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

Engineered Sales filed suit against Endress, alleging a violation of the Minnesota Termination of Sales Representatives Act. At issue is whether the Act, as amended in 2014, applies to their contractual relationship.The Eighth Circuit reversed and remanded the district court's ruling as to whether Endress had "good cause" and otherwise violated the Act in its termination of the agreement. The court held that Engineered Sales continued to solicit orders with Endress's "consent or acquiescence" after August 1, 2014, and thus the parties' agreement was renewed after August 1, 2014, making the anti-waiver provision applicable to its terms. The court also held that the parties' Indiana choice-of-law provision would allow Endress to circumvent the requirements of the Act in this case, and thus the provision is void and unenforceable under Minn. Stat. 325E.37, subd. 7. View "Engineered Sales, Co. v. Endress + Hauser, Inc." on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of a firearm. The court held that, in light of the totality of the circumstances, the officer had reasonable suspicion that defendant and his companion were the assailants described in a 911 call so as to have justification to stop them in the first place. In this case, defendant and his companion were two men, they matched the generic description of the assailants, they were in close temporal and geographical proximity to the crime, their clothing partly matched the assailants' clothing, and they were walking away from the crime scene. Having concluded that reasonable suspicion existed to justify the stop, the court had no trouble concluding further that reasonable suspicion existed to justify the frisk. View "United States v. Slater" on Justia Law

After Drake University and its Board of Trustees expelled plaintiff for sexually assaulting a female student, plaintiff filed suit for violations of Title IX and the Americans with Disabilities (ADA), as well as claims related to breach of contract. On appeal, plaintiff challenges the district court's grant of summary judgment on his Title IX claim based on an erroneous outcome theory, his ADA claim, and his breach of implied duty of good faith and promissory estoppel claims.After determining that the court had jurisdiction to review plaintiff's appeal, the court held that there is no genuine dispute of material fact regarding whether being male was a motivating factor for plaintiff's expulsion from Drake; Drake's Code of Student Conduct and Policy on Sexual and Interpersonal Misconduct processes, although not equivalent to those provided in nonacademic settings, are not reflective of gender bias, either in statement or in application; the hearing panel did not reach decisions contrary to the weight of the evidence; and the pressure that was being put on Drake to investigate and adjudicate Title IX complaints by females against males does not appear to have approached that described in Doe v. University of Arkansas-Fayetteville, 974 F.3d at 865, nor was it combined with the clearly irregular investigative and adjudicative processes that were found to support a prima facie claim of sex discrimination in Doe v. Columbia University, 831 F.3d at 56-57, and in Menaker v. Hofstra University, 935 F.3d 20, 35 (2nd Cir. 2019).The court rejected plaintiff's ADA claim and affirmed the district court's ruling that no genuine issue of material fact existed regarding plaintiff's need for accommodations. Finally, the court held that the district court did not err in granting summary judgment on plaintiff's claims for breach of implied duty of good faith and promissory estoppel. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Drake and remanded with instructions to dismiss with prejudice the claims that had previously been dismissed without prejudice by stipulation. View "Rossley v. Drake University" on Justia Law

The Eighth Circuit affirmed defendant's conviction for five controlled substance offenses. The court held that the evidence was sufficient to support defendant's convictions for conspiring to distribute crack and heroin and distribution of heroin; defendant's Batson challenge failed because the government offered race-neutral reasons for its peremptory strike and the district court did not clearly err in finding that defendant failed to establish that the government's combination of reasons was pretextual; and there was no error in answering the jury's question for clarification of the term "on or about" and there was no abuse of the district court's substantial discretion in formulating jury instructions. View "United States v. Stevenson" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to one count of being a felon in possession of a firearm. The court held that the district court did not err by applying an enhanced offense level pursuant to USSG 2K2.1(a)(2) based on prior state convictions for a crime of violence and a controlled substance offense. In this case, defendant's prior conviction for threatening to commit a crime which will result in death or great bodily injury to another person, in violation of California Penal Code 422(a), qualified as a crime of violence because the statute's elements necessarily include a threatened use of physical force capable of causing physical pain or injury to another person. The court rejected defendant's contention that his prior California conviction for possession of marijuana for sale does not qualify as a controlled substance offense due to California's reclassification of his conviction. The court has repeatedly rejected similar arguments to the federal effects of state classification. View "United States v. Doran" on Justia Law

The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm. The court held that the district court did not err by denying defendant's motion to suppress where police entry into the residence in response to the call for medical aid for a shooting victim was not constitutionally objectionable.In this case, given the fact of a shooting and the other information known to officers at the time, exigent circumstances made it permissible to look into other rooms to ensure the absence of a shooter or additional victims. Furthermore, the officers almost immediately saw ammunition and suspected narcotics in plain view; officers were permitted to secure the exterior of the residence for the same reasons; and, to the extent defendant takes issue with the officers looking on the adjacent property, any objects found there were abandoned. The court concluded that defendant's arguments do not merit relief where the officers were not "lingering" or "frolicking" in a manner inconsistent with a security sweep. Moreover, no information gleaned through lingering in the home, or re-entering after the ambulance departed, aided in securing the search warrant. Finally, the court held that the district court did not clearly err by finding that defendant possessed the firearms in connection with another felony under USSG 2K2.1(b)(6)(b). View "United States v. Crutchfield" on Justia Law

Minnesota law dictates that election officials only count ballots received by election day. The Minnesota Alliance for Retired Americans Education Fund filed suit against the Secretary, alleging that Minnesota's statutory deadline was unconstitutional. The Secretary and the Alliance entered into a consent decree that essentially made the statutorily-mandated absentee ballot receipt deadline inoperative. After the Minnesota state court confirmed the decree, the Secretary directed election officials to count absentee ballots received up to a week after election day, notwithstanding Minnesota law.Plaintiffs, both Minnesota registered voters and also certified nominees of the Republican Party to be presidential electors, filed suit alleging that the consent decree and the state court's order confirming it violate the United States Constitution. The district court denied plaintiffs' requested injunction, concluding that they lack standing to bring their claims.The Eighth Circuit reversed the district court's denial of the preliminary injunction and remanded to the district court to enter an injunction requiring the Secretary and those under his direction to identify, segregate, and otherwise maintain and preserve all absentee ballots received after the deadlines set forth in Minn. Stat. 203B.08, subd. 3.After determining that plaintiffs have Article III and prudential standing to bring their claims, the court considered plaintiffs' constitutional challenge to evaluate the propriety of preliminary injunctive relief rather than remanding for the district court to decide the merits in the first instance. The court held that the Secretary's instructions to count mail-in ballots received up to seven days after Election Day stand in direct contradiction to Minnesota election law governing presidential elections, and plaintiffs have strongly shown likely success on the merits since the Secretary's actions are likely to be declared invalid under the Electors Clause of Article II of the United States Constitution. The court stated that only the Minnesota Legislature, and not the Secretary, has plenary authority to establish the manner of conducting the presidential election in Minnesota. The court also held that the Secretary's plan to count mail-in ballots received after the deadline established by the Minnesota Legislature will inflict irreparable harm to plaintiffs. Furthermore, the balance of the equities and the public interest weigh in favor of the issuance of an injunction. Finally, the court held that the injunction does not violate the Purcell principle. View "Carson v. Simon" on Justia Law

The Eighth Circuit affirmed defendant's conviction for extortion, attempted extortion, and receipt of a firearm with intent to commit a felony. Defendant's convictions stemmed from the use of his official position on the Tri-County Drug Task Force to obtain an ATV and firearms from confidential informants. The court held that there was sufficient evidence to convict defendant of the charges.The court also held that the district court did exactly what it should have done after receiving unsolicited, case-related messages from a family member, and thus the district court did not err, plain or otherwise, by failing to sua sponte recuse the judge at sentencing. In this case, while the court did not know why the district judge's brother was interested in the case (nor did the district court), nothing in the text messages disclosed by the district judge revealed any favoritism or antagonism by the judge. Furthermore, none of the parties observed any potential issues or objected. View "United States v. Chastain" on Justia Law

Plaintiff filed suit against his arresting officers and others, alleging claims under 42 U.S.C. 1983 and the Fourth Amendment, after the officers seized him without probable cause.The Eighth Circuit held that the evidence, viewed in the light most favorable to plaintiff, would support a finding that the arresting officers violated plaintiff's clearly established right to be free from an unreasonable seizure without probable cause under the circumstances. In this case, about seven minutes after a black juvenile male with a gun fled from police in Kansas City, officers arrested plaintiff a mile away from the scene. Plaintiff and the suspect shared only generic characteristics in common: black, juvenile, and male. However, plaintiff had several characteristics distinct from the suspect: he was taller than the suspect; had distinguishable hair from the suspect; and wore shorts, shoes, and socks that differed from those donned by the suspect. Furthermore, these distinctions are depicted on a police video recording that the arresting officers reviewed. Plaintiff was in custody for three weeks before a detective reviewed the video and concluded that plaintiff was not the offender. Therefore, the district court erred in granting qualified immunity to the arresting officers where no reasonable officer could have believed that probable cause existed to arrest plaintiff based on the plainly exculpatory evidence available to them. The district court affirmed the district court's grant of summary judgment to the remaining defendants and remanded for further proceedings. View "Bell v. Neukirch" on Justia Law

A noncitizen who enters this country without inspection or admission, but who later receives Temporary Protected Status (TPS), may adjust her status to Lawful Permanent Resident because a TPS recipient is deemed inspected and admitted for purposes of 8 U.S.C. 1255(a).The Eighth Circuit held that section 1254a(f)(4) provides that TPS recipients "shall be considered as being in, and maintaining, lawful status as a nonimmigrant" for purposes of adjusting their status under section 1255. The court explained that those in nonimmigrant status are necessarily inspected and admitted. By operation of section 1254a(f)(4), then, TPS recipients are considered "inspected and admitted" under section 1255(a), regardless of whether they entered the United States without inspection. Therefore, USCIS's contrary interpretation conflicts with the plain meaning of the INA and is therefore unlawful. View "Velasquez v. Barr" on Justia Law