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

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

The case involves over 1,420 Peruvian citizens alleging environmental harm due to exposure to toxic substances from the La Oroya Metallurgical Complex (LOMC) in Peru. The plaintiffs claim that Doe Run Resources Corporation and related entities, which purchased LOMC in 1997, failed to reduce lead emissions, resulting in unsafe lead levels and subsequent health issues. The plaintiffs argue that Doe Run's decision-making in the United States led to their injuries.Initially, the plaintiffs filed common law tort lawsuits in Missouri state court, which were removed to federal court and consolidated. The district court dismissed several claims and defendants but allowed the substantive negligence-based claims to proceed under Missouri law. Doe Run filed motions to dismiss based on international comity and to apply Peruvian law, both of which were denied by the district court. The court also denied summary judgment on the safe harbor defense and certified its choice-of-law and comity rulings for interlocutory appeal.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decisions. The court held that the district court did not abuse its discretion in denying dismissal under the doctrine of international comity, as the harm occurred in Peru but the alleged conduct occurred in Missouri. The court also found that the Trade Promotion Agreement (TPA) between the United States and Peru did not require dismissal, as the plaintiffs' claims were not explicitly addressed by the TPA. Additionally, the court determined that traditional comity factors did not necessitate dismissal, as neither the State Department nor the government of Peru had asserted their positions, and there was no adequate alternative forum in Peru. Lastly, the court concluded that extraterritoriality principles did not warrant abstention, as the plaintiffs' claims were based on conduct within the United States.The Eighth Circuit affirmed the district court's judgment. View "Reid v. Doe Run Resources Corp." on Justia Law

A joint state and federal criminal investigation, "Operation Back Cracker," uncovered a scheme where Minnesota healthcare providers, primarily chiropractors, recruited car accident victims and fraudulently billed auto insurers for their treatment. In related civil settlements, some providers agreed not to bill certain insurance companies, including Illinois Farmers Insurance Company, for any treatment provided to their insureds. Plaintiffs, representing a class of insured individuals, sued Farmers, alleging that these no-bill agreements violated the Minnesota No-Fault Automobile Insurance Act.The United States District Court for the District of Minnesota granted summary judgment to the plaintiffs' injunctive class, enjoining Farmers from entering into or enforcing the no-bill agreements. The court found that these agreements effectively provided managed care services and set preestablished limitations on medical expense benefits, both of which are prohibited under the No-Fault Act. Farmers appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and vacated the injunction. The court held that the no-bill agreements did not constitute managed care services as defined by the No-Fault Act because they excluded, rather than used, the providers under contract with Farmers. Additionally, the court found that the agreements did not place preestablished limitations on medical expense benefits since they did not limit reimbursement for reasonable expenses incurred by insureds. The court concluded that an insurer does not violate the No-Fault Act by enforcing a no-bill agreement against a provider, as long as it does not refuse to reimburse an insured who has incurred a qualifying expense. The case was remanded for further proceedings consistent with this opinion. View "Taqueria El Primo LLC v. IL Farmers Insurance Co." on Justia Law

Marquice Morris was convicted by a jury of conspiracy to distribute fentanyl. The case involved Morris and his co-defendant, Brandon Johnson, who conspired to distribute at least 400 grams of fentanyl in Minnesota. Evidence presented at trial showed that Morris arranged a trip to Phoenix, Arizona, where he purchased fentanyl and provided it to Johnson for transport back to Minnesota. Johnson was apprehended in Texas with the drugs and a firearm, leading to recorded calls implicating Morris.The United States District Court for the District of Minnesota denied Morris's motions for acquittal or a new trial, sentenced him to 190 months of imprisonment, and revoked his supervised release. Morris appealed his conviction, revocation, and sentence. The district court found that Morris had attempted to bribe Johnson and pressured him to sign an affidavit exonerating Morris, leading to an obstruction of justice enhancement in his sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that there was sufficient evidence to support the jury's verdict, including corroborated testimony from Johnson and law enforcement officers. The court also found that venue was proper in Minnesota, as the conspiracy involved actions taken in the state. The court rejected Morris's arguments for a new trial, finding no abuse of discretion by the district court. Lastly, the court upheld the obstruction of justice enhancement, noting sufficient circumstantial evidence linking Morris to attempts to influence Johnson.The Eighth Circuit affirmed the judgments of the district court, including Morris's conviction, sentence, and the revocation of his supervised release. View "United States v. Morris" on Justia Law

James Setchfield, a 68-year-old man, filed a lawsuit against St. Charles County Police Department officers Nicholas Seiverling and Scott Ronald, alleging they used excessive force during an incident in a parking lot. The incident began when Setchfield arrived to pick up his son, who had been arrested for driving under the influence. A confrontation ensued between Setchfield and Corporal Ronald, during which Setchfield was allegedly beaten by the officers while still seated in his car. Setchfield claimed he did not threaten or resist the officers, but was nonetheless pulled from his car, beaten, and arrested, resulting in various injuries and subsequent PTSD.The United States District Court for the Eastern District of Missouri dismissed claims against St. Charles County and one officer, John Williams, but denied summary judgment for Corporal Ronald and Officer Seiverling on Setchfield’s excessive force and unlawful arrest claims. The court found that material factual disputes remained, precluding summary judgment based on qualified immunity for the officers.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s denial of summary judgment, holding that the officers were not entitled to qualified immunity. The court found that, viewing the facts in the light most favorable to Setchfield, the officers used unreasonable force against a non-threatening, non-resisting individual. Additionally, the court determined that the officers lacked probable cause or arguable probable cause to arrest Setchfield for interfering with police duties or resisting arrest. The court concluded that the officers’ actions violated clearly established constitutional rights, thus denying them qualified immunity. View "Setchfield v. Ronald" on Justia Law

Eddie Humes was arrested on October 19, 2017, and booked into the White County Detention Center. The next day, he was bitten by a spider, causing his hand and arm to swell significantly. Over three days, Humes repeatedly asked Lieutenant Misty Jones and Deputy Stephanie Gray for medical help, showing them his worsening condition. Despite their assurances, they took no action. By October 25, Humes's hand and arm had swollen to the size of a small watermelon and were oozing pus. He filed a grievance and was taken to the emergency room, where he was diagnosed with a staph infection and treated. The next day, he developed a high fever and was diagnosed with an abscess, requiring emergency surgery.Humes filed a civil-rights lawsuit against several defendants, including Jones and Gray, alleging deliberate indifference to his serious medical needs. The United States District Court for the Eastern District of Arkansas granted summary judgment to all defendants except Jones and Gray in their individual capacities, denying them qualified immunity. Jones and Gray appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of qualified immunity de novo. The court considered whether Jones and Gray violated a constitutional right and whether that right was clearly established. The court found that the district court correctly determined that a reasonable jury could find Jones and Gray were deliberately indifferent to Humes's serious medical needs, as they ignored his worsening condition. The court also held that the right to medical care for serious conditions was clearly established, referencing precedents like Hartsfield v. Colburn and Dadd v. Anoka County. Consequently, the Eighth Circuit affirmed the district court’s denial of qualified immunity and remanded the case for trial. View "Humes v. Jones" on Justia Law

Luke LeFever was involved in a series of criminal activities following a roadside encounter with Deputy Castellanos of the Dawson County Sheriff’s Department. LeFever lunged at the deputy, was tased twice, and fled the scene. He attempted to steal multiple vehicles, broke into a home, assaulted a resident, and led officers on a high-speed chase, driving recklessly and endangering public safety. The chase ended when officers fired 60 to 70 rounds at LeFever’s vehicle, resulting in serious injuries.The United States District Court for the District of Nebraska denied LeFever’s requests for appointed counsel and granted summary judgment in favor of the defendants. The court found that Deputy Castellanos had probable cause for the initial arrest and that the use of force, including the tasings and the shot fired at the utility vehicle’s wheel, was reasonable. The court also found that the report of “shots fired” by Deputy Castellanos did not rise to the level of a constitutional violation. Additionally, the court ruled that the actions of the other officers during the chase and subsequent shooting were reasonable under the circumstances and that qualified immunity applied.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 use of force by Deputy Castellanos and the other officers was reasonable and that qualified immunity protected the officers from liability. The court also found no abuse of discretion in the district court’s denial of LeFever’s requests for appointed counsel, noting that the facts and legal issues were clear and uncomplicated, and that the district court had provided adequate assistance to LeFever in managing his case. View "LeFever v. Castellanos" on Justia Law

Kelsey Weyer applied for long-term disability benefits under a policy issued by Reliance Standard Life Insurance Company through her employer. Weyer suffers from multiple medical conditions, including chronic fatigue syndrome, Lyme disease, migraines, neurocognitive disorder, and others. The policy defines "Totally Disabled" differently for the first twenty-four months and thereafter. Initially, it means being unable to perform the duties of one's regular occupation, and after twenty-four months, it means being unable to perform any occupation. Reliance Standard initially approved Weyer’s claim and paid benefits for twenty-four months but later terminated them, arguing she could perform sedentary jobs and that her anxiety and depression contributed to her disability.The United States District Court for the District of Minnesota reviewed the case and ruled in favor of Weyer. The court found that the evidence did not support Reliance Standard’s claim that Weyer’s mental health issues contributed to her inability to work. It also held that Weyer was totally disabled under the policy’s "Any Occupation" standard, based on evidence from Weyer’s physicians and independent reviews.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, finding no clear error in its determination that Weyer was totally disabled and that her physical conditions alone rendered her unable to work. The appellate court also agreed that the mental health disorders did not contribute to her total disability under the policy’s terms. The court applied a "but-for" causation standard, concluding that Weyer’s physical conditions independently caused her total disability, thus the mental health limitation clause did not apply. The court affirmed the district court’s judgment in favor of Weyer. View "Weyer v. Reliance Standard Life Insurance Company" on Justia Law

Izeall Collins was convicted by a jury of possession of heroin with intent to distribute and possession of a firearm in furtherance of drug trafficking. Collins was apprehended at the Kansas City Greyhound bus terminal after law enforcement officers observed his suspicious behavior and conducted a search that revealed heroin and a firearm. Collins appealed, arguing that the district court erred in denying his motion to suppress evidence and his motion for acquittal due to insufficient evidence.The United States District Court for the Western District of Missouri denied Collins's motion to suppress, finding that the initial encounter between Collins and the officers was consensual and that the officers had probable cause to arrest him after he admitted to possessing marijuana. The court also denied Collins's motion for acquittal, concluding that the evidence presented at trial was sufficient to support his convictions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's denial of the motion to suppress, agreeing that the initial encounter was consensual and that the officers had probable cause to arrest Collins. The court also upheld the sufficiency of the evidence, noting that the quantity of heroin found on Collins was sufficient to establish intent to distribute and that the firearm found in the cooler, along with other items linking it to Collins, supported the conviction for possession of a firearm in furtherance of drug trafficking.The Eighth Circuit concluded that the evidence was sufficient to support Collins's convictions and affirmed the judgment of the district court. View "United States v. Collins" on Justia Law