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

An egg farm owned by Rembrandt Enterprises, Inc. experienced a collapse of its poultry cage system in 2020, resulting in significant damage and the death of a farm worker. Rembrandt had contracted with Tecno Poultry Equipment, SpA in 2006 to design and manufacture the cage system, which included a provision for Tecno to supervise its installation. The installation was completed in 2007. Rembrandt sued Tecno in 2021, alleging strict products liability, breach of implied warranties, and negligence. The district court allowed the negligence claim to proceed to trial, where a jury found that Tecno did not breach its duty to supervise the installation.The United States District Court for the Northern District of Iowa granted summary judgment for Tecno on the strict products liability and breach of implied warranties claims. At trial, the jury heard conflicting expert testimony regarding the cause of the collapse. Rembrandt's expert attributed the collapse to missing screws and misplaced bolts, while Tecno's experts blamed improper manure disposal by Rembrandt. The jury ultimately sided with Tecno, and the district court entered judgment in favor of Tecno.The United States Court of Appeals for the Eighth Circuit reviewed the case. Rembrandt argued that the district court erred in denying its motions for judgment as a matter of law and in excluding a screenshot of Tecno's website. The appellate court held that Rembrandt failed to preserve its challenge to the sufficiency of the evidence by not renewing its motion under Rule 50(b) after the jury verdict. The court also found that the district court did not abuse its discretion in excluding the website screenshot, as it was not relevant to the 2006 contract. The Eighth Circuit affirmed the district court's judgment. View "Rembrandt Enterprises, Inc. v. Tecno Poultry Equipment, SpA" on Justia Law

Anthony Charles Deberry was convicted by a jury of being a felon in possession of a firearm and sentenced to 108 months in prison. The incident occurred outside Born’s Bar in St. Paul, Minnesota, where Deberry had an altercation with a man named Turtle. Surveillance footage showed Deberry returning to the bar later that evening, and witnesses testified that he had a gun. A shootout ensued, and Deberry was seen on video with a gun, which he later hid under a parked car. Deberry claimed he was acting in self-defense, stating he wrestled the gun away from another man who shot him.The United States District Court for the District of Minnesota instructed the jury that Deberry had to prove his justification defense by a preponderance of the evidence. The jury convicted Deberry, and he appealed, arguing that the burden of proof for his justification defense was misplaced and that his sentence enhancements for possessing a firearm in connection with another felony offense and for obstructing justice were erroneous.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Deberry’s justification defense did not negate his knowing possession of the firearm. The court affirmed the district court’s instruction that Deberry had the burden to prove his justification defense. Regarding the sentence enhancements, the court found no clear error in the district court’s application of enhancements for reckless discharge of a firearm and second-degree assault, as well as for obstructing justice. The court concluded that the district court’s findings were supported by the record and affirmed Deberry’s conviction and sentence. View "United States v. Deberry" on Justia Law

Walter Dushun Holmes, Jr. was indicted for conspiracy to distribute controlled substances. His father, Walter Holmes, Sr., and Monetessa Packineau, among others, were also indicted. While Holmes Sr. and Packineau entered plea agreements, Holmes Jr. went to trial. During the trial, Holmes Jr. requested a sequestration order for witnesses, which was granted. The Government presented multiple witnesses, including Packineau and A.P., who testified about their drug transactions with Holmes Jr. Holmes Jr. attempted to call his father as a witness, but the court excluded Holmes Sr. due to a violation of the sequestration order, based on recorded jail phone calls. Holmes Jr. moved for a mistrial and later for a new trial, both of which were denied by the district court.The United States District Court for the District of North Dakota sentenced Holmes Jr. to 188 months’ imprisonment. Holmes Jr. appealed, challenging the exclusion of his father’s testimony, the jury deliberation instructions, the denial of a new trial based on an alleged Brady violation, and the reasonableness of his sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no abuse of discretion in the district court’s exclusion of Holmes Sr. as a witness, as Holmes Jr. had violated the sequestration order. The court also determined that the district court’s scheduling communications with the jury were not coercive and did not constitute supplemental jury instructions. Regarding the alleged Brady violation, the court held that the undisclosed evidence was cumulative of information already available to Holmes Jr., and thus, there was no violation. Finally, the court found that the district court did not commit procedural error in sentencing and that the sentence was substantively reasonable.The Eighth Circuit affirmed the judgment of the district court. View "United States v. Holmes" on Justia Law

Officer Brandon Johnson of the Rapid City Police Department stopped a Ford F-150 with an obstructed rear license plate and a tinted windshield. The driver, Evan Brown Bull, and the passenger, Angel Bush, were both arrested based on outstanding warrants. A search of the vehicle revealed a handgun holster, three boxes of ammunition, and a wooden stock to a rifle or shotgun. Brown Bull was charged with being a felon in possession of ammunition.The United States District Court for the District of South Dakota held a two-day trial, after which the jury convicted Brown Bull. The district court overruled his motion for judgment of acquittal. Brown Bull appealed, arguing insufficient evidence of knowing possession of the ammunition.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo, applying the same standard of review for challenges to the sufficiency of the evidence. The court noted that the government must prove beyond a reasonable doubt that the defendant knowingly possessed the ammunition. The court found that the evidence, including testimony from Brown Bull's former girlfriend and Facebook communications, was sufficient for a reasonable jury to conclude that Brown Bull had constructive knowing possession of the ammunition.The Eighth Circuit affirmed the judgment of the district court, concluding that the evidence was sufficient to support the jury's verdict. View "United States v. Bull" on Justia Law

In 2021, the Turtle Mountain Band of Chippewa Indians, Spirit Lake Tribe, and three individual Native American voters filed a lawsuit against North Dakota’s Secretary of State. They claimed that the state's 2021 redistricting plan diluted Native American voting strength, violating Section 2 of the Voting Rights Act (VRA) and 42 U.S.C. § 1983. Section 2 of the VRA prohibits vote dilution, which can occur through packing a minority group into one district or dividing them among several districts to weaken their voting power.The United States District Court for the District of North Dakota denied the Secretary's motion to dismiss, which argued that private plaintiffs lacked a cause of action under Section 2 and could not use § 1983 to enforce it. The district court allowed the case to proceed, and after a bench trial, it ruled that the 2021 redistricting map violated Section 2. The court permanently enjoined the Secretary from using the map and ordered the North Dakota Legislative Assembly to adopt a remedial map. When the Assembly failed to do so, the court imposed the plaintiffs' proposed map.The United States Court of Appeals for the Eighth Circuit reviewed the case. The main issue was whether private plaintiffs could enforce Section 2 of the VRA through § 1983. The court held that Section 2 does not unambiguously confer an individual right enforceable under § 1983. The court emphasized that Section 2 focuses on the entities regulated (states and political subdivisions) rather than unambiguously creating individual rights. Consequently, the court vacated the district court's judgment and remanded the case with instructions to dismiss it for lack of a cause of action. View "Turtle Mountain Band of Chippewa Indians v. Howe" on Justia Law

Zackaria Dahir Mohamed, a native of Somalia, entered the United States as a child refugee in 1998. He was later convicted of several offenses, including theft and assault with a dangerous weapon. In 2013, the Department of Homeland Security initiated removal proceedings against him due to these convictions. An Immigration Judge (IJ) ordered his removal in 2018, and the Board of Immigration Appeals (BIA) dismissed his appeal. Mohamed then petitioned for review.The IJ initially found Mohamed removable for aggravated felony theft and crimes of violence. In 2020, the IJ ordered his removal to Somalia. Mohamed appealed to the BIA, which remanded the case to the IJ to assess Mohamed’s competency. On remand, Mohamed presented evidence of his mental health history, including a psychological evaluation by Dr. Jerry Kroll. The IJ ruled in 2021 that Mohamed was competent during the 2020 merits hearing, based on Dr. Kroll’s testimony and the IJ’s observations. The BIA dismissed Mohamed’s appeal on de novo review, leading to the current petition.The United States Court of Appeals for the Eighth Circuit reviewed the case. Mohamed argued that the BIA’s affirmation of the IJ’s competency finding was unsupported by the record. The court noted that it has jurisdiction to review final agency removal orders but not factual findings related to criminal offenses. The court found that Mohamed’s competency determination was a factual finding, which is generally affirmed unless clearly erroneous. Mohamed’s claims were barred by 8 U.S.C. § 1252(a)(2)(C).Even if Mohamed presented a legal or constitutional claim, the court found no fundamental procedural error or resulting prejudice. The IJ had considered all appropriate evidence, including Dr. Kroll’s testimony and Mohamed’s behavior during proceedings. The court concluded that there was no procedural error in holding a retroactive competency hearing. The petition for review was denied. View "Mohamed v. Bondi" on Justia Law

Danette Hester, a Special Agent for the IRS in Iowa, applied for a Criminal Investigator position in Georgia but was not hired. After filing a discrimination complaint, the IRS proposed her termination for alleged misconduct. Hester sued, claiming discrimination and retaliation. The district court granted summary judgment to the IRS, and Hester appealed.The United States District Court for the Southern District of Iowa granted summary judgment in favor of the IRS on all counts. Hester, a 53-year-old Black woman, alleged retaliation and race, sex, and age discrimination. The district court found that Hester did not provide sufficient evidence to support her claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Hester met her initial burden of establishing a prima facie case of race and sex discrimination but failed to show that the IRS's legitimate, nondiscriminatory reason for not hiring her was pretextual. The court noted that the IRS limited the hiring to one position due to an upcoming reorganization and that the selected candidate had qualifications Hester lacked, such as fluency in Spanish.Regarding age discrimination, the court found that the four-year age difference between Hester and the selected candidate was not significant enough to support her claim. For the retaliation claim, the court held that Hester did not establish a causal connection between her discrimination complaint and the proposed termination, as the seven-month gap was insufficient to infer causation.The Eighth Circuit affirmed the district court's judgment, concluding that Hester failed to provide evidence that the IRS's reasons for its actions were pretextual or that her age, race, or sex played a role in the decision not to promote her. View "Hester v. U.S. Department of Treasury" on Justia Law

In this case, Jae Michael Bernard was convicted of unlawful possession of a firearm by a person convicted of a misdemeanor crime of domestic violence. Bernard had a prior conviction in 2002 for domestic abuse assault causing injury. In September 2021, investigators found firearms and ammunition at his residence. Bernard pleaded guilty in June 2022 but later moved to withdraw his plea and dismiss the indictment, arguing that 18 U.S.C. § 922(g)(9) is unconstitutional under the Second Amendment.The United States District Court for the Northern District of Iowa denied Bernard's motion to dismiss the indictment. Bernard then entered a conditional guilty plea, reserving his right to appeal the denial of his motion. The district court sentenced him to thirty-seven months’ imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. Bernard's appeal was based on a facial challenge to the constitutionality of § 922(g)(9). The court noted that a facial challenge requires showing that no set of circumstances exists under which the statute would be valid. The court held that § 922(g)(9) is consistent with the historical tradition of firearm regulation, which allows disarming individuals who present a credible threat to the physical safety of others. The court found that the statute is constitutional in at least some of its applications, as it targets individuals convicted of crimes involving actual or attempted violence or the threatened use of a deadly weapon.The Eighth Circuit affirmed the district court's judgment, concluding that § 922(g)(9) is not unconstitutional on its face. View "United States v. Bernard" on Justia Law

Paul Cropper applied for disability insurance benefits and supplemental security income in February 2020, citing various impairments such as anxiety, depression, ADHD, insomnia, and COPD. His application was denied initially and upon reconsideration by the Social Security Administration. Cropper then requested a hearing before an administrative law judge (ALJ), where he presented opinions from his medical providers indicating severe limitations. The ALJ conducted a five-step analysis and denied the application, finding that while Cropper had severe impairments, he could still perform certain jobs available in the national economy. The ALJ found the opinions of Cropper’s primary care provider and psychiatrist unpersuasive.Cropper sought judicial review in the United States District Court for the District of Minnesota, arguing that the ALJ improperly evaluated the evidence, leading to an incorrect residual functional capacity determination. The district court granted summary judgment in favor of the Commissioner, concluding that substantial evidence supported the ALJ’s decision to find the medical opinions unpersuasive.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that the ALJ adequately considered the supportability and consistency of the medical opinions as required by the revised regulations. The court emphasized that the ALJ’s findings were supported by substantial evidence, including the conservative course of treatment and the lack of significant outpatient therapy. The court also noted that the ALJ’s reasoning was sufficiently clear to allow for appropriate judicial review. View "Cropper v. Dudek" on Justia Law

Trenton Johnson, an employee of Concorp, Inc., was injured while performing maintenance work at Exide Technologies, Inc.'s plant in Kansas City, Missouri. Johnson fell into a vat of molten lead while replacing a belt on a conveyor, resulting in severe burns. He subsequently sued Exide for negligence in Missouri state court.The case was removed to the United States District Court for the Western District of Missouri, where the parties engaged in discovery and briefed the issue of whether Johnson's exclusive remedy was under Missouri's workers' compensation system. The district court granted summary judgment in favor of Exide, concluding that Johnson's claim was indeed limited to workers' compensation benefits.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision de novo. The appellate court examined whether an employer-employee relationship existed between Exide and Johnson under Missouri's workers' compensation statute. The court applied the means/control test and the statutory-employee status test. It found that Concorp, not Exide, had the means/control relationship with Johnson. However, the court determined that Johnson was a statutory employee of Exide because his work was performed under a contract and in the usual course of Exide's business.The Eighth Circuit held that Johnson's exclusive remedy for his injuries was through Missouri's workers' compensation system, and Exide was immune from the negligence claim. The court affirmed the district court's summary judgment in favor of Exide. View "Johnson v. Exide Technologies, Inc." on Justia Law