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

Plaintiffs filed suit against CJS Solutions, a Florida entity doing business as The HCI Group, in the District of Minnesota. Plaintiffs moved to certify a collective action under the Fair Labor Standards Act (FLSA). The putative class of plaintiffs was composed of all HCI employees hired on a per-project basis who were not paid wages for out-of-town travel to and from remote project locations. After the district court conditionally certified a collective action limited to claims arising out of travel to and from Minnesota, it granted summary judgment for HCI on the ground that plaintiffs were not employees when traveling.The Eighth Circuit affirmed, concluding that the district court did not err in finding defendant had not waived its jurisdictional defense to plaintiffs' claims for certification of collective actions covering all of defendant's employees for all of their travel time anywhere in the United States; the district court properly excluded all claims with no connection with the forum state of Minnesota; and, in regard to the out-of-town travel claims, the district court did not err in finding that two plaintiffs were not employees when traveling and that defendant had no obligation to pay for their time. View "Vallone v. CJS Solutions Group, LLC" on Justia Law

After plaintiffs filed a class action against defendants under the Fair Labor Standards Act (FLSA) and the Arkansas Minimum Wage Act (AMWA), plaintiffs negotiated a settlement agreement with Welspun for the wage claim and attorneys' fees. However, the district court did not approve the settlement because it determined that the claim and fees were not separately negotiated. When the parties presented the district court with only the wage-claim portion of the settlement, the district court approved it. The district court subsequently partially granted plaintiffs' motion for an award of attorneys' fees and costs, awarding $1.00 in fees. Alternatively, the district court noted that it would award $25,000 in fees if $1.00 was improper.The Eighth Circuit concluded that the district court did not clearly err when it denied the parties' joint motion for approval of the settlement based on its conclusion that the FLSA claims and the attorneys' fees were not separately negotiated. However, because the record contains no lodestar calculation, the court vacated the award of attorneys' fees. In this case, plaintiffs' claim was not frivolous or groundless, and it is unlikely that a $1.00 attorneys' fee is reasonable. Furthermore, the court cannot conduct a meaningful review of the district court's alternative award. The court declined to reassign the case and remanded for further proceedings. View "Vines v. Welspun Pipes Inc." on Justia Law

The Eighth Circuit reversed the district court's grant of summary judgment against plaintiff where a reasonable factfinder could believe that plaintiff fully exhausted her administrative remedies. The court remanded for a factfinder to determine which set of papers plaintiff filed first. View "Prowse v. Washington" on Justia Law

The Eighth Circuit reversed the district court's denial of defendant's motion for a sentence reduction under the First Step Act of 2018, concluding that the district court erred in determining that defendant remains subject to a mandatory life sentence. The court explained that defendant's offense of conviction—not the underlying drug quantity—determines his applicable statutory sentencing range. In this case, the district court erred in determining that defendant remained subject to a mandatory life sentence based on defendant's conduct rather than the offense of conviction, and the district court erroneously concluded that relief was categorically unavailable because of the drug quantity. The court remanded for the district court to determine whether to exercise its discretion in imposing a reduced sentence. View "United States v. Robinson" on Justia Law

Petitioner filed a habeas action alleging that he received ineffective assistance of sentencing counsel when his lawyer failed to investigate potential impeachment evidence of his own expert witness, and that his death sentence was unconstitutional due to flaws in the jury instructions. The district court agreed and vacated petitioner's death sentence.The Eighth Circuit reversed the district court's judgment vacating petitioner's death sentence, concluding that counsel was not deficient by reasonably relying on the professional community to vet an expert. Furthermore, petitioner cannot show that, under the circumstances, no competent lawyer could have made the choice to trust the legal community's appraisal of the witness. Even if further investigation was more prudent, it is not clear that the investigation should have covered the witness's falsified lab reports. Therefore, petitioner did not overcome the presumption that counsel performed reasonably by not investigating the witness's credentials.The court also concluded that there was no substantial likelihood that the calling of an alternative psychiatric witness would have led to a different result; the state habeas court did not err in finding that petitioner was not prejudiced by sentencing counsel's failure to call a psychiatrist, and post-conviction counsel was not ineffective by failing to raise the issue; and the district court erred in concluding that the sentencing instructions violated Mills v. Maryland, 486 U.S. 367 (1988), and that Missouri's capital sentencing system violates Ring v. Arizona, 536 U.S. 584 (2002). View "McLaughlin v. Precythe" on Justia Law

The Eighth Circuit affirmed the district court's judgment in plaintiffs' case, which is part of the Bair Hugger multidistrict litigation (MDL). The court concluded that the district court did not abuse its discretion by excluding (1) evidence of 3M's knowledge of the risks and utility of the Bair Hugger and (2) evidence of reasonable alternative designs to the Bair Hugger besides the TableGard. Furthermore, even assuming the risk-utility and reasonable-alternative design evidence was erroneously excluded, plaintiffs failed to show that they suffered prejudice from the exclusion of the evidence. The court also concluded that the district court did not abuse its discretion by allowing 3M's expert to testify about operating-room airflow. Even if the admission of the testimony was erroneous, there was no basis to reverse the jury's verdict on this ground. Finally, the court concluded that the district court did not err in granting summary judgment to 3M on plaintiffs' failure-to-warn claim asserted under both negligence and strict-liability theories. The court explained that, even if the district court erred, the error was harmless. View "Gareis v. 3M Company" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Continental in an action brought by Millard Gutter, alleging that Continental breached insurance policies issued to third parties. The court concluded that Millard Gutter lacked authority to determine the scope of the loss or damage sustained by Midwest Screw or Dr. Schroeder. In this case, the authorization terms are clear and no reasonable person would construe them to assign Midwest Screw's and Dr. Schroeder's claims to Millard Gutter or to otherwise grant Millard Gutter the right to determine the scope of damages or loss. Rather, the plain language of the authorizations permits Millard Gutter only to seek payment from defendants and to negotiate the terms of those payments with defendants. View "Millard Gutter Co. v. Continental Casualty Co." on Justia Law

The Eighth Circuit affirmed defendant's conviction and 180-month sentence for offenses involving drug trafficking and possession of a firearm. The court concluded that the district court did not err in denying defendant's pre-trial motion for disclosure of coconspirator statements where defendant did not object to the magistrate judge's order and thus he waived his right to review. Even if the court excused defendant's waiver, the magistrate judge did not abuse her discretion in denying the motion. In this case, the magistrate judge recognized appropriately the burden that would be placed on the government by the pre-trial identification of coconspirator statements and the availability of the Bell procedure. Therefore, there was no abuse of discretion.The court also concluded that the district court did not err in rejecting defendant's buyer-seller instruction regarding the drug trafficking conspiracy and there was no plain error under Rehaif v. United States, 139 S. Ct. 2191 (2019). Finally, the court concluded that defendant's sentence was not substantively unreasonable where the district court considered the 18 U.S.C. 3553(a) sentencing factors and did not abuse its discretion. Defendant's remaining argument regarding his sentence is foreclosed by circuit precedent. View "United States v. Merrett" on Justia Law

The Eighth Circuit affirmed defendant's 180-month sentence imposed after he pleaded guilty to two firearm offenses. The court concluded that the district court did not clearly err in finding that defendant shot the victim. Taken as a whole, the forensic evidence, expert testimony, and lay witness testimony were sufficient to support the district court's finding and its corresponding application of the sentencing guidelines. View "United States v. Quinto-Pascual" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to possessing a firearm and violating his supervised release. The court concluded that the district court did not abuse its discretion by double-counting where defendant's sentences penalized distinct aspects of his conduct and distinct harms. In this case, the Sentencing Guidelines instruct courts to do what the district court did here: (1) add criminal history points because defendant committed the firearm offense while on supervised release; and (2) sentence him consecutively for the firearm offense and the revocation. View "United States v. Roe" on Justia Law