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

An inmate in the Arkansas Department of Corrections (ADC) filed a pro se 42 U.S.C. § 1983 action, alleging that several ADC employees retaliated against him for exercising his First Amendment rights. The inmate claimed retaliation occurred after he filed a grievance, circulated a memorandum encouraging other inmates to file grievances against a new administrative directive, and threatened a lawsuit. The directive in question imposed a three-page limit on non-privileged correspondence between inmates and non-incarcerated individuals. The inmate was charged with rule violations, placed in isolation, and later moved to administrative segregation.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants, concluding that they had valid, non-retaliatory reasons for their actions, as the inmate had violated prison rules. The district court also denied the inmate's request for an extension of time to file his own summary judgment motion, citing a lack of good cause and the age of the case. The inmate appealed both decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court’s grant of summary judgment, finding that the inmate’s circulation of the memorandum was protected conduct under the First Amendment and that there was insufficient evidence to demonstrate a security concern justifying the disciplinary actions. The court also found that the district court erred in relying on a written charge of a rule violation that was dismissed on procedural grounds and on the inmate’s deposition testimony given years later. However, the court affirmed the district court’s denial of the inmate’s request for an extension of time to file a summary judgment motion, finding no abuse of discretion. View "Lamar v. Payne" on Justia Law

Kylee Starr pleaded guilty to three controlled substance offenses in October 2022. She was released to a sober living home while awaiting sentencing. In March 2023, the district court sentenced her to time served and 48 months of supervised release, granting safety-valve relief and a substantial assistance downward departure. Starr relapsed on fentanyl in June 2023 and was terminated from the sober living home. Her probation officer filed a petition to revoke her supervised release, and Starr admitted to committing Grade C violations.The United States District Court for the District of North Dakota revoked her supervised release and imposed a 24-month imprisonment sentence, followed by three years of supervised release. The court varied upward from the advisory guidelines range of 3 to 9 months, citing the seriousness of Starr's violations and the danger she posed to others. The government had requested a 9-month sentence, while Starr's defense counsel argued for a 3-month sentence, emphasizing her previous year of sobriety and the potential negative impact of a long incarceration on her recovery.The United States Court of Appeals for the Eighth Circuit reviewed the substantive reasonableness of the revocation sentence under the deferential abuse-of-discretion standard. The court affirmed the district court's decision, noting that the district court had considered the relevant sentencing factors and the advisory guidelines. The court found that the district court did not abuse its discretion by imposing an above-range sentence, given Starr's repeated inability to adhere to supervised release conditions and the danger she posed to others. The court also noted that the district court had considered mitigating factors but afforded them less weight than Starr would have preferred. View "United States v. Starr" on Justia Law

In the 1950s, the U.S. Army Corps of Engineers purchased land from the Meltons and the Paines, using traditional surveying descriptions. A 1962 subdivision plat map indicated a stone (Peter’s Stone) that appeared to mark the boundary, but a 1974 Corps survey found the stone was not at the true centerline. This discrepancy led to a land dispute over a strip of land between the true centerline and the stone.In 1977, the United States filed quiet title actions against the owners of Lot 8 and adjacent landowners. The court consolidated the cases and found that the Meltons and the Corps likely believed the stone marked the true centerline. In 1979, the court awarded a small portion of Lot 8 to the Highfills but did not resolve the boundary for other lots. The judgment was recorded in 1989.In 2019, the Gambrells purchased several lots in the subdivision and, in 2020, were informed by the Corps that the true centerline was marked by the Corps’ monument, not Peter’s Stone. The Gambrells filed a quiet title action in 2021. The United States moved for summary judgment, arguing the 1979 judgment and the 1974 monument provided notice of a potential dispute. The district court granted summary judgment for the United States, citing the Quiet Title Act’s 12-year statute of limitations.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The court held that the 1979 judgment and the 1974 monument provided constructive notice of the United States’ claim, triggering the statute of limitations. The court also rejected the Gambrells’ collateral estoppel argument, noting that nonmutual offensive collateral estoppel does not apply against the United States. The court emphasized that the statute of limitations ruling does not resolve the underlying boundary dispute, leaving the parties free to pursue further legal actions. View "Gambrell v. United States" on Justia Law

Christopher Drew was arrested after officers responded to a harassment complaint from his neighbor, who reported that Drew had threatened her and her child. When officers arrived at Drew's apartment, they found him in a confrontation with another woman. During the arrest, Officer Hemsted pepper-sprayed Drew without warning after Drew refused to comply with orders and warned the officer not to touch him. Drew later pleaded guilty to second-degree harassment and subsequently sued the officers and the City of Des Moines under 42 U.S.C. § 1983 for excessive force, failure to intervene, and Monell liability.The United States District Court for the Southern District of Iowa granted summary judgment in favor of the defendants, finding that Officer Hemsted's use of force was objectively reasonable. The court concluded that the officers did not violate Drew's Fourth Amendment rights and dismissed all claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Officer Hemsted was entitled to qualified immunity because it was not clearly established that using pepper spray in this context violated Drew's constitutional rights. The court noted that Drew was suspected of a serious crime involving threats of violence and was noncompliant during the arrest. The court distinguished this case from others involving less severe crimes and minimal safety threats. Consequently, the court also found that Officer Ulin and the City of Des Moines were not liable, as they were not on fair notice that their actions were unconstitutional. The Eighth Circuit affirmed the district court's judgment and granted the motion to supplement the record with bodycam footage. View "Drew v. City of Des Moines" on Justia Law

Four parents of students in the Independence School District challenged the District’s policy of removing library materials upon receiving a complaint, pending a formal review. They argued that this policy violated their children's First Amendment rights and Fourteenth Amendment due process rights. The District moved to dismiss the case.The United States District Court for the Western District of Missouri granted the District’s motion to dismiss. The court concluded that the parents failed to demonstrate an injury-in-fact necessary for standing, as their claims were based on hypothetical future challenges rather than any current or imminent harm. The court noted that the plaintiffs did not allege any ongoing or threatened challenges to library materials, nor did they challenge the removal of any specific book.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court agreed that the plaintiffs lacked standing because they did not show a concrete and particularized injury that was actual or imminent. The court emphasized that the plaintiffs’ claims were speculative, as they were based on the possibility of future book challenges and removals. The court also noted that the plaintiffs did not allege any self-censorship or chilling effect on their children’s speech due to the policy. Therefore, the court held that the plaintiffs failed to meet the requirements for pre-enforcement review and affirmed the dismissal of the case. View "L.H. v. Independence School District" on Justia Law

Two tribal companies, Rock River Manufacturing, Inc. and HCI Distribution, Inc., challenged Nebraska's enforcement of its escrow and bond requirements for cigarette sales. These requirements stem from a Master Settlement Agreement (MSA) that mandates tobacco manufacturers either join the MSA or place money in escrow based on cigarette sales. The companies argued that the Indian Commerce Clause prevents Nebraska from enforcing these requirements on cigarettes sold within Indian country.The United States District Court for the District of Nebraska granted partial summary judgment, enjoining Nebraska from enforcing the escrow and bond requirements for cigarettes sold on the Winnebago Tribe's reservation but not for those sold on the Omaha Tribe's reservation. Nebraska appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Nebraska's escrow and bond requirements could be enforced for cigarette sales to nonmembers on the Winnebago Reservation but not for sales to tribal members. The court reasoned that the state's interest in public health and fiscal soundness outweighed the tribal and federal interests for sales to nonmembers. However, for sales to tribal members, the tribe's sovereignty and self-governance interests prevailed. The court reversed the district court's decision in part and remanded with instructions to tailor the injunction, enjoining Nebraska from enforcing the escrow and bond requirements for cigarettes sold on the Winnebago Reservation to tribal members. View "HCI Distribution, Inc. v. Hilgers" on Justia Law

Martin Brauner transmitted HPV to M.O. through sexual activity in Brauner’s GEICO-insured automobile. M.O. threatened to sue Brauner for negligence and demanded $1,000,000 from GEICO, which denied the claim and sought a federal court declaration that the policy did not cover M.O.’s injuries. Brauner and M.O. settled the threatened lawsuit, agreeing that M.O. would collect only from GEICO if an arbitrator found Brauner negligent. The arbitrator awarded M.O. $5,200,000, which M.O. sought to confirm in Missouri state court. The Supreme Court of Missouri vacated the confirmation and remanded the case to allow GEICO to intervene.The United States District Court for the District of Kansas initially handled the case but transferred it to the United States District Court for the Western District of Missouri due to lack of personal jurisdiction over M.O. The district court granted GEICO’s motion for summary judgment, ruling that the policy required bodily injury to arise out of the use of the automobile, and that sexual activity in an automobile did not constitute “use” under Kansas insurance law. Brauner and M.O. appealed.The United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court affirmed the district court’s decision, holding that the insurance policy unambiguously required bodily injury to arise out of the ownership, maintenance, or use of the automobile. The court found that sexual activity in an automobile did not meet this requirement, as the automobile was merely the situs of the injury and not causally connected to the negligent act. Therefore, M.O.’s injuries were not covered under the policy. View "GEICO General Insurance Co. v. M.O." on Justia Law

In 1993, Darrin Rick pleaded guilty to criminal sexual conduct involving four developmentally disabled girls and one seven-year-old boy. After failing to complete sex-offender treatment programs in prison, Hennepin County petitioned to civilly commit him as a "sexually dangerous person." Three psychologists, including two appointed by a Minnesota district court, agreed that Rick met the criteria for commitment. Consequently, he was committed to the Minnesota Sex Offender Program. In 2007, the Minnesota Supreme Court declined further review of his case. Years later, new expert reports suggested that the actuarial tools used to justify his commitment had overestimated his risk of recidivism.Rick filed a federal habeas petition, arguing that the new evidence showed he was "actually innocent" of being a sexually dangerous person. The United States District Court for the District of Minnesota entertained the petition under the actual-innocence exception, finding that the reliance on outdated expert reports and actuarial data violated his due-process rights. The court granted habeas relief, allowing Rick to bypass the one-year statute of limitations for filing the petition.The United States Court of Appeals for the Eighth Circuit reviewed the case and focused on whether the actual-innocence exception could apply to civil commitments. The court concluded that the exception, traditionally used in criminal cases to address wrongful convictions, does not extend to civil commitments. The court emphasized that the exception is meant for cases involving criminal guilt or innocence, not predictions of future dangerousness. Consequently, the Eighth Circuit reversed the district court's grant of habeas relief and remanded the case for denial of Rick's petition. View "Rick v. Harpstead" on Justia Law

Daniel Graff purchased a life insurance policy from Brighthouse Life Insurance Company for his father, with Graff as the beneficiary. Over the years, Graff paid more in premiums than the policy's death benefit. He sued Brighthouse, claiming the policy violated Minnesota's Readability of Insurance Policies Act (RIPA) and the implied covenant of good faith and fair dealing, and also sought recovery for unjust enrichment. Brighthouse removed the case to federal court, which dismissed Graff's claims for failing to state a claim.The United States District Court for the District of Minnesota dismissed Graff's complaint with prejudice. The court found that the RIPA did not provide a private cause of action, the implied-covenant claim was untimely, and Graff could not recover under unjust enrichment because a valid contract governed the parties' relationship.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the RIPA does not create a private cause of action, as enforcement authority is vested exclusively in the Minnesota Commissioner of Commerce. The court also determined that Graff's implied-covenant claim could not proceed because it was based on a statute that does not provide a private remedy. Lastly, the court upheld the dismissal of the unjust enrichment claim, noting that equitable remedies are unavailable when a valid contract governs the parties' rights, and Brighthouse was entitled to the premiums under the policy. View "Daniel Graff v. Brighthouse Life Ins. Co." on Justia Law

Robert Hansen was convicted by two juries of multiple gun and drug crimes. The district court sentenced him to 300 months in prison for the first case and 120 months for the second, to run concurrently. Hansen appealed, seeking to overturn both verdicts and vacate his sentences.In the first case, Hansen was involved in three controlled buys of methamphetamine, which led to search warrants being executed at three locations. Investigators found drugs and guns at these locations, leading to Hansen's indictment on several charges, including conspiracy to distribute methamphetamine and unlawful possession of firearms. The jury convicted him on most charges, but the district court ordered a retrial due to juror misconduct. In the retrial, Hansen was again convicted on most charges. In the second case, Hansen was charged with unlawful possession of firearms found at two different locations. The jury convicted him on both counts.Hansen argued on appeal that there was insufficient evidence to support his convictions, that the district court erred by not including a special interrogatory in the verdict form, and that his counsel was ineffective. He also challenged the admission of certain testimony under Federal Rule of Evidence 404(b) and the denial of his motion for a new trial. Additionally, he contested the drug quantity finding and the use-of-violence enhancement at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decisions. The court found that the evidence was sufficient to support the convictions and that the jury instructions and verdict form were adequate. The court also held that the admission of testimony under Rule 404(b) was not an abuse of discretion and that the denial of a new trial was justified. Finally, the court upheld the sentencing enhancements, finding no clear error in the district court's factual findings. The Eighth Circuit affirmed the district court's judgments. View "United States v. Hansen" on Justia Law