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

A sheriff’s deputy found Robert Wilburn asleep in the driver’s seat of a Chevrolet Camaro that was parked partially off a roadway with its hazard lights flashing. An open beer can was visible in the center cup holder, and the deputy smelled alcohol and marijuana on Wilburn. Upon searching the Camaro, the deputy found a loaded handgun next to the center console, a box of ammunition, and an extra magazine. The vehicle was registered to Samira Swift, who had purchased the firearm eleven days earlier. Wilburn, a twice-convicted felon, was on parole at the time, having been released from home confinement the day before Swift purchased the firearm.Wilburn was indicted for unlawful possession of a firearm and ammunition as a felon. The United States District Court for the Eastern District of Arkansas admitted evidence of Wilburn’s 2021 conviction for the same offense under Federal Rule of Evidence 404(b), as well as evidence that Wilburn had been released on parole shortly before the firearm’s purchase. At trial, the jury found Wilburn guilty, and the court sentenced him to 100 months in prison.On appeal to the United States Court of Appeals for the Eighth Circuit, Wilburn challenged the district court’s evidentiary rulings and argued that the evidence was insufficient to support his conviction. The Eighth Circuit reviewed the evidentiary rulings for abuse of discretion and the sufficiency of the evidence de novo. The court held that admitting Wilburn’s prior conviction and the parole release evidence was not an abuse of discretion, as both were relevant to knowledge and intent, and their probative value was not substantially outweighed by unfair prejudice. The court also concluded that the evidence was sufficient to sustain the conviction. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Wilburn" on Justia Law

After Jet Midwest International Co., Ltd. made a $6.5 million loan to Jet Midwest Group, LLC (JMG) for the purchase of a Boeing 737-700, JMG defaulted on repayment. Jet Midwest sued for breach of contract, and when it could not collect on its judgment due to JMG’s lack of funds, Jet Midwest brought claims under the Missouri Fraudulent Transfer Act against several individuals and entities (the Ohadi/Woolley defendants), alleging the improper transfer of assets to avoid payment. Following a bench trial, Jet Midwest prevailed on its claims, and the district court awarded money damages, interest, and set a schedule for further motions on attorney’s fees and costs.Previously, the United States District Court for the Western District of Missouri awarded Jet Midwest over $6.5 million in attorney’s fees and costs. The United States Court of Appeals for the Eighth Circuit vacated this award, finding the district court had not properly performed a lodestar calculation for attorney’s fees and had not analyzed which costs were recoverable under federal law. On remand, Jet Midwest reduced its fee request but sought a multiplier; the district court ultimately awarded $5.8 million in attorney’s fees, granted prejudgment interest at 14 percent, and included expert witness fees and other litigation costs. Both sides appealed aspects of this award.The United States Court of Appeals for the Eighth Circuit held that the district court properly calculated and awarded $5.8 million in attorney’s fees but erred in awarding expert witness fees as part of attorney’s fees, as Jet Midwest failed to provide sufficient evidence that such fees were recoverable under the relevant standards. The Eighth Circuit also held that the district court erred in applying a 14 percent prejudgment interest rate and ordered that Missouri’s statutory rate of nine percent should apply. Additionally, the court clarified that, after August 6, 2020, the federal postjudgment interest rate under 28 U.S.C. § 1961(a) governs. The case was affirmed in part, reversed in part, and remanded for further proceedings consistent with these rulings. View "Jet Midwest International Co., Ltd v. Ohadi" on Justia Law

A man whose only prior felony conviction had been expunged by a Missouri state court was arrested by a Missouri State Highway Patrol trooper for possessing a firearm as a convicted felon. The trooper had accessed his criminal history report, which still listed the expunged conviction with a notation indicating it was “Closed Pursuant to Chapter 610 RSMo.” However, the Missouri State Highway Patrol did not train officers to understand this notation meant the conviction was expunged and could not serve as a basis for arrest. The man informed the trooper of his expungement at the scene, but she stated she had to rely on the report’s information.Following his arrest, the plaintiff filed suit under 42 U.S.C. § 1983 in Missouri state court, asserting claims for damages and prospective relief against the Highway Patrol’s superintendent and others. The case was removed to the United States District Court for the Western District of Missouri. The superintendent moved to dismiss the official-capacity claim on sovereign immunity grounds and the individual-capacity failure-to-train claim on qualified immunity grounds. The district court denied both motions, prompting the defendants to file an interlocutory appeal.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of immunity de novo. The appellate court held that the current superintendent was a proper Ex parte Young defendant for purposes of prospective relief, as he had sufficient connection to the dissemination practices that risked future constitutional violations. The court also held that the plaintiff had plausibly alleged a Fourth Amendment violation and deliberate indifference by the former superintendent regarding failure to train. Accordingly, the Eighth Circuit affirmed the district court’s denial of sovereign and qualified immunity. View "Cunningham v. Olson" on Justia Law

A mother and her minor daughter, both citizens of El Salvador, entered the United States in 2017 without valid entry documents. The mother applied for asylum, withholding of removal, and protection under the Convention Against Torture, claiming that a criminal gang in El Salvador had repeatedly threatened her family with violence and kidnapping in attempts to extort money. Although her family partially complied with the gang’s demands and was not physically harmed, she asserted that returning to El Salvador would put her and her children at risk, as the gang had widespread influence and the Salvadoran government could not protect them.An immigration judge found the mother's testimony not credible due to inconsistencies and determined that, even if her testimony were credible, the threats did not amount to past persecution, the alleged social groups were not cognizable, and she could relocate within El Salvador. The judge denied all claims for relief. The Board of Immigration Appeals (BIA) affirmed, concluding that she had not established past persecution or a well-founded fear of future persecution. The BIA also determined that her argument that the immigration judge was biased was waived because she raised it only in a conclusory manner and abandoned it in her appellate brief.The United States Court of Appeals for the Eighth Circuit reviewed the BIA’s decision as the final agency action. The court held that the BIA properly applied its waiver rule and did not err in finding the due process claim waived, as the argument was inadequately raised and not meaningfully pursued. The court also concluded it lacked jurisdiction to review the Department of Homeland Security’s exercise of prosecutorial discretion regarding enforcement priorities. The petition for review was denied. View "Quijano-Duran v. Bondi" on Justia Law

The dispute arose from a business venture related to agricultural investments in Brazil. In 2007, an investment firm transferred funds totaling over $800,000 to another company to cover farm-related expenses, allegedly with the understanding that these funds would be repaid once the farm became profitable and prior to any distributions to owners. The parties later executed a written document summarizing their agreement, which stated that the investment firm would recover its funding when a newly formed management company generated fees. Despite the farm ultimately turning a profit years later, the management company never generated fees and the transferred funds were never repaid.The United States District Court for the Southern District of Iowa considered claims for breach of contract, promissory estoppel, and unjust enrichment. The court found that the written contract unambiguously set out the terms of repayment, which were not satisfied because the management company never generated fees. It also concluded that the document was fully integrated, barring admission of extrinsic evidence to vary its terms. The court granted summary judgment to the defendants on all claims, finding no genuine dispute of material fact.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the summary judgment rulings de novo. The appellate court held that the record did not contain sufficient evidence to support the claim that the written agreement was not fully integrated. It also found that the lack of an integration clause and the plaintiff’s testimony did not create a genuine dispute about integration. The court concluded that, because the contract was fully integrated, extrinsic evidence could not be used to alter its terms, and that implied contract and quasi-contract claims were precluded. The Eighth Circuit affirmed the judgment of the district court. View "Galtere, Inc. v. Harvest Capital Asset Mgmt." on Justia Law

Mark Isham and C.K. were in a long-term relationship, living together intermittently. In March 2023, after C.K. stayed with Isham following her release from a treatment center, the two drank alcohol and argued, resulting in Isham physically assaulting C.K. on two separate occasions. Several days after the second assault, C.K., who is an amputee, called 911 and reported being held against her will and physically abused. Police officers responded to Isham’s home, spoke separately to both individuals, and eventually arrested Isham after he admitted to hitting C.K. C.K. was hospitalized and required surgery for a fractured jaw.The United States District Court for the District of Minnesota heard Isham’s pretrial motions. The court denied Isham’s motion to suppress statements he made to officers before being arrested, concluding he was not in custody during the questioning. The court also partially granted a government motion to admit evidence of Isham’s prior assaults against C.K., allowing testimony about more recent incidents but excluding older ones. At trial, the jury acquitted Isham of assault with a dangerous weapon but convicted him of assault resulting in serious bodily injury and assault resulting in substantial bodily injury to an intimate partner.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the suppression motion de novo and found that Isham was not subjected to custodial interrogation before his arrest, as the questioning was brief, non-coercive, and Isham voluntarily participated. The appellate court also held that the district court did not abuse its discretion in admitting evidence of prior assaults, finding it relevant to issues raised at trial and adequately limited by jury instructions. The judgment of the district court was affirmed. View "United States v. Isham" on Justia Law

A member of the Lower Brule Sioux Tribe, the defendant moved onto the Swallow Ranch, located in the Cuny Table area of the Pine Ridge Indian Reservation, in 2022. He lived in a camper and worked as a ranch hand. During his time there, he developed a relationship with a 15-year-old girl, A.S., whom he taught to train horses and later groomed and sexually abused. The abuse occurred at various locations on and near the ranch, including a campground, a rock formation, and his camper. On one occasion, he also abused A.S.’s 12-year-old sister, N.S. The defendant further solicited nude photos from A.S. and from another minor, C.J.E., through Snapchat. When confronted by family members about the abuse, he denied the allegations and messaged N.S., urging her to claim A.S. was lying to protect himself from potential jail time. An FBI agent later investigated, uncovering evidence of the defendant’s communications and the sexual abuse.The United States District Court for the District of South Dakota tried the case. A jury convicted the defendant on multiple counts, including sexual abuse of a minor, abusive sexual contact, attempted sexual exploitation of a minor, attempted receipt of child pornography, and witness tampering. The district court denied the defendant’s motion for judgment of acquittal and sentenced him to 480 months in prison.Reviewing the appeal, the United States Court of Appeals for the Eighth Circuit affirmed the convictions for sexual abuse, abusive sexual contact, attempted sexual exploitation, and attempted receipt of child pornography, holding that sufficient evidence supported the jury’s findings. However, the court vacated the witness tampering conviction, finding insufficient evidence that the defendant contemplated a particular, foreseeable proceeding as required by law. The Eighth Circuit also vacated the entire sentence and remanded for resentencing in light of the vacated conviction. View "United States v. Goodlow" on Justia Law

A man experiencing a severe mental health crisis was shot and killed by a law enforcement officer after a prolonged standoff at his family’s ranch. Family members had contacted emergency services, reporting his deteriorating condition, threats of suicide, and the presence of firearms. Multiple law enforcement agencies responded, including the Custer County Sheriff’s Office and the Nebraska State Patrol (NSP). After failed negotiation attempts, the NSP disabled the man’s vehicle, and as he exited and approached officers unarmed, he was fatally shot by an NSP officer.The personal representative of the decedent’s estate filed a lawsuit in the United States District Court for the District of Nebraska, bringing claims under 42 U.S.C. § 1983 against various officers, the Sheriff’s Office, and the NSP training supervisor. Claims against the NSP officers in their official capacities were dismissed due to Eleventh Amendment immunity, as were claims against most officers in their individual capacities except for the officer who fired the shots. During discovery, the plaintiff served a Rule 30(b)(6) deposition subpoena on the non-party Nebraska State Patrol regarding officer training. The NSP moved to quash, citing state sovereign immunity. Both the magistrate judge and the district court denied the motion, relying on earlier circuit precedent that government entities are subject to federal discovery rules.Upon interlocutory appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of NSP’s motion to quash. The appellate court held that state sovereign immunity does, in this instance, bar enforcement of the deposition subpoena because the requested discovery was disruptive and infringed on the state’s autonomy and resources. The court clarified that prior circuit statements to the contrary were non-binding dicta and not controlling. The Eighth Circuit reversed the district court’s order. View "Mick v. Gibbons" on Justia Law

The case involves a defendant who, along with others, participated in two separate home invasion robberies targeting the residence of Michael Robertson. Surveillance footage captured Williams and others attempting to break in one night, and returning the following night to forcibly enter, simulating a police raid. During the second invasion, gunshots were fired by others, resulting in the death of Jessica Brandon, though Williams was not armed at that time. Substantial quantities of drugs and cash were found in the home, suggesting the motive was robbery of a drug dealer.Williams was indicted in the United States District Court for the District of Nebraska on charges including murder with a firearm during a crime of violence and two counts of interference with commerce by robbery. He pleaded guilty and was initially sentenced to a total of 660 months’ imprisonment. After the Supreme Court decided in United States v. Taylor that Hobbs Act robbery does not qualify as a crime of violence under 18 U.S.C. § 924, Williams’s conviction for murder with a firearm was vacated by the United States Court of Appeals for the Eighth Circuit, which remanded the case for resentencing on the two remaining robbery counts.Upon resentencing, the district court imposed consecutive sentences of 222 months for each count, resulting in a total of 444 months. Williams appealed, arguing the district court erred in applying the sentencing package doctrine, failed to adequately explain the equal sentences for each count, and imposed an unreasonable sentence. The United States Court of Appeals for the Eighth Circuit held that application of the sentencing package doctrine was proper, the district court’s explanation was sufficient, and the sentence was not substantively unreasonable. The court affirmed the amended judgment. View "United States v. Williams" on Justia Law

A group of parolees who had been detained challenged the procedures used by the Missouri Department of Corrections for revoking parole, arguing that these procedures violated their due process rights. The plaintiffs brought a class action suit under 42 U.S.C. § 1983 on behalf of all adult parolees in Missouri who currently face or will face parole revocation proceedings. The district court issued an order in 2020 requiring the Department to implement certain changes. After further proceedings, the plaintiffs sought and were awarded attorneys’ fees for their partial success and for monitoring the Department’s compliance.The Missouri Department of Corrections appealed the district court’s fee awards, arguing that the Prison Litigation Reform Act (PLRA) limited the attorneys’ fees that could be awarded. The district court had repeatedly rejected the Department’s argument, finding that the PLRA’s fee cap did not apply because the certified class included parolees who were not detained and because some of the relief benefited non-detained parolees. The district court issued its final judgment in January 2025 and permanently enjoined the Department while awarding additional attorneys’ fees.The United States Court of Appeals for the Eighth Circuit considered whether the PLRA’s attorneys’ fee cap under 42 U.S.C. § 1997e(d) applied to the class action. The Eighth Circuit held that the fee cap does apply because the certified class consisted of individuals who are, or will be, detained during parole revocation proceedings and thus fall under the statutory definition of “prisoner.” The court also found that the PLRA’s fee cap section is not limited to actions challenging prison conditions. The Eighth Circuit vacated the fee awards and remanded the case for the district court to recalculate the fee awards in accordance with the PLRA’s limitations. View "Gasca v. Precythe" on Justia Law