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

The Eighth Circuit vacated the district court's grant of summary judgment in favor of the plan beneficiary in an action arising under the Employee Retirement Income Security Act (ERISA). The court held that the district court erred in reviewing Reliance's denial of long-term disability benefits de novo rather than for an abuse of discretion. The court explained that the administrator's decisional delay on appeal does not in and of itself trigger de novo review. Rather, under circuit law, de novo review is not triggered in this context unless the administrator wholly fails "to act on an appeal" and that failure "raises serious doubts about the result reached by the plan administrator" in its initial denial. The court remanded for the district court to review Reliance's benefits decision for an abuse of discretion. View "McIntyre v. Reliance Standard Life Insurance Co." on Justia Law

After plaintiffs received criminal citations for trespassing and traffic violations while hunting, they filed suit alleging unreasonable search and seizure under the Fourth Amendment and Iowa Constitution, as well as violations of their substantive due process rights.The Eighth Circuit affirmed the district court's dismissal of the unreasonable seizure claim for failure to state a claim where the district court found no seizure under the prevailing federal standards because the officers were alleged only to have issued or verified citations. The court also affirmed the district court's grant of summary judgment to the officers on the unreasonable search claims where the district court did not err in considering summary judgment for the unreasonable search claims under the Iowa Constitution; the district court properly refused to consider plaintiffs' claim that the warrants for their Facebook records were overbroad; and the district court properly ruled that plaintiffs' allegation that defendants placed a GPS tracker on one of the plaintiff's vehicles is, at best, speculative and contradicts all objective evidence on the record. Finally, the court affirmed the district court's grant of summary judgment on the substantive due process claims where plaintiffs point to no evidence in the record that the officers intentionally or recklessly failed to investigate in a way that shocks the conscience. View "Wendt v. Iowa" on Justia Law

The Eighth Circuit affirmed the district court's reduction of defendant's life sentence to 360 months in prison for conspiracy to distribute 50 grams or more of cocaine base. The district court left defendant's 360 month sentence for distributing five grams or more of cocaine base unchanged.The court held that the district court understood its authority and discretion to resentence defendant under the First Step Act. In this case, the district court concluded that defendant was entitled to retroactive relief under the Act and that the Sentencing Guidelines recommended defendant serve between 360 months and life in prison because of his total offense level and criminal history, rather than the previous mandatory life sentence. The court also held that the district court considered defendant's motion and had a reasoned basis for its discretion. Finally, the court held that there is no Sixth Amendment right to counsel, nor is there a statutory right, in sentence modification proceedings under the Act. Although the Southern District of Iowa's standing administrative order permitted the public defender's office to represent eligible defendants, the court held that it was not an abuse of discretion for the district court to act on defendant's repeated requests to reduce his sentence. View "United States v. Meeks" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion for judgment of acquittal, holding that the evidence was sufficient to support defendant's conviction for sexual exploitation of a child, conspiracy to distribute methamphetamine, and distribution of the drug. The court declined to consider defendant's ineffective assistance of counsel claim on direct appeal. View "United States v. Frommelt" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of a gun seized without a warrant during a traffic stop and his subsequent statements to law enforcement. The court held that, based on the information the officers knew at the moment they seized the gun, they had probable cause to believe defendant possessed the weapon.The court also held that, although the district court erred by failing to suppress defendant's statements, the error was harmless in light of the overwhelming evidence of defendant's guilt. The court further held that the district court did not err by deciding that defendant voluntarily and knowingly waived his rights when he agreed to speak with the officers and then to the special agent. View "United States v. Figueroa-Serrano" on Justia Law

Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer used excessive force in seizing plaintiff's 16 year old son. The officer shot the son and the son sustained serious injuries paralyzing him below the waist.The Eighth Circuit reversed the district court's denial of the officer's motion for summary judgment, holding that the seizure was not unreasonable. The court held that, under the circumstances, a reasonable officer was justified in discharging his firearm where the son was carrying a gun that moved while he ran, the officers were investigating a report of a stolen firearm, and the son was fleeing from police who had arrived at the apartment building. Given the convergence of events and the split-second decision for the officer, the court stated that it was not unreasonable for the officer to use force as he did. View "Liggins v. Cohen" on Justia Law

The Eighth Circuit held that the transferee court has jurisdiction to resolve a motion to reduce sentence under the First Step Act of 2018 when the offender is serving a term of supervised release and the sentencing court has transferred jurisdiction over the offender to another district court.In this case, the district court in Northern Iowa dismissed defendant's motion under the First Step Act, without prejudice, on the ground that it lacked jurisdiction over the motion after the transfer. The district court in Northern Illinois later denied defendant's motion for relief under the First Step Act, and he did not appeal that decision to the Seventh Circuit. The court held that the transferee court in the Northern District of Illinois was the district court with jurisdiction to consider defendant's motion to reduce sentence under the First Step Act. The court explained that the powers of the transferred court under 18 U.S.C. 3583 encompasses the authority to resolve defendant's motion under the First Step Act. The court affirmed the judgment. View "United States v. El Herman" on Justia Law

After the district court granted petitioner's application for naturalization, petitioner then moved for attorney's fees and costs under the Equal Access to Justice Act (EAJA). The district court denied the motion. The government concedes that petitioner is entitled to costs in the amount he requests because he is the prevailing party and, unlike for attorney's fees, there is no "substantially justified" requirement for costs under the EAJA.The Eighth Circuit affirmed the district court's order with modifications that petitioner is awarded costs. The court held that the district court did not abuse its discretion by determining that the government's position was substantially justified and did not err in denying the requested attorneys' fees under the EAJA. In this case, the government's position that petitioner lacked good moral character because he had given false testimony for the purpose of obtaining immigration or naturalization benefits was substantially justified. Finally, the court denied petitioner's motion to supplement the record. View "Garcia v. Barr" on Justia Law

After Officers Jorgensen and Eckert shot and killed John O. Birkeland in his home, plaintiff filed a wrongful death action against the officers as well as the sergeant and the city. The district court granted summary judgment in favor of the officers and the city on all claims except the use of deadly force and "associated state-law claims."The Eighth Circuit granted the motion to dismiss the cross-appeal because the court lacked jurisdiction to review the grant of qualified immunity or the grant of official immunity under Minnesota state law. However, the court reversed the district court's denial of qualified immunity on the deadly force claim. In this case, regardless of whether Birkeland's movement toward the officers was voluntary, in light of the close proximity between the officers and Birkeland's location in the closet, Birkeland's failure to comply with Jorgensen's commands to drop the knife, and Birkeland's stabbing of the police dog in the face with a knife, Birkeland posed a threat of serious physical harm to the officers and the court cannot say that their use of deadly force, even if just over the line of reasonableness, violated a clearly established right.The court also reversed the district court's denial of official immunity on the state-law claims related to the use of deadly force where a reasonable fact finder could not conclude that the officers' conduct in this case was willful or malicious. Furthermore, because the officers' discretionary decisions are entitled to official immunity, the city is entitled to vicarious official immunity. View "Birkeland v. Jorgenson" on Justia Law

The Eighth Circuit affirmed defendant's 240 month sentence imposed after he pleaded guilty to distributing more than 500 grams of methamphetamine. The court held that the district court did not err by applying a four-level role enhancement for defendant's leadership role in the offense pursuant to USSG 3B1.1(a); the district court did not err by applying a two-level sentencing enhancement for obstruction of justice under USSG 3C1.1; and defendant's below-Guidelines sentence was not substantively unreasonable where the district court considered mitigating factors such as defendant's young age, absent father, minimal education, and lack of criminal history. View "United States v. Zambrano" on Justia Law