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

The Eighth Circuit affirmed an arbitration award that reinstated a member of the union to her former position after she was discharged by the company. The court concluded that the parties agreement authorized the arbitrator to determine whether there has been a violation of the parties' agreement within the allegations set forth in the grievance. In this case, the parties bargained for the arbitrator's interpretation of the agreement's just cause provision and the provision does not specify that the same just cause is sufficient to justify all types of adverse action.The court also concluded that the arbitrator's award drew its essence from the parties' agreement. Finally, the court concluded that the record does not establish that the employee committed abuse as defined by the cited statutes, or that allowing her to return to work after a suspension violates public policy. View "WM Crittenden Operations, LLC v. United Food and Commercial Workers" on Justia Law

The Eighth Circuit affirmed defendant's conviction and 360-month sentence for unlawfully possessing a gun. Defendant's conviction stemmed from a botched gun sale to a confidential informant.The court concluded that the district court did abuse its discretion by admitting evidence of defendant's six past felony convictions where the evidence was material and showed defendant's intent to possess it. Furthermore, the district court's limiting instruction diminished any danger of unfair prejudice from the admission of all six prior bad acts. The court also concluded that the district court did not abuse its discretion in denying the mere-presence instruction. Finally, the court concluded that the district court's upward variance did not amount to a substantively unreasonable sentence where the district court considered the 18 U.S.C. 3553(a) sentencing factors and did not abuse its discretion. View "United States v. Drew" on Justia Law

Plaintiffs, 14 purchasers of off-road vehicles, filed a putative class action against Polaris alleging that a design defect caused the vehicles, all of which contain "ProStar" engines, to produce excessive heat. Plaintiffs claim that the heat degrades vehicle parts, reduces service life, and creates a risk of catastrophic fires. 7 of the 14 plaintiffs experienced fires which destroyed their vehicles.The Eighth Circuit affirmed the district court's grant of Polaris's motion to dismiss the claims of the "no-fire" purchasers, because they failed to allege an injury in fact as required to establish an Article III case or controversy. The court concluded that the district court correctly applied circuit precedent in determining that the no-fire purchasers failed to allege an injury sufficient to confer standing. View "Forrest v. Polaris Industries, Inc." on Justia Law

The Eighth Circuit reversed the district court's denial of qualified immunity to a police officer in a 42 U.S.C. 1983 action brought by plaintiff on behalf of her two minor sons. The claims stemmed from a gang-related stakeout in a residential neighborhood that resulted in a car chase and subsequent car crash. The officer stopped and questioned the boys at gunpoint and held them for seven minutes until backup arrived.The court concluded that the officer is entitled to qualified immunity on the prolonged-investigative-detention claim and that the district court erred in holding that triable facts remain on whether the officer unlawfully prolonged the investigative detention of the boys. The court further concluded that the officer is entitled to qualified immunity on the de-facto-arrest-claim where, based on the totality of the circumstances, the investigative detention did not become an arrest here because the officer only used handcuffs briefly (under two minutes) when he had two indications that one of the boys may have been armed. Furthermore, the officer should receive qualified immunity on the unlawful-search claim where a frisk of one of the boys was authorized to protect officer safety and to maintain status quo during the course of the stop. Finally, the officer did not use unreasonable force when he pointed his gun at the boys while he waited for backup and before the situation was under control. Therefore, he is entitled to qualified immunity on the excessive force claim. View "Pollreis v. Marzolf" on Justia Law

Charles James and Designworks filed suit against real estate companies, as well as their affiliates and agents, claiming that defendants infringed their copyrights when they created and published certain floorplans without authorization. The district court granted defendants summary judgment on the infringement claims, as well as on plaintiffs' claims for contributory and vicarious copyright infringement.The Eighth Circuit held that the copyright statute, 17 U.S.C. 120(a), does not provide a defense to a claim of infringement for real estate companies, their agents, and their contractors when they generate and publish floorplans of homes they list for sale. The court reasoned that the terms Congress used in section 120(a) have a certain quality in common—they all connote artistic expression. The court explained that floorplans, like the ones here, serve a functional purpose. The court noted that its decision does not preclude the district court on remand from considering whether some other defense might apply or whether plaintiffs have demonstrated a claim of copyright infringement in the first place. Accordingly, the court reversed the district court's grants of summary judgment to defendants on the primary infringement claim as well as on the claims for contributory and vicarious infringement, vacated the district court's orders awarding defendants costs and attorney's fees, and remanded for further proceedings. View "Designworks Homes, Inc. v. Columbia House of Brokers Realty, Inc." on Justia Law

Plaintiff filed suit alleging 42 U.S.C. 1983 compensatory and punitive damage claims against paramedics for injecting her with ketamine without her consent, and against physicians who allegedly implemented ambulance protocols while conducting the second ketamine study, both in their individual and official capacities. Plaintiff also alleged claims of Monell liability against the county, several of its health care facilities, and the individual defendants for developing and implementing a countywide ketamine protocol. The complaint alleged that defendants used excessive force, violated her right to bodily integrity, and acted with deliberate indifference in violation of the Fourth Amendment and her right to substantive due process under the Fourteenth Amendment.The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims. In regard to plaintiffs' claims against the paramedics, the court concluded that the district court properly dismissed plaintiff's excessive force claims where it was not objectively unreasonable for paramedics to administer medical aid to an intoxicated, suicidal, semi-conscious woman who needed medical intervention; the district court properly dismissed the substantive due process claims where, even if the semi-conscious plaintiff was competent to refuse treatment, the paramedics did not engage in conscience shocking conduct in electing to sedate a suicidal, intoxicated woman to protect both the patient and themselves; and the paramedics were not deliberately indifferent to plaintiff.In regard to claims against the physicians, the court concluded that at minimum these defendants are entitled to qualified immunity on plaintiff's claims related to their oversight of the county's ketamine studies because they were not personally involved in the actions leading to plaintiff's emergency treatment. Finally, in regard to the Monell liability claims, the court concluded that plaintiff failed to establish that the paramedics violated her Fourth Amendment or substantive due process rights. View "Buckley v. Hennepin County" on Justia Law

In December 2015, the Judicial Panel on Multidistrict Litigation created and centralized the In re Bair Hugger Forced Air Warming Devices Products Liability Litigation (MDL) in the District of Minnesota for coordinated pretrial proceedings. Plaintiffs in the MDL brought claims against 3M alleging that they contracted periprosthetic joint infections (PJIs) due to the use of 3M's Bair Hugger, a convective (or forced-air ) patient-warming device, during their orthopedic-implant surgeries. The MDL court excluded plaintiffs' general-causation medical experts as well as one of their engineering experts, and it then granted 3M summary judgment as to all of plaintiffs' claims, subsequently entering an MDL-wide final judgment.The Eighth Circuit reversed in full the exclusion of plaintiffs' general-causation medical experts and reversed in part the exclusion of their engineering expert; reversed the grant of summary judgment in favor of 3M; affirmed the discovery order that plaintiffs challenged; affirmed the MDL court's decision to seal the filings plaintiffs seek to have unsealed; and denied plaintiffs' motion to unseal those same filings on the court's own docket. View "Amador v. 3M Company" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for distribution of child pornography. The court concluded that there was no reversible error in suppressing defendant's motion to suppress evidence where the information provided in the search warrant affidavit was sufficient to support the probable cause determination. In light of the collecting habits of those who use child pornography, the court concluded that there was a fair probability that defendant had not deleted the image that he uploaded, and that more images would be found. Furthermore, the information was not stale. Finally, the court concluded that defendant's sentence was not substantively unreasonable or an abuse of the district court's discretion where the district court had varied downward from the guideline range and where the district court exercised its substantial latitude in weighing the 18 U.S.C. 3553(a) sentencing factors. View "United States v. Espinoza" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of defendants in an action brought under 42 U.S.C. 1983 and state negligence law against prison officials, medical staff, and a medical services company for withholding plaintiff's prescription orthotic shoes.The court concluded that, although the district court erred by relying on Arkansas law to exclude parts of plaintiff's substituted expert's testimony because the matter should have been weighed under Daubert and relevant federal law, the error was harmless. The court also concluded that the district court did not err in excluding the nurse's testimony as a substituted expert when her opinions went beyond the scope of the earlier expert report and deposition. The court further concluded that the district court did not err in granting the warden's motion for summary judgment as there was no evidence that the warden recognized the risk of having plaintiff wear standard issue prison shoes or knew that requiring a doctor's authorization for special shoes would put plaintiff's health at risk. Furthermore, there was no error in granting summary judgment for the medical defendants where their actions either did not rise to the level of criminal negligence or were not so inappropriate that a jury would find intentional maltreatment or a refusal to provide essential care. View "Shipp v. Murphy" on Justia Law

Defendant moved twice to suppress evidence of guns, ammunition, and drug paraphernalia that the Kansas City police seized from his apartment. After the district court denied both motions, defendant appealed.Because the Eighth Circuit concluded that the record does not contain adequate findings of fact for the court to resolve the appeal, the court remanded to the district court for the limited purpose of making the supplemental findings of fact necessary to resolve defendant's Fourth Amendment claims, while retaining jurisdiction. View "United States v. Green" on Justia Law