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

Tyrell Gaston was on probation following a deferred judgment for a robbery that resulted in a gunfight, leaving him injured and his cousin dead. Shortly after, he was involved in two more violent incidents involving firearms, leading to charges of attempted murder and other offenses. Despite these charges being dismissed, Gaston continued to violate probation terms, including being out past curfew. During his arrest for these violations, a probation officer found keys to his truck and, upon questioning, Gaston mentioned a backpack in the truck, which led to a search revealing a loaded gun.The United States District Court for the Northern District of Iowa denied Gaston's motion to suppress the evidence found in the truck, concluding that the search was supported by reasonable suspicion. Gaston had consented to searches as part of his probation agreement, which allowed searches based on reasonable grounds. The district court found that the probation officer had reasonable suspicion to search the truck based on Gaston's history and his reaction to the questioning about the backpack.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the search was justified under the Fourth Amendment's reasonable suspicion standard. The court noted that Gaston's history of violent conduct and his immediate disclaimer of the backpack provided a particularized and objective basis for the search. The court also upheld the district court's credibility determination that the probation officer's decision to search was based on Gaston's suspicious response. The judgment of the district court was affirmed. View "United States v. Gaston" on Justia Law

Cybercriminals hacked into T-Mobile's computer systems, stealing personal information of approximately 76.6 million customers. Several customers filed class action lawsuits against T-Mobile, which were centralized in the U.S. District Court for the Western District of Missouri. The parties reached a settlement, with T-Mobile agreeing to create a $350 million fund for affected customers and to spend an additional $150 million on data security improvements. Class counsel requested $78.75 million in attorneys' fees, which two class members, Cassie Hampe and Connie Pentz, objected to as excessive.The district court struck Hampe's and Pentz's objections and overruled them on the merits. The court found Hampe's objection to be in bad faith, influenced by her attorneys' history as serial objectors, and struck it under Federal Rule of Civil Procedure 12(f). Pentz's objection was struck as a discovery sanction after she refused to cooperate with class counsel's discovery efforts. Both objectors appealed the district court's decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court abused its discretion in striking Hampe's objection, as Rule 12(f) does not apply to objections and there was no evidence of bad faith in this case. The court also found that the district court erred in awarding attorneys' fees, determining that the fee award was unreasonable given the relatively short duration and limited discovery of the case. The court affirmed the decision to strike Pentz's objection but reversed the decision to strike Hampe's objection and the award of attorneys' fees, remanding for further proceedings. View "Daruwalla v. Hampe" on Justia Law

The case involves three plaintiffs: Rockne Miller, a former Missouri legislator; John LaVanchy, a committee-records specialist currently working for the General Assembly; and Presidio Environmental, LLC, a company that sought to hire Miller as a lobbyist. They challenged a recent amendment to the Missouri Constitution that imposes a two-year ban on lobbying for former legislators and staff. Miller and LaVanchy argued that the ban prevented them from becoming lobbyists, while Presidio claimed it hindered their ability to hire Miller for lobbying purposes.The United States District Court for the Western District of Missouri granted summary judgment in favor of the Missouri Ethics Commission, upholding the lobbying ban. The court found that the ban was consistent with the First Amendment because it was narrowly tailored to further a compelling state interest in preventing corruption or the appearance of corruption.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court determined that the lobbying ban burdens political speech and thus must be subjected to strict scrutiny. The court found that Missouri failed to provide sufficient evidence of actual corruption or the appearance of corruption that the ban purportedly aimed to prevent. The court also concluded that the ban was not narrowly tailored, as it was both over-inclusive and under-inclusive, regulating too broadly and not addressing the specific issue of corruption effectively.The Eighth Circuit held that the two-year lobbying ban, as applied to the plaintiffs, violated the First Amendment. The court reversed the district court's judgment and remanded the case for further proceedings. View "Miller v. Ziegler" on Justia Law

The case involves a pass-through billing scheme orchestrated by Beau Gertz, Mark Blake, SeroDynamics, and LabMed Services (collectively, the Sero Defendants). They made it appear that blood tests conducted at their Colorado lab were performed at a small hospital in Unionville, Missouri, resulting in a $26.3 million profit. The scheme involved billing Blue Cross using the hospital's provider numbers, despite the tests not being conducted there. Blue Cross paid the hospital $18,053,015 for these tests. The Sero Defendants were found liable for fraud, tortious interference with contract, civil conspiracy, and money had and received.The United States District Court for the Western District of Missouri oversaw the trial. After five days of evidence, the jury found the Sero Defendants liable and awarded Blue Cross $18,053,015 in compensatory damages and $1.9 million in punitive damages against each of the four Sero Defendants. The Sero Defendants appealed, raising multiple claims of error, including the exclusion of their lead counsel from delivering closing arguments and the admission of certain evidence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's judgments, finding no abuse of discretion in the exclusion of lead counsel from closing arguments due to repeated misconduct. The court also upheld the admission of a portion of an audit report, finding it relevant and not unfairly prejudicial. The court found sufficient evidence to support the jury's findings of fraud and tortious interference, noting that the Sero Defendants had actual knowledge of the contract between Putnam and Blue Cross and intentionally interfered with it. The court also upheld the jury's award of damages and punitive damages, finding no miscarriage of justice.In conclusion, the Eighth Circuit affirmed the district court's judgments, rejecting all of the Sero Defendants' claims of error. View "RightCHOICE Managed Care v. Labmed Services, LLC" on Justia Law

Joshua Francisco, an inmate at Farmington Correctional Center (FCC), suffered from mental illness and was placed on suicide watch multiple times during his incarceration. Despite receiving treatment and being evaluated by mental health professionals, Francisco was found hanging in his cell on October 22, 2014, after his cellmate reported he was suicidal. Francisco had denied being suicidal to correctional officers and mental health staff earlier that day.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the correctional officers and the warden, finding no deliberate indifference to Francisco's medical needs. The court determined that the officers' actions did not rise to the level of criminal recklessness required to establish a violation of the Eighth Amendment.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the correctional officers and the warden were entitled to qualified immunity. The court found that the officers had conducted reasonable investigations and searches based on the information available to them and that Francisco's repeated denials of suicidal intent, along with the absence of a noose, did not indicate a strong likelihood of self-harm. The court also concluded that the warden was not personally involved in any unconstitutional custom or practice and that the claim of an unconstitutional policy requiring inmates to explicitly state they were suicidal was not supported by the evidence. View "Francisco v. Villmer" on Justia Law

The State of South Dakota charged Ronald Lee Neels with multiple sex-related offenses, including rape, sexual contact, and incest, for the sexual abuse of his adopted daughter over a 14-year period. During the trial, the prosecutor made an opening statement that asked the jury to imagine themselves in the victim's position, which is considered a "Golden Rule" argument and is generally condemned. Neels did not object to this statement at the time. Following his conviction, Neels filed a pro se petition for a writ of habeas corpus, claiming ineffective assistance of counsel for not objecting to the prosecutor's opening statement.The South Dakota Supreme Court summarily affirmed Neels's conviction on direct appeal, stating that the issues raised were without merit. Neels then filed a state habeas corpus petition, which was denied on the grounds of res judicata, as the court found that the issue of prejudice had already been decided on direct appeal. The South Dakota Supreme Court affirmed this decision, holding that the same standard of prejudice applied in both plain error review and ineffective assistance of counsel claims.Neels subsequently filed a federal habeas corpus petition under 28 U.S.C. § 2254. The district court granted the petition, concluding that Neels suffered prejudice from his attorneys' failure to object to the prosecutor's opening statement, despite acknowledging the overwhelming evidence of Neels's guilt. The court reasoned that the magnitude of the prosecutorial misconduct required vacating the conviction to ensure a fair trial.The United States Court of Appeals for the Eighth Circuit reversed the district court's decision. The appellate court held that Neels did not suffer Strickland prejudice from his counsel's failure to object to the prosecutor's opening statement, given the overwhelming evidence of his guilt. The court emphasized that the jury instructions and the strength of the evidence against Neels mitigated any potential prejudice from the prosecutor's improper remarks. View "Neels v. Fluke" on Justia Law

In 2020, a student organization at the University of Minnesota-Twin Cities, along with two students, sued the University for alleged First and Fourteenth Amendment violations. The case centered on the University's allocation of lounge space in the Coffman Memorial Union to certain student organizations, particularly nine cultural centers. The plaintiffs argued that this allocation constituted viewpoint discrimination and gave unbridled discretion to University officials.The United States District Court for the District of Minnesota dismissed three of the five claims and later granted summary judgment in favor of the University on the remaining claims. The court found no evidence of viewpoint discrimination and deemed the unbridled discretion doctrine inapplicable to the University's past allocation decision. The plaintiffs appealed the summary judgment on one claim.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court agreed that the lounge space was a limited public forum and found that the University's allocation process was viewpoint neutral and reasonable. The court noted that the plaintiffs failed to provide evidence of viewpoint discrimination and that the University's decision was based on status-based distinctions, not viewpoint-based ones. The court also upheld the district court's finding that the unbridled discretion doctrine did not apply, as the challenge was to a past decision rather than an ongoing policy.The Eighth Circuit affirmed the district court's summary judgment, concluding that the University's allocation of lounge space did not violate the First Amendment. View "Viewpoint Neutrality Now! v. Regents of the University of Minnesota" on Justia Law

On December 26, 2019, Officers Rozeboom and Malone responded to a shoplifting report at Dick’s Sporting Goods in Papillion, Nebraska. The suspects were described as a black male and black female in a silver four-door sedan. Malone spotted a similar vehicle and conducted a traffic stop. Storrs, a black male, was driving, and Smith, a white female, was the passenger. Despite the discrepancy in the suspect description, the officers detained Storrs and Smith. During the encounter, Storrs and Smith were uncooperative, leading to their arrest and a search of their vehicle, which allegedly smelled of marijuana.The United States District Court for the District of Nebraska granted summary judgment in favor of the officers, finding they were entitled to qualified immunity on all claims. The court determined that the officers had reasonable suspicion for the initial stop and probable cause for the continued detention and search based on the alleged odor of marijuana. The court also found no evidence of excessive force or First Amendment retaliation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision in part, agreeing that the officers had probable cause to arrest Storrs and Smith for obstructing a peace officer and that there was no evidence of excessive force or First Amendment retaliation. However, the court reversed the summary judgment on the claim of unlawful continued detention, finding that the officers lacked reasonable suspicion once they saw Smith was white. The court also found a genuine dispute of fact regarding the alleged odor of marijuana, precluding summary judgment on the illegal search claim. The case was remanded for further proceedings consistent with these findings. View "Storrs v. Rozeboom" on Justia Law

Allan Sanders, a foreman general at Union Pacific Railroad Company, sued his employer under the Americans with Disabilities Act (ADA). Sanders claimed that Union Pacific discriminated against him by imposing work limitations due to perceived cardiovascular health issues and by failing to provide a reasonable accommodation during a cardiovascular test. Sanders had suffered a brief cardiac arrest due to complications from a bleeding ulcer but had fully recovered. Union Pacific required him to undergo a fitness-for-duty evaluation, including a treadmill test, which he could not complete due to knee pain from osteoarthritis. Sanders requested an alternative test on a bicycle, which Union Pacific denied, leading to work restrictions that prevented him from returning to his job.The United States District Court for the District of Nebraska denied Union Pacific’s renewed motion for judgment as a matter of law after a jury found in favor of Sanders on both claims and awarded him damages. Union Pacific appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that there was sufficient evidence for a reasonable jury to conclude that Union Pacific regarded Sanders as disabled due to perceived cardiovascular issues and that Sanders was qualified to perform his job. The court also found that Union Pacific’s refusal to allow an alternative test constituted a failure to provide reasonable accommodation. The court rejected Union Pacific’s “direct threat” defense, concluding that the company’s decision was not objectively reasonable or based on the best available evidence. The appellate court upheld the jury’s verdict on both the disparate treatment and failure-to-accommodate claims. View "Sanders v. Union Pacific Railroad Co." on Justia Law

Enright Seeding, Inc. is involved in a dispute with the International Union of Operating Engineers, Local 150, AFL-CIO, regarding the nature of their collective bargaining agreement. Enright Seeding, a construction industry subcontractor, signed a bargaining agreement with the union in 2007, which included language suggesting it was a § 9(a) agreement under the National Labor Relations Act, indicating majority employee support for the union. The company later claimed that its obligations ended when it repudiated the contract in 2016. The union, however, argued that the agreement was a § 9(a) agreement and that the company violated the Act by not providing requested information.An administrative law judge determined that the agreement was a § 9(a) agreement and that Enright Seeding violated Sections 8(a)(1) and (5) of the Act by failing to provide the requested information. The judge also concluded that even if the agreement was under § 8(f), the company did not clearly repudiate it. A three-member panel of the National Labor Relations Board (NLRB) affirmed this decision, focusing on the § 9(a) status and not addressing the repudiation issue.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the NLRB's decision was not supported by substantial evidence, as there was no actual evidence of majority employee support for the union in 2007, only boilerplate contract language. The court emphasized that all evidence must be considered to determine the status of the relationship, and mere contract language is insufficient. The court also rejected the argument that Enright Seeding was barred from disputing the agreement's status due to the six-month limitation period in § 10(b) of the Act.The Eighth Circuit vacated the NLRB's order and remanded the case for further proceedings, without expressing a view on whether Enright Seeding had effectively repudiated the agreement or whether the union was entitled to the requested information under a § 8(f) agreement. View "NLRB v. Enright Seeding, Inc." on Justia Law