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

Robert Cottier was driving with a suspended license and a high blood alcohol concentration when he collided head-on with Cheryl Cross' vehicle, causing serious injuries to Cross and her passengers. Cottier's passenger, Harold Long Soldier, died from the crash. Cottier was charged with involuntary manslaughter and four counts of assault resulting in serious bodily injury. He pleaded guilty to the manslaughter charge and one count of assault.The United States District Court for the District of South Dakota accepted Cottier's guilty plea. The plea agreement included a government recommendation for sentences within the applicable Guideline range to run consecutively. The Presentence Investigation Report calculated a total offense level of 21, resulting in a guideline range of 37-46 months. The government’s Sentencing Memorandum recommended a 73-month sentence, which Cottier argued breached the plea agreement. The district court varied upwards and sentenced Cottier to 96 months, explaining the decision was based on the severity of the injuries and Cottier's history of DUI offenses.The United States Court of Appeals for the Eighth Circuit reviewed the case. Cottier argued that the government breached the plea agreement by recommending a 73-month sentence. The court found no breach, noting that the government’s final position at the sentencing hearing aligned with the plea agreement. The court also determined that any potential breach in the Sentencing Memorandum did not affect the district court’s decision to impose a 96-month sentence. The Eighth Circuit affirmed the district court’s judgment, concluding that the government honored its plea agreement obligations and that the district court’s sentence was justified. View "United States v. Cottier" on Justia Law

In April 2017, Mark Mehner was injured when a chair he was sitting on at a Panera café in Omaha collapsed. Mehner sued Panera and the chair manufacturer, Furniture Design Studios (FDS), for negligence, spoliation, and strict liability. He claimed permanent injuries, including spinal fractures. Panera's general manager filled out an incident report but discarded the broken chair and the handwritten report. Mehner alleged that he had requested the preservation of the chair and surveillance video, which Panera denied.The United States District Court for the District of Nebraska granted summary judgment to both FDS and Panera. The court found that Mehner failed to provide evidence of a specific defect in the chair or causation, particularly since the chair had been out of FDS's possession for nearly eight years. The court also denied Mehner's motion for spoliation sanctions, finding no intentional destruction of evidence by Panera. Additionally, the court rejected Mehner's motion for relief from judgment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of FDS, agreeing that Mehner did not present sufficient evidence of a defect or causation. The court also upheld the summary judgment for Panera, determining that Mehner failed to establish that Panera created or had notice of the chair's condition. The court rejected Mehner's res ipsa loquitur argument, noting that he did not show the chair was under Panera's exclusive control or that the incident would not have occurred without negligence.The Eighth Circuit also affirmed the district court's discovery rulings, including the denial of Mehner's motion to defer, the denial of his motion to extend progression, and the issuance of a protective order to Panera. The court found no abuse of discretion in these rulings. Finally, the court upheld the denial of spoliation sanctions and the denial of Mehner's motion to revise, alter, or amend the judgment. View "Mehner v. Furniture Design Studios, Inc." on Justia Law

During the COVID-19 pandemic, K7 Design Group, Inc. (K7) offered to sell hand sanitizer to Walmart, Inc., doing business as Sam’s Club (Sam’s Club). K7 and Sam’s Club discussed and agreed upon the product, price, quantity, and delivery terms for various hand sanitizer products through email communications. K7 delivered over 1,000,000 units of hand sanitizer to Sam’s Club, which paid approximately $17.5 million. However, Sam’s Club did not collect or pay for the remaining hand sanitizer, leading to storage issues for K7.The United States District Court for the Western District of Arkansas held a jury trial, where the jury found in favor of K7 on its breach of contract claim and awarded $7,157,426.14 in damages. Sam’s Club’s motions for judgment as a matter of law and for a new trial were denied by the district court.The United States Court of Appeals for the Eighth Circuit reviewed the case. Sam’s Club argued that K7 failed to present sufficient evidence of an obligation to pay for the products, the jury’s verdict was against the weight of the evidence, and the district court abused its discretion in instructing the jury. The Eighth Circuit affirmed the district court’s decision, holding that the communications between K7 and Sam’s Club constituted binding orders under Arkansas’s Uniform Commercial Code (UCC). The court found that the evidence supported the jury’s verdict and that the district court did not abuse its discretion in its jury instructions or in denying Sam’s Club’s motions. The court also affirmed the district court’s award of prejudgment interest and attorney fees and costs. View "K7 Design Group, Inc. v. Walmart, Inc." on Justia Law

Lamar Catchings, a 20-year-old pretrial detainee, died from undiagnosed acute leukemia while in custody at the St. Louis County Buzz Westfall Justice Center in February 2019. His mother, Tashonda Troupe, filed a 42 U.S.C. § 1983 lawsuit against St. Louis County and numerous jail officials, medical staff, and correctional officers, alleging deliberate indifference to her son’s serious medical needs and failure to train or supervise the staff responsible for his care.The United States District Court for the Eastern District of Missouri dismissed the claims against most defendants at the pleading stage, citing qualified immunity and insufficient factual allegations. The court found that many of Troupe’s allegations were based on “information and belief” and lacked specific factual support. The district court allowed the claim against defendant Anthony Young, a practical nurse, to proceed, but dismissed the claims against other defendants, including correctional officers and medical staff, for lack of sufficient allegations of personal involvement or knowledge of Catchings’s condition.The United States Court of Appeals for the Eighth Circuit reviewed the case and addressed whether Troupe’s “upon information and belief” allegations were sufficient to state a claim. The court held that such allegations are permissible if the facts are within the possession and control of the defendants or based on factual information that makes the inference of culpability plausible. The court found that Troupe’s allegations met this standard and reversed the district court’s dismissal of claims against certain defendants, including Swims, Beard, Oliver, Doucette, and Murphy. The court affirmed the dismissal of claims against Mohler and Williams and partially reversed the dismissal of claims against the County, allowing the failure-to-train-or-supervise claim to proceed. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Troupe v. St. Louis County, Missouri" on Justia Law

The Equal Employment Opportunity Commission (EEOC) sued Drivers Management and Werner Enterprises on behalf of Victor Robinson, a deaf individual, under the Americans with Disabilities Act (ADA). The jury found in favor of the EEOC, awarding Robinson compensatory and punitive damages. The district court awarded Robinson backpay, reduced the damages to comply with the statutory cap, ordered injunctive relief, and granted prejudgment interest. Werner appealed, challenging multiple aspects of the proceedings.The United States District Court for the District of Nebraska granted a directed verdict on causation, dismissed Werner’s affirmative defenses of direct threat and undue hardship, and made several evidentiary rulings against Werner. The jury found that Werner failed to hire and accommodate Robinson in violation of the ADA. The district court reduced the punitive damages award to the statutory maximum and awarded backpay and prejudgment interest. Werner’s motions for judgment as a matter of law and for 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 decisions, holding that there was direct evidence of discrimination, justifying the directed verdict on causation. The court found that Werner failed to provide sufficient evidence for its undue hardship and direct threat defenses. The evidentiary rulings were deemed appropriate, as the comments and policies of other companies were relevant to the case. The court also upheld the jury’s finding that Robinson was qualified for the position and that Werner acted with malice or reckless indifference, justifying the punitive damages award. The court affirmed the district court’s equitable awards of injunctive relief and prejudgment interest, finding no abuse of discretion. View "EEOC v. Drivers Management, LLC" on Justia Law

Jacqueline Pilot applied for a promotion with the Federal Aviation Administration (FAA) in Kansas City, Missouri. After another candidate was selected, Pilot sued the Secretary of Transportation under Title VII and the Age Discrimination in Employment Act (ADEA), alleging race, sex, and age discrimination, as well as retaliation for a previous employment discrimination complaint. The district court granted summary judgment to the Secretary.The United States District Court for the Western District of Missouri reviewed the case and granted summary judgment in favor of the Secretary. The court found that Pilot did not provide sufficient evidence to support her claims of discrimination and retaliation. Pilot then appealed the decision to the United States Court of Appeals for the Eighth Circuit.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court applied the burden-shifting framework from McDonnell Douglas Corp. v. Green, which is used for claims lacking direct evidence of discrimination or retaliation. The court found that while Pilot made a prima facie case for her claims, the Secretary provided a legitimate, nondiscriminatory reason for the employment decision: the FAA hired the highest-ranked candidate based on a standardized hiring process. The court concluded that Pilot failed to show that the Secretary's reason was pretextual. The court noted that the hiring process used a mix of objective and subjective criteria, and the top-ranked candidate was selected based on a standardized rubric. The court affirmed the district court's grant of summary judgment to the Secretary, finding no evidence of pretext or discrimination. View "Pilot v. Duffy" on Justia Law

Melissa Wanna discovered her profile on MyLife, an information broker, which contained a poor reputation score and references to court records. MyLife offered to provide details or remove the profile for a fee. Believing she lost employment opportunities due to this profile, Wanna filed a class action lawsuit against several Lexis entities, alleging violations of the Fair Credit Reporting Act (FCRA), Driver’s Privacy Protection Act (DPPA), and the federal Racketeer Influenced and Corrupt Organizations Act (RICO), along with several Minnesota state law claims.The United States District Court for the District of Minnesota dismissed Wanna’s claims, concluding that MyLife was not Lexis’s agent. The court found that the data-licensing agreement between Lexis and MyLife explicitly stated that their relationship was that of independent contractors, not principal and agent. As a result, Wanna’s federal claims, which depended on an agency relationship, failed. The district court also declined to exercise supplemental jurisdiction over Wanna’s state law claims and dismissed them without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo and affirmed the dismissal. The appellate court agreed that Wanna’s federal claims required an agency relationship between Lexis and MyLife, which was not established. The court found that MyLife did not have actual or apparent authority to act on Lexis’s behalf, nor did Lexis ratify MyLife’s actions. Additionally, the appellate court held that the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over the state law claims. View "Wanna v. RELX Group, PLC" on Justia Law

Milton Porter pled guilty to being a felon in possession of a firearm, violating 18 U.S.C. § 922(g)(1). The district court sentenced him to 200 months in prison under the Armed Career Criminal Act (ACCA), 18 U.S.C. § 924(e), based on three prior violent felony convictions: a 2008 domestic assault in the second degree, a 2018 domestic assault in the second degree, and a 2018 domestic assault in the third degree, all under Missouri law. Porter appealed, arguing he did not have the requisite three prior violent felony convictions to qualify as an armed career criminal.The United States District Court for the Eastern District of Missouri determined that each of Porter's domestic assault convictions qualified as violent felonies under the ACCA. The court did not address whether Porter’s 2018 Missouri conviction for burglary in the second degree qualified as a violent felony, as the domestic assault convictions were sufficient for the ACCA enhancement.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court applied the modified categorical approach to determine that Porter's 2008 and 2018 second-degree domestic assault convictions were violent felonies under the ACCA, as they involved knowingly causing physical injury. The court also determined that Porter's 2018 third-degree domestic assault conviction was a violent felony, as it involved attempting to cause physical injury. The court affirmed the district court's judgment, holding that Porter’s three domestic assault convictions were violent felonies under the ACCA, justifying the sentence enhancement. View "United States v. Porter" on Justia Law

Anderson & Koch Ford, Inc., a Ford dealership in North Branch, Minnesota, operates under a Ford Sales and Service Agreement. In late 2022, Ford announced plans to establish a new dealership in Forest Lake, Minnesota, and to reassign half of Anderson & Koch’s designated sales area to the new dealership. Anderson & Koch filed a lawsuit in state court, alleging violations of the Minnesota Motor Vehicle Sale and Distribution Act (MVSDA), specifically sections 80E.13(k) and (p). Ford removed the case to federal court and moved to dismiss the claims.The United States District Court for the District of Minnesota partially granted Ford’s motion to dismiss, ruling that Anderson & Koch failed to state a claim under sections 80E.13(k) and (p) regarding the establishment of the new dealership. However, the court allowed Anderson & Koch to challenge the proposed change to its designated sales area under the same sections. Anderson & Koch then appealed the dismissal of its claims related to the new dealership.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court agreed that Anderson & Koch could not challenge the establishment of the new dealership under sections 80E.13(k) or (p) of the MVSDA. The court held that the establishment of a new dealership did not modify the existing franchise agreement, as required by section 80E.13(k), nor did it arbitrarily change the dealer’s area of sales effectiveness under section 80E.13(p). The court also noted that Anderson & Koch had dismissed its claims regarding the change to its sales area, leaving only the challenge to the new dealership on appeal. View "Anderson & Koch Ford, Inc. v. Ford Motor Company" on Justia Law

In several Minnesota cities, only members of a pre-approved union can work on municipal construction jobs. Multiple contractors, a carpenter, and a union objected to this requirement, alleging it violated the First Amendment. The contractors, Kaski, Inc.; Nordic Group, Inc.; and Roen Salvage Co., claimed they missed out on lucrative work due to these project-labor agreements. Luke Krhin, a carpenter, and the Christian Labor Association, which has a local chapter in Minnesota, also joined the lawsuit.The United States District Court for the District of Minnesota determined that none of the plaintiffs had standing to sue. The court found that the contractors, Krhin, and the Christian Labor Association could not succeed on their First Amendment claim. The plaintiffs appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on the issue of standing, a jurisdictional requirement. The court found that the contractors did not have standing because the relevant constitutional claims belonged to their employees, not to them. The court also found that Krhin, who opposed joining a pre-approved union, was exempt from the requirement as a supervisor, thus lacking standing. The Christian Labor Association also lacked standing because it failed to identify any members who would have standing to sue in their own right.The Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss based on a lack of standing. View "Christian Labor Association v. City of Duluth" on Justia Law