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

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

In early 2023, law enforcement in Sioux City, Iowa, used a confidential informant, MS, to investigate methamphetamine distribution. MS identified AP as a supplier, who, in turn, sourced methamphetamine from a man known as “Arkansas,” believed to be Johnnie A. Cannon. Through three controlled buys, investigators observed Cannon’s involvement: he was seen at AP’s residence during each transaction, and physical evidence—including serialized cash from a controlled buy—was seized from him. During a post-arrest interview, Cannon admitted to distributing methamphetamine, including to AP.The United States District Court for the Northern District of Iowa presided over Cannon’s trial. Cannon’s counsel made several motions and challenges at trial, including a Batson challenge regarding jury composition, a motion for judgment of acquittal, and motions for a new trial and arrest of judgment. The district court denied these motions. A jury found Cannon guilty of conspiracy to distribute methamphetamine and three counts of distribution and aiding and abetting distribution. The court sentenced him to 262 months’ imprisonment for these convictions and revoked his supervised release from a prior conviction, imposing an additional 37 months.On appeal, Cannon argued before the United States Court of Appeals for the Eighth Circuit that his Sixth Amendment right to a jury drawn from a fair cross-section was violated, that the admission of his prior conviction was improper under Rule 404(b), that there was insufficient evidence to support his convictions, and that he received ineffective assistance of counsel. The Eighth Circuit held that Cannon’s cross-section jury claim lacked evidence of systematic exclusion, affirmed the admission of his prior conviction as relevant under established precedent, found the trial evidence sufficient to sustain the convictions, and declined to consider the ineffective assistance claim on direct appeal. The court affirmed both the convictions and the revocation of supervised release. View "United States v. Cannon" on Justia Law

Late on January 10, 2022, Kansas City police officers stopped a pickup truck with a broken headlight and expired license plate. The driver, Alonzo Miller, was not the vehicle’s owner and could not provide proof of insurance. The officers recognized the area Miller had driven from as one known for criminal activity. During the stop, Miller exhibited nervous behavior. A computer check revealed Miller was on probation and parole for a violent felony involving a firearm. The officers, noting a significant age difference between Miller and his passenger and the late hour, suspected possible illicit activity. After Miller mentioned “something under there” when asked about illegal items and consented to a vehicle search, the officers asked him to step out. Miller behaved unusually, triggering further suspicion. As an officer attempted a frisk, Miller resisted, and a firearm discharged from his coat pocket. Miller was arrested and later indicted for being a felon in possession of a firearm.The United States District Court for the Western District of Missouri denied Miller’s motion to suppress evidence from the stop and search. The magistrate judge found the stop lawful, that Miller’s consent to search was voluntary, and that the officers had reasonable suspicion to extend the stop and frisk Miller based on the totality of the circumstances—including Miller’s criminal history, behavior, and responses during the encounter. The district court adopted these findings. Miller then entered a conditional guilty plea, preserving his right to appeal the suppression ruling.The United States Court of Appeals for the Eighth Circuit reviewed the denial of Miller’s suppression motion, applying de novo review to legal conclusions and clear error review to factual findings. The court held that, under the totality of the circumstances, the officers had reasonable suspicion to extend the stop, request consent to search the vehicle, and frisk Miller. The judgment of the district court was affirmed. View "United States v. Miller" on Justia Law

In this case, Roland Pour Sr. purchased and insured a home in Minnesota, where his children Kmontee and Roland Jr. lived. Pour Sr. moved to Georgia in 2019, updating all personal records to reflect his new residence but did not sell the Minnesota home or notify the insurer of his change in residence. He maintained some belongings in the Minnesota home and visited occasionally, while his children continued to live there and paid for utilities. In September 2021, a fire damaged the home and personal property. Pour Sr., living in Georgia at the time, filed a claim under the homeowners insurance policy for damages to the house, his own property stored there, and his children’s property and living expenses.The United States District Court for the District of Minnesota reviewed cross motions for summary judgment. Applying Minnesota law, the court granted summary judgment to Liberty Mutual, holding that the policy did not cover the home or attached structures because Pour Sr. did not “reside” at the house at the time of the fire. The court also held that Kmontee and Roland’s property was not covered because, although they lived in the home, they were not “residents of Pour Sr.’s household” as defined by the policy and Minnesota law. Pour Sr.’s claim for his own property was settled and not at issue.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s ruling de novo. The appellate court affirmed the district court’s judgment, holding that, under the unambiguous terms of the policy and Minnesota law, Pour Sr. did not reside at the Minnesota home during the relevant period, and his children were not insureds under the policy because they did not reside in his household. The court found no conflict with Minnesota’s Standard Fire Insurance Policy and rejected arguments regarding ambiguity or illusory coverage. View "Pour v. Liberty Mutual Pers. Ins. Co." on Justia Law

A Missouri consumer purchased several containers of coffee that prominently displayed the number of servings each container could make. He claimed these representations were misleading, arguing that following the recommended single-serving brewing method would not produce as many servings as advertised. He filed a lawsuit against the coffee manufacturer and its parent company, alleging violations of the Missouri Merchandising Practices Act (MMPA) and unjust enrichment. The plaintiff sought to represent a class of Missouri consumers who purchased the same products.Multiple similar lawsuits from around the country were consolidated in the United States District Court for the Western District of Missouri. The district court appointed interim class counsel and, at the parties’ suggestion, considered whether to certify a Missouri class before addressing other states. The district court ultimately certified the Missouri class, finding that the plaintiff’s claims were suitable for class treatment under Federal Rule of Civil Procedure 23(b)(3), which requires that common questions predominate over individual ones.On appeal, the United States Court of Appeals for the Eighth Circuit held that the district court erred in certifying the class. The appellate court determined that individual questions about whether consumers saw, interpreted, or relied upon the product representations would predominate over common questions. The court rejected the plaintiff’s argument that all class members suffered harm due to alleged price inflation, reasoning that only those who were actually misled or cared about the representations could have incurred an ascertainable loss under the MMPA. The court also found the unjust enrichment claim similarly unsuited to class treatment because it would require individualized inquiries into whether each transaction was unjust. The Eighth Circuit reversed the class certification order and remanded the case for further proceedings. View "Sorin v. The Folger Coffee Company" on Justia Law

During a protest in Omaha, Nebraska, following the death of George Floyd, law enforcement declared the gathering an unlawful assembly and ordered the crowd to disperse. Adam Keup, who was present with his partner and friends to document the protest, was standing on a sidewalk near a Walgreens with a backpack containing camera equipment. Unaware of the dispersal order, Keup was shot in the eye with a pepper ball by Deputy Nicholas Palmer, resulting in permanent vision loss. After being shot, Keup was taken behind police lines for medical attention but was not arrested.The United States District Court for the District of Nebraska granted summary judgment in favor of Deputy Palmer, finding that he was entitled to qualified immunity on both the First and Fourth Amendment claims. The district court determined that Keup had not shown he was engaged in protected First Amendment activity that was the but-for cause of the force used against him, and that the use of the pepper ball and subsequent actions did not constitute a clearly established Fourth Amendment seizure.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eighth Circuit held that Keup failed to establish a causal connection between any protected First Amendment activity and Deputy Palmer’s actions, as there was no evidence Keup was singled out for his expression. Regarding the Fourth Amendment claim, the court concluded that the use of the pepper ball was intended to disperse, not to apprehend, and that taking Keup for medical care did not amount to an unreasonable seizure. Therefore, Deputy Palmer was entitled to qualified immunity, and the district court’s decision was affirmed. View "Keup v. Palmer" on Justia Law

Drexel Starks was arrested for possession of a controlled substance and taken to the St. Louis County Justice Center, where he reported heroin withdrawal symptoms. Jail medical staff placed him on a withdrawal protocol, which included comfort medication and regular nurse assessments. Over the next day, nurses noted some improvement in his symptoms. However, there is no evidence of further assessments as required by protocol. On August 6, a correctional officer found Drexel on the floor with withdrawal symptoms; he was transferred to the infirmary and then to a hospital, where he died. The medical examiner attributed his death to withdrawal from heroin and cocaine, dehydration, and cardiac dysrhythmia.Margaret Starks, Drexel’s mother, filed suit in the United States District Court for the Eastern District of Missouri under 42 U.S.C. § 1983, alleging that jail nurses and a correctional officer were deliberately indifferent to Drexel’s serious medical needs, and that nurse supervisors and St. Louis County failed to train or supervise staff and maintained an unlawful policy of denying medical care. The district court granted summary judgment for the defendants, finding that Margaret failed to establish a violation of Drexel’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that no reasonable jury could find Drexel had an objectively serious medical need that was obvious to a layperson or supported by medical evidence, nor that the defendants acted with deliberate indifference akin to criminal recklessness. The court also held that, absent an underlying constitutional violation, claims against the nurse supervisors and the County for failure to train or supervise, or for unlawful policy, could not succeed. The judgment of the district court was affirmed. View "Starks v. St. Louis County" on Justia Law

A woman who immigrated from Vietnam to the United States and became active in the Vietnamese community in Sioux City, Iowa, organized a campaign in 2020 to assist Vietnamese Americans—many of whom had limited English proficiency and were unfamiliar with the U.S. election system—in registering to vote and casting absentee ballots. Her efforts were not solely for civic engagement; she hoped these voters would support her husband, who was a candidate in the election. She facilitated the process by providing forms, translating, and returning completed documents to the county auditor. However, she also engaged in fraudulent conduct by instructing family members to complete and submit voting documents for absent adult children, and in some cases, she filled out and signed the forms herself. In total, she submitted 26 documents with forged signatures. The county auditor became suspicious and contacted the FBI, leading to her arrest and indictment on 52 counts of voter fraud under two federal statutes.The United States District Court for the Northern District of Iowa presided over her trial. The court used model jury instructions that did not require the jury to find that she knew her conduct was illegal or that the children did not consent to her actions, despite her request for such an instruction. The jury found her guilty on all counts, and her motion for judgment of acquittal was denied.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the jury instructions accurately reflected the law and whether the evidence was sufficient to support the convictions. The court held that the instructions properly conveyed the required mental states—knowledge and willfulness—and did not need to require knowledge of the specific law violated. The court also found the evidence sufficient for conviction, including for counts involving equivocal testimony, based on the defendant’s pattern of conduct. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Taylor" on Justia Law

Bliv, Inc. owned a commercial building insured by Charter Oak Fire Insurance Company against hail damage, but not against damage caused by wear and tear. After a storm on July 9, 2021, Bliv claimed that water intrusion had damaged both the exterior and interior of the building, asserting that hail was the cause. Charter Oak’s expert, Isaac Gaetz, inspected the property and found hail damage to vents and air conditioner fins, but no damage to the roof’s membrane. Gaetz concluded that the water intrusion was due to long-term wear and tear, not hail. Bliv disputed this and retained its own expert, Brian Johnson, who opined that hail caused the loss, relying on reports and satellite images rather than direct testing or inspection of the interior.The United States District Court for the Eastern District of Missouri reviewed the case. Charter Oak moved to exclude Johnson’s expert opinion, arguing it lacked sufficient factual support and was not based on reliable methods. The district court found Johnson qualified but excluded his opinion due to deficiencies in his investigation, such as failing to review key reports, not inspecting the interior, and not conducting independent testing. Without Johnson’s opinion, Bliv could not rebut Charter Oak’s causation evidence, and the district court granted summary judgment in favor of Charter Oak.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s exclusion of Johnson’s opinion under the abuse of discretion standard. The appellate court found that, despite some inconsistencies in the district court’s reasoning, there was a sufficient basis for exclusion because Johnson’s opinion relied on incomplete information and failed to address critical evidence. The Eighth Circuit held that the district court did not abuse its discretion and affirmed the summary judgment in favor of Charter Oak. View "Bliv, Inc. v. The Charter Oak Fire Insurance Company" on Justia Law