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

The Eighth Circuit affirmed defendant's conviction of second degree murder and discharging a firearm during a crime of violence. Defendant's charges arose from a shooting on the Pine Ridge Reservation in South Dakota.The court held that the district court did not abuse its discretion by denying defendant's Federal Rule of Criminal Procedure 33(a) motion for a new trial because the evidence did not weigh heavily enough against the verdict that a miscarriage of justice may have occurred; there was no reversible error in the district court permitting three of the witnesses to meet before trial; there was no plain error in the district court's instructions to the jury regarding witness credibility; and the district court did not abuse its discretion in denying defendant's request for the jury to view the area where the victim was shot. View "United States v. Dowty" on Justia Law

Plaintiff filed suit under Title VII against Midwest after it allegedly withdrew his job offer after learning that he was gay. The Eighth Circuit reversed the district court's dismissal based on Williamson v. A.G. Edwards & Sons, Inc., 876 F.2d 69, 70 (8th Cir. 1989), and remanded for further proceedings in light of the Supreme Court's decision in Bostock v. Clayton Cty., 590 U.S. ___, Nos. 17-1618, 17-1623, 18-107, slip op. at 4 (June 15, 2020), which held that it "defies" Title VII for "an employer to discriminate against employees for being homosexual or transgender," because to do so, it "must intentionally discriminate against individual men and women in part because of sex." View "Horton v. Midwest Geriatric Management" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment on plaintiff's 42 U.S.C. 1983 claims against the county, the sheriff, and two deputy sheriffs. The court held that Deputy Ford was entitled to qualified immunity on the Fourth Amendment false arrest claim where he had probable cause to make the warrantless arrest of plaintiff. In this case, prior to arresting plaintiff, Deputy Ford was told by his dispatcher that plaintiff had tried to stab the victim; the victim gave both oral and written statements about the incident; and other evidence corroborated the victim's statements.The court also held that the sheriff and the second deputy are entitled to qualified immunity on the Fourth Amendment false arrest claim; the officers are entitled to qualified immunity on plaintiff's Fourteenth Amendment substantive due process claim for failure to investigate; plaintiff's section 1983 civil conspiracy claim failed as a matter of law because plaintiff failed to establish that he was deprived of a constitutional right or privilege; and in the absence of a constitutional violation, plaintiff's Monell claim also failed. View "Kingsley v. Lawrence County" on Justia Law

The Eighth Circuit reversed the district court's sua sponte dismissal of plaintiff's in forma pauperis complaint as failing to state a claim under the Americans with Disabilities Act (ADA). Plaintiff is currently serving a prison sentence and has a diagnosis of diverticulitis, a chronic colon condition that causes diarrhea and constipation.The court held that plaintiff has stated a Title II claim by sufficiently alleging that he is a qualified individual with a disability under the ADA and that he was denied the benefit of the prison's privilege system by reason of his disability. The court also held that plaintiff has stated a claim under Title VI and that defendants retaliated against him for his filing of ADA grievances by taking the adverse action of rescinding his medical classification without providing a medical reevaluation or rationale. Finally, because plaintiff's complaint sufficiently states a claim upon which relief may be granted, the court necessarily reversed the district court's assignment of a strike under the Prison Litigation Reform Act. View "Rinehart v. Weitzell" on Justia Law

The Eighth Circuit affirmed defendant's conviction for aggravated sexual abuse. The court held that the trial judge did not plainly err by not recusing himself sua sponte. Even if it considered defendant's recusal arguments despite the fact that he untimely raises them for the first time on appeal, the court held that he has not shown that the judge's impartiality might reasonably be questioned. In this case, the statements to which defendant cites do not show that the judge's disposition was so extreme as to display clear inability to render fair judgment.The court also rejected defendant's evidentiary challenges, holding that it was not an abuse of discretion for the judge to allow an agent to testify as a lay witness about his experience in forensic interviews under Federal Rule of Evidence 701, and to not allow defendant to question the agent about an incident involving a white pick up trick. Finally, defendant failed to show plain error in the judge's decision to allow the agent to testify about his opinion that defendant was guilty based on the agent's interview with defendant. View "United States v. Delorme" on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act (ERISA) alleging that the Committee wrongfully denied his disability claim under its Employees' Retirement Plan and breached its fiduciary duty by failing to conduct a full and fair review of his medical records when reconsidering his claim.The Eighth Circuit affirmed the district court's judgment in favor of the Plan, holding that the district court properly found that the Committee did not breach its fiduciary duty by failing to review the medical records. The court rejected defendant's claim that the Committee offered different rationales for denying his claim and held that the Committee's denial letters consistently state that the application was denied as untimely because it was not made before or in connection with plaintiff's separation. View "DaPron v. Spire Inc. Retirement Plans Committee" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Koss in an action brought by plaintiff, a former employee, alleging that Koss terminated her employment in retaliation for her complaints about pay discrimination based on sex in violation of the Equal Pay Act (EPA).The court held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact as to pretext. In this case, plaintiff failed to present sufficient evidence as to the question of whether there was no basis in fact for Koss's proffered reason for her termination: there was lack of work at the project. The court also held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact on the question of whether a retaliatory reason more likely motivated the manager's decision to terminate her. View "Yearns v. Koss Construction Co." on Justia Law

Plaintiff filed suit against the railroad under the Missouri Human Rights Act (MHRA) and the Family and Medical Leave Act (FMLA), alleging that the railroad discriminated against her on the basis of her gender and her use of FMLA leave when it terminated her. The railroad maintains that plaintiff was terminated as part of a reduction in force (RIF) without discriminatory intent.The Eighth Circuit affirmed the district court's grant of summary judgment to the railroad, holding that the affidavits that the district court relied on were not sham affidavits; plaintiff failed to present any evidence to create a genuine dispute of material fact that her gender was a contributing factor in her termination; the RIF was legitimate and plaintiff failed to demonstrate evidence showing that her gender was a contributing factor in her termination; and thus the district court properly granted the railroad summary judgment on plaintiff's MHRA gender-discrimination claim. Because plaintiff does not offer any direct evidence that the railroad terminated her in the RIF for exercising her FMLA rights, the court analyzed her claim under the McDonnell Douglas burden-shifting framework. In this case, the railroad proffered a legitimate, nondiscriminatory reason for terminating plaintiff and she failed to show that the stated reason was a pretext for FMLA discrimination. View "Button v. Dakota, Minnesota & Eastern Railroad Corp." on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against defendants under 42 U.S.C. 1983 and state law, stemming from plaintiff's acquittal of a first degree murder charge. Plaintiff was a St. Louis Metropolitan Police Department (SLMPD) officer at the time he shot and killed a fleeing suspect.The court held that the district court did not err in dismissing plaintiff's claims against the city prosecutor based on absolute immunity; the prosecutor's decision that there was sufficient evidence to end the investigation, even after only one day, and charge plaintiff with first degree murder clearly falls within the prosecutorial function of initiating judicial proceedings; and, even if the prosecutor's termination of the investigation and initial decision declining to prosecute plaintiff could be construed as indicating that she had an improper motive, allegations of unethical conduct and improper motive in the performance of prosecutorial functions did not defeat the protection of absolute immunity. The court also held that plaintiff failed to state a substantive due process claim against the prosecutor based on her public statements where the conduct did not rise to the level of conscience-shocking. Finally, plaintiff failed to state a defamation claim against the prosecutor.The court also held that the district court did not err in dismissing the section 1983 and malicious prosecution claims against a sergeant in the police department's Internal Affairs Division in his individual capacity. Furthermore, the district court properly dismissed the Monell claim against the city where the prosecutor's decision to terminate the investigation and charge plaintiff was an individual charging decision based upon a particular set of facts supported by arguable probable cause. View "Stockley v. Joyce" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to UPS in an action brought by plaintiff for retaliation and discrimination under 42 U.S.C. 1981. The court held that plaintiff's retaliation claim failed because he cannot link protected conduct with his demotion. In this case, plaintiff concedes that his supervisor and his supervisor's supervisor did not know about the statements plaintiff made on two different occasions. The court also held that plaintiff's race discrimination claim failed at the third step of the McDonnell Douglas framework because UPS provided a legitimate, non-discriminatory basis for the action: plaintiff was failing to perform his duties. Furthermore, plaintiff failed to raise a genuine issue of material fact as to whether UPS's explanation for his demotion was pretext for discrimination. View "Williams v. United Parcel Service, Inc." on Justia Law