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

Plaintiff filed suit against several prison officials in their individual capacities under 42 U.S.C. 1983, challenging a disciplinary adjudication, conditions of confinement, adequacy of medical treatment, and alleged retaliatory acts. The district court denied motions to dismiss and for summary judgment.The Eighth Circuit held that officials were entitled to a ruling on their defense of qualified immunity as to the Eighth Amendment claims in Count II. Because the order granting the motion for reconsideration effectively denied the officials' motion to dismiss without ruling on qualified immunity, the court remanded the case for further proceedings to address the question of qualified immunity on Count II. As to the remaining claims, the court held that the district court did not abuse its discretion by determining that the officials failed to properly plead or carry their burden of proof as to any defenses of privileges and immunities. Accordingly, the court rejected the challenge to the order denying summary judgment on the remaining counts. View "Spann v. Lombardi" on Justia Law

A student and her parents filed suit against the Minnesota Department of Education, alleging that the school district's failure to classify the student as disabled denied her the right to a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). The ALJ concluded that the school district's treatment of the student violated the IDEA and related state special-education laws. The district court then denied the school district's motion for judgment on the administrative record and granted, in part, the student's motion for judgment on the record, modifying the award of compensatory education.The Eighth Circuit held that the district court did not abuse its discretion in denying the school district's request for supplementation of the record; the school district's evaluation of the student was insufficiently informed and legally deficient; the student is eligible for special education and a state-funded FAPE like every other child with a disability; the ALJ and the district court did not err in concluding the school district had breached its obligation to identify the student by the spring of her eighth-grade year as a child eligible for special education; and the district court did not err in finding plaintiffs were entitled to recover the costs associated with comprehensive psychological evaluation, educational evaluation and private educational services. However, the court reinstated the ALJ's award of compensatory education costs. View "Independent School District No. 283 v. E.M.D.H." on Justia Law

The Eighth Circuit affirmed defendant's conviction of drug trafficking and firearms offenses. The court held that the district court's jury instructions adequately covered the substance of defendant's proposed instruction on "mere presence" and the district court did not abuse its discretion in rejecting defendant's proposed instruction. In this case, defendant's proposed mere presence instruction would have been largely duplicative, and the instructions as a whole already conveyed that the government must prove more than proximity to the gun and drugs in order to convict. View "United States v. Franklin" on Justia Law

The Eighth Circuit reversed the district court's order affirming the ALJ's denial of plaintiff's application for disability benefits. The court held that the ALJ's error in failing to provide good reason for giving plaintiff's treating psychiatrist's opinion limited weight was not harmless error. In this case, the failure to comply with SSA regulations is more than a drafting issue, it is legal error. Furthermore, the court cannot determine whether the ALJ would have reached the same decision denying benefits, even if the ALJ had followed the proper procedure for considering and explaining the value of the psychiatrist's opinion. Accordingly, the court remanded for further administrative proceedings and for reconsideration of plaintiff's claims. View "Lucus v. Saul" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to plaintiff's former employer, Con-E-Co, on plaintiff's sex discrimination claim, her sexual harassment claim, and her retaliation claims under Title VII of the Civil Rights Act of 1964, and the Nebraska Fair Employment Practice Act.The court held that plaintiff failed to establish a prima facie case of sex discrimination because she did not demonstrate that she met Con-E-Co's legitimate job expectations or that Con-E-Co treated her differently than similarly situated male employees; the district court did not err in granting summary judgment to Con-E-Co regarding her sexual harassment claim based on vulgar behavior directed at her by her coworkers, because plaintiff failed to demonstrate that she subjectively perceived the alleged harassment as abusive; and plaintiff failed to establish a prima facie case for retaliation in response to either her race discrimination or sex discrimination complaints. View "Gibson v. Concrete Equipment Co., Inc." on Justia Law

The Ritchie entities filed suit seeking to recover millions of dollars they loaned Tom Petters, a convicted fraudster, and two of his companies. The Ritchie entities alleged that defendants helped conceal the fraud so that they could recover millions they had tied up with Petters' companies. The district court dismissed the claims as time-barred.The Eighth Circuit first held that the district court had subject matter jurisdiction under the Edge Act, and the court need not decide whether the district court also had subject matter jurisdiction under 28 U.S.C. 1334(b). Furthermore, the district court was correct to apply New York choice-of-law principles to determine that Illinois law applied to the question of whether the action was time-barred.The court also held that the district court erred in concluding that Illinois's statute of limitations applied to three of the plaintiffs because the pleadings do not definitively establish their claims accrued in Illinois. The district court did not err in finding that the remaining claims were untimely under Illinois law and that the doctrines of discovery rule, equitable estoppel, and equitable tolling did not apply. The court also held that the district court did not abuse its discretion by failing to grant the Ritchie entities leave to amend their complaint yet again because the Ritchie entities failed to submit a motion to amend or indicate what a proposed amended pleading would have stated. Finally, the court reversed the dismissal of the Ritchie Cayman entities' claims against JP Morgan Europe in order for the district court to permit jurisdictional discovery if it deems necessary to determine whether it has personal jurisdiction over JP Morgan Europe. View "Ritchie Capital Management v. JP Morgan Chase & Co." on Justia Law

Defendant's prior Arkansas convictions for possession of child pornography qualified as prior convictions under 18 U.S.C. 2252A(b)(1). The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to receipt of child pornography. The court held that defendant's contention that the Arkansas statute punished more conduct than its federal counterpart is foreclosed by this court's decision in United States v. Mayokok, 854 F. 3d 987 (8th Cir. 2017). In this case, defendant's prior convictions related to the possession of child pornography. View "United States v. Box" on Justia Law

After apprentice electrician Timothy Sky was seriously burned by an arc flash while connecting wires from a new electrical panel at the ADM corn processing plant, Jacobs was cited for a single serious violation of 29 C.F.R. 1910.335(a)(1)(i) for failing to ensure that Sky was wearing appropriate personal protective equipment (PPE). The ALJ upheld the citation and the Commission denied Jacobs' administrative appeal.The Eighth Circuit denied the petition for review, holding that substantial evidence on the record supports the ALJ's finding that Jacobs knew or should have known of the need to reevaluate its permissive PPE policy when Sky was told he had not finished the work. The court rejected Jacobs' contentions that the ALJ erred in failing to establish an affirmative defense; Sky violated its work rule requiring employees to stay within the scope of their assigned work; 29 C.F.R. 1910.335(a)(1)(i) does not impose a legal duty on employers to ensure that employees wear appropriate PPE; and the citation mistakenly stated that Sky was terminating the ground wire when the arc flash occurred. The court concluded that Jacobs' contentions were either without merit or did not warrant vacating the ALJ's final decision. View "Jacobs Field Services North America, Inc. v. Scalia" on Justia Law

After the district court granted defendant's motion to stay the execution, the execution date passed, and the government appealed. Defendant argued that the government's appeal is moot because the execution date has passed and the execution has not been rescheduled.The Eighth Circuit held that there is a live controversy over the validity of the district court's ongoing injunction. Furthermore, that another district court also had enjoined defendant's execution on different grounds, does not preclude the government from appealing this order too. The court held that the district court applied the incorrect legal standard in relying on Chambers v. Bowersox, 197 F.3d 308 (8th Cir. 1999) (per curiam), to justify a stay of execution pending a decision by the Supreme Court in Banister v. Davis, No. 18-6943. Therefore, an appreciable chance that Banister could allow for additional judicial consideration of defendant's previously denied Rule 59(e) motion was not sufficient to justify a stay of execution. The court vacated the district court's order. View "United States v. Lee" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute methamphetamine and six related gun and money laundering counts. The court held that the inventory search of defendant's motorcycle was lawful and the district court did not err in denying defendant's motion to suppress evidence. In this case, the inventory search was not a pretext for an investigatory search where the district court did not clearly err in crediting the officer's testimony that he towed the motorcycle because defendant lacked the proper endorsement and had no insurance. Furthermore, the officer towed the vehicle because defendant could not lawfully drive the vehicle and the vehicle was a safety hazard on the street.The court also held that defendant's 460 month sentence was substantively reasonable where the district court discussed the 18 U.S.C. 3553(a) factors. Although the district court did not expressly discuss defendant's mental health and emotional issues as mitigating factors, the court indicated that it had reviewed his sentencing memorandum that identified these mitigating factors. View "United States v. Nevatt" on Justia Law