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

The Eighth Circuit affirmed the district court's imposition of a 7 month sentence and a 60 month term of supervised release after defendant's second revocation of supervised release. In this case, defendant pleaded guilty to two felonies and violated the conditions of his release several times.The court concluded that the 60 month term of supervised release was substantively reasonable where the district court was authorized to impose as much as 86 months of supervised release; it had wide latitude to weigh the 18 U.S.C. 3553(a) factors; and thus was entitled to focus in particular on the offense of conviction, the problems on supervised release, and the nature of the problems while on supervised release. Furthermore, there were reasonable considerations in light of defendant's consistent resistance to complying with the conditions of his release and the multiple revocations of his release. View "United States v. Barber" on Justia Law

Following the death of Justin Stufflebean after he allegedly was denied necessary medication while incarcerated, his parents filed suit alleging that the County and others were liable for wrongful death under Missouri law. The district court denied the County's motion to dismiss, concluding that the County had waived sovereign immunity by purchasing liability insurance that covered the wrongful-death claim.The Eighth Circuit affirmed the district court's denials of the County's motion to dismiss, as well as a related motion for reconsideration, concluding that Mo. Rev. Stat. 537.610(1)'s plain text, bolstered by the statute's purpose and Missouri caselaw, shows that the County's acquisition of liability insurance in this case constitutes a waiver of its sovereign immunity. In this case, the County entered into an inmate-health-services contract with ACH; the contract contained an agreement to pay ACH approximately $300,000 per year; and, in exchange, ACH agreed to provide various services. View "Davis v. Buchanan County, Missouri" on Justia Law

The Eighth Circuit concluded that the evidence was sufficient to support defendant's conviction for conspiracy to distribute a controlled substance, and affirmed the district court's denial of his motion for judgment of acquittal. In this case, there was plenty of evidence to show a conspiracy and a reasonable jury could find a methamphetamine distribution model agreed to by at least one of the participants. View "United States v. Smith" on Justia Law

After plaintiff suffered injuries to his right hand while using a RotoZip Model RZ20 hand-held spiral saw, he filed suit against Bosch, the manufacturer, and Lowe's, the retailer, alleging strict liability and negligence products liability theories. Plaintiff alleged that he was injured when the saw’s auxiliary handle spontaneously detached from the saw's body.The Eighth Circuit affirmed the district court's grant of defendants' joint motion to bar the opinions of plaintiff's expert regarding the saw's alleged design defects and the saw's failure to have an interlocking device safety measure. The court concluded that the expert's proposed opinion lacked relevance as it did not fit the facts of this case. The court explained that plaintiff did not meaningfully argue in his brief his claim that the saw was defective for not having an interlocking safety measure and thus waived his claim. Furthermore, even if the issue was not waived, the district court did not err in concluding the expert's testimony on alternative-design options was not reliable and should not be admitted.The court also affirmed the district court's grant of defendants' joint motion for summary judgment on plaintiff's claims of strict products liability, negligent design, negligent failure to warn, and negligent supply of a dangerous instrumentality. In this case, the district court concluded that the claims involved such complex or technical information that they required expert testimony. Therefore, the exclusion of plaintiff's expert was fatal to his claims. View "McMahon v. Robert Bosch Tool Corp." on Justia Law

The Eighth Circuit denied a petition for review of the BIA's decision denying petitioner's application for cancellation of removal. The court concluded that the substitution of immigration judges between the removal hearing and the decision did not violate the text of 8 U.S.C. 1229a(a)(1) nor petitioner's due process rights. The court explained that the phrase "the immigration judge" used in subsequent clauses simply refers to whichever immigration judge is conducting that part of the removal proceedings; the phrase does not require that the first immigration judge oversee the case from initiation to completion. Furthermore, the judge who wrote the decision fully complied with the governing regulations. Finally, petitioner failed to establish a due process right. View "Orpinel-Robledo v. Garland" on Justia Law

After the parties resolved a dispute involving a challenge by Native American residents of North Dakota to portions of the States elections statutes with a consent decree, the district court granted plaintiffs' motions for attorney's fees.The Eighth Circuit affirmed, concluding that, although plaintiffs' motion was untimely under Federal Rule of Civil Procedure 54, plaintiffs' failure to meet the filing deadline was the result of excusable neglect. In this case, there is no evidence that plaintiffs acted in bad faith; there are defensible reasons for their delay; and the Secretary could have factored the uncertainty in the law into his decision whether to appeal the injunction. View "Spirit Lake Tribe v. Jaeger" on Justia Law

The Eighth Circuit granted a petition for review of the BIA's order determining that petitioner was removable because his prior conviction for enticing a minor under Iowa law was a "crime of child abuse." Applying the categorical approach, the court concluded that the Board's decision cannot be upheld on the rationale advanced by the government because it conflates two separate elements in the Iowa statute. Looking only at the plain text of the Iowa statute, the court cannot exclude the possibility that an offender could be prosecuted for enticing a minor with intent to commit disorderly conduct or harassment upon a minor. Furthermore, the Board's decision is not clear about how it understood the "realistic probability" requirement. Accordingly, the court vacated the Board's decision and remanded for further proceedings. View "Pah Peh v. Garland" on Justia Law

The Eighth Circuit affirmed the district court's holding that University employees violated InterVarsity's First Amendment rights and denial of qualified immunity. In this case, the University deregistered InterVarsity as a Registered Student Organization based on the University's determination that InterVarsity had violated the University's Policy on Human Rights by requiring its leaders to subscribe to certain religious beliefs.The court agreed with the district court that the University's policy was reasonable and viewpoint neutral, but not as applied to InterVarsity. The court explained that the University's choice to selectively apply the policy against InterVarsity suggests a preference for certain viewpoints over InterVarsity's. Furthermore, these rights were clearly established at the time of the violation. View "Intervarsity Christian Fellowship/USA v. University of Iowa" on Justia Law

On remand from the Supreme Court in light of Caniglia v. Strom, 593 U.S. ---, 141 S. Ct. 1596 (2021), the Eighth Circuit affirmed the district court's grant of summary judgment for the officers and the City in this action under 42 U.S.C. 1983 and Minnesota state law.The court concluded that it was well established at the time that the community-caretaking exception was a standalone doctrine that could justify the officers' warrantless entry into a home. In the circumstances here, the court concluded that the officers' warrantless entry did not violate plaintiff's Fourth Amendment rights under the then-extant community-caretaking jurisprudence. Therefore, the officers were entitled to qualified immunity with respect to the Fourth Amendment warrantless-entry claim.In regard to plaintiff's claim that the officers violated her Fourth Amendment right to be free from unreasonable seizures when they seized her for a mental-health evaluation, the court affirmed summary judgment and concluded that probable cause of dangerousness is the standard that must be met for a warrantless mental-health seizure to be reasonable under the Fourth Amendment. Furthermore, assuming the officers lacked probable cause here, they may still be entitled to qualified immunity given the ambiguity in the court's case law about the requisite standard. Finally, the officers are entitled to qualified immunity because their actions did not violate clearly established law under the lower reasonable-belief standard some of the court's precedents suggested was the requisite standard.In regard to plaintiff's claim of retaliatory arrest, the court affirmed summary judgment because no reasonable jury could conclude that retaliatory animus was a but-for cause of plaintiff's arrest. In regard to plaintiff's claim that the City's policy concerning seizures for emergency mental-health evaluation was facially unconstitutional, the district court affirmed summary judgment because the policy requires probable cause that the person is a threat to self or others. The court rejected plaintiff's inadequate-training claim and concluded that the officers were entitled either to statutory or official immunity on the state law claims. View "Graham v. Barnette" on Justia Law

On remand from the Supreme Court in light of Caniglia v. Strom, 593 U.S. ___, 141 S.Ct. 1596 (2021), the Eighth Circuit affirmed the district court's denial of defendant's motion to suppress.The court concluded that officers had an objectively reasonable basis to enter the victim's house without a warrant. In this case, the officers were dispatched to the scene of a domestic disturbance call; an officer observed a child in an upstairs window acting excitedly and gesturing at him; the victim answered the door with visible injuries, even though she said everything was okay; and, after the officers heard crying coming from inside the house, decided to enter to provide emergency assistance. The court explained that, although the presence of a domestic violence suspect in a home with children cannot alone justify a warrantless entry, here the officers were confronted with facts indicating that the suspect was a threat to the children or others. In this case, the record establishes that the officers had reason to believe that a domestic violence suspect was inside the home with children. Furthermore, the scope of the encounter was carefully tailored to satisfy the officers' purpose for entry, and one of the officers had an objectively reasonable belief that a gun was inside the house. Finally, the court concluded that the district court did not err in applying a two-level sentencing enhancement under USSG 3C1.1 for obstruction of justice for attempting to influence a witness. View "United States v. Sanders" on Justia Law