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

The Bankruptcy Appellate Panel vacated the bankruptcy court's order confirming debtor's chapter 12 plan, concluding that the bankruptcy court erred by failing to hold an evidentiary hearing to determine the value of the Bank's collateral where the collateral was disputed. The panel also concluded that the Bank needed to file a proof of claim. The panel explained that, until the bankruptcy court holds the requisite evidentiary hearing and determines the value of the Bank's collateral, it is impossible to say whether under the debtor's plan the Bank will be paid not less than the allowed amount of its secured claim. Accordingly, the panel remanded for further proceedings. Finally, the panel concluded that the record amply supports the bankruptcy court's finding of disposable income under 11 U.S.C. 1225(b)(1)(B). View "Citizens State Bank v. Schiller" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Cactus Farms in an action brought by plaintiff, alleging a violation of the overtime provisions of the Fair Labor Standards Act (FLSA). The court concluded that the district court did not err in finding that plaintiff was exempt from coverage under the FLSA because he was an agricultural employee. In this case, plaintiff's load assessments were on-the-farm practices "incident to or in conjunction with such farming operations" regardless of whether the assessment was for the transportation of pigs between farms or for their transportation from a farm to processing. View "Bills v. Cactus Family Farms, LLC" on Justia Law

The Eighth Circuit reversed the district court's grant of summary judgment to plaintiff in an action brought against several officials under the Administrative Procedure Act. The district court concluded that the doctrine of issue preclusion barred the government's rationale for denying plaintiff's application for adjustment of status.The court concluded that the disputed issue of whether plaintiff solicited funds for a terrorist organization was not actually litigated in an earlier proceeding, and thus issue preclusion does not apply. In this case, the record shows that whether plaintiff was inadmissible because he solicited funds for a terrorist organization was not raised, contested, and submitted for determination in the 2001 asylum proceeding. The court remanded for further proceedings. View "Fofana v. Mayorkas" on Justia Law

The Eighth Circuit reversed the district court's decision affirming the ALJ's termination of plaintiff's disability insurance benefits and supplemental security income, because substantial evidence does not support the termination of benefits. In this case, plaintiff alleged that her disability began in July 2012 due to degenerative disc disease (DDD), bulging disc, irritable bowel syndrome, depression, anxiety, bipolar disorder, and post-traumatic stress disorder (PTSD).The court concluded that substantial evidence on the record as a whole does not support the finding that plaintiff's pain significantly improved to the point where she would no longer miss two days or more of work per month. In this case, the ALJ erroneously discounted plaintiff's allegations regarding her pain and also erroneously discounted other physicians' opinions. Finally, the court concluded that substantial evidence did not support the residual functioning capacity finding. The court remanded with instructions to return the case to the Social Security Administration for a new medical-improvement evaluation. View "Koch v. Kijakazi" on Justia Law

After plaintiff sustained significant injuries during the course of an arrest on domestic violence and related charges, he filed suit against the arresting officers, city officials, and the City of Independence, alleging violations of his constitutional rights. The district court granted summary judgment to the defendants on all claims.The Eighth Circuit concluded that the district court erred in granting qualified immunity to Defendant Schmidli; plaintiff has shown a violation of the constitutional right to be free from excessive force by law enforcement; and a reasonable officer would have had fair warning that, at the time, he could not violently takedown a person who was not threatening anyone, not actively resisting arrest, and not attempting to flee. However, the court concluded that Defendant Gentile was entitled to qualified immunity because there was insufficient evidence that he used excessive force or significantly contributed to the driving force that caused the injury.The court also concluded that the defendant officers are entitled to summary judgment on the substantive due process claim where plaintiff failed to provide any evidence that any inaccuracy in the officers' reports was fabricated in order to frame him. Furthermore, there is no reasonable inference drawn from plaintiff's version of the facts that would allow a finder of fact to conclude that Schmidli and Gentile deliberately lied with the intention of framing him. Finally, the City was entitled to summary judgment on plaintiff's Monell claim where plaintiff failed to establish the City had an unofficial custom authorizing officers to use excessive force. View "McReynolds v. Schmidli" on Justia Law

The Eighth Circuit denied a petition for review of the BIA's decision affirming the IJ's denial of petitioner's application for asylum, withholding of removal, and relief under the Convention Against Torture. The court concluded that substantial evidence supported the IJ's specific, cogent reasons for finding that petitioner's testimony was not credible.In this case, the IJ identified petitioner's inconsistency regarding the year her relationship began with her abusive boyfriend; pointed to contradictions about her living arrangements with him; noted her omission, until the hearing, of his shooting at her house; mentioned her failure to describe, until the hearing, the gang ambush; cited her failure to indicate, until the hearing, that he was a member of a gang; noted that her mother's letter of support mentioned only one pregnancy and did not mention any threat from the boyfriend; detailed discrepancies between petitioner's statement and the medical records she submitted; and determined that she was nonresponsive to the question asked of her during the hearing. View "Coto-Albarenga v. Garland" on Justia Law

The Eighth Circuit reversed defendant's sentence in a case where defendant and the government entered into a plea agreement in which he stipulated that he had sold methamphetamine to a confidential informant for thirty dollars. The court agreed with defendant that the district court miscalculated his Sentencing Guidelines range when it found him responsible for drugs to which he had no connection. The court explained that the district court committed procedural error when it found a connection between defendant and the materials found in his girlfriend's home and car. The court remanded for resentencing. View "United States v. Sarchett" on Justia Law

The Eighth Circuit affirmed the district court's order committing defendant to the custody of the Attorney General for mental health care pursuant to 18 U.S.C. 4246 after he was charged with being a prohibited person in possession of a firearm. The court concluded that the district court did not improperly discount the finding of defendant's expert regarding defendant's future dangerousness. The court explained that the district court's standard did not improperly shift the burden of proof, and that the inherent time disparity between the government experts and defendant's expert does not warrant reversal. Moreover, the district court explained that the primary reason for ordering commitment was the weakness of defendant's expert's opinion. View "United States v. Dalasta" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress, concluding that the warrant affidavit contained sufficient corroborated information to support a fair probability that evidence of a crime would be found at defendant's house. In this case, the detective's corroboration, combined with the specificity of the anonymous source's information and physical presence before the officer and issuing judge, sufficiently established probable cause for the search warrant. The court also concluded that, because the affidavit underlying the search warrant for defendant's residence also supported probable cause to detain and arrest him, the officers did not need separate indicia of criminal activity occurring at the time of the arrest to make the arrest. View "United States v. Evans" on Justia Law

The Eighth Circuit affirmed defendant's conviction of two counts of aggravated sexual abuse of a child. The court concluded that the district court did not err by denying his motion for judgment of acquittal where the evidence was sufficient to support defendant's convictions; the district court did not err by denying his motions to exclude evidence of prior drug and alcohol use; the district court did not err by excluding expert testimony and his request for a Daubert hearing where the district court determined that no hearing was necessary and the experts were qualified based on their knowledge, skill, experience, training, and education; the district court did not err by excluding text messages between defendant and the victim as hearsay; and any error in excluding specific details of the victim's misbehavior was harmless. View "United States v. Aungie" on Justia Law