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

During an oil pipeline protest in Hubbard County, Minnesota, Matthew Locke and another protestor locked themselves to construction equipment using a device known as a “sleeping dragon,” which made removal difficult. Law enforcement officers, including Sheriff Cory Aukes and Chief Deputy Scott Parks, responded to the scene. In their efforts to remove Locke, the officers used several pain compliance techniques, applying pressure to various nerves on Locke’s head and neck. Locke alleges that as a result, he suffered facial paralysis, tinnitus, and emotional distress. After being removed from the device by extraction teams, Locke was evaluated by EMTs, taken to the hospital, and then jailed.The United States District Court for the District of Minnesota dismissed Locke’s claims under 42 U.S.C. § 1983 and Minnesota law. The court held that Sheriff Aukes and Deputy Parks were entitled to qualified and official immunity, and that Locke’s complaint did not state a claim for municipal liability against Hubbard County. The district court also dismissed Locke’s state law claims for assault and battery.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The Eighth Circuit held that, accepting the complaint’s allegations as true, Locke plausibly alleged a violation of his clearly established Fourth Amendment right to be free from excessive force, as the officers’ use of pain compliance techniques on a nonviolent, passively resisting misdemeanant was not objectively reasonable. The court also found that the district court erred in dismissing the official capacity claim without considering whether the sheriff was a final policymaker for the county. Additionally, the Eighth Circuit reversed the grant of official immunity on the state law claims, finding that the complaint sufficiently alleged willful violation of a known right. The court reversed and remanded for further proceedings. View "Locke v. County of Hubbard" on Justia Law

Two former employees of a steel plant in Blytheville, Arkansas, brought claims against their employer, alleging racial discrimination, a racially hostile work environment, and retaliation under the Arkansas Civil Rights Act. One employee, who worked at the plant for nearly three decades, was terminated after a series of disciplinary incidents, including an altercation during an internal investigation and subsequent violations of workplace policies. The other employee, who resigned after several years, claimed he was subjected to disparate discipline and racially offensive remarks by supervisors, including an incident where a supervisor referred to himself as a “slave driver” and mimed cracking a whip.After the plaintiffs filed suit in Arkansas state court, the case was removed to the United States District Court for the Eastern District of Arkansas. The plaintiffs amended their complaint, dropping federal claims and non-diverse parties, leaving only state law claims under the Arkansas Civil Rights Act. The district court granted summary judgment in favor of the employer on all claims, finding insufficient evidence to support the allegations of discrimination, retaliation, or a hostile work environment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that the plaintiffs failed to establish a prima facie case of racial discrimination or retaliation, as there was no evidence of similarly situated employees being treated more favorably or of a causal connection between protected activity and adverse employment actions. The court also found that the incidents cited did not rise to the level of a hostile work environment, particularly given the employer’s prompt and effective responses to reported incidents. The Eighth Circuit affirmed the district court’s grant of summary judgment in favor of the employer. View "Warren v. Nucor Corporation" on Justia Law

Two brothers, Tom and Robert Hoffmann, were formerly partners in a family heating and air conditioning business. After Robert bought out Tom’s interest, they settled their disputes in state court with an agreement that included a four-year prohibition on Tom’s use of the “Hoffmann” name in any HVAC business, as well as non-disparagement and non-solicitation clauses. After the four-year period, Tom started a new company, Hoffmann Air Conditioning & Heating, LLC, using the family name. Robert and his company, Hoffmann Brothers Heating and Air Conditioning, Inc., objected and filed suit in federal court, alleging copyright infringement, trademark infringement, unfair competition, and breach of contract.The United States District Court for the Eastern District of Missouri granted summary judgment to Tom and his company on the copyright claim, finding insufficient evidence of damages or a causal link between the alleged infringement and any profits. The remaining claims proceeded to a jury trial, which resulted in a mixed verdict largely favoring Tom and his company on the trademark and unfair competition claims. Both sides sought attorney fees, but the district court denied all requests.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s rulings. The appellate court affirmed the summary judgment on the copyright claim, holding that the evidence of damages and profits was too speculative. It also upheld the jury instructions and verdict on the trademark claims, finding the instructions properly reflected the law regarding customer sophistication and initial-interest confusion. The court agreed that ambiguity in the settlement agreement’s language about post-four-year use of the Hoffmann name was a factual question for the jury. Finally, the court affirmed the denial of attorney fees to Robert, as he had not personally incurred any fees. The judgment of the district court was affirmed in all respects. View "Hoffmann Bros. Heating & Air v. Hoffmann Air & Heating" on Justia Law

Philip Myers, a native and citizen of Liberia, was adopted by a U.S. citizen and entered the United States as a child. He later sustained several criminal convictions, including for aggravated felonies. In 2021, the Department of Homeland Security initiated removal proceedings against him. Myers claimed derivative citizenship through his adoptive mother, who had become a naturalized U.S. citizen, and also alleged that he had been abused by her. The United States Citizenship and Immigration Services (USCIS) had previously denied his derivative citizenship application, finding insufficient evidence that he was in his adoptive mother’s legal and physical custody at the relevant time. During removal proceedings, Myers, sometimes represented by counsel and sometimes pro se, was found competent to proceed without safeguards. He applied for various forms of relief, including asylum and protection under the Convention Against Torture, but these were denied.The Immigration Judge ordered Myers removed to Liberia. Myers appealed to the Board of Immigration Appeals (BIA), arguing that the competency determination was flawed and that he should have been found incompetent to proceed pro se. The BIA found no clear error in the Immigration Judge’s competency finding and dismissed the appeal. Myers then moved to reopen the proceedings, citing a pending motion with USCIS regarding derivative citizenship, alleged errors in the competency determination, a new asylum claim based on his sexual orientation, and a pending T-visa application as a victim of sex trafficking. The BIA denied the motion to reopen, and Myers was removed to Liberia.The United States Court of Appeals for the Eighth Circuit reviewed the BIA’s denial of the motion to reopen for abuse of discretion and found none. The court also rejected Myers’s constitutional challenge to the statutory requirements for derivative citizenship and found no genuine issue of material fact regarding his nationality claim. The petition for review was denied. View "Myers v. Bondi" on Justia Law

The case concerns a challenge to a 2024 rule issued by the Department of Energy (DOE) that revised the method for calculating the “petroleum equivalency factor” (PEF), which is used to determine the fuel economy values of electric vehicles for regulatory purposes. The DOE had previously used a “fuel content factor” of 1/0.15, which significantly inflated the fuel economy ratings of electric vehicles. In its 2023 proposal, DOE suggested eliminating this factor, but in the final rule, it opted to phase it out gradually over several model years. The final rule also introduced a new method for calculating the PEF, using a “cumulative gasoline-equivalent fuel economy of electricity” based on the projected useful life of an electric vehicle fleet—a method not included in the proposed rule.Several states and the American Free Enterprise Chamber of Commerce petitioned for review in the United States Court of Appeals for the Eighth Circuit. They argued that the DOE exceeded its statutory authority by retaining the fuel content factor and violated notice-and-comment requirements by adopting a new calculation method not previously proposed. The petitioners asserted standing based on increased costs to maintain public roads due to heavier electric vehicles and environmental harms from increased greenhouse gas emissions.The Eighth Circuit found that the petitioners had standing and that the case was not moot, even in light of new EPA emissions standards. The court held that DOE exceeded its statutory authority by retaining the fuel content factor, as the relevant statute did not authorize such an approach. Additionally, the court determined that DOE violated notice-and-comment procedures by failing to provide adequate notice of the new cumulative calculation method. The court concluded that these deficiencies were not severable from the rest of the rule.Accordingly, the Eighth Circuit granted the petition for review, vacated the 2024 final rule, and remanded the matter to DOE. View "State of Iowa v. Wright" on Justia Law

Several commercial air tour operators challenged federal regulations that banned all commercial air tours over Mount Rushmore National Memorial and Badlands National Park. The dispute arose after the Federal Aviation Administration (FAA) and the National Park Service, in response to statutory requirements and litigation, issued air tour management plans (ATMPs) in 2023 that prohibited such tours, citing negative impacts on visitor experience, wildlife, and tribal cultural resources. The operators argued that the agencies’ actions were arbitrary and capricious, violated the National Environmental Policy Act (NEPA), and failed to consider reasonable alternatives or aviation safety.Previously, the agencies had attempted to negotiate voluntary agreements with the tour operators, as permitted by the Air Tour Management Act. However, after one operator declined to participate, the agencies shifted to developing ATMPs. This change was influenced by a writ of mandamus issued by the United States Court of Appeals for the District of Columbia Circuit in In re Public Employees for Environmental Responsibility, which compelled the agencies to bring certain parks into compliance with the Act. The agencies then considered several alternatives before ultimately banning all commercial air tours in the final plans.The United States Court of Appeals for the Eighth Circuit reviewed the petitions for review filed by the tour operators. The court held that the agencies’ decision to end voluntary agreement negotiations and proceed with ATMPs was not arbitrary or capricious. It further found that the agencies complied with NEPA’s procedural requirements, used reasonable data, considered an adequate range of alternatives, and sufficiently addressed aviation safety concerns. The court concluded that the agencies’ decisions were reasonable and reasonably explained, and therefore denied the petitions to vacate the air tour management plans. View "Badger Helicopters Inc. v. FAA" on Justia Law

A group of business associations challenged a Minnesota law that prohibits employers from taking adverse action against employees who decline to attend meetings or receive communications about religious or political matters. The law also requires employers to post a notice of employee rights and directs the Commissioner of the Department of Labor and Industry to develop an educational poster about these rights. The plaintiffs sued the Minnesota Attorney General, the Commissioner, and the Governor, seeking to prevent enforcement of the law. The Attorney General and Commissioner both declared that they had not enforced, nor intended to enforce, the law. The Governor, who was added as a defendant after making public statements about the law, also had no direct enforcement role.The United States District Court for the District of Minnesota denied the defendants’ motion to dismiss, which was based on state sovereign immunity under the Eleventh Amendment. The court found that the Governor’s public statements and removal power over the Commissioner, as well as the Commissioner’s duties under the law, were sufficient to allow the suit to proceed under the Ex parte Young exception to sovereign immunity. The court also found that the Attorney General’s statutory enforcement authority was enough to keep him in the case, despite his declaration of no present intent to enforce the law.The United States Court of Appeals for the Eighth Circuit reversed. It held that the Governor’s administrative powers, such as appointing or removing the Commissioner, were too attenuated from enforcement to make him a proper defendant under Ex parte Young. The Commissioner’s role in developing an educational poster was deemed ministerial, not enforcement-related. As for the Attorney General, the court found that his sworn declaration of no present intent to enforce the law deprived the plaintiffs of standing. The court ordered dismissal with prejudice as to the Governor and Commissioner, and without prejudice as to the Attorney General. View "MN Chapter of Assoc. Builders v. Ellison" on Justia Law

Medtronic, a medical device company, allocated profits from its class III devices and leads among its U.S. and Puerto Rico subsidiaries through intercompany licensing agreements. The dispute centers on the appropriate method for determining arm’s length royalty rates for intangible property transferred between Medtronic US and Medtronic Puerto Rico for the 2005 and 2006 tax years. The Internal Revenue Service (IRS) challenged Medtronic’s use of the comparable uncontrolled transaction (CUT) method and instead applied the comparable profits method, resulting in a tax deficiency. Medtronic contested the IRS’s adjustment, leading to litigation.The United States Tax Court initially rejected both parties’ proposed methods and conducted its own valuation, ultimately favoring a modified CUT method based on a patent-licensing agreement with Siemens Pacesetter, but with adjustments. The Tax Court’s decision was vacated by the United States Court of Appeals for the Eighth Circuit in Medtronic, Inc. & Consolidated Subsidiaries v. Commissioner, 900 F.3d 610 (8th Cir. 2018), which remanded for additional factual findings regarding the best transfer pricing method. On remand, the Tax Court abandoned the CUT method, rejected the Commissioner’s comparable profits method, and adopted a three-step unspecified method, resulting in a new profit allocation and tax deficiencies for Medtronic.The United States Court of Appeals for the Eighth Circuit reviewed the Tax Court’s decision, holding that the Tax Court erred in using the Pacesetter Agreement under both the CUT and unspecified methods because the intangible property involved did not have similar profit potential. The Eighth Circuit also found that the Tax Court applied incorrect legal standards and made insufficient factual findings regarding the comparable profits method, asset bases, functions, and product liability risks. The Eighth Circuit vacated the Tax Court’s order and remanded for further proceedings consistent with its opinion. View "Medtronic, Inc, etc. v. CIR" on Justia Law

Anthony Browne was convicted in Iowa in 1991 of willful injury causing serious injury, a Class C forcible felony, and criminal gang participation, a Class D felony. After completing his sentence in 1998 and maintaining a law-abiding life, Browne sought to possess firearms for hunting, target shooting, and home defense. Iowa law prohibits felons, especially those convicted of forcible felonies, from possessing firearms or obtaining a permit to acquire a handgun, and does not allow restoration of firearms rights for such individuals except through a gubernatorial pardon.Browne filed suit in state court against the Governor of Iowa and the Sheriff of Johnson County, arguing that the statutory prohibition on restoration of firearms rights for forcible felons violates the Second Amendment as applied to him. The defendants removed the case to the United States District Court for the Southern District of Iowa. Browne requested a declaratory judgment that the statute is unconstitutional, and injunctions against enforcement and denial of a handgun permit without an individualized determination of dangerousness. The district court dismissed Browne’s federal claim for failure to state a claim, finding the statute constitutional, and remanded his state constitutional claim to state court.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The appellate court held that Browne had standing because applying for restoration or a permit would be futile under current law. On the merits, the court affirmed the district court’s dismissal, holding that Iowa’s lifetime prohibition on firearm possession by forcible felons, subject to the possibility of a gubernatorial pardon, is consistent with the Nation’s historical tradition of firearms regulation and does not violate the Second Amendment. The judgment of the district court was affirmed. View "Browne v. Reynolds" on Justia Law

Randolph Jay Forrest worked at a used car dealership in Iowa from 2012 to 2021, where he and the owners engaged in a scheme to roll back odometers on dozens of vehicles, alter their titles, and resell them without disclosing the true mileage. After the scheme was discovered, Forrest was indicted on multiple counts, including odometer tampering, mail fraud, and wire fraud. He ultimately pled guilty to one count of wire fraud under a plea agreement, which required him to pay full restitution to all victims harmed by his conduct.The United States District Court for the Northern District of Iowa was tasked with determining the appropriate amount of restitution. Several methodologies were presented: Forrest’s expert suggested calculating loss based on average vehicle value using industry guides, resulting in a total loss of $38,070; the probation office recommended a 40% loss valuation, totaling $76,690; and the government proposed using either the total purchase price paid by victims or the estimated profit from the scheme. The government’s expert, Howard Nusbaum, calculated loss based on the diminished use value of the vehicles, considering the impact of branded titles and misrepresented mileage, arriving at a total loss of $140,178.56. The district court adopted Nusbaum’s methodology, finding it reasonable and supported by the evidence, and rejected Forrest’s arguments regarding salvage value and the reliability of purchase prices.On appeal, Forrest challenged the district court’s adoption of Nusbaum’s methodology, arguing it was insufficiently individualized and did not account for the actual value retained by purchasers. The United States Court of Appeals for the Eighth Circuit reviewed the restitution award for abuse of discretion and clear error. The court held that the district court did not abuse its discretion or clearly err in its loss estimation, given the complexity of the scheme and the evidence presented. The judgment of the district court was affirmed. View "United States v. Forrest" on Justia Law