The court determined that the teachers' speech was government speech, not their own, and thus any chill on their speech did not harm their rights. The court concluded that the students demonstrated that the law blocked their receipt of information previously provided before its enactment and that the Arkansas officials did not show a legitimate pedagogical reason for withholding teaching about CRT.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the Arkansas officials. The court held that the students conceded the classroom materials and instruction they sought to receive constituted government speech. Since the government's own speech is not restricted by the Free Speech Clause, the government is free to choose what to say and what not to say. The court concluded that the students could not show a likelihood of success on their claim and vacated the preliminary injunction. The court also declined to uphold the preliminary injunction based on the teachers' vagueness claim, as the teachers did not file a cross-appeal. The case was remanded for further proceedings. View "Walls v. Oliva" on Justia Law

Moses Crowe was convicted of aiding and abetting a carjacking resulting in serious bodily injury, aiding and abetting the use of a firearm during and in relation to a crime of violence, and unlawful possession of a firearm as a felon. The incident involved Crowe and his accomplices forcing Phillip Moore at gunpoint to drive a van, assaulting him, and subsequently beating him unconscious. Crowe was sentenced to 235 months’ imprisonment.The United States District Court for the District of South Dakota initially sentenced Crowe, applying a four-level increase under the sentencing guidelines for abduction. Crowe appealed, arguing that the court erred in applying this increase and improperly considered conduct not relevant to his sentencing guideline range. The court also remanded for resentencing after vacating one of Crowe’s convictions and reducing it to a lesser charge.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court properly considered Crowe’s conduct at Nike Road under the sentencing factors of 18 U.S.C. § 3553(a) and correctly applied the four-level increase for abduction. The court determined that Moore was abducted to facilitate the escape from the carjacking scene, thus justifying the increase. Additionally, the court held that the district court did not abuse its discretion in sentencing Crowe within the advisory range and adequately considered the § 3553(a) factors. The Eighth Circuit affirmed the judgment of the district court, upholding Crowe’s 235-month sentence. View "United States v. Crowe" on Justia Law

Lackie Drug Store, Inc. filed a putative class action against OptumRx, Inc. and other pharmacy benefit managers (PBMs), alleging violations of several Arkansas statutes due to the PBMs' failure to disclose, update, and notify pharmacies of changes to their Maximum Allowable Cost (MAC) lists. Lackie claimed this resulted in under-reimbursement for prescriptions. The case was initially filed in Arkansas state court and later removed to federal court. Lackie amended its complaint to include five claims, and OptumRx moved to dismiss the complaint on various grounds, including failure to state a claim and failure to exhaust administrative remedies.The United States District Court for the Eastern District of Arkansas dismissed two of Lackie's claims but retained three. The court also denied OptumRx's motion to dismiss based on the argument that Lackie failed to comply with pre-dispute procedures outlined in the Network Agreement. OptumRx later filed an answer and participated in discovery. After Lackie amended its complaint again, adding two new claims and tailoring the class definition to OptumRx, OptumRx moved to compel arbitration based on the Provider Manual's arbitration clause.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that OptumRx waived its right to compel arbitration for the original three claims by substantially invoking the litigation machinery before asserting its arbitration right. However, the court found that OptumRx did not waive its right to compel arbitration for the two new claims added in the amended complaint. The court also held that the district court erred in addressing the arbitrability of the new claims because the Provider Manual included a delegation clause requiring an arbitrator to decide arbitrability issues.The Eighth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case with instructions to grant OptumRx's motion to compel arbitration for the two new claims. View "Lackie Drug Store, Inc. v. OptumRx, Inc." on Justia Law

In December 2020, Robert and Kristina Shoults filed for Chapter 7 bankruptcy in the United States Bankruptcy Court for the Eastern District of Missouri. In June 2021, they amended their schedule to claim a pre-petition, contingent, unliquidated personal injury tort claim as exempt under Missouri common law and Missouri Revised Statutes § 513.427. The Chapter 7 Trustee, Tracy A. Brown, objected to this exemption.The bankruptcy court disallowed the exemption, and the United States District Court for the Eastern District of Missouri affirmed this decision. The Debtors then appealed to the United States Court of Appeals for the Eighth Circuit. The district court and the bankruptcy court both concluded that the Eighth Circuit's decisions in In re Benn and In re Abdul-Rahim were controlling precedents, which held that Missouri debtors could only exempt property explicitly identified by Missouri statutes as exempt.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the lower courts' decisions. The court held that the Supreme Court's decision in Rodriguez v. FDIC did not overrule or abrogate the Eighth Circuit's precedents in Benn and Abdul-Rahim. The court emphasized that Benn and Abdul-Rahim required a state statutory basis for bankruptcy exemptions and that Missouri Revised Statute § 513.427 did not create new exemptions but merely opted out of the federal exemption scheme. Consequently, the court concluded that the Debtors' unliquidated personal injury tort claim was not exempt under Missouri law and affirmed the district court's order denying the exemption. View "Shoults v. Brown" on Justia Law