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

Plaintiffs filed suit against Peco Foods and Jonathan and DeAnn Vaught, seeking an order that would prevent Peco Foods and the Vaughts from bringing a civil suit against plaintiffs under an Arkansas statute, Ark. Code Ann. 16-118-113. Plaintiffs, who describe themselves as "nonprofit organizations dedicated to reforming industrial animal agriculture," claim that the statute violates their rights to free speech under the First Amendment. In this case, two lead organizations allege that they have "specific and definite plans" to investigate Peco Foods's chicken slaughterhouses and the Vaughts' pig farm. The district court dismissed the action based on lack of Article III standing.The Eighth Circuit reversed, concluding that the complaint adequately alleges the elements of Article III standing where plaintiffs allege that, but for the statute, the lead organizations would send an investigator to gather information and take video and audio recordings in the facilities owned by Peco Foods and the Vaughts; that all plaintiffs would use the results of the investigations in their advocacy; and that this conduct is arguably affected with a constitutional interest, because "the creation and dissemination of information are speech within the meaning of the First Amendment." The complaint also alleges an intention to engage in a course of conduct arguably proscribed by the Arkansas statute, and the complaint sufficiently alleges a credible threat of enforcement. Accordingly, the court remanded for the district court to consider the merits in the first instance. View "Animal Legal Defense Fund v. Vaught" on Justia Law

The Eighth Circuit affirmed Defendants Merrett and Frencher's convictions and sentences for crimes related to their membership in a drug trafficking organization.The court affirmed the district court's denial of defendant's motion to suppress evidence obtained from a wiretap, concluding that the wiretap authorization was valid where the government established necessity and probable cause that the phone was connected to criminal activity; there was reasonable suspicion to stop the vehicle in which Frencher was riding because the police had reasonable grounds to believe, based on the wiretap, that he was on his way to commit burglary; the search was not unreasonably extended; and the police had probable cause to search the vehicle based on the smell of marijuana emanating from the vehicle.The court concluded that Frencher and Merrett's sentences were not substantively unreasonable where the district court did not clearly err in weighing the 18 U.S.C. 3553(a) factors. Furthermore, the district court considered Merrett's mitigation arguments and his sentence was not extremely disparate from Frencher's sentence. View "United States v. Merrett" on Justia Law

The Eighth Circuit affirmed the district court's denial of the 28 U.S.C. 2254 petition for habeas relief as procedurally defaulted. In this case, petitioner's ineffective-assistance-of-counsel claim was first procedurally defaulted on appeal, not at the initial-review collateral proceeding, which makes the Martinez exception inapplicable to petitioner's case. Therefore, with no excuse for the procedural default, federal habeas review of the claim is barred. View "Hartman v. Payne" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the employer in an action brought by plaintiff, alleging that the employer violated the Nebraska Equal Pay Act and the Nebraska Fair Employment Practices Act by giving her male counterparts better pay despite her stronger work performance.The court concluded that the facts presented were insufficient to establish plaintiff's prima face case under the Nebraska Equal Pay Act because nothing in the record suggests that her position required her to take on the additional duties and responsibilities of her higher-ranked coworkers. Because plaintiff's evidence was insufficient either to establish her prima facie case under the Nebraska Fair Employment Practices Act or to show that the employer's reasons for the pay disparity were pretextual, the district court properly granted the employer's motion for summary judgment. View "Perry v. Zoetis LLC" on Justia Law

CRST filed suit alleging that Swift wrongfully recruited and hired long-haul truck drivers who were "under contract" with CRST. Ruling on post-verdict motions, the district court upheld the intentional interference with contracts award, vacated the unjust enrichment award because it was predicated on a theory of damages rejected in the court's summary judgment rulings, and remitted the punitive damages to $3 million.The Eighth Circuit reversed the district court's post-verdict order upholding the intentional interference verdict because it relied upon CRST's theory of liability that the court rejected in CRST Expedited, Inc. v. TransAm Trucking, Inc., 960 F.3d 499 (8th Cir. 2020). The court explained that the proper focus is on intentionally and improperly causing the employee to violate his or her covenant not to compete, not merely on the hiring of a competitor's at-will employee to further the actor's legitimate competitive interests. After careful review of the record, the court concluded that it must reverse with instructions to dismiss because, for multiple reasons, CRST failed to prove its interference with contract claim and therefore its claim for unjust enrichment as well. The court affirmed the amended judgment in favor of Swift on CRST's unjust enrichment claim. View "CRST Expedited, Inc. v. Swift Transportation Co." on Justia Law

The Eighth Circuit affirmed the district court's dismissal of a petition for writ of habeas corpus where petitioner challenged his 2000 felon-in-possession conviction under Rehaif v. United States, 588 U.S. ---, 139 S. Ct. 2191 (2019). The court agreed with the district court that petitioner failed to show that 28 U.S.C. 2255's remedy was ineffective or inadequate to test the legality of his detention—a prerequisite in his case to habeas relief. In this case, section 2255's remedy was itself perfectly capable of facilitating petitioner's argument where section 2255 authorizes a motion challenging a sentence upon the ground that the sentence was imposed in violation of the laws of the United States. View "Jones v. Hendrix" on Justia Law

The Union, Welfare Plan, and Pension Plan filed suit against Anderson Excavating, requesting that the district court order Anderson Excavating to pay the contributions it allegedly owes to the Welfare Plan and Pension Plan, along with interest, liquidated damages, and attorneys' fees and costs. The district court found Anderson Excavating liable to plaintiffs for delinquent contributions and entered judgment in favor of plaintiffs. Anderson Excavating appealed, and the Eighth Circuit concluded that the district court legally erred in applying the alter-ego doctrine to justify an award of unpaid contributions for an alleged employee's work.The Eighth Circuit affirmed the district court's judgment on remand, concluding that the district court did not err in calculating the prejudgment interest at the rate set by the Delinquent Policy and Procedure document adopted by the Plan Trustees as part of the trust agreement, which Anderson had agreed to; the district court properly calculated the amount of liquidated damages, which was based on the amount of prejudgment interest; and the district court did not abuse its discretion in awarding attorneys' fees. View "Marshall v. Anderson Excavating & Wrecking Co." on Justia Law

The Eighth Circuit affirmed the district court's order granting summary judgment to Agrifund on the conversion claim Agrifund brought against Heartland. The court concluded that Heartland failed to exercise reasonable commercial standards of fair dealing, and Heartland does not qualify as a holder in due course. In this case, it would have taken minimal effort for Heartland to confirm, whether with the borrowers or with Agrifund, that Agrifund had been fully recompensed before accepting the payment at issue.The court also concluded that the Subrogation Agreement did not bind Heartland to the terms of the Note; the 14% contractual interest rate does not apply to the damages award; and the district court properly awarded pre-judgment interest at the rate required by Iowa law and post-judgment interest at the federal rate. Finally, the court concluded that Heartland is not liable for attorney fees as set forth in the Note, and there is no abuse of discretion in the district court's decision to deny Agrifund's request for attorney fees. Accordingly, the court affirmed the district court's award of damages and attorney fees. View "Agrifund, LLC v. Heartland Co-op" on Justia Law

Trustees of five multi-employer benefits funds filed suit against Green Nature under section 515 of the Employee Retirement Income Security Act (ERISA) and section 301 of the Labor Management Relations Act (LMRA), alleging that Green Nature failed to contribute to the funds on behalf of its non-union employees and sought to collect from Green Nature the delinquent contributions, interest, costs, and attorney's fees.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the trustees. The court concluded that the district court correctly determined that the collective bargaining agreement (CBA) unambiguously required fringe benefit contributions for non-union employees. The court also found that an award of delinquent fringe benefit contributions would not improperly require Green Nature to "duplicate fringe contributions." The court need not determine whether issue preclusion could ever be a valid defense to a collection action because the substantive elements of issue preclusion are not satisfied. Finally, the district court did not abuse its discretion in awarding the trustees attorney's fees and in declining to reduce the amount. View "Nesse v. Green Nature-Cycle, LLC" on Justia Law

Plaintiff filed suit against Officers Kuykendall and Henry, arguing that they violated his Fourth and First Amendment rights. After the district court denied defendants' motion for summary judgment on the basis of qualified immunity, they filed this interlocutory appeal.Concluding that it has jurisdiction under the collateral order doctrine, the Eighth Circuit reversed the district court's denial of defendants' motion for summary judgment. The court concluded that John Doe's and the third party's reports were sufficient to have provided probable cause to arrest plaintiff for assault in the fourth degree under Missouri law. In this case, the facts that plaintiff directs the court to do not diminish the officers' probable cause to believe, at the time of plaintiff's arrest, that he had committed a crime. Furthermore, the fact that no formal charges were initiated against plaintiff does not retroactively diminish the reasonableness of the officers' belief. Even if the officers were mistaken that probable cause existed, that mistake was "objectively reasonable" and arguable probable cause exists, entitling them to qualified immunity. Finally, the officers were also entitled to qualified immunity on plaintiff's First Amendment retaliation claim. View "Just v. Kuykendall" on Justia Law