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

Michelle Collins, a black woman, worked at Union Pacific Railroad Company for 42 years, holding over twenty positions. She alleged that several managers discriminated against her based on race, including assigning her unpleasant tasks and increasing her workload. Collins also reported conflicts with a coworker, Rhonda VanLew, who allegedly made her job more difficult. In 2020, Collins filed an internal complaint about VanLew, and VanLew also filed a complaint against Collins. A Union Pacific analyst concluded that the conflict was appropriately resolved by local management.The United States District Court for the Western District of Missouri granted summary judgment in favor of Union Pacific. The court found that Collins could not establish a prima facie case of race discrimination or retaliation because she did not suffer an adverse employment action. Additionally, the court ruled that Collins's hostile work environment claim failed as she could not prove severe or pervasive harassment based on her race.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the summary judgment on the hostile work environment claim, agreeing that Collins did not sufficiently oppose the summary judgment on this ground in the lower court. However, the court reversed and remanded the discrimination and retaliation claims. The appellate court noted that the district court's analysis relied on outdated legal standards requiring a "materially significant disadvantage," which the Supreme Court had recently clarified was not necessary. The case was sent back to the district court to reconsider these claims under the correct legal framework. View "Collins v. Union Pacific Railroad Co." on Justia Law

The case involves a dispute over a Surface Use Agreement (SUA) between Mikkelson Land, LLLP, and Continental Resources, Inc. The disagreement centers on whether the SUA authorized Continental to install water pipelines on Mikkelson's property. Mikkelson claimed that the SUA did not permit such installations and filed a lawsuit alleging breach of contract, trespass, and seeking injunctive relief. Continental argued that the SUA explicitly allowed for the installation of water pipelines and moved forward with the project, compensating Mikkelson as per the SUA terms.The United States District Court for the District of North Dakota reviewed the case and granted summary judgment in favor of Continental. The court found that the SUA was unambiguous and explicitly authorized Continental to install water pipelines. The court also noted that the SUA included provisions for compensation related to the installation of such pipelines. Additionally, the court considered an addendum to the SUA, which expanded Continental's rights and further supported the installation of the pipelines. The district court concluded that Continental's actions were within the scope of the SUA and dismissed Mikkelson's claims.The United States Court of Appeals for the Eighth Circuit reviewed the appeal and affirmed the district court's decision. The appellate court agreed that the SUA's language was clear and unambiguous, granting Continental the right to install water pipelines. The court emphasized that the SUA specifically contemplated future installations of water pipelines and provided a payment structure for them. The court also found that the addendum to the SUA expanded Continental's rights, allowing for necessary operations, including the installation of water pipelines. Consequently, the appellate court upheld the summary judgment in favor of Continental, rejecting Mikkelson's arguments. View "Mikkelson Land, LLLP v. Continental Resources, Inc." on Justia Law

Kenneth Hunt arrived at the Lee County Courthouse to testify in a criminal case. Directed outside due to courtroom scheduling, Hunt re-entered and sat on a staircase. Officer Dale Acosta confronted Hunt, leading to a heated exchange. Despite Hunt's explanation of his courthouse business, Acosta arrested him for obstruction, claiming Hunt disrupted the county tax office.The United States District Court for the Eastern District of Arkansas dismissed most of Hunt's claims but allowed his Fourth Amendment claim against Acosta, a failure to train or supervise claim against Mayor Jimmy Williams and Chief of Police Martin Wilson, and a Monell claim against the City of Marianna. The court denied qualified and quasi-judicial immunity for Acosta and qualified immunity for Williams and Wilson. Acosta, Williams, and Wilson appealed the denial of immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court's denial of quasi-judicial immunity for Acosta's initial stop of Hunt, as Acosta acted under a judge's directive. However, the court affirmed the denial of quasi-judicial and qualified immunity for Acosta's arrest of Hunt, finding no probable cause for obstruction. The court also reversed the denial of qualified immunity for Williams and Wilson, ruling that Hunt failed to show a pattern of unconstitutional acts by Acosta that would have put them on notice. The case was remanded for further proceedings consistent with these findings. View "Hunt v. Acosta" on Justia Law

Frank Bibeau, a member of the Minnesota Chippewa Tribe, argued that his self-employment income from his law practice on the Leech Lake Reservation was exempt from federal taxation. For the 2016 and 2017 tax years, Bibeau reported his income on a joint federal income tax return with his wife, claiming a net operating loss carryforward that shielded his income from taxes but not from self-employment taxes. After receiving a notice from the IRS regarding his tax debts, Bibeau requested a Collection Due Process (CDP) hearing, arguing his income was exempt. The IRS disagreed and issued a notice of determination to collect the tax.Bibeau petitioned the United States Tax Court, asserting that Indians are generally exempt from federal taxes or that treaties between the U.S. and the Chippewa exempted his income. The Tax Court ruled against him, stating that Indians are subject to federal tax laws unless a specific law or treaty provides otherwise. The court found that neither the Indian Citizenship Act of 1924 nor the 1837 Treaty between the U.S. and the Minnesota Chippewa Tribe contained a specific exemption from federal taxation.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that as U.S. citizens, Indians are subject to federal tax requirements unless specifically exempted by a treaty or act of Congress. The court found that Bibeau failed to point to any statute or treaty that specifically exempted his self-employment income from taxation. The court also noted that the Indian Citizenship Act of 1924 and the 1837 Treaty did not provide such an exemption. Consequently, the Eighth Circuit affirmed the Tax Court’s decision, holding that Bibeau’s self-employment income is subject to federal self-employment taxes. View "Bibeau v. CIR" on Justia Law

Dalonte Foard and his uncle, Thomas Holbert, picked up two foster youths, M.D. and M.J., from their foster home. M.D. and M.J. were taken to a motel where Holbert took provocative photos of them to include in online prostitution advertisements. Holbert attempted to set up the minors with sex buyers but was unsuccessful. Eventually, M.D. left, leaving M.J. at the motel with Foard and his girlfriend, Tashian Hickman. Foard pressured M.J. to engage in sex acts and later created an online prostitution advertisement for her. A sex buyer, Michael Blue, paid for sex acts with M.J., and Foard took a portion of the money. M.J. was later returned to her foster home, and her foster mother called the police.A grand jury indicted Foard for conspiracy to engage in sex trafficking and sex trafficking of M.J. and M.D. The jury found Foard guilty of conspiracy to engage in sex trafficking and sex trafficking of M.J. but acquitted him of sex trafficking M.D. The United States District Court for the District of Nebraska sentenced Foard to 45 years of imprisonment followed by lifetime supervision.The United States Court of Appeals for the Eighth Circuit reviewed the case. Foard raised several challenges, including issues with jury instructions, admission of out-of-court statements, denial of his motion for acquittal, sentencing adjustments, and the substantive reasonableness of his sentence. The court found that the jury instructions permissibly narrowed the indictment, the out-of-court statements were admissible under the co-conspirator exclusion to hearsay, and there was sufficient evidence to support the jury's verdict. The court also upheld the sentencing enhancements for undue influence of a minor, use of electronic communications, vulnerable victim, and obstruction of justice. The court found no error in the district court's denial of a mitigating role reduction and concluded that the 45-year sentence was substantively reasonable. The Eighth Circuit affirmed the district court's judgment. View "U.S. v. Foard" on Justia Law

Colton Bagola was convicted of first-degree murder and discharge of a firearm during a crime of violence after shooting Sloane Bull Bear in the back of the head at a gathering in Pine Ridge, South Dakota. Witnesses testified that Bagola shot Bull Bear from approximately one inch away. Following the incident, Bagola and others fled the scene, and Bull Bear's body was found in the exterior doorway. Bagola was indicted on multiple charges, including first-degree murder and tampering with evidence. The district court severed the conspiracy count and granted a motion for acquittal on the tampering charge. The jury convicted Bagola of first-degree murder and discharge of a firearm during a crime of violence, and he was sentenced to life imprisonment.The United States District Court for the District of South Dakota handled the initial trial. After the jury's guilty verdict, Bagola filed a motion for judgment of acquittal, which the district court denied. Bagola then appealed his conviction, raising several challenges, including the admission of expert testimony, the adequacy of jury instructions regarding his "Indian" status, the sufficiency of evidence for premeditated first-degree murder, and whether premeditated first-degree murder qualifies as a crime of violence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that any error in admitting expert testimony was harmless due to the overwhelming evidence against Bagola. The court also determined that the district court's failure to properly instruct the jury on the "Indian" status element did not affect Bagola's substantial rights, given the uncontroverted evidence of his tribal membership. Additionally, the court held that there was sufficient evidence to support the jury's finding of premeditation. Finally, the court ruled that premeditated first-degree murder is categorically a "crime of violence" under 18 U.S.C. § 924(c). The Eighth Circuit affirmed Bagola's convictions. View "United States v. Bagola" on Justia Law

Officer Daniel Irish, while pursuing a suspect, was bitten by a police K9 named Thor, handled by Deputy Keith McNamara. Irish sued McNamara under 42 U.S.C. § 1983, claiming a violation of his Fourth Amendment rights due to excessive force and unreasonable seizure. The incident occurred during a high-speed chase that ended in a cemetery, where McNamara deployed Thor without a leash. Irish, unaware of the K9's presence, was bitten by Thor, who was commanded to "get him" by McNamara.The United States District Court for the District of Minnesota denied McNamara's motion to dismiss based on qualified immunity. The court reasoned that it was clearly established that a seizure occurred under the Fourth Amendment, despite acknowledging the incident as a "highly unfortunate accident."The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on whether it was clearly established that the K9's bite constituted a seizure under the Fourth Amendment. The court noted that for a seizure to occur, an officer must intentionally apply physical force or show authority to restrain an individual's freedom of movement. The court found that the law was not clearly established regarding whether an officer's subjective intent was necessary for a seizure. The court concluded that McNamara did not subjectively intend to seize Irish, as evidenced by his commands to Thor to disengage and his immediate actions to restrain the K9.The Eighth Circuit held that it was not clearly established that an officer could seize a fellow officer with a K9 without subjectively intending to do so. Therefore, McNamara was entitled to qualified immunity. The court reversed the district court's decision and remanded with instructions to dismiss Irish's complaint. View "Irish v. McNamara" on Justia Law

Jackie Davidson was convicted of assaulting federal officers with a deadly weapon and discharging a firearm during a crime of violence after he shot at an SUV, mistakenly believing it was driven by a man named Omar, who Davidson suspected of criminal activities. The SUV was actually driven by federal law enforcement officers. Davidson fired at the vehicle after it passed him, thinking he was in imminent danger.The United States District Court for the Eastern District of Arkansas barred Davidson from arguing self-defense at trial, concluding that he did not act out of a reasonable belief of imminent harm. The court also ruled that under United States v. Feola, the government did not need to prove that Davidson knew his victims were federal officers. At trial, the jury found Davidson guilty of assaulting federal officers and discharging a firearm during a crime of violence, but acquitted him of other charges. Davidson was sentenced to 120 months and 1 day in prison and 3 years of supervised release.The United States Court of Appeals for the Eighth Circuit reviewed Davidson's appeal, which raised three arguments: the district court erred in prohibiting his self-defense claim, the government needed to prove he knew his victims were federal officers, and the jury instructions were flawed. The appellate court affirmed the district court's decisions, holding that Davidson did not meet the burden of production for a self-defense claim, Feola was still binding precedent, and the jury instructions were adequate. The court concluded that Davidson's conviction should be upheld. View "United States v. Davidson" on Justia Law

Clyde O. Carter, Jr. filed a complaint under the Federal Rail Safety Act (FRSA) against BNSF Railway Company, alleging retaliation for reporting a work-related injury. Carter claimed that BNSF initiated disciplinary investigations and terminated him due to his injury report. Initially, an administrative law judge (ALJ) found in favor of Carter, and the Administrative Review Board (ARB) affirmed. However, the United States Court of Appeals for the Eighth Circuit vacated the ARB’s order and remanded the case for further proceedings.The Occupational Safety and Health Administration initially found no FRSA violation by BNSF. After Carter objected, the case was transferred to an ALJ, who ruled in Carter’s favor. The ARB affirmed, but the Eighth Circuit vacated this decision, citing errors in the ALJ’s causation theory and lack of substantial evidence supporting the ARB’s findings. On remand, a different ALJ found that Carter’s injury report was not a contributing factor in BNSF’s decisions to investigate and terminate him, attributing the actions to Carter’s dishonesty. The ARB affirmed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and denied Carter’s petition for review. The court held that substantial evidence supported the ALJ’s findings that Carter’s injury report did not contribute to BNSF’s decision to terminate him. The court also found no procedural errors in the ALJ’s handling of the case on remand. Consequently, the court concluded that Carter failed to prove that his injury report was a contributing factor in his termination, and thus, BNSF was not liable under the FRSA. The petition for review was denied. View "Carter v. Secretary, Department of Labor" on Justia Law

Kevin Bordeaux pled guilty to assault with a dangerous weapon, using and carrying a firearm during a crime of violence, and assaulting, resisting, and impeding a federal officer. On July 6, 2022, Bordeaux shot his girlfriend, Megan Hawk, in the hip and fled the scene. Two days later, he led law enforcement on a high-speed chase, during which he and an accomplice fired at officers. Bordeaux was subsequently captured and indicted on multiple charges.The United States District Court for the District of South Dakota sentenced Bordeaux based on an offense level of 29 and a Criminal History Category of III, resulting in a Guidelines range of 108 to 135 months. This calculation was based on the Presentence Investigation Report (PSR), which initially included a five-level enhancement for discharging a firearm. Bordeaux objected to the addition of two criminal history points, which the court sustained, reducing his Criminal History Category from IV to III. However, the court mistakenly maintained the offense level at 29 instead of 28, leading to the incorrect Guidelines range.The United States Court of Appeals for the Eighth Circuit reviewed the case. The government conceded that the district court had miscalculated the Guidelines range, but argued that the error did not prejudice Bordeaux. The Eighth Circuit disagreed, noting that the correct Guidelines range should have been 97 to 121 months. The court found that the miscalculation affected Bordeaux’s substantial rights and the fairness of the judicial proceedings, as there was a reasonable probability that the district court would have imposed a lower sentence within the correct range. Consequently, the Eighth Circuit remanded the case to the district court for resentencing under the correct Guidelines range. View "United States v. Bordeaux" on Justia Law