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

Jose Rolando Gonzalez entered a conditional guilty plea to one count of conspiracy to distribute a controlled substance, reserving the right to appeal the district court's denial of his motion to suppress evidence. On September 25, 2022, two separate calls were made to law enforcement reporting a black car driving erratically on I-29. South Dakota State Trooper Chris Spielmann and Trooper Mitchell Lang, along with Brookings Police Officer Seth Bonnema, located the car at a gas station. Gonzalez and his passenger, Marquez Gonzalez, were questioned, and their inconsistent and suspicious responses led Officer Bonnema to use a K-9 unit, which indicated the presence of drugs. A search revealed methamphetamine, cash, drug paraphernalia, and cell phones.The United States District Court for the District of South Dakota denied Gonzalez's motion to suppress the evidence, finding that the officers had reasonable suspicion to stop and search the vehicle. Gonzalez appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court applied a mixed standard of review, examining factual findings for clear error and legal conclusions de novo. The court held that the officers had reasonable suspicion for the Terry stop based on the consistent reports of erratic driving, the car's location, and the corroboration of details such as the car's color and behavior. The court also found that the officers did not unlawfully prolong the stop, as Gonzalez's responses and the circumstances provided reasonable suspicion to expand the scope of the stop. The court affirmed the district court's denial of the motion to suppress. View "United States v. Gonzalez" on Justia Law

Plaintiffs, E&I Global Energy Services, Inc. and E&C Global, LLC, sued Liberty Mutual Insurance Company for breach of contract and tort claims related to a construction project. The United States, through the Western Area Power Administration (WAPA), contracted with Isolux to build a substation, and Liberty issued performance and payment bonds for Isolux. After Isolux was terminated, Liberty hired E&C as the completion contractor, but E&I performed the work. Plaintiffs claimed Liberty failed to pay for the work completed.The United States District Court for the District of South Dakota granted summary judgment for Liberty on the unjust enrichment claim and ruled in Liberty's favor on all other claims after a bench trial. The court denied Plaintiffs' untimely request for a jury trial, excluded an expert witness report filed after the deadline, found no evidence of an assignment of rights between E&C and E&I, and ruled against Plaintiffs on their fraud, deceit, and negligent misrepresentation claims.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the jury trial request, as Plaintiffs failed to timely file the motion and did not justify the delay. The exclusion of the expert report was also upheld, as the district court properly applied the relevant factors and found the late report was neither substantially justified nor harmless. The court affirmed the district court's finding that there was no valid assignment of rights from E&C to E&I, meaning Liberty's promise to pay was to E&C, not E&I. The court also upheld the findings that Liberty did not have the intent to deceive or induce reliance, and that Bruce did not reasonably rely on Mattingly's statements. Finally, the court declined to address the unjust enrichment claim as Plaintiffs did not raise the argument below. The Eighth Circuit affirmed the district court's rulings in their entirety. View "E&I Global Energy Services v. Liberty Mutual Insurance Co." on Justia Law

Devin Ledbetter was seriously injured by Springfield, Missouri police officer Brandon Helmers. Ledbetter sued Helmers under 42 U.S.C. § 1983, claiming Helmers used excessive force in violation of the Fourth Amendment. The incident occurred when Helmers and his partner responded to a 911 call about a man holding a woman captive in a tent. Ledbetter, who was in the tent, exited holding a knife. The accounts of what happened next differ, with Helmers claiming Ledbetter was non-compliant and threatening, while Ledbetter claimed he immediately dropped the knife and was compliant. Ledbetter sustained severe injuries, including a fractured hip, during the arrest.The United States District Court for the Western District of Missouri denied Helmers's motion for summary judgment based on qualified immunity, noting disputed facts about the threat Ledbetter posed and the amount of force used. The case proceeded to trial, but the jury could not reach a verdict on liability. However, they answered special interrogatories, finding Helmers reasonably believed Ledbetter posed an immediate threat but did not believe Ledbetter was resisting arrest. The district court then granted Helmers's motion for judgment as a matter of law based on qualified immunity, concluding that Helmers did not use excessive force and that his conduct did not violate clearly established law.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that a reasonable jury could find Helmers used excessive force, given the evidence and the jury's special findings. However, the court also held that it was not clearly established that Helmers's use of force was excessive under the circumstances, as existing case law did not provide sufficient guidance for the specific situation Helmers faced. Therefore, the court affirmed the district court's judgment granting Helmers qualified immunity. View "Ledbetter v. Helmers" on Justia Law

Joseph Thompson, Sr. was convicted by a jury of voluntary manslaughter under 18 U.S.C. §§ 1153 and 1112. The incident occurred when Thompson was visiting Charmayne Grooms at her home in Lower Brule, South Dakota. Marty LaRoche, the father of Grooms's children, attempted to enter the home through a window, leading to a confrontation outside between Thompson and LaRoche. LaRoche was found with multiple stab wounds and later died from his injuries. Thompson claimed self-defense, stating LaRoche tried to fight him.The United States District Court for the District of South Dakota denied Thompson's motion for judgment of acquittal and his request for a self-defense jury instruction based on South Dakota law. Instead, the court used the federal self-defense instruction. The jury found Thompson guilty of voluntary manslaughter, a lesser-included offense of the original second-degree murder charge.The United States Court of Appeals for the Eighth Circuit reviewed the case. Thompson argued that the district court erred in not using the South Dakota self-defense instruction and that there was insufficient evidence to support the jury's verdict. The Eighth Circuit held that the district court did not abuse its discretion in using the federal self-defense instruction, noting that federal law, not state law, governs self-defense claims in federal criminal trials. The court also found that sufficient evidence supported the jury's verdict, as Thompson left the safety of the home to confront LaRoche and inflicted multiple stab wounds, including fatal injuries.The Eighth Circuit affirmed the district court's judgment, upholding Thompson's conviction and sentence of 128 months' imprisonment. View "United States v. Thompson" on Justia Law

Muhammad Masood, a licensed physician from Pakistan, came to the United States in 2018 on a non-immigrant visa to work as an unpaid medical researcher. In 2019, he became radicalized by Islamic extremist content and planned to join ISIS. In March 2020, he was arrested at the Minneapolis airport with plans to travel to ISIS-controlled territory. A search revealed military and medical supplies, computers, and digital storage devices containing extremist propaganda. Masood pleaded guilty to attempting to provide material support to a designated foreign terrorist organization.The United States District Court for the District of Minnesota adopted the Presentence Investigation Report (PSR) and sentenced Masood to 216 months imprisonment, varying downward from the statutory maximum of 240 months. Masood appealed, arguing procedural errors in applying the terrorism enhancement, considering the 18 U.S.C. § 3553(a) sentencing factors, and alleged violations of his due process rights and right to allocution.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no procedural error in applying the terrorism enhancement, as the evidence supported that Masood's offense was intended to promote terrorism. The court also found that the district court adequately considered the § 3553(a) factors and provided a sufficient explanation for the sentence. Additionally, the court determined there was no violation of Rule 32(i) or the Due Process Clause, as Masood and his counsel were given opportunities to argue and allocute before the final sentence was imposed. The Eighth Circuit affirmed the district court's judgment. View "United States v. Masood" on Justia Law

Anthony Red Elk was convicted by a jury on one count of aggravated sexual abuse of a minor and two counts of sexual abuse. The charges were based on allegations by his niece, C.T.B., that Red Elk raped her once when she was under twelve and again on two occasions when she was nineteen and twenty. Additionally, the government introduced testimony from K.W., who alleged that Red Elk attempted to sexually assault her in 2007 when she was sixteen.The United States District Court for the District of South Dakota admitted K.W.'s testimony under Federal Rule of Evidence 413, which allows evidence of prior sexual assaults to show a defendant's propensity to commit such offenses. The court also applied two sentencing enhancements: a four-level enhancement for use of force on Counts 2 and 3, and a five-level enhancement for being a repeat and dangerous sex offender against minors, resulting in a total offense level of 46, reduced to the Sentencing Guidelines' maximum of 43. Red Elk was sentenced to life imprisonment on each count, to run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in admitting K.W.'s testimony, finding it relevant and not unduly prejudicial under Rule 403. The court also upheld the application of the repeat and dangerous sex offender enhancement, finding that K.W.'s testimony established by a preponderance of the evidence that Red Elk attempted aggravated sexual abuse. Finally, the court found that any error in applying the use of force enhancement was harmless, as it did not affect the total offense level. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Elk" on Justia Law

Robert Carl Sharp was released from federal prison in 2012 and later sold herbal incense products containing a synthetic cannabinoid, AB-FUBINACA, while on supervised release. He was arrested in 2014 for violating his supervised release terms. During a proffer interview, Sharp, represented by attorney Joel Schwartz, admitted to selling synthetic cannabinoids to several individuals. In 2015, Sharp was indicted for conspiracy to manufacture and distribute a controlled substance and possession with intent to distribute. He pleaded guilty without a plea agreement but later sought to withdraw his plea, claiming Schwartz had a conflict of interest due to previous representation of potential witnesses.The United States District Court for the Northern District of Iowa denied Sharp's motion to withdraw his guilty plea, finding Schwartz credible and Sharp not credible. Sharp was sentenced to 360 months' imprisonment. On appeal, the Eighth Circuit affirmed his conviction, concluding that Sharp had not shown that proceeding to trial would have been objectively reasonable or that Schwartz's advice to plead guilty was linked to an actual conflict of interest.Sharp then filed a 28 U.S.C. § 2255 motion, claiming ineffective assistance of counsel due to Schwartz's alleged conflict of interest from previous representation of other individuals involved in the case. The district court denied the motion, determining that Sharp had not shown Schwartz failed to pursue a reasonable alternative defense strategy due to any conflicts.The United States Court of Appeals for the Eighth Circuit reviewed the denial of Sharp's § 2255 motion, affirming the district court's decision. The court held that Sharp did not demonstrate that any alleged conflict of interest actually affected the adequacy of his representation, nor did he show that his new counsel, Michael Lahammer, performed deficiently. Thus, the court concluded that Sharp was not denied effective assistance of counsel and affirmed the judgment of the district court. View "Sharp v. United States" on Justia Law

Edwin Giovanni Salinas was stopped by law enforcement on the Lake Traverse Reservation in South Dakota. He was a passenger in a vehicle driven by Berta Rosmelvi Gonzales, who initially provided false identification. After her arrest, officers found Salinas throwing items inside the vehicle. They discovered methamphetamine in Gonzales’s purse and a backpack containing fentanyl in the trunk. Salinas and Gonzales were charged with conspiracy to distribute and possession with intent to distribute a controlled substance. A jury found Salinas guilty on both counts.The United States District Court for the District of South Dakota calculated a base offense level of 34 for Salinas, applying a two-level enhancement under U.S.S.G. § 2D1.1(b)(13) for trafficking counterfeit fentanyl pills and additional enhancements for his role in the offense. The court imposed a life sentence, citing Salinas’s presence on the reservation with a large quantity of fentanyl and the potential harm to the community.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the application of the § 2D1.1(b)(13) enhancement, finding sufficient evidence that Salinas acted with willful blindness regarding the counterfeit nature of the pills. However, the court held that the district court procedurally erred by basing the life sentence on clearly erroneous facts, specifically the unproven intention to distribute drugs on the reservation. The appellate court vacated Salinas’s life sentence and remanded for resentencing. View "United States v. Salinas" on Justia Law

The Acting Secretary of the U.S. Department of Labor filed a lawsuit against Levering Regional Health Care Center and Reliant Care Management Company for violating the Fair Labor Standards Act (FLSA). The suit alleged that Levering deducted 30 minutes of pay for employees' meal breaks, despite knowing that employees routinely worked through these breaks. An investigation revealed that many employees did not receive lunch breaks or had them interrupted, and some were unaware of the policy to report missed breaks for compensation.The United States District Court for the Eastern District of Missouri granted Levering's motion for summary judgment. The court concluded that Levering did not have actual or constructive knowledge of the unpaid overtime work due to the employees' failure to use the established reporting policy. Additionally, the court found that the Secretary did not adequately establish the amount of overtime owed.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that there was sufficient evidence to suggest that Levering may have failed to effectively communicate its policy to employees, as evidenced by the lack of time sheets submitted during the audit period compared to a later period. The court also found that the Secretary provided enough evidence to estimate the amount of unpaid overtime work, meeting the burden of showing the extent of the work as a matter of just and reasonable inference. The case was remanded for further proceedings. View "Micone v. Levering Regional HCC, L.LC." on Justia Law

Jeremy James Allen, while incarcerated at the Minnesota Correctional Facility in Faribault, filed a complaint against several officials alleging deliberate indifference and medical malpractice related to a hand injury from December 2017. He did not file any grievances with prison officials regarding his injury or medical treatment during his incarceration. Allen's complaint was initially filed in state court and later removed to federal court. After his release from custody, Allen amended his complaint, substituting Charles Brooks and Cheryl Piepho for previously unidentified defendants.The United States District Court for the District of Minnesota granted Allen's unopposed motion to amend his complaint after his release. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction and failure to state a claim, but did not initially raise the issue of exhaustion of administrative remedies. The district court denied the motion to dismiss on qualified immunity grounds, finding that Allen plausibly alleged a violation of his Eighth Amendment right to adequate medical care.Brooks and Piepho later raised the failure to exhaust defense in a summary judgment motion, arguing that Allen's original complaint, filed while he was incarcerated, was subject to the Prison Litigation Reform Act (PLRA) exhaustion requirement. The district court denied their motion, ruling that the amended complaint, filed after Allen's release, was not subject to the PLRA's exhaustion requirement and did not relate back to the original complaint under Federal Rule of Civil Procedure 15(c).The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that Allen's amended complaint, filed after his release, was the operative complaint and not subject to the PLRA's exhaustion requirement. Additionally, the court found that the amended complaint did not relate back to the original complaint because naming John and Jane Doe defendants did not qualify as a "mistake" under Rule 15(c). View "Allen v. Brooks" on Justia Law