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

Plaintiffs, six former inmates of the Faulkner County Detention Center, filed suit against the County and two jail employees under 42 U.S.C. 1983, alleging that their conditions of confinement were unconstitutional because of mold in and around the jail's shower.The Eighth Circuit reversed in part and held that the district court erred in denying the individual jail employees summary judgment based on qualified immunity. The court held that the only thing clearly established in this case is that the definition of the asserted constitutional right embraced by the district court — a right to sanitary prison conditions — was impermissibly broad. The court also held that a finding that such a right was clearly established based on this general definition was therefore in error. Because the right at issue has not been properly defined and there are genuine disputes of material fact at play, it is not possible for the court to determine whether the individual officers committed a constitutional violation in the detention center due to the presence of Cladosporium. Finally, the court held that it lacked jurisdiction to reach the County's appeal where the question of whether the County was liable for failing to train its officers is not inextricably intertwined with the matter of qualified immunity. View "Thurmond v. Andrews" on Justia Law

The Eighth Circuit affirmed defendant's conviction for one count of conspiracy to commit an offense against the United States and four counts of health care fraud. The court held that the evidence was sufficient to establish that defendant entered into an agreement with others to create a medical testing lab that made money through illegal kickbacks. The court also held that the evidence was sufficient to establish that members of the conspiracy committed substantive violations and defendant, as a co-conspirator, was properly held liable for these substantive crimes committed in furtherance of the scheme. View "United States v. Golding" on Justia Law

In Al-Saadoon I, the Eighth Circuit affirmed the denial of petitioners' (husband and wife) petitions for naturalization because husband engaged in unlawful employment and thus the couple never lawfully adjusted to permanent resident status. Petitioners then filed a Supplement A to Form I-485 with USCIS to adjust their status to lawful permanent residents nunc pro tunc.The court affirmed the district court's denial of petitioners' requests for nunc pro tunc adjustment to lawful permanent resident status, holding that the district court did not have jurisdiction to review a discretionary denial of an adjustment of status application. The court explained that, because petitioners failed to adjust their status to lawful permanent residents, they cannot meet the requirements for naturalization. To the extent that petitioners attempt to relitigate the determination that they were unlawfully admitted to permanent resident status in 2002, they are barred by res judicata. The court also held that the district court correctly dismissed petitioner's Controlled Application Review and Resolution Program claim. Finally, petitioners' Religious Freedom Restoration Act of 1993 (RFRA) claim fails because they did not assert a claim for relief under RFRA in their petition. View "Al-Saadoon v. Barr" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for receipt or attempted receipt of child pornography. The court held that the district court did not plainly err in admitting images of a female minor relative defendant had uploaded under Federal Rule of Evidence 404(b); in striking an FBI agent's testimony regarding defendant's children; and by permitting the agent to explain why the FBI requested a no-knock warrant.The court also held that the evidence was sufficient to support the jury's verdict convicting him of the knowing receipt of child pornography, as opposed to the lesser included offense of knowing access of child pornography. Finally, the court held that defendant's below-Guidelines sentence of 110 months' imprisonment was not substantively unreasonable where the district court did not abuse its discretion in sentencing defendant. View "United States v. Croghan" on Justia Law

The Eighth Circuit affirmed defendant's conviction for conspiring to violate federal health care laws and eleven counts of health care fraud. Defendant's conviction stemmed from his involvement in a health care fraud scheme involving AMS, an entity that provided medical testing of blood, urine, and other specimens.The court held that the evidence was sufficient to establish that defendant voluntarily and intentionally participated in the conspiracy with knowledge that his plan to receive kickback payments and defraud Medicare was unjustifiable and wrongful. In this case, the evidence of defendant's significant experience within the health care industry combined with his attempt to conceal the true terms of his agreement with AMS was enough for the jury to conclude he knew the arrangement was unjustifiable and wrongful when he knowingly became a part of the conspiracy. View "United States v. McTizic" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment on plaintiff's 42 U.S.C. 1983 claim against the City for depriving plaintiff of her constitutional right to a prompt first appearance in a criminal proceeding. Plaintiff alleged that a district court lacks jurisdiction to conduct a first appearance for a defendant who was arrested and charged in a separate county or judicial district.The court held that any Arkansas district court may perform pretrial functions as necessary and as authorized by the Arkansas Rules of Criminal Procedure. Because the Ashley County district judge had jurisdiction and authority to conduct the first appearance, the court held that plaintiff's constitutional claim necessarily fails. Furthermore, because the City discovered new evidence and presented it promptly to the court, the district court did not abuse its discretion in finding the doctrine of equitable estoppel inapplicable here. The court also held that the doctrine of equitable estoppel is not properly invoked here because there has been no showing that the City knew of plaintiff's first appearance before the new evidence was discovered or that the City tried to induce her to act to her detriment. View "Green v. Byrd" on Justia Law

After plaintiff was injured while serving as an engineer for UP when the train he was operating partially derailed because of a misaligned switch, he filed suit under the Federal Employers' Liability Act (FELA), alleging claims of FELA negligence per se and negligence.The Eighth Circuit affirmed the district court's denial of plaintiff's motion for partial summary judgment and grant of UP's motion for summary judgment. In regard to plaintiff's negligence per se claim, the court held that plaintiff failed to present any evidence that would raise a genuine issue of material fact that UP "played any part, even the slightest" to cause the switch to be moved from its designated position. Rather, the evidence showed the switch was misaligned by a criminal act of a third party. Furthermore, there is no evidence in the record that any act of a UP employee contributed to the misalignment. Therefore, UP committed no act violating the regulation requiring switches to be aligned per the railroad's written policy.In regard to the negligence claim, the court held that UP cannot be liable under a negligence theory for failing to properly align the switch unless it knew or had reason to know it was misaligned. In this case, there was no evidence that UP was aware the switch was not properly aligned. Likewise, plaintiff presented no evidence that UP failed to reasonably protect its keys or had reason to know that the security of its keys or locks were compromised; plaintiff proffered no evidence of an industry standard or other evidence that could lead a jury to find UP negligent for failing to remove the switch or track; and plaintiff failed to point to any evidence that would establish that UP was negligent if it failed to install additional or different devices to prevent someone from tampering with the switch. View "Miller v. Union Pacific Railroad Co." on Justia Law

The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm, holding that the district court did not err by denying defendant's motion to suppress evidence under the Fourth Amendment. In this case, the officers discovered the gun in defendant's possession in a routine search incident to his arrest where the officer had a valid arrest warrant and had positively identified defendant before entering the property; the officer could lawfully enter the curtilage to make an arrest with the warrant; and any intrusion on defendant's privacy interest was minimal.The court also affirmed the district court's determination that defendant did not qualify for a 15-year minimum sentence under the Armed Career Criminal Act (ACCA), because defendant's prior conviction for going armed with intent, in violation of Iowa Code 708.8, does not constitute an ACCA predicate violent felony. The court explained that going armed with intent does not necessarily involve the use, attempted use, or threatened use of physical force. View "United States v. Bennett" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Abbott in an action brought by a former employee, alleging a failure-to-accommodate claim under the Minnesota Human Rights Act (MHRA). The court held that plaintiff has not made a facial showing that reasonable accommodation is possible and that the accommodation will allow him to perform the essential functions of the job. In this case, plaintiff requested that he be permitted to use electric forklifts in place of manual pallet jacks, but he has not presented evidence that this accommodation would allow him to perform the essential functions of an M&I Specialist. View "Collins v. Abbott Laboratories, Inc." on Justia Law

The Eighth Circuit affirmed defendant's conviction for three counts of drug and gun charges. The court held that the evidence was sufficient to convict defendant for conspiracy to distribute heroin, powder cocaine, and crack cocaine, as well as for possessing firearms as a convicted felon. The court also held that the district court did not err by denying defendant's motion for a new trial based on defendant's claim that the jury was not representative of a cross-section of the community where defendant failed to provide evidence of the racial composition of the jury pool used by the District of Minnesota, or even the composition of the potential jurors called for his trial.Finally, the court upheld defendant's within-Guidelines 240 month sentence, holding that the district court expressly recognized its authority to vary based on a disagreement with the crack cocaine conversion rate but declined to do so. The court stated that the district court did not abuse its discretion by declining to vary downward and that defendant's sentence was substantively reasonable. View "United States v. Reed" on Justia Law