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

The Eighth Circuit reversed the district court's grant of defendant's motion to dismiss plaintiff's action alleging a claim under the Americans with Disabilities Act (ADA). The court held that the district court erred by dismissing plaintiff's claim where plaintiff's allegations were sufficient to state a claim based on the statutory elements of the ADA. In this case, plaintiff has plausibly alleged that defendant refused to consider rehiring him because of his disability. The court also held that plaintiff's request for leave to amend was not futile and should have been granted. View "Cook v. George's, Inc." on Justia Law

Plaintiff filed suit against Continental, seeking damages for breach of contract, bad faith, and misrepresentation, and declaratory relief. The district court dismissed all claims, holding that TLC, the registered residential living center plaintiff had moved into, was not a covered provider.The Eighth Circuit applied South Dakota law and considered the interpretation of the Qualified Long Term Care insurance policy de novo, holding that the district court properly granted summary judgment to Continental. In this case, the policy excluded TLC because TLC was not an "assisted living center" under South Dakota law. View "Van Dusseldorp v. Continental Casualty Co." on Justia Law

Plaintiff filed suit against several out-of-state defendants in Minnesota state court, alleging that defendants participated in a fraudulent scheme. After defendants removed to federal district court, the case was dismissed based on lack of personal jurisdiction. The Eighth Circuit affirmed the district court's dismissal, holding that plaintiff was the only connection between Minnesota and the underlying dispute. In this case, requiring defendants to litigate this action in Minnesota would offend due process because defendants' contacts were insufficient to confer specific jurisdiction. View "Pederson v. Frost" on Justia Law

The Eighth Circuit affirmed the denial of social security disability benefits to plaintiff, holding that substantial evidence supported the ALJ's residual functional capacity (RFC). The court held that the ALJ's finding that plaintiff can perform frequent but not constant grasping, handling, and fingering with her right arm is supported by substantial evidence. View "Pemberton v. Saul" on Justia Law

The Eighth Circuit reversed the Bankruptcy Appellate Panel's (BAP) conclusion that Lariat's claim against debtor no longer exists because her husband discharged his liabilities in an earlier bankruptcy. Rather, the court affirmed the bankruptcy court's allowance of Lariat's claim based on the fraudulent-transfer judgment. The court held that the husband's discharge did not extinguish debtor's liability because it did not cover all the money owed, and that Lariat's claim against debtor is capped under 11 U.S.C. 502(b)(6). View "Lariat Companies, Inc. v. Wigley" on Justia Law

The Eighth Circuit denied a petition for review of the BIA's denial of petitioner's application for asylum based on his claim that he belonged to a particular social group of "individuals with schizophrenia who exhibit erratic behavior." The BIA found that there was no connection between the alleged persecution and the social group.The court held that the BIA did not err in concluding that petitioner failed to establish that he would be subjected to persecution on account of his membership in the alleged social group. In this case, the record was not so substantial that a reasonable factfinder would have to conclude that Mexico's government targets individuals on account of group membership. Rather, the BIA noted that economic considerations, as well as political considerations, contributed substantially to the regrettable institutional conditions. View "Perez-Rodriguez v. Barr" on Justia Law

Plaintiff, a former police officer, filed a 42 U.S.C. 1983 action against the city and the chief of police, alleging unlawful retaliation for exercising his First Amendment right to participate in a media interview, deprivation of his right to pretermination process, and violation of his rights under the North Dakota Constitution.The Eighth Circuit affirmed the district court's grant of defendants' motion for summary judgment. The court held that the district court properly granted summary judgment on the First Amendment claim where plaintiff failed to prove his speech as a public employee was protected by the First Amendment. In this case, the district court found that plaintiff was not speaking as a citizen in a local news interview; plaintiff's speech during the interview was not on a matter of public concern because his asserted desire was to clear the name of his Facebook alias, which was a purely private interest; and even assuming plaintiff was a citizen commenting on a matter of public concern, his speech at the interview was not First Amendment protected, because it created great disharmony in the workplace, interfered with plaintiff's ability to perform his duties, and impaired his working relationships with other employees. The court also held that plaintiff was not deprived of his right to due process, and declined to exercise supplemental jurisdiction over the state law claims. View "Nagel v. City of Jamestown" on Justia Law

After plaintiff was sexually assaulted by a deputy acting within the scope of his employment with the sheriff's office, she filed claims of unreasonable search and seizure, equal protection, due process, supervisory liability, and municipal liability under the Civil Rights Act, 42 U.S.C. 1983.The Eighth Circuit reversed the district court's denial of qualified immunity and summary judgment in favor of the sheriff. The court held that the sheriff was entitled to qualified immunity, because prior instances of sexual misconduct were not similar in kind or sufficiently egregious in nature to demonstrate a pattern of sexual assault against members of the public by deputies. Therefore, a reasonable officer in the sheriff's position would not have known that he needed to more closely supervise his deputies, including defendant, or they might sexually assault a member of the public. Furthermore, a reasonable supervisor in the sheriff's position would not know that a failure to specifically train defendant not to sexually assault a woman would cause defendant to engage in that behavior. View "McGuire v. Cooper" on Justia Law

The Eighth Circuit denied a petition for review challenging the BIA's decision reversing the IJ's ruling that petitioner merited asylum because he had a well-founded fear of future persecution in Nigeria for his political opinions. The court held that, despite the harmless error of substituting its own findings about communicating his political opinions, substantial evidence supported the BIA's determination that petitioner was ineligible for asylum, because he failed to show that he faced a particularized threat of persecution. Furthermore, the BIA did not exceed its authority by requiring corroborating evidence for petitioner to meet his burden of proof.The court also held that petitioner could not show that the outcome of proceedings would have differed with notice and opportunity, and thus he failed to demonstrate prejudice from any procedural error. View "Uzodinma v. Barr" on Justia Law

Nelson Auto filed suit against KARE 11, alleging that the news provider published false and defamatory statements regarding a criminal complaint filed by the State of Minnesota in Otter Tail County District Court charging Gerald Worner, Nelson Auto's former Fleet Manager, with five counts of theft by swindle.The Eighth Circuit affirmed the district court's grant of KARE 11's motion to dismiss, holding that the district court did not err by concluding that Nelson Auto is a public figure as a matter of Minnesota law. The court agreed with the district court that, given the absence of facts from which actual malice might reasonably be inferred, the allegations show nothing more than oversight on KARE 11's part, which does not constitute actual malice. View "Nelson Auto Center, Inc. v. Multimedia Holdings Corp." on Justia Law