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

A group of individuals with beneficial interests in Indian trust lands on the Fort Berthold Reservation in North Dakota challenged the continued operation of an oil pipeline by Andeavor Logistics and related entities after the expiration of a federally granted right-of-way in 2013. Despite the expiration, Andeavor continued to operate the pipeline while negotiating for renewals with both the tribal government and individual landowners, but was unable to secure agreements with all landowners. The plaintiffs, known as the Allottees, alleged ongoing trespass, breach of the expired easement agreement, and unjust enrichment, seeking monetary damages, injunctive relief, and removal of the pipeline.The United States District Court for the District of North Dakota twice dismissed the Allottees’ case, first for failure to exhaust administrative remedies, a decision reversed by the United States Court of Appeals for the Eighth Circuit in a prior appeal (Chase I), which instructed a stay for further agency action. After further BIA proceedings and related litigation (including the Tesoro case), the district court again dismissed all of the Allottees’ claims with prejudice, finding no individual federal common law cause of action for trespass, breach of contract, or unjust enrichment, and denied their motion to intervene in the Tesoro case, concluding the United States adequately represented their interests.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s dismissal of the Allottees’ claims for trespass, breach of contract, and unjust enrichment, holding that individual Indian allottees with only equitable interests in land held in trust by the United States lack standing to bring these claims under federal common law. The court also affirmed denial of intervention in the Tesoro litigation. However, the Eighth Circuit remanded for further consideration of whether consolidation of the two related cases is appropriate under Rule 42(a) of the Federal Rules of Civil Procedure. View "Chase v. Andeavor Logistics, L.P." on Justia Law

Reinhardt Enterprises, LLC entered into a contract with BNG Holdings, Inc. to market BNG's services, with the contract set to automatically renew each year unless either party provided notice of non-renewal. After several years of automatic renewal, and shortly before BNG’s sale to Kaseya U.S., LLC, the parties amended the contract to include a provision entitling Reinhardt to a buyout fee if the agreement was "terminated" by BNG under certain circumstances. After acquiring BNG, Kaseya continued the contractual relationship for over two years before sending Reinhardt a letter of non-renewal, invoking the contract’s renewal clause, and explicitly refusing to pay the termination buyout fee.The case began after Reinhardt sued Kaseya in state court for breach of contract, alleging entitlement to the buyout fee. Kaseya removed the case to the United States District Court for the District of North Dakota, where it moved to dismiss under Rule 12(b)(6). The district court granted the motion and dismissed the case with prejudice, holding that the non-renewal of the contract did not constitute a "termination" as contemplated by the contract, and thus Reinhardt was not entitled to the buyout fee.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s contract interpretation de novo. The appellate court found the term "termination" to be ambiguous in the context of the contract, as it could reasonably refer both to ending the agreement midterm or simply to the end of the contractual relationship, including non-renewal. Because of this ambiguity, the Eighth Circuit held that the parties’ intent regarding the buyout fee must be resolved as a question of fact, reversed the district court’s dismissal, and remanded the case for further proceedings. View "Reinhardt Enterprises, LLC v. Kaseya U.S., LLC" on Justia Law

A citizen of the Ivory Coast immigrated to the United States as a child refugee and later became a lawful permanent resident. As an adult, he was convicted in North Dakota of robbery, a Class B felony, for brandishing a gun and menacing others during a theft. The Department of Homeland Security initiated removal proceedings, charging him with removability based on two convictions for crimes involving moral turpitude and for the robbery conviction, which it classified as an aggravated felony for attempted theft.The Immigration Judge initially found the individual removable for the moral-turpitude convictions but determined he was eligible for cancellation of removal, concluding that the North Dakota robbery statute was overbroad compared to the federal definition of theft. The Department appealed, and the Board of Immigration Appeals (BIA) disagreed, finding the statute not facially overbroad and instructing the Immigration Judge to apply the “realistic probability” test to determine if the statute was applied to conduct beyond the generic federal definition. On remand, the Immigration Judge found the petitioner failed to show a realistic probability that the statute covered nongeneric conduct and ordered removal. The BIA dismissed the appeal, upholding the order.The United States Court of Appeals for the Eighth Circuit reviewed only the legal and constitutional claims, as required by statute. It held that North Dakota’s robbery statute is not unambiguously broader than the federal generic definition of attempted theft and that the petitioner had not demonstrated North Dakota actually prosecutes robbery based on conduct beyond that definition. Thus, the court found the robbery conviction to be an aggravated felony, rendering the petitioner ineligible for cancellation of removal, and denied the petition for review. View "Banyee v. Bondi" on Justia Law

A seven-year-old child, J.F., died from malnutrition and an infection caused by untreated head lice while living in a house on the Red Lake Indian Reservation in Minnesota. The home was shared by Sharon Rosebear, her husband, their son Derrick’s five children, and, starting in 2021, her son Julius and his five children, including J.F. The house lacked running water, but free showers and medical care were available nearby. Rosebear regularly provided food for Derrick’s children but not for Julius’s, including J.F., who was often kept home from school due to chronic head lice. In the days before J.F.’s death, Julius left his children in Rosebear’s care, and she acknowledged being responsible for them during that time. J.F. ultimately died on December 25, 2022. The autopsy revealed severe malnutrition and a prolonged lice infestation.The United States District Court for the District of Minnesota presided over Rosebear’s trial. The jury found her guilty of felony child neglect under the Major Crimes Act, which incorporates applicable Minnesota law. The district court denied Rosebear’s motion for acquittal or a new trial and sentenced her to 15 months in prison and two years of supervised release. Rosebear argued both that the evidence was insufficient to prove she was J.F.’s caretaker and that her sentence exceeded the state’s mandatory maximum under Minnesota’s sentencing guidelines, in violation of the Major Crimes Act and Supreme Court precedents.The United States Court of Appeals for the Eighth Circuit affirmed the conviction and sentence. The court held that sufficient evidence supported the jury’s finding that Rosebear was J.F.’s caretaker and had willfully deprived her of food and medical care. The court also held that the Major Crimes Act requires sentencing within the statutory minimum and maximum penalties set by state law, but not adherence to state sentencing guidelines; instead, the federal sentencing guidelines apply, as long as the sentence does not exceed the state statute’s maximum. View "United States v. Rosebear" on Justia Law

Law enforcement uncovered a large-scale fentanyl distribution conspiracy involving multiple individuals transporting fentanyl pills from Phoenix, Arizona, to the Twin Cities. The conspirators concealed pills inside stuffed animals and shipped them as birthday gifts, taking measures to evade detection. Da’Shawn Domena participated by coordinating, receiving, and delivering packages he knew contained fentanyl. Police intercepted some packages, but others were shipped undetected. A search of Domena’s apartment revealed fentanyl pills and other evidence linking him to the conspiracy. Domena admitted his involvement, specifically acknowledging the receipt and distribution of multiple packages containing fentanyl.The United States District Court for the District of Minnesota accepted Domena’s guilty plea to conspiracy to distribute 400 grams or more of fentanyl, an offense carrying a statutory minimum sentence of 120 months under 21 U.S.C. §§ 841(b)(1)(A), 846. Despite being eligible for safety-valve relief under 18 U.S.C. § 3553(f), which could have avoided the mandatory minimum, Domena chose not to cooperate with the government. The Presentence Investigation Report found him responsible for 30.8 kilograms of fentanyl and calculated a lower guidelines range, but the statutory minimum controlled. At sentencing, Domena argued that the mandatory minimum violated the Eighth Amendment’s prohibition on cruel and unusual punishment, citing his minor role, lack of criminal history, absence of violence, and personal struggles. The district court rejected this argument, referencing existing Eighth Circuit precedent.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Domena’s Eighth Amendment challenge de novo. The court held that the mandatory minimum sentence was not grossly disproportionate to the crime and did not violate the Eighth Amendment. The court emphasized that circuit precedent consistently upholds mandatory minimum sentences for drug offenses and found Domena’s arguments unpersuasive. The Eighth Circuit affirmed the sentence imposed by the district court. View "United States v. Domena" on Justia Law

A nonprofit organization, which hosts an annual art auction, held its 2022 event virtually. To facilitate the livestreamed auction and online bidding, it contracted with two vendors: one to provide the video feed and another to supply bidding software. The video vendor created a YouTube link for attendees to view the auction, and the bidding software synced with this feed, enabling participants to watch and bid on a single screen. Minutes before the event, the video vendor lost its internet connection, causing the YouTube link to break and severing the connection between the video feed and the bidding platform. As a result, auction attendees could neither view the auction nor place bids through the intended system. The auction was hurriedly redirected to a different platform, which resulted in a less effective, asynchronous experience and significantly lower fundraising.The nonprofit threatened legal action against the video vendor for breach of contract and negligence. The vendor, unable to pay, assigned its insurance claim to the nonprofit. The vendor’s insurer, Auto-Owners Insurance Company, had issued a general liability policy that covered certain types of property damage but contained a specific exclusion for damages arising out of the loss or inability to access electronic data. Auto-Owners filed for a declaratory judgment in the United States District Court for the Western District of Missouri, seeking a ruling that its policy did not provide coverage. The district court granted summary judgment to Auto-Owners, holding that the policy’s electronic-data exclusion barred recovery.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s interpretation of Missouri law de novo. The appellate court held that the policy’s electronic-data exclusion clearly and unambiguously applied to the circumstances, barring coverage for the losses. Therefore, the Eighth Circuit affirmed the district court’s grant of summary judgment in favor of Auto-Owners Insurance Company. View "Auto-Owners Insurance Company v. Halo Foundation: Helping Art Liberate Orphans" on Justia Law

Lucas Alzu and Amy Nichole Huff met in Colombia in 2018 and began a romantic relationship that led to Huff becoming pregnant. Both led highly nomadic lives, moving frequently and attending international gatherings. In July 2019, due to expiring Colombian visas, they decided to relocate to Argentina, where Alzu’s family lived, for the birth of their child. Huff moved to Argentina when six months pregnant, but soon left Alzu’s family home because of physical assault and lived independently before Alzu joined her again. Their child was born in March 2020, and the COVID-19 pandemic shortly thereafter restricted travel. Following a breakdown in their relationship in 2021, Huff was granted an order of protection and, after travel restrictions were lifted, obtained permission from an Argentinian court to travel with the child. Instead of returning, Huff remained in the United States and began working full-time.The United States District Court for the Western District of Missouri bifurcated proceedings to first determine the child’s habitual residence under the Hague Convention and International Child Abduction Remedies Act. After a two-day evidentiary hearing, the district court found that Alzu had not established Argentina as the child’s habitual residence and dismissed his petition for return of the child.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s determination for clear error, applying the totality-of-the-circumstances standard as required by Supreme Court precedent. The appellate court found that the district court properly weighed factors such as parental intentions, immigration status, the child’s age, residency, family relationships, and pandemic-related restrictions. The Eighth Circuit held that Alzu had not met his burden to show Argentina was the child’s habitual residence and affirmed the district court’s judgment. View "Alzu v. Huff" on Justia Law

A man engaged in sexually explicit exchanges with a 13-to-14-year-old girl, during which he solicited and received images and videos depicting the minor’s genitalia and acts of self-penetration with a sex toy. His communications included explicit language suggesting rough and anal sex and requesting increasingly graphic content. After he received sexually explicit media from the minor, he was arrested and charged with several offenses, including sexual exploitation of a minor, receipt and possession of child pornography, and transfer of obscene material to a minor. He ultimately pled guilty to the receipt of child pornography.The United States District Court for the Southern District of Iowa applied a four-level sentence enhancement under U.S.S.G. § 2G2.1(b)(4)(A), reasoning that the material he received depicted sadistic or masochistic conduct or other depictions of violence, specifically the minor’s self-penetration with a foreign object. The court sentenced him to 240 months in prison. The defendant appealed, contending that the enhancement did not apply because the victim was not prepubescent, used a sex toy rather than another object, and appeared to experience sexual pleasure rather than pain.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and its application of the Sentencing Guidelines de novo. The appellate court held that, under its precedent including United States v. Starr, acts of self-penetration by a minor with a foreign object constitute "violence" under the guideline, regardless of the minor’s age, the type of object, or whether the minor experienced pain. The appellate court affirmed the district court’s judgment, upholding the four-level enhancement. View "United States v. Vannausdle" on Justia Law

After the death of his father, Richard, the plaintiff, Rich, brought suit against his stepbrother, Tim, and his stepmother, Patti, regarding the management of Richard’s IRA funds. Richard had named Rich and Patti as the primary beneficiaries of his IRA, with 75% and 25% interests, respectively. When Richard’s health declined due to dementia, Tim obtained a power of attorney and was later appointed conservator by an Iowa state court, but Rich was not notified of these proceedings. Tim subsequently withdrew funds from Richard’s IRA, transferred assets between brokerage accounts, and, after Richard’s death, facilitated distributions to Patti. Rich alleged he was not informed about these transfers and was unable to access his inherited share for several months, during which time the funds lost value.Following a three-day trial in the United States District Court for the Northern District of Iowa, a jury found in favor of Rich on claims of fraud and conversion against Tim and unjust enrichment against both Tim and Patti, but found no liability on certain other claims. The jury awarded compensatory and punitive damages. Both parties filed post-trial motions. The district court declined to give a jury instruction on undue influence, reasoning that the evidence did not support such a claim, and amended the judgment to prevent duplicative recovery by making Tim and Patti jointly liable for part of the award.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. It held that the refusal to instruct the jury on undue influence was not an abuse of discretion, given the record and Iowa law. The appellate court also upheld the district court’s decision to amend the judgment to avoid double recovery. Furthermore, it rejected Tim’s argument that there was insufficient evidence to support the fraud verdict, concluding that the jury’s findings of justifiable reliance and damages were supported by the trial record. View "Jeffery v. Townsend" on Justia Law

Patrick J. Newcomer was serving supervised release for two separate federal convictions related to burglary of a Post Office and possession of a firearm by a felon. After completing his prison terms and beginning supervised release, he was again convicted in state court of two counts of burglary and possession of a firearm by a prohibited person. These new convictions constituted violations of his federal supervised release conditions.Following Newcomer’s state convictions, the United States District Court for the District of Nebraska revoked his supervised release for both federal cases. The court imposed 24 months’ imprisonment for each federal conviction, to run concurrently, and ordered these terms to be served after his state sentences. Additionally, the district court imposed two terms of supervised release—12 months each—set to run consecutively upon his release from imprisonment. Newcomer appealed, arguing that under 18 U.S.C. § 3624(e), the new terms of supervised release should run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the legality of the district court’s revocation sentence de novo. It held that 18 U.S.C. § 3624(e) governs only the commencement of original supervised release terms and does not apply to supervised release imposed following revocation. Instead, 18 U.S.C. § 3583 provides the relevant authority, permitting a district court to impose additional supervised release upon revocation, and does not require such terms to run concurrently. The Eighth Circuit found that the district court acted within its discretion in imposing consecutive supervised release terms and affirmed the judgment. View "United States v. Newcomer" on Justia Law