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

The Eighth Circuit affirmed Defendants Pugh and Warren's convictions for drug related crimes and affirmed Pugh's sentence. The court held that the informant's testimony, together with the government's other evidence, was sufficient to support Pugh's convictions; the district court did not abuse its discretion in denying Pugh's proposed jury instruction; there was no error in admitting under Federal Rule of Evidence 404(b), a certified copy of Pugh's 2010 information and guilty plea on the Illinois attempted robbery in order to show knowledge and intent; Pugh's Rehaif challenge failed, because sufficient evidence existed such that a reasonable jury could find that Pugh knew of his prohibited status, and because Pugh cannot show a reasonable probability of a different outcome absent the instructional error; and defendant's prior conviction in Illinois for attempted robbery qualifies as a crime of violence for purposes of USSG 2K2.1(a)(4)(a).In regard to Warren's challenges, the court held that the district court did not abuse its discretion by admitting evidence of two prior convictions to prove knowledge and intent, and Warren's Rehaif challenge failed for the same reasons as Pugh's Rehaif claim. View "United States v. Warren" on Justia Law

Plaintiff filed suit against Owners, which had issued an insurance plan to her father, for underinsured motorist benefits. On Owner's first appeal, the Eighth Circuit held that the district court improperly applied a heightened duty of care to the driver of the vehicle as the designated driver. On remand, the district court stated that it was not applying a heightened standard and did not alter the fault allocation.After careful review, the court was not satisfied that the order on remand eliminated the legal error that this court identified in the original conclusions of law. Therefore, the court vacated and remanded for new findings and conclusions on the allocation of fault. The district judge is no longer in service in the district court and thus the chief judge of the district court should reassign this case for further proceedings. View "Hiltner v. Owners Insurance Co." on Justia Law

This case arose when plaintiff fell from the trunk of the car that her friend was driving and sustained serious injuries. In a related case, the district court held a bench trial to apportion the fault between the friends involved in the accident. In this case, plaintiff filed suit to recover the portion of the judgment allocated to one of the friends, seeking underinsured motorist benefits for the friend's portion of the judgment. The district court granted Owners' motion for summary judgment.The Eighth Circuit held that removal was not proper under diversity jurisdiction where the parties conceded that the amount in controversy was statutorily insufficient. The court also held that there was no supplemental jurisdiction because this case was a separate action and not another claim in an underlying action over which the federal courts have jurisdiction. Accordingly, the court vacated and remanded to the district court with instructions to remand the case to state court. View "Mensah v. Owners Insurance Co." on Justia Law

The Eighth Circuit affirmed defendant's conviction as a career offender under USSG 4B1.1 based on his controlled substance convictions in Illinois and in Iowa. The court held that the district court did not err in concluding that defendant's Iowa and Illinois controlled substance convictions qualified as predicates for career offender sentencing. The court declined to find that the Illinois and Iowa statutes are categorically not career-offender predicates because they include the word "deliver," which may not involve a commercial activity; the Illinois and Iowa convictions are not overbroad; and defendant's remaining claims to the contrary were rejected. View "United States v. Clayborn" on Justia Law

Plaintiff filed suit alleging that she suffered permanent injuries from a fall caused by the negligent removal of ice and maintenance of an asphalt parking lot operated by U-Park. Plaintiff's husband sought damages for loss of consortium.The Eighth Circuit affirmed the district court's grant of U-Park's motion in limine to exclude an expert's opinions on causation. The court explained that, in the absence of any record evidence that the expert used reliable principles and methods or applied them reasonably to the facts of this case to form his opinion that plaintiff's fall was caused by black ice forming in a birdbath, his opinion did not satisfy Federal Rule of Evidence 702 standards for admissibility. The court also affirmed the district court's grant of U-Park's motion for summary judgment. Under Nebraska premises liability law, there was no evidence in the record from which the court could draw a reasonable inference that if the ice was visible and apparent that plaintiff would not discover or realize the danger of the ice or fail to protect herself against it. View "Ackerman v. U-Park, Inc." on Justia Law

The Eighth Circuit affirmed defendant's conviction for possessing a firearm, possessing with intent to distribute a controlled substance, possessing a firearm in furtherance of a drug trafficking crime, and possessing a stolen firearm. The court held that there was no error in admitting eyewitness identification evidence, because the show-up identification was not impermissibly suggestive and the identification was reliable; the district court did not abuse its discretion by failing to instruct the jury on eyewitness identification where the government's case did not rest solely on questionable eyewitness identification; there was no Sixth Amendment violation of defendant's right to counsel where the district court allowed defendant to give his own closing argument, defendant was still represented by counsel and received advice, there was no duty to conduct a Faretta hearing, and defendant knowingly and intelligently waived his right to counsel; and the evidence was sufficient to support defendant's conviction. View "United States v. Heard" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to one count of possession with intent to distribute cocaine base. The court held that the district court's application of the sentencing guidelines did not result in impermissible double-counting. In this case, by considering the December 2017 drug quantity under USSG 2D1.1, while also considering defendant's December 2017 supervised release status under USSG 4A1.1(d), the district court did not penalize defendant twice for the same conduct. Rather, the court explained that the district court evaluated the seriousness of the offense and defendant's criminal history. View "United States v. Jones" on Justia Law

Plaintiffs filed suit under the Individuals with Disabilities Education Act (IDEA), bringing a due process challenge to the school district's individualized education plan (IEP) and school placement before the Missouri Administrative Hearing Commission. The Commission affirmed the plan and placement, denying reimbursement. The district court reversed the Commission but limited the reimbursement award based on equitable considerations.The Eighth Circuit held that the school district violated the IDEA and the district court erred in limiting the award. As a preliminary matter, the court held that the school district's jurisdictional challenge was without merit; the school district's mootness challenge also failed; and the district court properly placed the burden on plaintiffs in the proceeding before it and correctly stated the standard of review on appeal.On the merits, the court held that the school district denied plaintiffs' son a free and appropriate education as required by the IDEA when it placed him at a school without direct occupational therapy or a sensory diet plan in place to address his autism-related issues. The court also held that an award limitation based on improvements to the school was inappropriate and inconsistent with the purposes of the IDEA because the school district failed to give any notice to plaintiffs. Furthermore, limiting an award based on improvements not communicated to plaintiffs was inconsistent with the IDEA's purpose. Accordingly, the court reversed the district court's limitation of tuition reimbursement and awarded full tuition reimbursement. View "D. L. v. St. Louis City School District" on Justia Law

Plaintiffs, a group of pretrial arrestees who were detained in St. Louis jails, filed a 42 U.S.C. 1983 action, challenging the constitutionality of the procedures by which defendants, state and city officials, set money bail.The Eighth Circuit reversed the district court's grant of plaintiffs' motion for class certification and entry of a preliminary injunction enjoining the enforcement of any monetary condition of release resulting in detention. In this case, the district court resorted to the extraordinary remedy of injunctive relief without adequately considering the new rules and their implementation. The district court abused its discretion by interjecting the power of the federal government into the Missouri Supreme Court's attempt to police its own lower courts, without contemplating what this would mean for federal-state relations. On remand, the district court should consider the effect of the rule changes on the question of whether a preliminary injunction served the public interest in comity between the state and federal judiciaries, as well as the necessity of an injunction. View "Dixon v. City of St. Louis" on Justia Law

The Eighth Circuit affirmed the district court's revocation of supervised release for a Grade A violation for possession of heroin and three Grade C violations for disobeying the probation office. The court held that there was sufficient evidence to find that defendant committed the Grade A violation of possession of heroin by a preponderance of the evidence; the district court did not plainly err in denying defendant's due process rights by admitting evidence unrelated to a violation in the petition for revocation of supervised release; and, even if defendant's due process rights were violated, he failed to show how further disclosure would have helped him. View "United States v. Burrage" on Justia Law