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

Plaintiffs filed a putative class action, asserting breach of contract claims under Iowa law and breach of fiduciary duty claims under the Employee Retirement Income Security Act (ERISA), based on allegations that Wellmark violated the Patient Protection and Affordable Care Act's (ACA) mandate's cost-sharing and "information and disclosure" requirements. The district court dismissed the information and disclosure claims for failure to state a claim and granted Wellmark summary judgment on the cost-sharing claims.The Eighth Circuit affirmed and held that the district court accurately noted that neither the ACA's statutory mandate nor its implementing regulations requires the disclosure of information -- including a list of providers -- or prohibits "administrative barriers" or "inconsistent guidance." Rather, the mandate provides that group health plans and health insurance issuers "shall, at a minimum provide coverage for and shall not impose any cost sharing requirements for" preventive health services. The court also held that the summary judgment record established that defendant provided plaintiffs qualified, available in-network providers of comprehensive lactation support and consulting services and did not violate the ACA's cost-sharing mandate. View "York v. Wellmark, Inc." on Justia Law

Plaintiff filed suit alleging a sex discrimination claim for a failure to promote against the County of Wright and the Wright County Sheriff's Department under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA).The Eighth Circuit affirmed the district court's grant of summary judgment to the County, holding that plaintiff failed to present evidence that one of the reasons for the chief deputy's actions in not promoting plaintiff was gender animus; plaintiff failed to argue that the interview notes show that the other panelists' negative impressions of her were pretextual, or that the chief deputy was somehow responsible for their negative impressions; and plaintiff failed to point to any evidence of gender animus from the other panelists. The court also held that the district court did not err by concluding that plaintiff failed to raise a genuine issue of material fact as to her cat's-paw theory. View "Pribyl v. County of Wright" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to being a felon in possession of a firearm. The court held that the district court did not err by applying a four-level enhancement for possessing a firearm in connection with another felony offense under USSG 2K2.1(b)(6)(B) & cmt. n.14(c), and a two-level enhancement for recklessly creating a substantial risk of death or serious bodily injury to another person in the course of fleeing from a law enforcement officer under USSG 2A1.4 cmt. n.1. The court also held that the district court did not err in finding defendant's prior Iowa controlled substance conviction was an enhancing predicate. View "United States v. Esquibel" on Justia Law

This appeal stemmed from a collective bargaining agreement (CBA) dispute between the parties where an arbitrator resolved the dispute in favor of the union. The Eighth Circuit held that because the arbitrator was arguably construing or applying the contract and acting within the scope of his authority, there is no basis for vacating the arbitrator's finding that Exide violated the CBA.The court also held that the district court correctly determined that it did not have jurisdiction over Exide's claim that the arbitrator's decision that unilaterally changing Family Medical Leave Act leave administrators was a material, substantial and significant change in the employees' terms and conditions of employment in violation of Section 8 of the National Labor Relations Act. Rather, Congress has empowered the NLRB to resolve unfair-labor-practice claims in the first instance. Furthermore, the cases cited by the parties do not expand the court's original jurisdiction. View "Exide Technologies v. International Brotherhood of Electrical Workers" on Justia Law

The Eighth Circuit affirmed defendant's conviction for being a felon in possession of a firearm and the district court's denial of his motion to suppress evidence. The court applied the Supreme Court's analysis in Michigan v. Summers, 452 U.S. 692, 705 (1981), and Bailey v. United States, 568 U.S. 186, 200 (2013), holding that defendant's brief detention was permissible and that the police had valid justifications for the detention. In this case, the officers' brief detention of the vehicle's passengers and approach of the car were constitutionally permissible; during the approach, the officers developed probable cause to search the car when they smelled marijuana and saw defendant's furtive movements; and thus the brief seizure and subsequent search of the vehicle based on probable cause was constitutional. View "United States v. Freeman" on Justia Law

An August 14, 2019 subpoena duces tecum ordered the IDPS to appear before the court's grand jury and provide documents relating to the investigation of an ISP officer for misconduct or use of excessive force. IDPS complied with five of the listed document categories but filed a motion to quash categories 3 and 4, which seek any and all records relating to the investigation of Officer John Doe for misconduct and any and all records relating to complaints made against Officer John Doe.The Eighth Circuit affirmed the district court's order denying IDPS's motion to quash and rejected IDPS's assertion that quashing the subpoena is needed to protect the Fifth Amendment rights of IDPS employees who participated in internal investigations; the procedural protections established by Kastigar v. U.S., 406 U.S. 401 (1972), and Garrity v. New Jersey, 385 U.S. 493 (1967), provide sufficient protection from the improper use of compelled statements; the Fifth Amendment allows the government to prosecute using evidence from legitimate independent sources; and the district court did not abuse its Federal Rule of Criminal Procedure 17(c)(2) discretion in deciding that IDPS failed to meet its substantial burden to show that compliance with the challenged portions of the grand jury subpoena would be "unreasonable or oppressive" when balanced against the interests of the government in enforcing the subpoena. View "In Re: Grand Jury Subpoena Dated August 14, 2019" on Justia Law

Dunbar, a Service Disabled Veteran Owned Small Business (SDVOSB), was awarded an Army Corps of Engineers ditch and tributary project in Arkansas. Dunbar then hired a subcontractor, Harding Enterprises, to work on the project. After Harding Enterprises defaulted, Dunbar made a demand on the bond guaranteed by Hanover, which Hanover denied. Hanover then filed suit seeking a declaration that it had no obligations under the bond and seeking to have the bond rescinded based on illegality of the subcontract.The Eighth Circuit reversed the district court's grant of summary judgment in favor of Hanover, holding that the district court erroneously concluded that the subcontract was undisputedly in violation of 13 C.F.R. 125.6(b)(2) because the percentage that Dunbar spent on contract performance relative to the prime contract price could not be conclusively ascertained until conclusion of performance of the prime contract. The court also held that the potential that Hanover may have liability under the False Claims Act if it were to perform under the bond does not justify discharging Hanover from its obligations and rescinding the contract. View "Hanover Insurance Co. v. Dunbar Mechanical Contractors, LLC" on Justia Law

The Eighth Circuit affirmed the denial for disability insurance benefits and supplemental security income to plaintiff. The court held that the ALJ properly weighed the opinions of medical professionals, including a physician's assistant, and gave partial weight to the opinion of a certain medical expert. The court also held that sufficient evidence in the record supported the ALJ's decision, including clinical notes that plaintiff lost weight from moving around so much, left a clinical appointment with a brisk walk and no cane, and stated he was doing well after a total hip replacement. Finally, the court held that a hypothetical question given to the vocational expert captured the concrete consequences of plaintiff's impairments, and the court need not consider plaintiff's Appointments Clause challenge. View "Hilliard v. Saul" on Justia Law

The Eighth Circuit held that the evidence was sufficient to support defendant's conviction for conspiracy to retaliate against a witness. The court held that a reasonable jury could believe that defendant and her co-defendants formed a conspiracy where a reasonable jury could understand a certain conversation between defendant and her sister as evidence of a knowing agreement between them to retaliate against the new interim executive director that replaced defendant at the not-for-profit for providing evidence to federal investigators. Furthermore, a reasonable jury could conclude that overt acts were taken in furtherance of the conspiracy. View "United States v. Colombe" on Justia Law

Plaintiff filed suit against a police officer under 42 U.S.C. 1983, alleging that the officer used excessive force and seeking damages for injuries sustained during plaintiff's arrest. The district court denied the officer's motions for summary judgment.The Eighth Circuit agreed with the district court that, on balance, the challenged use of force was unreasonable, but that the question is not beyond debate, and the right at issue was thus not clearly established. In this case, officers were attempting to arrest plaintiff for his role in a brutal beating, plaintiff fled from officers at high speed for several miles while armed with a handgun and ammunition, and a foot race ensued after the car chase where five officers pinned plaintiff. While the officers pinned plaintiff, plaintiff refused to surrender his hands and the officers reasonably believed that plaintiff's position posed a threat to officer safety, because at least one of his hands was unrestrained in an area of his body where weapons could be concealed. Therefore, the court held that it was objectively reasonable for officers to apply some amount of supplemental force in order to gain control of plaintiff's hands and to restrain him. However, the court held that the officer's use of force was unreasonable under the Fourth Amendment. The court stated that a stomp on the ankle with sufficient force to break it was excessive when the legitimate objective was to facilitate restraint of plaintiff's hands while he was pinned to the ground by several officers.The court stated that a number of the relevant factors supported the use of force, so reasonableness was a matter of degree, and qualified immunity protects officers from the specter of lawsuits and damages liability for mistaken judgments in gray areas. Accordingly, the court reversed the denial of qualified immunity. View "Shelton v. Stevens" on Justia Law