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

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Plaintiff filed suit alleging that Missouri's lobbying requirements violate his freedom of speech and right to petition the government, and that the law is facially invalid because ordinary citizens do not have fair notice of whom it covers. The Eighth Circuit vacated the district court's order denying plaintiff a preliminary injunction. The court held that Missouri's application of the law to plaintiff violates the First Amendment, because his political activities did not involve the transfer of money or anything of value, either to him or anyone else, and Missouri's interest in transparency did not reflect the seriousness of the actual burden on his First Amendment rights. The court also held that, even though the law does not define or otherwise explain what "designated" means, it is not vague. Instead, the court applied the word's common and ordinary meaning, in context, and held that, just because the law is broad does not mean that it is ambiguous, much less constitutionally vague. Accordingly, the court remanded for further consideration of plaintiff's request for a permanent injunction. View "Calzone v. Summers" on Justia Law

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At issue was whether the district court erred in concluding that it has no authority under 18 U.S.C. 3599 and the All Writs Act, 18 U.S.C. 1651(a), to order South Dakota prison officials to allow petitioner to meet with mental health experts retained by appointed counsel for purposes of preparing a clemency application. The Eighth Circuit held that circumstances underlying the issue have changed, and a decision on this narrow issue was no longer needed. The court held that, at the present time, with South Dakota clemency proceedings commenced and the time for granting or denying imminent, the issues raised by petitioner in this appeal were either moot or have not been fully exhausted. Accordingly, the court dismissed the appeal. View "Rhines v. Young" on Justia Law

Posted in: Criminal Law
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The Eighth Circuit reversed the district court's denial of the law firm's motion to compel arbitration between the firm and its client. The court held that the law firm's offer to pay plaintiff's share of the arbitration costs cured any substantive unconscionability that the agreement may have contained; the offer also cured any issue regarding substantive unconscionability where the arbitration provision in effect allowed only the firm to obtain redress of claims; plaintiff has not demonstrated that she lacked meaningful choice, and thus the circumstances giving rise to the lawsuit did not render the retainer agreement procedurally unconscionable; and the language in the agreement adequately disclosed the consequences of the arbitration provision, and the agreement was not unenforceable because the firm violated their ethical duties under DC Circuit precedent. View "Plummer v. McSweeney" on Justia Law

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The Eighth Circuit affirmed defendant's sentence and rejected the contention that the district court created unwarranted disparities contrary to 18 U.S.C. 3553(a)(6), when it refused to vary from a guidelines provision that other district judges disagree with as a matter of sentencing policy. In this case, defendant was essentially asking the court to compel the district court to disagree with a guidelines provision as a matter of sentencing policy because other sentencing judges have done so. View "United States v. Heim" on Justia Law

Posted in: Criminal Law
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Plaintiffs filed suit against Dometic, alleging that the fire that extensively damaged a storage building and personal property owned by plaintiffs was caused by a defective Dometic refrigerator installed in their RV. The Eighth Circuit affirmed the district court's grant of summary judgment to Dometic, holding that Dometic was immune from liability under Iowa Code 613.18 because it sold, but did not manufacture, design, or assemble the refrigerator. The court held that any design input by Dometic was not related in any way to the boiler tubes, or that Dometic had any role in designing the boiler tubes. View "Merfeld v. Dometic Corp." on Justia Law

Posted in: Products Liability
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Plaintiff and others filed a class action against defendants, alleging claims under the Fair Labor Standards Act (FLSA) and Nebraska law, arising out of an eight-week student-driver training program operated by defendants and intended for new truck drivers. The Eighth Circuit agreed with defendants that the district court abused its discretion by granting plaintiffs' request to extend the Federal Rule of Civil Procedure 16(b) disclosure deadline, despite finding that good cause for the extension had not been shown, based on an erroneous application of Rule 37(c)(1). The court held that the error was not harmless because the jury clearly relied on the opinion of plaintiff's expert in reaching the damages award. Accordingly, the court vacated and remanded for further proceedings. View "Petrone v. Werner Enterprises, Inc." on Justia Law

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The Eighth Circuit denied a petition for review of the BIA's order denying cancellation of removal and ordering petitioner removed, and subsequently denying his timely motion to reopen proceedings. The court held that petitioner was challenging the discretionary conclusion of the BIA against him and thus the court did not have jurisdiction. The court also held that the BIA did not abuse its discretion in denying the motion to reopen, because the BIA had the final authority to decide whether to grant discretionary cancellation-of-removal relief. View "Urrutia Robles v. Barr" on Justia Law

Posted in: Immigration Law
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Plaintiff filed suit against Dollar General after the company denied her request for a leave of absence due to a medical condition, alleging claims under the Americans with Disabilities Act (ADA), the Family Medical Leave Act (FMLA), and state law. The court reversed the district court's dismissal of plaintiff's ADA claim and held that a reasonable jury could conclude that Dollar General was aware of her disability; that she requested an accommodation; and that Dollar General, had it engaged in the interactive process, could have reasonably accommodated her. However, plaintiff's remaining claims failed because she could not show defendants' actions amounted to retaliation and she failed to follow the steps Dollar General had established for requesting FMLA leave. View "Garrison v. Dolgencorp, LLC" on Justia Law

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The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court rejected defendant's claim under Rehaif v. United States, 139 S. Ct. 2191 (2019), and held that there was no plain error where defendant failed to show a reasonable probability that, but for the error, the outcome of the proceeding would have been different. Assuming without deciding that the district court erred in admitting a photo lineup identification in violation of defendant's Sixth Amendment right to confrontation, the court held that admission of such evidence did not affect defendant's substantial rights. The court also held that the evidence was sufficient for a reasonable jury to find defendant guilty beyond a reasonable doubt. Finally, the court held that the district court did not abuse its discretion by imposing two special conditions for defendant's supervised-release term --requiring defendant to participate in anger management treatment and domestic violence treatment -- in light of defendant's behavior problems in the past. View "United States v. Hollingshed" on Justia Law

Posted in: Criminal Law
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The Eighth Circuit affirmed defendant's appeal of the Sex Offender Registration and Notification Act (SORNA) registration requirements as a condition of his release. The court held that the plea agreement, in which defendant entered into knowingly and voluntarily, waived the issue presented and there was no miscarriage in enforcing it. View "United States v. Knight" on Justia Law

Posted in: Criminal Law