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

After defendant pleaded guilty to honest services wire fraud, he claimed that the district court should have dismissed the indictment against him after alleged government misconduct came to light. Defendant was a college president involved in a bribery-and-kickback scheme with three main participants, including a state senator and a business consultant.The Eighth Circuit affirmed, holding that defendant lacked standing to assert a violation of his Sixth Amendment right to counsel and he failed to show the constitutional violation that the senator allegedly suffered specifically affected his right to a fair trial. In this case, the senator's attorney had previously represented a law enforcement agent, who was present at an interview between the senator and government agents, in a divorce proceeding. The court also held that a co-defendant's decision to record numerous conversations was made on his own and there was no government action involved that violated defendant's constitutional rights. Finally, the court held that the agent's decision to erase his laptop's hard drive did not entitle defendant to dismissal. View "United States v. Paris" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after he pleaded guilty to possession of child pornography. The court held that the Leon good-faith exception to the exclusionary ruled applied where law enforcement officers had no indication that the state court judge had failed to understand the affidavit or otherwise acted as a rubber stamp. Therefore, because the officers had no evidence that the judge abandoned his judicial role, they acted in good-faith reliance on the warrant's validity. View "United States v. Dickerman" on Justia Law

Plaintiff, a former detainee at the detention center, filed suit against the sheriff and nurse, alleging that defendants delayed his access to adequate medical treatment for a serious condition while he was detained.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants, holding that there was insufficient evidence to support a submissible case. In this case, the nurse's actions demonstrated concern for plaintiff's condition and showed repeated efforts to make arrangements for surgery. Even if the nurse could be second-guessed for not acting more aggressively when the doctor's office delayed, her handling of the situation was at most negligent and does not amount to deliberate indifference that violates the Due Process Clause. Because plaintiff has not presented sufficient evidence that the nurse was deliberately indifferent to his serious medical needs, it follows that the sheriff did not violate plaintiff's rights by supposedly turning a blind eye to his complaints about the nurse. Likewise, claims against defendants in their official capacities, which are treated as claims against the municipality, failed for lack of a constitutional violation. View "Morris v. Cradduck" on Justia Law

The bankruptcy appellate panel affirmed the bankruptcy court's dismissal of appellants' adversary proceeding against appellees, individually and in their capacity as assignees of Beresford. The panel held that the bankruptcy court correctly determined that the North Dakota state courts possessed concurrent jurisdiction to decide appellants' quiet title action and interpret the Chapter 12 Plan, as well as the incorporated settlement agreement and Beresford Deed. The panel also held that the bankruptcy court properly determined that it must apply North Dakota law (including the parol evidence statute) to determine ownership of the farm, because property interests are created and defined by state law.Furthermore, because the state courts had jurisdiction and determined property interests in accordance with North Dakota law, and because the bankruptcy court properly decided that it would be constrained to follow that law, preemption under the United States Constitution or federal bankruptcy laws does not apply. Finally, the panel held that the Rooker-Feldman doctrine applies and the bankruptcy court correctly concluded that it lacked subject matter jurisdiction to review appellants' claim of ownership, and appellants' claims and causes of action were barred by the doctrine of res judicata. The panel rejected appellants' remaining claims as without merit. View "Finstad v. Gord" on Justia Law

Plaintiff filed suit against Mercy Health, alleging that Mercy's plan management disregards requirements under the Employee Retirement Income Security Act. Mercy asserted that it does not have to comply with ERISA's requirements because the plan falls under ERISA's church-plan exemption pursuant to 29 U.S.C. 1003(b)(2).The Eighth Circuit held that whether a plan is an ERISA plan is an element of the plaintiff's case and not a jurisdictional inquiry. Therefore, the district court erred in dismissing the case for lack of jurisdiction. The court remanded to the district court to determine whether the deprivation of ERISA protections confers Article III standing, and if so, whether the church-plan exemption violates the Establishment Clause. If there is Article III standing, the state law claims should be reinstated pursuant to the court's supplemental jurisdiction. View "Sanzone v. Mercy Health" on Justia Law

Plaintiff filed suit against UND Law under Title II of the Americans With Disabilities Act of 1990 (ADA), alleging that UND Law discriminated against him because of his mental illness when it rejected his admission application.The Eighth Circuit affirmed the district court's grant of summary judgment to UND Law, holding that plaintiff failed to show that UND Law's legitimate, nondiscriminatory reason for rejecting plaintiff's application was pretext for discrimination. The court reasoned that UND Law's holistic approach to application reviews did not discriminate against plaintiff in determining that he would not be a good fit for UND Law. In this case, plaintiff had dropped out of law school three times, had a very low undergraduate GPA, and submitted out-of-date recommendation letters. View "Power v. University of North Dakota School of Law" on Justia Law

The Eighth Circuit denied petitions for review challenging the BIA's interpretation of the Supreme Court's decision in Esquivel–Quintana v. Sessions, 137 S. Ct. 1562 (2017). Petitioner asked the BIA to reopen his proceedings under 8 C.F.R. 1003.2 and 8 U.S.C. 1229a(c)(7), contending that Esquivel–Quintana narrowed what crimes qualify as "sexual abuse of a minor."The court held that the time for filing a motion to reopen was not equitably tolled and thus petitioner's motion was untimely. In this case, petitioner did not raise a colorable constitutional claim, so under currently existing law, the court could not review the BIA's decision not to reopen his case on its own motion. The court declined to recognize a second exception permitting appellate review when the Board relies "on an incorrect legal premise." View "Chong Toua Vue v. Barr" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress images and videos retrieved from his cell phone. The court held that the district court correctly determined that investigators and prosecutors were permitted to use the images and video from defendant's phone that an acquaintance viewed on his own initiative. In this case, the Fourth Amendment does not extend to private searches that are neither instigated nor performed on behalf of a government entity; defendant's acquaintance acted entirely on his own when he searched defendant's cell phone; and the agents examining the phone went no further than the private search when they examined the phone. As to the remainder of the materials found on the phone, the court held that the state investigators reasonably understood the state warrant to authorize a search of the phone. View "United States v. Suellentrop" on Justia Law

The Eighth Circuit affirmed the district court's order granting Jet Midwest and PMC's motion for a preliminary injunction to prevent Appellant Ohadi and Woolley from foreclosing on the assets of JMG until the parties conduct an expedited trial on the merits of the underlying fraudulent transfer act.The court held that the district court properly applied the Dataphase factors and did not abuse its discretion in making the reasonable decision to grant the preliminary injunction to maintain the status quo and expedite the trial to further develop the record. In this case, the district court did not abuse its discretion in determining that Jet Midwest demonstrated a likelihood of success on the merits where there was no dispute that the sale initially contained parts from Jet Midwest's Aircraft and that Jet Midwest had a purchase money interest in the Aircraft; Jet Midwest would suffer irreparable harm if Ohadi and Woolley were allowed to proceed with the foreclosure sale; Ohadi and Woolley's burden is outweighed by the serious potential harm Jet Midwest would face if Ohadi and Woolley conducted a foreclosure sale of its possible interests; and the district court did not abuse its discretion in finding that the public interest favored enforcing the injunction to prevent fraud. View "Jet Midwest International Co. v. Ohadi" on Justia Law

The Eighth Circuit affirmed the district court's determination that Minn. Stat. Sec. 216B.246, subdiv. 2, which grants incumbent electric transmission owners the right of first refusal (ROFR) to construct, own and maintain electric transmission lines that connect to their existing facilities does not violate the dormant Commerce Clause.The court held that the statute was not facially discriminatory and had no discriminatory purpose nor effect. Furthermore, the court dismissed the undue burden claim, because the court could not say that the burden imposed by the ROFR law is clearly excessive in relation to Minnesota’s legitimate state interests in regulating its electric industry and maintaining the status quo. View "LSP Transmission Holdings, LLC v. Sieben" on Justia Law