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

Abrahim Fofana, a Liberian national, attempted to enter the United States with fraudulent documents in 2001. After disclosing his fundraising activities for the United Liberation Movement of Liberia for Democracy (ULIMO) and claiming fear of persecution due to his affiliation, he was granted asylum by an immigration judge. In 2002, Fofana applied to adjust his status to lawful permanent resident. In 2018, the United States Citizenship and Immigration Services (USCIS) denied his application, determining he was inadmissible because he had solicited funds for ULIMO, which was classified as a Tier III terrorist organization under federal law.Fofana challenged the denial in the United States District Court for the District of Minnesota, arguing that USCIS’s decision was arbitrary and capricious and that collateral estoppel precluded his inadmissibility finding. The district court initially ruled in his favor on collateral estoppel grounds, but the United States Court of Appeals for the Eighth Circuit reversed and remanded the case. On remand, the district court again granted summary judgment to Fofana, rejecting the government’s argument that it lacked jurisdiction, and finding that Fofana was not inadmissible for engaging in terrorist activity. The court also concluded that USCIS’s determination regarding ULIMO was arbitrary and capricious and that the record did not support the finding that Fofana knew or should have known of ULIMO’s terrorist activities.On appeal, the United States Court of Appeals for the Eighth Circuit held that the district court lacked jurisdiction to review the Secretary’s decision on adjustment of status, finding that federal law precludes judicial review of both discretionary and non-discretionary determinations made by the Secretary regarding such applications. The appellate court reversed the district court’s judgment and remanded with instructions to dismiss the complaint for lack of jurisdiction. View "Fofana v. Noem" on Justia Law

On December 25, 2019, a patrol sergeant noticed a van idling in a driveway, twice encountered it, and approached the vehicle. The driver, Raymond Kelley, identified himself and his residence. The sergeant observed signs of alcohol and learned Kelley had a prior DUI and an active warrant. Kelley exited, was patted down, and sat on a wall; after asking to call his wife and being denied, Kelley ran up the driveway. The sergeant pursued and tackled Kelley, gaining control of his wrist. A deputy arrived after Kelley was tackled and assisted with handcuffing. Kelley complained of an arm injury, received medical attention, and was cited for public intoxication and resisting law enforcement before being released. Disputed facts center on the degree of Kelley’s resistance and the force used during handcuffing.Kelley sued under 42 U.S.C. § 1983, alleging unlawful arrest and excessive force against the officers in both their official and individual capacities. The United States District Court for the Eastern District of Arkansas granted summary judgment to the officers on the false arrest claim and on all claims against them in their official capacities. However, the court denied qualified immunity to both officers on the excessive force claim in their individual capacities, finding that disputed facts about Kelley’s conduct and the techniques used precluded summary judgment and should be resolved by a jury.Reviewing this interlocutory appeal, the United States Court of Appeals for the Eighth Circuit determined that the district court erred by failing to construe disputed facts in the light most favorable to Kelley and by not completing the required two-prong qualified immunity analysis. The Eighth Circuit vacated the district court’s order denying qualified immunity and remanded the case for a more detailed assessment, instructing the district court to consider both prongs of the qualified immunity analysis after properly construing the facts. View "Kelley v. Pruett" on Justia Law

A group of patients civilly committed under Minnesota law challenged the state's sex offender treatment program, alleging inadequate treatment and unconstitutional conditions of confinement. The lawsuit was brought as a class action, initially filed pro se and later supported by counsel through the Minnesota Federal Bar Association’s Pro Se Project. During the litigation, the patients, citing indigence and the need for expert testimony, requested court-appointed experts under Federal Rule of Evidence 706. Both parties jointly nominated experts, and in 2013, they recommended a 50/50 split of expert costs. However, the court initially allocated all costs to the defendants, reserving the option to adjust later.After more than a decade of litigation, the United States District Court for the District of Minnesota ruled in favor of the state officials on all claims. The officials then sought to recover litigation costs, including expert fees, as prevailing parties under Federal Rule of Civil Procedure 54(d)(1). The district court declined to award any costs to the officials, citing the plaintiffs' indigence, good faith, public importance of the issues, vigorous litigation, difficulty and closeness of the issues, and potential chilling effect on future litigants.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court failed to consider the plaintiffs’ 2013 recommendation to share expert costs and did not adequately weigh their acknowledged ability to pay half at that time. The Eighth Circuit vacated the district court’s cost judgment and remanded with instructions to award half of the expert costs to the prevailing defendants, to be assessed jointly and severally against the named plaintiffs. View "Karsjens v. Gandhi" on Justia Law

A man named Jordan was incarcerated in the Madison County Jail in Iowa, where he exhibited signs of acute mental health distress, including a recent history of suicide attempts, hearing voices, and expressing thoughts of self-harm. His parents and girlfriend raised concerns about his mental state to jail staff. In response, Scott Thomas, a Jail Diversion Case Manager employed by Eyerly-Ball Community Mental Health Services, met with Jordan, who disclosed his mental health struggles and suicidal thoughts. Thomas reported to jail staff only that Jordan said he would not harm himself while in custody, omitting other serious statements. Ten minutes after being returned to his cell, Jordan died by suicide.The Paynes, Jordan’s parents, sued Thomas and Eyerly-Ball for negligence in the United States District Court for the Southern District of Iowa. The district court dismissed the federal claims and retained jurisdiction over the state-law claims. Later, the court granted summary judgment to Thomas and Eyerly-Ball on the negligence claims, holding that they owed no legal duty to Jordan under Iowa law and relevant sections of the Restatement (Third) of Torts.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The appellate court found that there were genuine disputes of material fact regarding whether Thomas and Eyerly-Ball undertook a duty to assess and communicate Jordan’s suicide risk and whether their actions increased the risk of harm or caused jail staff to rely on their assessment. The court held that, under Iowa law, summary judgment was inappropriate on the question of duty based on an undertaking. However, it agreed that no duty arose from a custodial relationship, as Thomas and Eyerly-Ball did not have custody of Jordan. The appellate court reversed the district court’s grant of summary judgment and remanded for further proceedings. View "Payne v. Eyerly-Ball" on Justia Law

Aguilar-Hernandez, a citizen of Guatemala, began a relationship with Arreaga Soto at age fifteen. After the birth of their child, Jose, she experienced repeated sexual and physical abuse from Arreaga Soto, who threatened her life and verbally abused her. Despite multiple attempts to leave, she reconciled with him each time, but the abuse continued. In 2016, Aguilar-Hernandez and her son left Guatemala and were apprehended at the U.S. border. She applied for asylum, humanitarian asylum, withholding of removal, and protection under the Convention Against Torture, with her son seeking derivative relief.An Immigration Judge denied all applications, finding that Aguilar-Hernandez failed to establish a nexus between the alleged persecution and her membership in the proposed social groups. The judge concluded that the abuse stemmed from a personal relationship and not from her membership in a particular social group. The judge also found no evidence that the Guatemalan government acquiesced in torture. On administrative appeal, the Board of Immigration Appeals affirmed all findings and denials.The United States Court of Appeals for the Eighth Circuit reviewed the Board’s decision, applying de novo review to legal questions and substantial evidence review to factual findings. The Eighth Circuit held that substantial evidence supported the Board’s conclusion that Aguilar-Hernandez’s membership in the proposed social groups was incidental or tangential to the motive for abuse, and that she did not show persecution “on account of” such membership. The court further found that she failed to meet the higher standard required for withholding of removal and did not provide particularized evidence that she would more likely than not be tortured with government acquiescence upon return. Accordingly, the Eighth Circuit denied both petitions for review. View "Aguilar-Hernandez v. Bondi" on Justia Law

Darrick Ferguson pleaded guilty to being a felon in possession of a firearm, in violation of federal law. At the time of sentencing, Ferguson had three prior felony convictions, one of which was under Arkansas law for delivery of a controlled substance—specifically, cocaine. The district court determined that all three prior convictions, including the Arkansas drug conviction, qualified as predicate offenses for an enhanced sentence under the Armed Career Criminal Act (ACCA), which mandates a minimum sentence for individuals with three or more prior convictions for “serious drug offenses.” Ferguson was sentenced to 180 months’ imprisonment.The United States District Court for the Eastern District of Arkansas found that Ferguson’s Arkansas conviction qualified as a serious drug offense under the ACCA. Ferguson appealed, contending that the Arkansas statute under which he was convicted criminalizes a broader range of cocaine isomers than are covered by the federal Controlled Substances Act, and therefore, his conviction should not count as a predicate offense for ACCA purposes.The United States Court of Appeals for the Eighth Circuit reviewed de novo whether Ferguson’s Arkansas conviction qualified as a predicate offense under the ACCA. Applying the categorical approach, the court held that the Arkansas statute criminalizes all cocaine isomers, while the federal law only covers specific ones. Because the Arkansas statute is broader and punishes conduct not included in the federal definition, Ferguson’s conviction does not qualify as a predicate offense under the ACCA. The Eighth Circuit vacated Ferguson’s sentence and remanded the case for resentencing without the ACCA enhancement. The court did not address Ferguson’s argument regarding his burglary conviction since the drug conviction was dispositive. View "United States v. Ferguson" on Justia Law

Two individuals were charged with multiple criminal offenses following an encounter with law enforcement. The initial police contact arose when an officer observed their vehicle driving at night without a functioning license plate light. After the officer followed the vehicle, one passenger exited and ran away, prompting further investigation. The officer questioned the driver, who admitted to having a suspended license and denied ownership of the car. Other officers arrived, and both individuals were eventually detained and handcuffed. A search of the vehicle revealed marijuana, methamphetamine, drug paraphernalia, and identification for the passenger. Subsequent criminal charges against both individuals were dismissed after a state court granted their motions to suppress the evidence.After the dismissal of the state charges, the two individuals filed a civil suit in the United States District Court for the Southern District of Iowa. They brought claims under 42 U.S.C. § 1983, alleging violations of their Fourth Amendment rights, and asserted additional claims under state law. The district court granted summary judgment in favor of the defendants—local officers and government entities—concluding that the officers were entitled to qualified immunity on the federal claims. The court also declined to exercise supplemental jurisdiction over some state law claims.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the district court erred in granting summary judgment on the federal claims against two officers. The Eighth Circuit held that the officers had, at minimum, arguable reasonable suspicion to justify the initial detention, that the warrantless search of the vehicle was permissible under the plain view doctrine, and that the arrests were supported by probable cause or, at least, arguable probable cause. The appellate court affirmed the district court’s judgment, upholding the grant of summary judgment in favor of the defendants. View "Valdivia v. Porsch" on Justia Law

Robbie Dean Fetters was convicted by a jury in 2011 of several serious offenses, including being a felon in possession of a firearm, using or carrying a firearm in furtherance of a drug crime, conspiracy to distribute methamphetamine, distribution of methamphetamine, and possession with intent to distribute methamphetamine. Following his conviction, the United States District Court for the Southern District of Iowa imposed a downward-variant sentence of 320 months’ imprisonment and five years of supervised release. Fetters later developed multiple significant medical conditions, such as cirrhosis, diabetes, and complications with a feeding tube, and is classified by the Bureau of Prisons as a Level Three chronic care inmate.In 2020, Fetters sought compassionate release from the district court, arguing that his health issues warranted a reduction in his sentence. The district court denied the motion, finding that he did not establish that the sentencing factors under 18 U.S.C. § 3553(a) supported release. In 2024, Fetters renewed his motion for compassionate release, emphasizing the progression and severity of his medical conditions. Again, the United States District Court for the Southern District of Iowa denied the request, concluding that his medical needs, while serious, did not amount to “extraordinary and compelling reasons” for release and that the Bureau of Prisons could provide adequate care.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial for abuse of discretion. The appellate court held that the district court properly exercised its broad discretion, considered both the guideline and BOP definitions of “terminal illness,” and thoroughly evaluated Fetters’s health and criminal history. The court further found that the district court appropriately weighed the § 3553(a) factors and did not err in denying compassionate release. The judgment of the district court was affirmed. View "United States v. Fetters" on Justia Law

Michelle Siebrecht worked as a physician assistant in the emergency room at a rural Iowa hospital operated by Mercy Health Services. Her employment contract required her to work three 24-hour shifts per pay period, including weekends. Siebrecht, diagnosed with multiple sclerosis, took FMLA leave twice due to her condition. Upon returning, her doctor imposed restrictions: she could work no more than one 24-hour shift per week and no weekends. Mercy’s CEO expressed concern that these limitations made it difficult to staff the ER and were unfair to other providers. Mercy ultimately chose not to renew Siebrecht’s contract, notifying her that her employment would end after the temporary renewal period.Siebrecht filed suit in Iowa state court, alleging that Mercy violated the Americans with Disabilities Act, the Iowa Civil Rights Act, and the Family and Medical Leave Act by discriminating against her based on her disability and retaliating against her for taking FMLA leave. Mercy removed the case to the United States District Court for the Northern District of Iowa. The district court granted summary judgment in favor of Mercy, finding that Siebrecht was not a “qualified individual” under the ADA and ICRA, as she could not perform the essential functions of her job with or without reasonable accommodation. The court also concluded that there was no causal connection between her FMLA leave and the termination of her employment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo and affirmed. The Eighth Circuit held that the ability to work three 24-hour shifts per pay period and weekends was an essential function of Siebrecht’s position and that no reasonable accommodation would have enabled her to perform these functions. The court also found insufficient evidence of FMLA retaliation or pretextual termination. The judgment of the district court was affirmed. View "Siebrecht v. Mercy Health Services - Iowa Corp." on Justia Law

An 11-year-old child, L.D., was placed in foster care with Trina Mae Johnson. Over a period of fifteen months, Johnson inflicted severe abuse on L.D., including physical torture, starvation, denial of medical care, and psychological torment. The abuse resulted in significant weight loss, untreated injuries, and lasting trauma. Johnson concealed the abuse, enlisted others in her household to participate, and intimidated L.D. into silence. The abuse came to light when Johnson brought L.D. to a youth shelter, prompting an investigation by child services and the FBI.Johnson and several co-defendants were indicted on charges of child torture, child neglect, child endangerment, and assaulting a minor with a dangerous weapon in both federal and Minnesota state law violations. Some co-defendants pleaded guilty, while Johnson’s sister went to trial. Johnson was unable to accept a plea agreement because it was contingent on both sisters pleading guilty. She ultimately pleaded guilty without an agreement. The United States District Court for the District of Minnesota sentenced Johnson to 216 months in prison, after considering the relevant sentencing factors and victim impact statements. The sentence was below the government’s recommendation but above the prior plea offer.On appeal to the United States Court of Appeals for the Eighth Circuit, Johnson argued that the district court judge’s direct, sympathetic comments to L.D. at sentencing demonstrated judicial bias and violated her due process right to an impartial tribunal. The Eighth Circuit applied plain error review, noting Johnson did not object to the judge’s comments at sentencing or seek recusal. The court held that the judge’s empathetic remarks to the victim did not display deep-seated favoritism or antagonism that would make fair judgment impossible. Finding no plain error or due process violation, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Johnson" on Justia Law