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

The Eighth Circuit affirmed the district court's dismissal of plaintiff's 42 U.S.C. 1983 action alleging that investigating officers had violated his constitutional rights. After spending more than 10 years in prison, plaintiff was released when new evidence suggested that he was not the driver of a vehicle that caused a fatal accident.In regard to plaintiff's reckless-investigation claims, the court concluded that, even if the trooper could have conducted a more thorough investigation, there is no evidence that he recklessly or purposefully ignored eyewitnesses. Furthermore, failing to locate an unavailable witness does not qualify as recklessly or purposefully ignoring evidence. Nor did the trooper's failure to ask additional questions at the scene shock the conscience. The court also concluded that the officers' decision to leave the vehicle at a local impound lot also did not rise to the level of reckless or purposeful misconduct. Finally, because plaintiff failed to establish a constitutional violation, his remaining claims also fail. View "Engesser v. Fox" on Justia Law

The Eighth Circuit affirmed defendant's sentence for distributing a controlled substance near a protected location resulting in death and of possession with intent to distribute a controlled substance near a protected location. The court concluded that the district court did not err by denying defendant's motion to suppress statements made to law enforcement where defendant's statements were consensual and he was never seized or detained. In this case, an officer's statement to "just kinda stay here" was not a seizure or a significant restraint on his movement, and latter statements to stay outside the apartment were made to assure the officer and defendant did not get in the way of medical staff and did not amount to a detention. The court explained that none of the other factors suggest that defendant's encounter had ripened into a seizure or custodial arrest. Even if the court assumed that defendant was seized and in custody at the police station, it is clear from the totality of the circumstances that defendant voluntarily waived his Miranda rights.The court also concluded that the district court did not abuse its discretion by denying defendant's request for a lesser-included-offense jury instruction of possession of heroin for Count II, in addition to distribution of heroin; there was sufficient evidence to support defendant's conviction; and the elements necessary to apply the concurrent sentence doctrine are present in this case. View "United States v. Parker" on Justia Law

After the district court denied defendant's motion to suppress video recordings discovered on his laptop, defendant pleaded guilty conditionally to one count of receiving child pornography and unconditionally to one count of wire fraud.The Eighth Circuit concluded that probable cause combined with exigent circumstances justified the warrantless seizure of defendant's laptop. In this case, the investigators had probable cause to believe the laptop contained evidence of a crime based on an interview with defendant's uncle; the investigators had an objectively reasonable belief that exigent circumstances demanded the seizure; and the fifteen-day delay between seizure and application for the search warrant was not unreasonable. The court also concluded that, even under de novo review, the district court provided an adequate explanation of defendant's within-guidelines-range sentence. The court further concluded that the district court did not rely on clearly-erroneous facts in setting the sentence. However, the imposition of certain special conditions concerning computer use, contact with persons under the age of 18, and participation in sex-offender treatment are vacated and remanded so that the district court may conduct the requisite "individualized inquiry" and make sufficient findings on the record. Furthermore, the special condition concerning possession of use of sexually oriented materials is also remanded to permit the district court to amend its written judgment to conform to its oral pronouncement at sentencing. View "United States v. Mays" on Justia Law

The Eighth Circuit granted the petition for writ of mandamus directing the district court to reinstate petitioner's demand for a jury trial. In this case, the United States filed suit against petitioner and her ex-husband seeking an avoidance of allegedly fraudulent transfers of funds, claiming that petitioner received assets from her spouse through a "sham divorce." The court concluded that petitioner has no other adequate means to attain the relief desired; petitioner has a clear and indisputable right to a jury trial; and the remedy sought is at least partially legal. Accordingly, the court directed the district court to reinstate petitioner's demand for a jury trial. View "In re: Lorraine Brazile" on Justia Law

After plaintiff admitted to using fentanyl at work, he was terminated from his position as a certified nurse anesthetist at Mid-Missouri. Plaintiff then submitted claims for short- and long-term disability benefits to Kansas City Life, which issued disability insurance policies to Mid-Missouri as part of its employee benefit plan.The Eighth Circuit affirmed the the district court's conclusion that Kansas City Life had abused its discretion in denying plaintiff benefits under the Employee Income Security Act of 1974 (ERISA). The court concluded that Kansas City Life's denial of benefits is not supported by substantial evidence where reasonable minds could not reconcile Kansas City Life's position that plaintiff was unable to safely administer anesthesia on October 6, 2017, with its position that he had safely administered anesthesia while under the influence of fentanyl during the time period between his relapse and termination. Therefore, the evidence that plaintiff made no medical errors and did not seek treatment until after he was terminated, as well as the fact that the record does not disclose his exact date of disability, could not support Kansas City Life's conclusion that plaintiff was not disabled before his insurance coverage ended. View "Bernard v. Kansas City Life Insurance Co." on Justia Law

Plaintiff sought life and accidental death benefits under her brother's insurance plan after he died in a single-vehicle crash. Unum Life paid plaintiff life insurance benefits, but denied her claim for accidental death benefits. Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA).The Eighth Circuit reversed the district court's grant of summary judgment for plaintiff, concluding that the administrator's decision was supported by substantial evidence. The court explained that the evidence is sufficient to support a reasonable finding that the brother's speeding and improper passing contributed to the crash; the crime exclusion applies to "accidental losses;" and Unum Life's interpretation of the "crime" exclusion was reasonable because the brother's conduct constituted a crime under Missouri law. In this case, the brother was driving more than twice the legal speed limit and passing vehicles in a no-passing zone on a two-lane road in icy road conditions. Furthermore, Missouri's classification of improper passing and speeding as misdemeanor offenses reinforces the reasonableness of Unum Life's determination. View "Boyer v. Schneider Electric Holdings, Inc." on Justia Law

The Eighth Circuit reversed the district court's denial of defendant's motion for summary judgment in an action brought by DeJuan Bison's family after DeJuan committed suicide by hanging himself in a cell after being transferred from the St. Louis City Justice Center to the City of Jennings Detention Center. Plaintiffs alleged that defendant was an officer who failed to notify detainee intake personnel with the City that Brison was suicidal when St. Louis transferred Brison into the City's custody.The court concluded that defendant did not violate any clearly established right where she was not required to second-guess a mental health professional's judgment as to the substantiality of a suicide risk. The court explained that a mental health professional had determined that DeJuan was not suicidal and his classification as under Close Observation was, in an of itself, indicative of the absence of suicide risk. View "Perry v. Adams" on Justia Law

The Eighth Circuit affirmed the bankruptcy court's grant of summary judgment in favor of debtors in an action brought by Lund-Ross, seeking to determine the dischargeability of a debt it alleges debtors owe. The court concluded that Lund-Ross's legal theory for the recovery of a debt from debtors personally and the probative evidence Lund-Ross would offer in support of that theory were absent from the summary judgment record before the bankruptcy court. In this case, there is no dispute Lund-Ross did not plead that the corporate veil should be pierced, and it did not argue the corporate veil should be pierced when contesting debtors' motion for summary judgment; Lund-Ross did not allege specific facts that demonstrate debtors used Signature Electric or D & J Electric to commit fraud, violate a legal duty, or perpetrate a dishonest or unjust act in contravention of the rights of another; and Lund-Ross did not identify any state statute or other nonbankruptcy law that would govern debtors' actions as principals of Signature Electric and create a personal debt to Lund-Ross.Because Lund-Ross did not first demonstrate for the bankruptcy court how it could establish a personal debt owed by debtors under nonbankruptcy law, the court, like the bankruptcy court, did not reach the issue of whether such a debt would be nondischargeable under 11 U.S.C. 523(a)(2)(A). View "Lund-Ross Constructors, Inc. v. Buchanan" on Justia Law

During a search of plaintiff's home, police seized a large number of coins and gave them to the IRS where an IRS agent deposited the coins at their face value into an IRS account and later remitted the amount to plaintiff. Plaintiff filed suit under the Federal Tort Claims Act (FTCA) for conversion, contending that the coins were collectors' items. The district court agreed with plaintiff and awarded her $94,880.The Eighth Circuit reversed and concluded that the district court erred when it concluded that the FTCA had waived the government's sovereign immunity to suit in the current circumstances. The court concluded that the agent's decision to deposit the coins for processing rather than preserve them was a discretionary decision and the agent was not required to first investigate whether the coins had collectors' value. Furthermore, the agent's choice to treat the coins as ordinary currency was based on relevant policy considerations. Therefore, the discretionary function exception applies and the government has not waived its sovereign immunity. View "Willis v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of Defendant Hanel and Clark's motions to suppress all evidence obtained during a traffic stop. The court concluded that, at the time the officers initiated the traffic stop, they had grounds for reasonable suspicion that the vehicle lacked proper registration in violation of Nebraska law. In this case, although the officers cited the lane change as their reason for stopping the vehicle, they already had an objective basis to stop it when the first two NCIC searches failed to indicate proper registration.The court noted that its holding should not be interpreted as justifying all warrantless vehicle stops based on ambiguous results from data searches. Rather, the court emphasized that its holding depends on the express factual findings that: (1) the NCIC database was not inherently unreliable; (2) the officers were competent in the use of their laptop; and (3) the officers were competent in accessing the NCIC database. View "United States v. Hanel" on Justia Law