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

Plaintiff filed suit against HealthEast and others, alleging multiple causes of action related to peer review determinations stemming from his practice of neurosurgery. After the district court granted defendants' motion for judgment on the pleadings, three claims remained against appellees: defamation, tortious interference with prospective economic relationship, and tortious interference with contract. Appellees moved for summary judgment on the remaining claims and the district court granted their motion.As to the defamation claims, the Eighth Circuit concluded that only three statements are before the court on appeal because plaintiff did not amend his complaint to incorporate the additional allegedly defamatory statements identified during discovery and, given the requirement that defamation claims be pleaded with specificity, only the statements included in the amended complaint can form the basis of plaintiff's claim. As to the first remaining statement, the court concluded that it was waived. In regard to the two remaining statements, the court concluded that Minnesota peer review immunity applies.As to the tortious interference claims, the court concluded that to the extent these alleged interferences occurred solely through the peer review process itself, appellees are entitled to peer review immunity. In the event peer review immunity does not fully shield appellees, these claims failed on the merits. Accordingly, the district court properly concluded that appellees were entitled to summary judgment on all of plaintiff's claims, and the court affirmed its judgment. View "Sherr v. HealthEast Care System" on Justia Law

Petitioner, an Arkansas prisoner under a sentence of death for capital murder, petitioned for habeas corpus in the federal district court. In a previous appeal, the Eighth Circuit affirmed the dismissal of several claims, but remanded for further proceedings on four claims alleging ineffective assistance of counsel under the Sixth Amendment. The court also remanded for further proceedings on petitioner's claim that he is ineligible for the death penalty, due to intellectual disability, under the Eighth Amendment and the rule of Atkins v. Virginia, 536 U.S. 304 (2002). On remand, the district court rejected the Atkins claim, but granted relief on two of the ineffective-assistance claims and set aside petitioner's sentence. Both parties appealed.The Eighth Circuit reversed the grant of relief based on alleged ineffective assistance of counsel. In this case, petitioner's federal claim that trial counsel failed to obtain a timely psychological evaluation of him was presented in the state postconviction court and defaulted when he declined to appeal on that ground. As such, the procedural default cannot be excused based on alleged ineffectiveness of state postconviction counsel. Likewise, the third claim cannot be excused based on alleged ineffectiveness of state postconviction counsel. The court affirmed the denial of relief under the Eighth Amendment, concluding that the district court considered the Atkins claim under both the DSM-IV-TR and DSM-V criteria, reached the same conclusion based on each, and thus there was no legal error. The court rejected petitioner's remaining challenges to the district court's analysis of his intellectual functioning, including additional indicia of intellectual disability, expert and witness testimony, adaptive strengths and weaknesses, and adaptive functioning deficits. View "Sasser v. Payne" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence seized from her lockbox in an action where she pleaded guilty to possession with intent to distribute a controlled substance. In this case, the search warrant was for evidence of drug use and distribution. Furthermore, officers saw defendant on the couch, asleep, with a meth pipe next to her. The court concluded that this was enough to give officers particularized suspicion that defendant was connected to the illicit activity that provided the basis for the warrant. The court explained that, while defendant had a reasonable expectation of privacy in the lockbox, officers had probable cause that she was involved in the criminal activity that formed the basis for the warrant. Therefore, defendant's lockbox fell within the scope of the warrant and searching it was lawful. View "United States v. Simmermaker" on Justia Law

Hallmark filed a declaratory judgment action contending that it did not breach the insurance policy or act in bad faith when adjusting Phoenix's claims stemming from a fire on Phoenix's property. Phoenix asserted three counterclaims. The district court granted Hallmark's motion in its entirety and granted Phoenix's motion in part. Phoenix appealed.The Eighth Circuit affirmed the district court's judgment in favor of Hallmark on Phoenix's claims for bad faith and Hallmark's claim for declaratory judgment. The court concluded that Hallmark had an objectively reasonable basis for denying Phoenix's demand and limiting its payment to $28,774.34 on January 9, 2018. Furthermore, to the extent that HSNO's report included any inaccuracies, an imperfect investigation, standing alone, is not sufficient cause for recovery if the insurer in fact has an objectively reasonable basis for denying the claim. The court also found that there was a reasonable basis for Hallmark to deny Phoenix's demand for an additional $124,800 in October 2017, and Hallmark had an objectively reasonable basis for denying Phoenix's bad faith claim for equipment loss and repair. Because summary judgment was appropriate on Phoenix's bad faith claim, the court explained that it follows that summary judgment was appropriate on Hallmark’s declaratory judgment claim. Finally, Phoenix's punitive damages claim is moot. View "Hallmark Specialty Insurance Co. v. Phoenix C & D Recycling, Inc." on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for unlawfully distributing methamphetamine and of conspiring to distribute it. The court concluded that, viewed in the light most favorable to the verdict, a single conspiracy existed. Furthermore, even if a variance occurred, reversal is warranted only if it infringes on defendant's substantial rights. In this case, defendant raised neither notice nor double-jeopardy concerns, only asserting a spillover of evidence from one conspiracy to another. The court concluded that the evidence of defendant's participation in one conspiracy would have been probative of his intent to participate in the other and was therefore admissible. Furthermore, the jury instructions also reduced any risk of prejudice. The court also concluded that there was no error in admitting statements under the coconspirator exception because they were not in furtherance of the conspiracy, in not separately polling a juror, and in calculating drug quantity. View "United States v. Sims" on Justia Law

Plaintiffs, ten former University of Minnesota football players, appealed the dismissal of their Amended Complaint against the University and two University officials, asserting a variety of claims arising out of the University’s investigation of a complaint of sexual assault and harassment by another student, Jane Doe. Plaintiffs are African-American males who alleged that the University targeted them on the basis of their sex and race and unfairly punished them in response to Jane's accusations. The district court dismissed all claims.The Eighth Circuit concluded that plaintiffs' complaint alleged a number of circumstances which, taken together, are sufficient to support a plausible claim that the University discriminated against plaintiffs on the basis of sex. In this case, plaintiffs alleged that the University was biased against them because of external pressures from the campus community and the federal government, and plaintiffs alleged historical facts that reinforce the inference of bias in this specific proceeding. Therefore, the court reversed the district court's dismissal of plaintiffs' Title IX discrimination claims.The court affirmed the district court's dismissal of the Title IX claims for retaliation where plaintiffs did not plausibly allege that their request for a Student Sexual Misconduct Subcommittee hearing was tantamount to a complaint of sex discrimination, and even if a request for a hearing made by a person accused of sexual misconduct could amount to protected activity, the Amended Complaint did not plausibly plead prima facie retaliation claims. The court also affirmed the dismissal of the race discrimination claims where the Amended Complaint did not plausibly allege a comparator similarly situated to plaintiffs in all relevant aspects; affirmed the dismissal of plaintiffs' due process claims where plaintiffs failed to exhaust the existing procedures for appealing the University's disciplinary decision and failed to allege prehearing deprivations or deprivation of protected property or liberty interests in violation of due process; and affirmed the dismissal of the contract and negligence claims on Eleventh Amendment grounds. View "John Does 1-2 v. Regents of the University of Minnesota" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's motion to recuse the district court judge in petitioner's 28 U.S.C. 2254 motion for habeas relief and denial of his application for a certificate of appealability (COA) on three of his habeas corpus claims. Petitioner was found guilty of first-degree murder for killing an officer and sentenced to death. In this case, petitioner concedes that the judge left the Missouri Supreme Court before his case was briefed, argued, or decided. Furthermore, in reviewing petitioner's habeas petition, the judge never had to review any of his past state court rulings.The court concluded that a knowledgeable, reasonable person would not question the judge's impartiality as he took no part in the consideration of petitioner's state appeal. Furthermore, the judge's prior dissent in an unrelated case while a member of the Missouri Supreme Court did not require his recusal from petitioner's federal habeas case where there was no evidence of pervasive personal bias and prejudice against petitioner. Finally, the court declined to disturb the prior administrative panel's denial of petitioner's application for a COA. View "Johnson v. Steele" on Justia Law

Plaintiffs filed suit against CCMC, alleging that CCMC failed to obtain the proper construction permit under the Clean Air Act (CAA), and failed to implement the requisite dust control plan for the Coyote Creek Mine, which is adjacent to plaintiffs' ranch. The district court granted summary judgment in favor of CCMC, concluding the federal regulations imposing permitting and dust control requirements do not apply to CCMC's operations.The Eighth Circuit affirmed the district court's grant of summary judgment for CCMC and agreed with the district court that the regulations, standing alone, are ambiguous. The court also concluded that the most reasonable interpretation of the relevant regulations is that the coal pile is not "in" CCMC's coal processing plant. Therefore, the district court did not err in granting summary judgment to CCMC on the basis that the coal pile is not subject to Subpart Y regulations, which would have required a major source permit and a fugitive dust control plan. View "Voigt v. Coyote Creek Mining Co., LLC" on Justia Law

The Eighth Circuit affirmed the district court's sua sponte grant of judgment as a matter of law to defendants in an action brought by plaintiff against prison officials, alleging that they failed to protect him from his fellow inmates after he was labeled a snitch.Even assuming the court agreed with plaintiff that Federal Rule of Civil Procedure 50(a) requires a motion, the court did not think that requirement is clear or obvious under its case law. The court concluded that the district court did not err in directing a verdict in favor of the five defendants who were not on the Classification Committee. In this case, plaintiff cannot show that defendants acted with deliberate indifference by entrusting the decision to the Classification Committee—the prison's selected arbitrator. The court explained that, even if they disagreed with the choice, there is nothing to suggest that four of the defendants had any power to circumvent the ruling of the Classification Committee and it was a close call with the fifth defendant. Finally, the court concluded that the district court did not abuse its discretion by denying plaintiff's motions for continuance by ensuring an expeditious disposition of the case and while affording significant time to allow plaintiff to prepare. View "Axelson v. Watson" on Justia Law

The Eighth Circuit reversed and vacated the district court's permanent injunction enjoining plaintiff from litigating claims against 3M in Texas state court, where he had filed suit three years earlier. The parties had previously agreed to dismiss with prejudice similar claims that plaintiff brought against 3M in a multidistrict litigation (MDL) in federal court. The district court concluded that this previous dismissal had preclusive effect in the Texas case, authorizing it to enjoin the state court proceedings under the relitigation exception to the Anti-Injunction Act.Applying Texas choice-of-law principles and Texas substantive law, the court concluded that it is evident that the stipulated dismissal with prejudice in plaintiff's MDL case was simply an agreement to dismiss and was therefore not a final judgment on the merits. Accordingly, plaintiff's claims in Texas state court are not precluded under Texas law. Because plaintiff's state law claims were not previously presented to and decided by the federal court, the relitigation exception of the Anti-Injunction Act has no effect in this case. View "Petitta v. 3M Company" on Justia Law