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

The bankruptcy appellate panel affirmed the bankruptcy court's dismissal of debtor's Chapter 13 bankruptcy case. The panel held that the bankruptcy court properly dismissed the Chapter 13 case as void because it was a violation of the automatic stay in his pending Chapter 7 bankruptcy case. In this case, by filing his Chapter 13 petition, debtor attempted to exercise control over his interest in the property, which was undisputed to be property of his Chapter 7 bankruptcy estate. View "In re: Benitez" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of UPS, holding that plaintiff's action alleging that he was fired because of his race in violation of the Arkansas Civil Rights Act of 1993 was preempted under the Labor Management Relations Act (LMRA). In this case, plaintiff's claim depended on interpreting the collective bargaining agreement provisions, and thus was completely preempted under the LMRA. Therefore, the district court did not err by denying plaintiff's motion to remand to state court or in granting judgment for UPS. View "Johnson v. Humphreys" on Justia Law

The Eighth Circuit affirmed the district court's denial of a successive petition for a certificate of innocence, holding that the petition was barred by the doctrine of res judicata and that the district court did not err in finding that defendant's petition was barred.In a previous case, the court reversed federal gambling and money laundering convictions of RSI and its president, defendant, because the government failed to prove any of the offenses charged. RSI and defendant then petitioned for a certificate of innocence, the statutory prerequisite to an action in the Court of Federal Claims seeking damages from the government for wrongful imprisonment. The court affirmed the denial of the district court's petition, because RSI and defendant were not truly innocent of a state criminal gaming law violation. View "United States v. Bala" on Justia Law

The Eighth Circuit reversed the district court's grant of summary judgment to Principal in an action brought under the Employee Retirement Income Security Act (ERISA). The court held that Principal is a fiduciary when its sets the Composite Crediting Rate (CCR) for its 401(k) retirement plan. Under the two-part test in Teets v. Great-West Life & Annuity Ins. Co., 921 F.3d 1200 (10th Cir. 2019), the court held that Principal's setting of the CCR does not conform to a specific term of its contract with the employer plan, and the plan sponsors here did not have the unimpeded ability to reject the service provider's action or terminate the relationship. Accordingly, the court reversed and remanded for further proceedings. View "Rozo v. Principal Life Insurance Co." on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute and possess methamphetamine. The court rejected defendant's claim of ineffective assistance of counsel, because the court could not say that counsel acted unreasonably by failing to reach a final plea agreement or by failing to find a way to preserve the plea offer during the mental health evaluation; defendant's claim that counsel was ineffective in failing to request a second competency evaluation after a brief period without medication failed, because the Forensic Report contained no conclusion that defendant's legal competency was dependent on a specific medication regime; and the district court did not err by rejecting defendant's ineffective assistance of counsel claim without conducting an evidentiary hearing. View "Love v. United States" on Justia Law

The Eighth Circuit affirmed the district court's determination that Westfield had a duty to defend its insurer, Miller Architects and Builders, because the claims against Miller in the underlying action did not "clearly" fall outside the scope of coverage. The court held that the alleged damages from the leaky roof were arguably within the policy's scope and there are no clearly applicable exclusions. View "Westfield Insurance Co. v. Miller Architects & Builders" on Justia Law

The Eighth Circuit granted a petition for review of the ARB's final decision ruling that CP violated the whistleblower retaliation provisions of the Federal Railroad Safety Act (FRSA) when it suspended a locomotive engineer for his untimely reporting of a "work-related personal injury" or a "hazardous safety or security condition." The court agreed with CP's argument that the ARB's analysis of the contributing factor element of the employee's prima facie case used a legal causation standard contrary to controlling Eighth Circuit precedents.The court held that the ARB's reasoning was both contrary to the court's governing precedents and fatally flawed; the FRSA prohibits a rail carrier from discriminating against an employee for engaging in protected activity; the employee does not have to conclusively prove retaliatory motive but must show more than temporal proximity between the protected activity and the adverse action; and the court expressly rejected the contention that, when an employer learns about an employee's conduct warranting discipline in a protected injury report, the report and the discipline are "inextricably intertwined" and this factual connection is "sufficient to establish the contributing-factor element of his prima facie case." Because the ARB did not attempt to apply the appropriate Eighth Circuit legal standard, the court remanded to the ARB with instructions. View "Dakota, Minnesota & Eastern Railroad Corp. v. U.S. Department of Labor Administrative Review Board" on Justia Law

The Eighth Circuit affirmed defendant's conviction for crossing a state line with intent to engage in a sexual act with a minor under the age of twelve. The court held that a defendant has the requisite intent under 18 U.S.C. 2241(c) if engaging in sexual activity with the minor was one of the purposes motivating the defendant to cross state lines, even if the sexual activity is not the sole or dominant purpose for the trip, so long as it is more than incidental.In this case, the admission of text messages defendant had made to a friend allowed a reasonable factfinder to find beyond a reasonable doubt that defendant was guilty of crossing state lines with the intent to engage in sexual activities with the victim, a child less than twelve years of age. The court explained that the sexual encounters with the child were a motivating factor for defendant's trips across state lines and were not merely incidental. View "United States v. Perkins" on Justia Law

The Eighth Circuit vacated the district court's dismissal of plaintiff's amended complaint against TAW Enterprises, alleging that TAW retaliated against plaintiff in contravention of public policy established by the Gramm-Leach-Bliley Act and breached its employment contract with plaintiff.The court held that neither this court or the district court could properly exercise subject matter jurisdiction over this action because removal premised on diversity jurisdiction would violate the forum-defendant rule, a jurisdictional defect in this circuit, and plaintiff's amended complaint did not present a federal question. Accordingly, the court remanded with instructions to the district court to remand the case to state court. View "Holbein v. Baxter Chrysler Jeep, Inc." on Justia Law

Plaintiff filed suit against the city and others, seeking damages and injunctive and declaratory relief under 42 U.S.C. 1983, alleging unlawful arrest, detention, and prosecution, and the setting of an excessive cash-only bond that plaintiff was unable to pay due to indigency.The Eighth Circuit affirmed the district court's dismissal of the section 1983 claims and held that the municipal judge was entitled to absolute judicial immunity from plaintiff's arrest and detention damage claims based on an invalid warrant issued by the court clerk; the judge's practice of setting a bond schedule conditioning the pretrial release of persons accused of municipal ordinance violations was a judicial act within his jurisdiction to which judicial immunity attaches; and the district court correctly concluded that the clerk was entitled to quasi-judicial immunity. Even if the court considered the judge's judicial bond practice to be part of municipal custom or usage, the court would still affirm the dismissal of the claim because there was no evidence of deliberate indifference to plaintiff's rights as an indigent arrestee. Finally, the court held that there was insufficient evidence for a reasonable jury to find a meeting of the minds between defendants on the conspiracy claim. View "Hamilton v. City of Hayti" on Justia Law