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

Joshua Vogt died of a drug overdose while detained in a county jail. His daughter, Molly Vogt, filed a lawsuit under 42 U.S.C. § 1983, alleging that three officers deliberately disregarded his medical condition. The magistrate judge recommended summary judgment in favor of the officers, and the district court agreed. Molly Vogt appealed, arguing that a pending adverse-inference instruction against the officers created a material factual dispute regarding their deliberate indifference to Mr. Vogt’s medical condition.The United States District Court for the District of Minnesota initially reviewed the case. The magistrate judge found that the county had intentionally destroyed footage from Camera 18, which could have shown Mr. Vogt’s condition. Despite this, the magistrate judge recommended summary judgment for the officers, concluding that even with the adverse inference, the available evidence did not support a finding of deliberate indifference. The district court adopted these recommendations, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that to establish a § 1983 medical indifference claim, the plaintiff must show that officers acted with deliberate indifference to a pretrial detainee’s objectively serious medical needs. The court found that the officers repeatedly checked on Mr. Vogt, questioned him about his condition, and called for emergency medical help when his condition worsened. The court concluded that the adverse inference regarding the missing footage did not create a genuine issue of material fact sufficient to preclude summary judgment. The court affirmed the district court’s decision, granting summary judgment to the officers. View "Vogt v. Crow Wing County" on Justia Law

Elmarries Harris was serving a term of supervised release following a prison sentence for a firearms offense. In January 2023, the probation office reported several violations of his release conditions, including an allegation that he assaulted his wife, Erica. At a revocation hearing in June 2023, Harris denied the allegations, and the government presented a violation report and a defense investigator’s report stating Erica denied being assaulted. Harris objected to the hearsay evidence, and the court continued the hearing for additional evidence. In August, the government presented medical records of Erica’s injuries and testimony from a police officer who responded to a 911 call reporting the assault. The officer’s body camera footage and testimony from Erica’s neighbor and a 911 caller were also presented, despite Harris’s objections to hearsay.The United States District Court for the Western District of Missouri found Harris committed a Grade A violation by committing a domestic assault in the second degree, supported by medical records and corroborating witness statements. The court also found Harris violated other conditions of his release, including failing to answer the probation officer’s questions truthfully, failing to notify the probation officer before changing his residence, and consuming alcohol. Harris was sentenced to 24 months’ imprisonment, the statutory maximum, with no supervised release to follow.The United States Court of Appeals for the Eighth Circuit reviewed the case. Harris argued that the reliance on hearsay evidence violated Federal Rule of Criminal Procedure 32.1 and due process. The court concluded that the district court’s decision was consistent with due process, noting the reliability of the evidence and the government’s reasonable explanations for the absence of witnesses. The judgment of the district court was affirmed. View "United States v. Harris" on Justia Law

Two high school brothers, Kameron and Noah Evans, were arrested for disorderly conduct after wearing tactical vests to school. The brothers, who had faced racial bullying, wore the vests on a day when the school was screening an active-shooter video. They were searched by school resource officers, who found no weapons. The principal decided to have them arrested, and they were charged with disorderly conduct. The state court later acquitted them, and the brothers filed a lawsuit under § 1983 and state tort claims against the officers, alleging lack of probable cause and excessive force.The United States District Court for the Eastern District of Arkansas denied the officers' motion for summary judgment based on qualified immunity. The officers appealed, arguing they had probable cause or at least arguable probable cause to arrest the brothers for disorderly conduct under Arkansas law.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that the officers lacked probable cause to arrest the brothers, as their actions did not disrupt a lawful assembly or constitute threatening behavior. The court also determined that the officers did not have arguable probable cause, as the brothers were cooperative and their attire did not violate the school dress code. The court affirmed the district court's denial of qualified immunity on the unlawful arrest, malicious prosecution, and false imprisonment claims. However, the court reversed the denial of qualified immunity on the excessive force and abuse of process claims, as the plaintiffs failed to respond to these arguments on appeal. The case was remanded for further proceedings. View "Evans v. Dodd" on Justia Law

Derrick Lovell Parker pleaded guilty to possession with intent to distribute heroin, violating 21 U.S.C. §§ 841(a)(1) and (b)(1)(B). The advisory Guidelines range for his sentence was 70 to 87 months. However, the district court varied upward and sentenced Parker to 180 months of imprisonment and 5 years of supervised release. Parker appealed his sentence, arguing that it was substantively unreasonable.The United States District Court for the Eastern District of Arkansas initially reviewed the case. The court considered the nature of Parker's offense, which involved a significant amount of heroin and an incident where Parker, armed with a gun, created a "very scary situation" at a residential re-entry center. The district court expressed concern about Parker's potential to repeat his unlawful conduct and decided on a substantial upward variance from the Guidelines range.The United States Court of Appeals for the Eighth Circuit reviewed the case under a deferential abuse-of-discretion standard. Parker contended that the district court gave undue weight to factors already considered by the Guidelines, such as his offense conduct and criminal history. The appellate court noted that while courts should be cautious when supporting a substantial upward variance with factors already reflected in the Guidelines, such factors can still justify a variance. The appellate court found that the district court did not give undue weight to these factors.Parker also argued that the district court failed to consider the need to avoid sentence disparities and mitigating factors like his mental health issues. The appellate court observed that the district court had considered these factors and recommended substance abuse treatment and mental health counseling for Parker. The appellate court concluded that the district court acted within its discretion and affirmed the 180-month sentence. View "United States v. Parker" on Justia Law

In March 2022, federal and local law enforcement in Sioux Falls conducted an undercover operation to identify individuals enticing minors online for sexual purposes. Agents created profiles on social media applications, posing as minors. Sky Thomas Roubideaux, a 22-year-old man, engaged in explicit conversations with an undercover agent posing as a minor on the Grindr app. Roubideaux arranged to meet the supposed minor and was arrested upon arrival with items indicating intent for sexual activity.The United States District Court for the District of South Dakota convicted Roubideaux of attempted enticement of a minor using the internet, sentencing him to 120 months in prison followed by five years of supervised release. Roubideaux appealed, arguing that the district court erred in denying his Batson challenge, his motion for judgment of acquittal based on entrapment, his motion for a new trial, and his right to present a complete defense.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no clear error in the district court's Batson ruling, determining that the prosecution's race-neutral explanation for striking a juror was credible. The court also upheld the denial of the motion for judgment of acquittal, concluding that a reasonable jury could find Roubideaux predisposed to commit the crime. The court found no abuse of discretion in denying a new trial, as substantial evidence supported the verdict. Lastly, the court ruled that the exclusion of certain evidence did not violate Roubideaux's right to present a complete defense, as the district court acted within its discretion under Federal Rule of Evidence 403.The Eighth Circuit affirmed the district court's judgment, upholding Roubideaux's conviction and sentence. View "United States v. Roubideaux" on Justia Law

Christina Barrera, the office manager at PowerMed, was involved in a scheme to help unqualified individuals, mainly employees of AB InBev, fraudulently obtain disability benefits from the Social Security Administration (SSA) and private insurers. Patients paid PowerMed $21,600 for a "disability package" that included unnecessary medical tests and assistance in fraudulently applying for disability benefits. Barrera explained the scheme to patients, helped them complete paperwork, and coached them on how to appear disabled. An undercover officer's investigation led to Barrera's indictment and subsequent trial, where a jury found her guilty of conspiracy to defraud the SSA but acquitted her of health care fraud and theft of government funds.The United States District Court for the Eastern District of Missouri sentenced Barrera, ordering her to pay restitution to the SSA and private insurers. The presentence investigation report (PSR) recommended $339,407.80 in restitution to the SSA, but the Government argued for additional restitution to private insurers, totaling $203,907.62. The district court adopted the Government's figures, ordering Barrera to pay a total of $543,315.42 in restitution. After Barrera's sentencing, her co-conspirator Clarissa Pogue was sentenced but was not required to pay restitution to private insurers, leading Barrera to appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Barrera's criminal conduct included defrauding private insurers as part of the scheme to defraud the SSA, affirming the district court's decision to order restitution to private insurers. However, the court found errors in the calculation of restitution amounts for Prudential and MetLife, vacating those portions and remanding for further proceedings. The court rejected Barrera's argument regarding sentencing disparities with Pogue, emphasizing that the statutory direction to avoid unwarranted sentence disparities refers to national disparities, not differences among co-conspirators. The judgment was affirmed in part, vacated in part, and remanded. View "United States v. Barrera" on Justia Law

The case involves the Center for Biological Diversity's efforts to protect the Canadian lynx, a threatened species, from incidental trapping in Minnesota. The Center sued the Minnesota Department of Natural Resources, alleging that the state had not done enough to prevent trappers from accidentally capturing lynx. This led to a proposed consent decree requiring Minnesota to implement additional restrictions on trapping methods to protect the lynx.The United States District Court for the District of Minnesota reviewed the case and approved the consent decree over objections from three pro-trapping organizations. These organizations argued that the decree was prejudicial and harmful to their interests and that state law did not permit the adoption of the new regulations in the manner proposed. The district court found the consent decree to be a reasonable compromise that balanced the interests of both parties and had a reasonable relationship to the claims and defenses in the case.The United States Court of Appeals for the Eighth Circuit reviewed the district court's approval of the consent decree. The appellate court examined whether the consent decree was procedurally fair and reasonable. It found that the negotiations were conducted in good faith and at arm's length, and that the trappers had ample opportunity to raise their objections. The court also determined that the consent decree was reasonable because it aimed to reduce the number of lynx deaths and furthered the objectives of the Endangered Species Act. The court concluded that the district court did not abuse its discretion in approving the consent decree and affirmed the judgment. View "Center for Biological Diversity v. MN Trappers Association" on Justia Law

Four female hockey players filed a lawsuit against the University of North Dakota, alleging that the university violated Title IX by eliminating the women’s ice hockey program after the 2016-17 season. None of the plaintiffs were enrolled at the university at the time of the program's termination. They sought to represent a class of current, prospective, and future female students and requested a declaratory judgment and an injunction to reinstate the women’s hockey program.The United States District Court for the District of North Dakota dismissed the case for lack of jurisdiction, finding that the plaintiffs did not demonstrate a "concrete" injury as required for standing under Article III.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that two plaintiffs, Calli Forsberg and Maya Tellmann, had standing. Forsberg was recruited to play for the university’s hockey team but chose another school after the program was cut. Tellmann, a two-time state hockey champion, was accepted as a student but had no opportunity to play due to the program's elimination. Both plaintiffs demonstrated a concrete injury by being denied the opportunity to compete for the team of their choice, and they expressed a definite intent to attend the university if the program were reinstated.The court found that the other two plaintiffs, Emily Becker and Morgan Stenseth, did not allege sufficient facts to establish standing. Becker did not provide details about her qualifications or acceptance to the university, and Stenseth did not express an intent to attend the university in the future.The Eighth Circuit reversed and remanded the case in part, allowing Forsberg and Tellmann’s claims to proceed, but affirmed the dismissal of Becker and Stenseth’s claims. View "Becker v. North Dakota University System" on Justia Law

A Columbia County resident, Roderick McDaniel, was shot and killed by Deputy Charles McClinton outside an apartment complex in Magnolia, Arkansas. McDaniel was a suspect in a first-degree murder case, and an arrest warrant had been issued for him. Deputy McClinton encountered McDaniel in a white SUV, which matched the description of the vehicle used in the crime. When McDaniel attempted to flee by reversing into McClinton's patrol car and then accelerating forward, McClinton fired a single shot, killing McDaniel. A loaded handgun, later confirmed to be the murder weapon, was found near McDaniel.The United States District Court for the Western District of Arkansas denied Deputy McClinton's motion for summary judgment based on qualified immunity. The court found that there were material factual disputes, particularly regarding whether McDaniel was driving the SUV forward toward McClinton when he was shot. The court concluded that McClinton was not entitled to qualified immunity because it was clearly established that using deadly force against a suspect merely for fleeing, even in a vehicle, was unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that Deputy McClinton was entitled to qualified immunity. The court reasoned that McClinton had probable cause to believe McDaniel was a dangerous felon who had committed first-degree murder and was still armed. Therefore, using deadly force to prevent McDaniel's escape was constitutionally permissible. The court also noted that McClinton's conduct did not violate McDaniel's clearly established rights, as existing precedent did not clearly prohibit the use of deadly force in such circumstances. The case was remanded with instructions to enter summary judgment in favor of Deputy McClinton and dismiss the case. View "Arnold v. McClinton" on Justia Law

In August 2020, Joe Willie Cannon, an inmate at Anamosa State Penitentiary (ASP), injured his right wrist while playing basketball. He sought medical attention from ASP staff, including nurses and a doctor, but experienced delays and inadequate treatment. Cannon alleged that the medical staff's failure to promptly diagnose and treat his wrist injury, which was later found to be a displaced fracture, constituted deliberate indifference to his serious medical needs, violating his Eighth Amendment rights.The United States District Court for the Northern District of Iowa denied summary judgment to four defendants—Dr. Michael Dehner and Nurses Amy Shipley, Courtney Friedman, and Barbara Devaney—who claimed qualified immunity. The court found that a reasonable jury could conclude that the defendants acted with deliberate indifference to Cannon's medical needs. The defendants appealed this interlocutory order.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court concluded that the district court failed to properly apply the principle that each defendant's knowledge and conduct must be individually assessed. The appellate court found that the nurses' actions, including their assessments and treatment plans, did not amount to deliberate indifference. Similarly, Dr. Dehner's decisions, including ordering an X-ray and referring Cannon to an orthopedic specialist, were based on his medical judgment and did not constitute deliberate indifference.The Eighth Circuit held that each appellant was entitled to qualified immunity because Cannon failed to prove that any of them acted with deliberate indifference to his serious medical needs. The court reversed the district court's order and remanded the case for further proceedings consistent with its opinion. View "Cannon v. Dehner" on Justia Law