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

S.A.A. filed a lawsuit under 42 U.S.C. § 1983 against Officer Samantha Geisler, alleging Fourth Amendment violations during her arrest. The initial complaint, filed on September 20, 2021, claimed false arrest and excessive force but did not specify the capacity in which Geisler was sued. S.A.A. admitted she had not alleged official capacity claims. She amended her complaint twice before the deadline in May 2022 and sought to amend it a third time after the deadline, which the magistrate judge allowed with a warning. Geisler moved for summary judgment, arguing that S.A.A. failed to plead personal capacity claims as required by the Eighth Circuit’s clear statement rule. S.A.A. then moved to amend her complaint a fourth time, which the magistrate judge denied.The United States District Court for the District of Minnesota granted Geisler’s motion for summary judgment, overruled S.A.A.’s objection to the magistrate judge’s denial of her motion to amend, and denied her fourth motion to amend. The court found that S.A.A. failed to plead personal capacity claims against Geisler, adhering to the Eighth Circuit’s clear statement rule, which interprets complaints silent on the capacity in which the defendant is sued as including only official capacity claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that S.A.A. did not explicitly plead individual capacity claims and that the district court did not abuse its discretion in denying her fourth motion to amend the complaint. The court emphasized that S.A.A. failed to demonstrate diligence in meeting the scheduling order’s requirements, which is the primary measure of good cause under Federal Rule of Civil Procedure 16. View "S.A.A. v. Geisler" on Justia Law

Three gun rights organizations and their members challenged Minnesota’s permit-to-carry statute, which requires applicants to be at least 21 years old, arguing it violates the Second and Fourteenth Amendments. The district court granted summary judgment to the plaintiffs, finding that the Second Amendment’s plain text covered their conduct and that the government failed to show that restricting 18 to 20-year-olds’ right to bear handguns in public was consistent with the nation’s historical tradition of firearm regulation. Minnesota appealed the decision.The United States District Court for the District of Minnesota ruled in favor of the plaintiffs, declaring the age restriction facially unconstitutional for otherwise qualified 18 to 20-year-olds and enjoining its enforcement. The district court applied the two-part test from New York State Rifle & Pistol Association, Inc. v. Bruen, focusing on the Second Amendment’s text and historical tradition. The court found that the plain text covered the plaintiffs’ conduct and that the government did not meet its burden to demonstrate a historical tradition of similar firearm regulations.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court held that ordinary, law-abiding 18 to 20-year-olds are part of “the people” protected by the Second Amendment. The court found that Minnesota failed to provide sufficient historical analogues to justify the age restriction, noting that the state’s proffered evidence did not meet the burden of demonstrating a historical tradition of similar firearm regulations. Consequently, the court ruled that the age restriction in Minnesota’s permit-to-carry statute is unconstitutional. View "Worth v. Jacobson" on Justia Law

Kalvin Earl Richardson purchased a house in St. Louis County, Missouri, through a Post Third Sale Offering, a process for selling tax-delinquent properties that have not been sold in three consecutive annual tax-collection auctions. Richardson then applied for homeowner insurance from Nationwide Mutual Insurance Company, stating on the application that the property was not purchased at a public auction. After a fire damaged the house, Nationwide refused to pay the claim, asserting that Richardson had misrepresented the purchase method. Nationwide sued, claiming the policy was void due to this misrepresentation.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of Nationwide. The court ruled that the Post Third Sale Offering constituted a public auction and that Richardson's contrary statement on the insurance application was a material misrepresentation, rendering the insurance policy void ab initio.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The appellate court found that the term "public auction" was not clearly defined in Nationwide's insurance application and that the Post Third Sale Offering did not meet the ordinary understanding of a public auction, which typically involves competitive bidding. The court noted that Missouri statutes and case law emphasize competition among bidders as a key element of a public auction, which was absent in the Post Third Sale Offering. Consequently, the court held that Nationwide did not meet its burden to prove that Richardson's representation was false in fact. The Eighth Circuit reversed the district court's summary judgment and remanded the case for further proceedings. View "Nationwide Mutual Insurance Company v. Richardson" on Justia Law

Two men, Bruce Sanford and Houston Simmons, were found in a car outside a nightclub in Waterloo, Iowa. A nightclub owner reported to the police that the men were smoking and drinking in the car. When officers arrived, they smelled marijuana and subsequently searched the car, finding marijuana, cash, and a handgun. Both men were charged with possessing a firearm after being convicted of a felony.At the United States District Court for the Northern District of Iowa, both Sanford and Simmons filed motions to suppress the evidence, arguing they were unlawfully seized when the officers blocked their car. The district court held an evidentiary hearing and found that the car was not completely blocked and could have moved. The court concluded that the men were not unlawfully seized before the officers smelled marijuana and denied the motions to suppress.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, finding no clear error in the lower court’s factual determinations. The appellate court agreed that a reasonable person in the defendants' position would have felt free to leave, despite the presence of armed officers and flashing lights. The court held that the positioning of the squad cars did not constitute a seizure under the Fourth Amendment and upheld the denial of the motions to suppress. View "United States v. Sanford" on Justia Law

Darius Sledge and Baquan Sledge were involved in a large-scale drug distribution conspiracy in North Dakota, targeting several Indian Reservations. They transported thousands of oxycodone pills from Michigan and recruited local residents as sub-distributors. Despite being arrested, Baquan continued his involvement from jail. Both were charged with multiple counts, including conspiracy to distribute controlled substances, money laundering, and maintaining drug-involved premises. A jury found Baquan guilty on all counts and Darius on all but one.The United States District Court for the District of North Dakota denied Baquan's motion to be returned to North Dakota from a Colorado facility, deeming it moot as he had already been returned. The court also denied Darius and Baquan's motion for a new trial based on alleged juror bias, finding no dishonesty in juror responses during voir dire. Both were sentenced to 360 months for the continuing criminal enterprise (CCE) count and 240 months for other counts, to run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the case. It reversed Darius’s CCE conviction due to an error in jury instructions, specifically the lack of a unanimity instruction regarding the predicate felonies. The court found this error affected Darius’s substantial rights and the fairness of the proceedings. The court remanded for a new trial on this count and remanded Baquan’s drug conspiracy conviction to the district court to vacate the lesser-included offense. The court affirmed the judgments in all other respects, including the denial of a new trial based on juror bias and the handling of Baquan’s pre-trial detention location. View "United States v. Sledge" on Justia Law

Kendra Kingsbury, an FBI Intelligence Analyst with Top Secret/Sensitive Compartmented Information (SCI) security clearance, pled guilty to two counts of willful retention of national defense information. During her employment, she improperly retained classified documents at her home, which were discovered during an FBI investigation. The investigation revealed that Kingsbury had approximately 20,000 documents, including 386 classified ones, some related to counterterrorism. Additionally, phone records indicated calls to and from individuals involved in counterterrorism investigations, which Kingsbury denied making.The United States District Court for the Western District of Missouri applied a two-level enhancement under U.S.S.G. § 3B1.3 for abusing a position of public trust, increasing her advisory Guidelines range to 46-57 months of imprisonment. Kingsbury was sentenced to 46 months. She appealed the enhancement, arguing it was already included in her base offense level.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s application of the enhancement for plain error, as Kingsbury did not object at sentencing. The court found that the enhancement was appropriate because Kingsbury’s position of trust significantly facilitated the commission of the offense. The court rejected her argument that the enhancement was subsumed within the base offense level, noting that another FBI employee without her security clearance could have committed the same crime without the enhancement. Therefore, the court concluded that the enhancement was not duplicative of her base offense level.The Eighth Circuit affirmed the district court’s application of the two-level enhancement and upheld Kingsbury’s 46-month sentence. View "United States v. Kingsbury" on Justia Law

Petitioners, Sandra Estela Calvo-Tino and her minor daughter A.M.L.C., are natives of Guatemala. A.M.L.C. suffers from a severe genetic disorder that requires constant medical attention. In Guatemala, they faced inadequate medical care and alleged mistreatment by hospital staff, including accusations of poisoning and improper medical procedures. Fearing further mistreatment, they entered the United States in October 2016 and were subsequently charged as inadmissible aliens. They applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT).The Immigration Judge denied all forms of relief, finding that Calvo-Tino had not suffered past persecution, had not established a well-founded fear of future persecution, and that her proposed social group of "parents of permanently disabled or handicapped individuals" was not cognizable. The judge also found no likelihood of torture. The Board of Immigration Appeals (BIA) adopted and affirmed these findings, dismissing the appeal.The United States Court of Appeals for the Eighth Circuit reviewed the BIA's decision under the substantial evidence standard. The court upheld the BIA's findings, agreeing that the alleged mistreatment did not amount to persecution and that there was no evidence of a well-founded fear of future persecution. The court also found that the BIA did not need to address the cognizability of the proposed social group since the claim failed on other grounds. Additionally, the court concluded that the petitioners did not meet the burden of proof for CAT relief, as there was no evidence that Calvo-Tino would be tortured if returned to Guatemala.The Eighth Circuit denied the petition for review, affirming the BIA's decision. View "Calvo-Tino v. Garland" on Justia Law

Following the fatal police shooting of Daunte Wright, protests erupted in Brooklyn Center, Minnesota. Sam Wolk, a protester, filed a lawsuit under 42 U.S.C. § 1983, alleging First and Fourth Amendment violations and civil conspiracy against various law enforcement officials and agencies. Wolk claimed he was injured by tear gas, flashbang grenades, pepper spray, and rubber bullets used by officers during the protests, resulting in chronic knee pain.The United States District Court for the District of Minnesota denied the defendants' motions to dismiss most of Wolk's claims but dismissed his Fourteenth Amendment due process claim. The defendants appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court reversed the district court's denial of the Minnesota Department of Natural Resources' (DNR) motion to dismiss, citing Eleventh Amendment immunity. The court also reversed the denial of qualified immunity for former Brooklyn Center Police Chief Tim Gannon, as he had resigned before Wolk's injuries occurred. Additionally, the court found that the Fourth Amendment claims for excessive force and failure to intervene were not clearly established as constitutional violations at the time of the incident, granting qualified immunity to the supervisory defendants on these claims.However, the court affirmed the district court's denial of qualified immunity for the First Amendment retaliation claims against the supervisory defendants, except for Gannon. The court found that more facts were needed to determine whether the officers' actions were driven by retaliatory animus. The court also reversed the district court's denial of the supervisory defendants' motion to dismiss the civil conspiracy claims, finding the allegations insufficient to show a meeting of the minds.The court reversed the district court's denial of the municipal defendants' motion to dismiss the Fourth Amendment and conspiracy claims but lacked jurisdiction over the First Amendment retaliation claim against the municipal defendants. The case was remanded for further proceedings consistent with the opinion. View "Wolk v. Hutchinson" on Justia Law

Kayne Russell Donath pleaded guilty to unlawful possession of a firearm by a felon. During a traffic stop, Donath, who had an outstanding warrant, refused to exit the vehicle, grabbed the gearshift, and commanded the driver to flee. He threatened the driver with a concealed firearm, which he later discarded while fleeing on foot. Police recovered the firearm and arrested Donath, who had a prior felony conviction prohibiting him from possessing a firearm.The United States District Court for the Northern District of Iowa categorized two of Donath’s prior state offenses as “crimes of violence” under the Sentencing Guidelines, resulting in a higher base offense level. The court also decreased his offense level by two levels for acceptance of responsibility but did not grant an additional one-level decrease because the government did not move for it. Donath was sentenced to 90 months’ imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s categorization of Donath’s prior offenses as crimes of violence, citing precedent that assaulting a correctional officer under Iowa law qualifies as such. The court also upheld the district court’s decision to decrease Donath’s offense level by only two levels for acceptance of responsibility, noting that the government did not move for the additional one-level decrease and had a rational basis for withholding the motion. The appellate court concluded that Donath was not entitled to the additional decrease and affirmed the district court’s judgment. View "United States v. Donath" on Justia Law

Law enforcement executed a search warrant at Ryan Dewayne Myrick’s apartment, discovering 69.01 grams of methamphetamine, drug packaging, a digital scale, and other paraphernalia. In his vehicle, they found additional drug packaging. Myrick was charged with conspiracy to distribute methamphetamine and possession with intent to distribute. He pleaded guilty to the latter charge, admitting to possessing 69.01 grams of methamphetamine, with the intent to distribute at least 50 grams. The government agreed to dismiss the conspiracy charge and recommend a reduction for acceptance of responsibility, contingent on Myrick’s continued demonstration of acceptance.The United States District Court for the Southern District of Iowa reviewed the case. The Presentence Investigation Report (PSR) recommended holding Myrick responsible for 4.5 kilograms or more of methamphetamine, resulting in a base offense level of 38. It also suggested a two-level enhancement for maintaining a premises for drug distribution and a three-level reduction for acceptance of responsibility. Myrick objected to the drug quantity and the premises enhancement, while the government objected to the reduction for acceptance of responsibility. The district court overruled Myrick’s objections and sustained the government’s, resulting in a total offense level of 40 and an advisory Guidelines range of 360 months to life. Myrick was sentenced to 300 months of imprisonment and 5 years of supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case. Myrick challenged the district court’s drug quantity determination, the premises enhancement, and the denial of a reduction for acceptance of responsibility. The appellate court found no clear error in the district court’s findings, including the credibility of witness testimony and the application of relevant conduct principles. The court affirmed the district court’s judgment, upholding Myrick’s sentence. View "United States v. Myrick" on Justia Law