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

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

In January 2019, Robert Wolter robbed a bank in Bismarck, North Dakota, taking approximately $6,800. He was later arrested in February 2019 for smuggling bulk cash while attempting to fly to Ghana. Those charges were dismissed in February 2020, and he was subsequently arrested for bank robbery. Wolter was arraigned in July 2020. He filed multiple motions to continue the trial, delaying it significantly. He also requested a psychological evaluation, which further delayed proceedings. Wolter eventually moved to dismiss the indictment, claiming his right to a speedy trial was violated under the Speedy Trial Act (STA) and the Sixth Amendment.The United States District Court for the District of North Dakota denied Wolter's motion to dismiss. The court found that most delays were excludable under the STA and that the government did not negligently or intentionally cause delays. The court calculated that only 31 days of non-excludable time counted toward the STA. Regarding the Sixth Amendment claim, the court found no evidence of government misconduct and attributed most delays to Wolter. The court also found no demonstrable prejudice to Wolter due to the delays. Wolter was convicted of bank robbery by a jury in January 2023 and sentenced to 60 months of imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, finding that the delays were either excludable under the STA or attributable to Wolter. The court concluded that only 46 days of non-excludable time counted toward the STA, well below the 70-day limit. Additionally, the court applied the Barker v. Wingo balancing test and determined that Wolter's Sixth Amendment right to a speedy trial was not violated, as the delays were largely due to his own actions and did not result in demonstrable prejudice. View "United States v. Wolter" on Justia Law

David Burke died after falling down retractable steps attached to his motorhome. His estate, wife, and children filed product liability claims against Lippert Components, Inc., and LCI Industries, who had purchased the product brand after the Burkes bought the vehicle. The plaintiffs alleged negligence, design defects, manufacturing defects, and inadequate instructions and warnings. They later sought to add the previous owners of the product brand as defendants and amend the scheduling order, but the district court denied these motions and granted summary judgment in favor of Lippert and LCI.The United States District Court for the Northern District of Iowa denied the plaintiffs' motions to amend the complaint and the scheduling order, citing unreasonable delay. The court then granted summary judgment for Lippert and LCI, finding that they did not manufacture, distribute, or sell the steps in question, and thus were not liable under Iowa law. The plaintiffs appealed these decisions.The United States Court of Appeals for the Eighth Circuit affirmed the district court's rulings. The appellate court held that Lippert and LCI were not required to plead an affirmative defense regarding successor liability, as their defense negated an essential element of the plaintiffs' claims. The court also found that Lippert and LCI did not assume liability through the purchase agreement and that expert testimony was necessary to support the claim of inadequate post-sale warnings. Finally, the court agreed that the plaintiffs failed to show good cause for their delayed motions to amend the complaint and scheduling order. The judgment of the district court was affirmed. View "Burke v. Lippert Components, Inc." on Justia Law

Henry Stursberg, a financial consultant, sued Morrison Sund PLLC, a Minnesota law firm, for allegedly running up legal fees without achieving results. After Stursberg decided to change counsel, Morrison Sund filed an involuntary bankruptcy petition against him. Stursberg sought to dismiss the petition, which the bankruptcy court granted under 11 U.S.C. § 305(a)(1), noting the petition was used improperly to collect fees. Stursberg then filed a diversity action in Pennsylvania, asserting state law tort claims against Morrison Sund.The Eastern District of Pennsylvania dismissed Stursberg’s claims due to lack of personal jurisdiction and improper venue, transferring the case to the District of Minnesota. The Minnesota district court dismissed the state law claims, ruling they were preempted by the Bankruptcy Code, specifically 11 U.S.C. § 303(i), which provides remedies for bad faith filings of involuntary bankruptcy petitions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s dismissal, holding that the federal court that dismisses an involuntary bankruptcy case has exclusive jurisdiction to enforce debtor remedies under § 303(i). The court concluded that Stursberg’s state law claims were preempted by the federal statute, and his failure to appeal the bankruptcy court’s denial of his motion for attorney’s fees and costs under § 303(i)(1) precluded him from seeking further damages. The court emphasized that § 303(i) provides an exclusive remedy for bad faith filings, precluding state law tort claims in this context. View "Stursberg v. Morrison Sund PLLC" on Justia Law

James Hanapel was convicted by a jury of attempting to entice a minor to engage in sexual activity. The case stemmed from an undercover operation during the Sturgis Motorcycle Rally in South Dakota, where a Department of Homeland Security agent posed as a fourteen-year-old girl named "Journey" on a dating app. Hanapel initiated contact with Journey, and after learning her age, he continued to communicate with her, suggesting they meet and engage in sexual activities. Hanapel was arrested when he arrived at the agreed-upon location with condoms.In the United States District Court for the District of South Dakota, Hanapel raised an entrapment defense, arguing that he was induced by law enforcement to commit the crime. The district court denied his motion for judgment of acquittal, and the jury found him guilty. Hanapel was sentenced to 120 months in prison, the statutory minimum. He appealed the conviction, contending that he was entrapped as a matter of law.The United States Court of Appeals for the Eighth Circuit reviewed the case, focusing on whether Hanapel was induced by the government and whether he was predisposed to commit the crime. The court found that Hanapel initiated contact and was the first to suggest sexual activity. The court also determined that the photo sent by the undercover agent was not overly suggestive and did not constitute inducement. Additionally, the court noted that Hanapel's quick agreement to meet and his possession of condoms indicated predisposition. The court concluded that a reasonable jury could reject the entrapment defense and affirmed the district court's judgment. View "United States v. Hanapel" on Justia Law

In November 2018, 16-year-old S.G. was reported missing but returned to her Iowa high school the next day. She told the school resource officer, Matthew Poirier, that she had spent the weekend in Chicago at "Sweat's" father's home, earning money by packaging cocaine. She later admitted to making money through dates but denied engaging in sex acts. S.G. identified Keith Euring, Sr., also known as "Sweat," in a photo lineup. Her statements to medical personnel and police contained inconsistencies, including the amount of money given to Euring and whether she had sex with him. Law enforcement found evidence linking Euring to S.G.'s trips to Chicago, including phone records and hotel bookings.The United States District Court for the Southern District of Iowa indicted Euring on multiple counts, including sex trafficking of a child. At trial, the government presented testimony from S.G. and her clients, as well as cell phone data suggesting Euring's involvement. S.G. testified that Euring facilitated her dates and took a portion of her earnings. The defense attempted to introduce extrinsic evidence of S.G.'s inconsistent statements and the grand-jury testimony of Dr. Muhammad Ali, who had interacted with S.G. during one of her trips. The district court excluded Dr. Ali's testimony and limited the use of extrinsic evidence, ruling that S.G. had not been given the opportunity to explain her statements.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in excluding Dr. Ali's grand-jury testimony, as the government did not have a similar motive to develop his testimony at that stage. The court also upheld the district court's limitation on extrinsic evidence, interpreting Rule 613(b) to require that a witness be given the opportunity to explain or deny prior inconsistent statements. Finally, the court found sufficient evidence to support Euring's conviction for sex trafficking of a child, affirming the district court's decision. View "United States v. Euring" on Justia Law

The case involves several states suing the President of the United States, the Secretary of Education, and the U.S. Department of Education to prevent the implementation of a plan to forgive approximately $475 billion in federal student loan debt. The plan, known as SAVE, significantly alters the existing income-contingent repayment (ICR) plan by lowering payment amounts, often to $0 per month, and forgiving principal balances much sooner than previous plans.The United States District Court for the Eastern District of Missouri granted a preliminary injunction in part, finding that Missouri had standing through its state instrumentality, MOHELA, which faced certain irreparable harm. The court concluded that the states had a fair chance of success on the merits, particularly that loan forgiveness under SAVE was not statutorily authorized and violated the separation of powers under the major-questions doctrine. However, the court only enjoined the ultimate forgiveness of loans, not the payment-threshold provisions or the nonaccrual of interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and agreed with the district court that Missouri had standing. The court found that the states demonstrated a fair chance of success on the merits, noting that the SAVE plan's scope was even larger than a previously contested loan-cancellation program. The court also found that the Government's actions had rendered the district court's injunction largely ineffective. Balancing the equities, the court decided to grant in part and deny in part the states' motion for an injunction pending appeal, prohibiting the use of the hybrid rule to circumvent the district court's injunction. The injunction will remain in effect until further order of the court or the Supreme Court of the United States. View "State of Missouri v. Biden" on Justia Law

In May 2023, Iowa's Governor signed Senate File 496 (SF496) into law, which introduced new regulations for public school libraries, classrooms, and curriculum, and required parental notification for certain gender identity accommodations. Two groups of plaintiffs, including students, authors, and educators, filed lawsuits to enjoin SF496, arguing it violated the First Amendment, the Fourteenth Amendment, and the Equal Access Act. The plaintiffs sought a preliminary injunction to prevent the law's enforcement.The United States District Court for the Southern District of Iowa granted the preliminary injunction, enjoining the enforcement of SF496's provisions related to the removal of books from school libraries and the prohibition of instruction on gender identity and sexual orientation for students in kindergarten through grade six. The court found that the plaintiffs had standing and that the law's enforcement would likely cause irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the district court's analysis was flawed. The appellate court held that the district court did not properly apply the legal standards for facial challenges and failed to consider the law's legitimate applications. The Eighth Circuit also noted that the district court did not adequately address the as-applied challenges raised by the plaintiffs. Consequently, the appellate court reversed the district court's decision, vacated the preliminary injunction, and remanded the case for further proceedings consistent with its opinion. The plaintiffs were allowed to pursue injunctive relief under the correct legal framework and address the unconsidered as-applied challenges. View "GLBT Youth in Iowa Schools Task Force v. Reynolds" on Justia Law

Gabriel White Plume, Sr. was convicted of multiple charges, including witness tampering and assault, following a violent incident involving his girlfriend, CLS. On January 10, 2023, White Plume, while under the influence of alcohol and methamphetamine, assaulted CLS with the help of his friend, Edison Jumping Eagle. White Plume choked CLS, forced her to perform oral sex, and inflicted severe physical injuries, including a deep laceration in her vagina. CLS was treated at a hospital for extensive injuries, including bruises, bite marks, and cigarette burns. White Plume recorded part of the assault, and these recordings were used as evidence at trial.The United States District Court for the District of South Dakota indicted White Plume on nine counts, including sexual assault, assault, witness tampering, and distribution of a controlled substance. A jury convicted him on eight of the nine counts, and he was sentenced to 480 months of imprisonment. White Plume appealed, arguing insufficient evidence for his convictions on witness tampering and assault, and claimed double jeopardy for three of the charges.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found sufficient evidence to support the jury's verdict on witness tampering, noting that White Plume attempted to persuade CLS to recant her statements through his daughter and direct communication. The court also upheld the assault conviction, determining that the evidence of CLS’s substantial bruising was sufficient to meet the statutory definition of substantial bodily injury. Regarding the double jeopardy claim, the court applied the Blockburger test and concluded that each of the three challenged charges required proof of an element not required by the others, thus rejecting the double jeopardy argument. The Eighth Circuit affirmed the district court’s judgment. View "U.S. v. Plume" on Justia Law

The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) issued a final rule reclassifying pistols equipped with stabilizing braces as short-barreled rifles under the National Firearms Act (NFA) and the Gun Control Act (GCA). This reclassification subjects these weapons to stringent regulations. The plaintiffs, including a stabilizing-brace manufacturer, a firearm manufacturer, a gun association, an individual owner, and twenty-five states, challenged the rule, arguing it exceeded the ATF’s statutory authority and was arbitrary and capricious. The district court denied the plaintiffs' motion for a preliminary injunction, leading to this appeal.The United States District Court for the District of North Dakota initially reviewed the case and denied the plaintiffs' request for a preliminary injunction. The court concluded that the plaintiffs did not demonstrate a substantial likelihood of success on the merits of their claims, which included arguments that the rule exceeded the ATF’s statutory authority and was arbitrary and capricious. The plaintiffs then appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the plaintiffs were likely to succeed on the merits of their arbitrary-and-capricious challenge. The court held that the ATF’s rule was arbitrary and capricious because it lacked clear metrics for determining when a stabilizing brace provides sufficient surface area to shoulder a weapon, and the multifactor test used by the ATF was internally inconsistent and inadequately explained. Additionally, the court found that the accompanying slideshows, which classified certain weapons as short-barreled rifles without explanation, further demonstrated the arbitrary nature of the rule. Consequently, the Eighth Circuit reversed the district court’s denial of the preliminary injunction and remanded the case for reconsideration consistent with its opinion. View "Firearms Regulatory Accountability Coalition, Inc. v. Garland" on Justia Law