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

Several former employees of a logistics company left their positions and later joined a competitor. The former employer alleged that, as a condition of their employment, these individuals had signed agreements containing restrictive covenants, including broad non-solicitation and business interference clauses. The company claimed the employees breached these restrictive covenants and further alleged that the competitor had tortiously interfered with its contractual relationships.Initially, the United States District Court for the District of Minnesota granted summary judgment for the defendants, holding that the agreements were unenforceable under California law, and thus the breach of contract and tortious interference claims failed. On the first appeal, the Eighth Circuit determined that Minnesota law rather than California law governed the agreements for all but one employee, remanding the case to the district court to reconsider the enforceability of the contracts under Minnesota law and to resolve related summary judgment motions. On remand, the district court again granted summary judgment to the defendants, holding the restrictive covenants were overly broad and unenforceable under Minnesota law, and denied the plaintiff’s motion for voluntary dismissal of certain claims.On appeal, the United States Court of Appeals for the Eighth Circuit held that the restrictive covenants in the agreements are unenforceable under Minnesota law, as they sweep more broadly than necessary to protect the former employer’s business interests, both in scope and geographic reach. The Eighth Circuit also affirmed the district court’s denial of voluntary dismissal, finding it would waste judicial resources and could prejudice the affected employee. The Eighth Circuit affirmed the district court's grant of summary judgment for the defendants, denial of the plaintiff’s summary judgment motion, and denial of the plaintiff’s motion for voluntary dismissal. View "C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc." on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

A member of the Sisseton Wahpeton Oyate tribe was observed by a tribal police officer driving erratically within the city limits of Sisseton, nearly causing multiple collisions and fleeing from law enforcement. He was apprehended in a tribal housing unit. Subsequently, the tribal prosecutor charged him in tribal court with driving under the influence (DUI) and resisting arrest, while South Dakota state court charged him with resisting arrest, reckless driving, and assaulting a law enforcement officer. He later pled guilty in state court to assault and was sentenced to two years in prison. The tribal court then dismissed the DUI charge without prejudice.He filed a federal lawsuit in the United States District Court for the District of South Dakota against various tribal officials, alleging that the DUI charge exceeded the tribe’s criminal jurisdiction and violated his rights under the Fourth Amendment and the Indian Civil Rights Act. The District Court dismissed the case for lack of subject matter jurisdiction, holding that the complaint failed to raise a federal question under 28 U.S.C. § 1331.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the dismissal. The court concluded that, even assuming it had jurisdiction to consider the scope of the tribe’s criminal authority, the case had become moot because the tribal DUI charge was dismissed and could not be refiled due to the expiration of the statute of limitations. The court found that neither the voluntary cessation exception nor the “capable of repetition, yet evading review” exception to mootness applied. Accordingly, the Eighth Circuit affirmed the district court’s judgment and vacated its decision, declining to address the underlying questions of tribal jurisdiction, sovereign immunity, or exhaustion of tribal remedies. View "LaBatte v. Gangle" on Justia Law

A police officer in Des Moines, Iowa attempted to stop a vehicle driven by Dylan Pettyjohn for lacking license plates or a temporary registration. Pettyjohn fled, leading the officer on a high-speed chase through a residential area before crashing. He then ran from the vehicle, discarding a loaded revolver and a fanny pack containing 54 fentanyl pills, $389 in small bills, marijuana, and about 85 grams of methamphetamine. A search of his vehicle yielded a digital scale with white residue, more marijuana, and shell casings. Pettyjohn was arrested, and a federal grand jury indicted him on multiple counts related to drug possession with intent to distribute, possession of a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm.The United States District Court for the Southern District of Iowa denied Pettyjohn’s motion to dismiss the felon in possession charge, rejecting his argument that 18 U.S.C. § 922(g)(1) violated the Second Amendment. The court also allowed limited admission of his prior felony convictions for impeachment purposes, after an agreement between Pettyjohn and the government. At trial, Pettyjohn moved for acquittal based on insufficient evidence, but the district court found the evidence sufficient and denied the motions. The jury found Pettyjohn guilty on all counts, and the court sentenced him to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence de novo, affirmed the district court’s evidentiary rulings under Rules 404(b) and 609, and upheld the constitutionality of § 922(g)(1) based on circuit precedent. The Eighth Circuit held that the evidence was sufficient to support the convictions, the district court did not abuse its discretion in admitting prior conviction evidence, and § 922(g)(1) is constitutional. The judgment of the district court was affirmed. View "United States v. Pettyjohn" on Justia Law

A company operating movie theaters in several Midwestern states offered free movie trailers on its website to attract customers. After a website visitor viewed these trailers, she began to receive targeted advertisements on her Facebook page. She alleged that the company had installed a program, Meta Pixel, which tracked her activity and shared her personal information with Meta (Facebook’s parent company). She claimed that the company, as a “video tape service provider,” had a duty under the Video Privacy Protection Act not to disclose her personally identifiable information without consent.The United States District Court for the District of Minnesota dismissed the complaint. The district court found that the company was not a “video tape service provider” as defined by the statute, because it was not engaged in the business of renting, selling, or delivering prerecorded video cassette tapes or similar audio visual materials. As a result, the court concluded that the company had no statutory obligation to withhold the plaintiff’s personal information under the Act.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The appellate court agreed with the district court, holding that movie theaters are not “engaged in the business” of renting, selling, or delivering prerecorded video cassette tapes or similar audio visual materials. The court reasoned that the statutory definition requires a physical medium similar to video cassette tapes, which does not include theatrical screenings or free online trailers. The court further determined that offering trailers online did not constitute a separate business of delivering audio visual materials for livelihood or gain. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "Christopherson v. Cinema Entertainment Corp." on Justia Law

Devon Holt was charged with being a felon in possession of a firearm after investigators obtained a warrant to search his Facebook account and found posts and messages referencing firearms. These included statements suggesting he was carrying a firearm and expressing motives related to self-protection and respect. Holt pleaded not guilty, and his case proceeded to trial. He objected to the admission of this Facebook content, arguing it was prejudicial, but the district court admitted some of the posts for the limited purpose of showing knowledge and motive, instructing the jury accordingly. The jury convicted Holt.The United States District Court for the District of Minnesota sentenced Holt to 42 months’ imprisonment, slightly above the minimum of the guideline range. Holt argued for a lower sentence, citing difficult pretrial detention conditions and uncertainty before sentencing. The district court explained its reasoning in detail, acknowledging both aggravating and mitigating factors, including Holt’s positive use of his time in jail. Holt then appealed, challenging both the admission of the Facebook evidence and the adequacy of the sentencing explanation.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary and sentencing decisions. It held that the Facebook content was properly admitted under Federal Rule of Evidence 404(b) because it was relevant to issues of Holt’s knowledge and motive and was not unfairly prejudicial. The appellate court also found that the district court gave a sufficiently detailed explanation for its sentencing decision, considered the relevant factors, and imposed a substantively reasonable sentence. Consequently, the Eighth Circuit affirmed both the conviction and the sentence. View "United States v. Holt" on Justia Law

Raphael Nunn was convicted of kidnapping, bank fraud, and aggravated identity theft based on three incidents involving separate victims. In the first incident, Nunn robbed C.L. at gunpoint and stole her purse, later using her bank cards for unauthorized purchases. The second incident involved the theft of J.T.’s backpack, which contained her bank cards, subsequently used without her permission. In the third incident, Nunn kidnapped S.E. from a parking garage, forced her to withdraw cash from a bank, and left her at a park. Law enforcement identified Nunn as the perpetrator in all three cases and arrested him.Prior to trial in the United States District Court for the District of Minnesota, Nunn moved to suppress statements made during a custodial interview, arguing he had invoked his right to counsel. The magistrate judge denied the motion, finding the invocation ambiguous, and the district court adopted this ruling. At trial, the government introduced Nunn’s interview statements and allowed C.L. to make a spontaneous in-court identification, to which Nunn did not object. The jury found Nunn guilty on all counts. The Presentence Investigation Report calculated an advisory guidelines range of 168 to 210 months plus a 24-month mandatory minimum. The district court varied upward, citing Nunn’s lengthy criminal history and imposed a total sentence of 288 months.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the conviction and sentence. The court held that the district court did not clearly err in denying the motion to suppress because Nunn’s statement was not an unambiguous invocation of his Miranda rights. The admission of C.L.’s in-court identification did not constitute plain error. Additionally, the district court did not abuse its discretion in imposing an above-guidelines sentence, properly weighing both aggravating and mitigating factors. View "United States v. Nunn" on Justia Law

A detainee at the St. Louis County jail, Jovon Mitchell, developed severe symptoms including vomiting, a severe headache, dizziness, difficulty standing and walking, and slurred speech over the course of December 23–25, 2019. Various jail nurses and staff responded to his complaints with minimal or delayed medical care, despite jail policies requiring prompt attention for such symptoms. Jovon was ultimately found unresponsive and died from a stroke after being transferred to a hospital. His brother, Juan Mitchell, filed suit under 42 U.S.C. § 1983, alleging deliberate indifference to Jovon’s serious medical needs by individual medical staff and correctional officers, as well as failure-to-train and unconstitutional policy claims against supervisory staff and St. Louis County. State law claims were also asserted.The United States District Court for the Eastern District of Missouri granted the defendants' motions to dismiss the federal claims for failure to state a claim and declined to exercise supplemental jurisdiction over the state law claims, thereby dismissing them as well. The district court did not address the issue of qualified immunity. Juan Mitchell appealed the dismissal as to certain defendants.The United States Court of Appeals for the Eighth Circuit held that the complaint plausibly alleged deliberate indifference to Jovon’s serious medical needs by three nurses, but not by the physician assistant or correctional officers involved. The Court also found that the failure-to-train claim against St. Louis County was plausibly stated but concluded that the claims against the individual supervisors did not sufficiently allege notice of a pattern of unconstitutional acts. The Court affirmed the dismissal in part and reversed in part, remanding for further proceedings. The Court instructed the district court to exercise supplemental jurisdiction over the state law claims, given the reinstatement of certain federal claims. View "Mitchell v. Saint Louis County" on Justia Law

An inmate at the McPherson Unit, a maximum-security prison in Arkansas, alleged that from 2010 to 2014, a chaplain at the facility sexually assaulted her weekly in his office. The chaplain, who was permitted by policy to be alone with female inmates, also assaulted at least two other inmates in a similar, regular manner. He resigned in 2014 and later pleaded guilty to third-degree sexual assault. The inmate brought a lawsuit under 42 U.S.C. § 1983 against several prison officials in their individual capacities, claiming they failed to protect her from the assaults and failed to supervise the chaplain adequately.The United States District Court for the Eastern District of Arkansas, Chief Judge Kristine G. Baker presiding, denied in part the defendants’ motions for summary judgment based on qualified immunity. The court found there were genuine issues of material fact regarding whether the defendants—three particular officials—were aware of the chaplain’s conduct and were deliberately indifferent to the risk he posed. The district court also found genuine disputes as to whether two of the officials had sufficient supervisory authority over the chaplain to be liable for failure to supervise and whether they took appropriate remedial action.The United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment on qualified immunity grounds. It held that, construing the facts in the light most favorable to the inmate, a reasonable jury could find the defendants were deliberately indifferent to a substantial risk of serious harm, violating clearly established Eighth Amendment rights. The appellate court also held that there were genuine disputes of material fact regarding the supervisory liability of two officials. Accordingly, the Eighth Circuit affirmed the district court’s denial of summary judgment, allowing the inmate’s claims to proceed to trial. View "Arnett v. Norris" on Justia Law

Two individuals from Colorado, involved in drug trafficking, drew law enforcement attention while driving through South Dakota. After a high-speed chase ended on the Pine Ridge Indian Reservation, their vehicle ran low on gas. When they stopped, an FBI victim specialist, returning from a work assignment in an official vehicle, stopped to offer assistance. The defendants carjacked him at gunpoint, forced him into the backseat, and drove to a gas station. The victim escaped, and the defendants later abandoned the stolen vehicle. Both men were subsequently arrested in Colorado. The government brought multiple charges, including kidnapping a federal officer, carjacking, using a firearm during a crime of violence, and illegal firearm possession.The United States District Court for the District of South Dakota oversaw their joint trial. The court denied Morales’s motions to sever the trials and to obtain the victim’s medical records. It allowed limited portions of a codefendant’s confession and evidence of other drug activity, some as intrinsic and some as extrinsic under Federal Rule of Evidence 404(b). Both defendants were convicted on all counts by a jury and received lengthy sentences. The district court applied enhancements and upward variances based on the facts found at sentencing.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed several trial and sentencing issues. It held that the district court did not abuse its discretion in denying severance or in admitting the challenged evidence. The court found that any error in failing to give a limiting instruction regarding the confession did not affect the outcome. The court concluded the evidence was sufficient to support all convictions, including the statutory elements of kidnapping a federal officer and using a firearm. The Eighth Circuit affirmed the sentences, finding no clear or obvious error with the enhancements or the upward variance. Accordingly, the court affirmed the district court’s judgments. View "United States v. Alvarez-Sorto" on Justia Law