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

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of a urine sample that police took from him. The court held that the warrant was supported by probable cause when it was executed; the district court permissibly relied on testimony of a forensic criminalist that evidence of marijuana use in a chronic user can remain in the user's system for up to two months; and, given that defendant's girlfriend informed officers that defendant used marijuana daily, there was a fair probability that a urine sample collected on August 30 would reveal evidence of his drug use on or before August 22. View "United States v. Leick" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's complaint against Hartford Life in an Employee Retirement Income Security Act (ERISA) action. The court held that the district court did not err by dismissing the complaint with prejudice, because substantial evidence supported Hartford Life's decision to terminate benefits based on exhaustion of mental illness benefits and the lack of a disabling physical condition. In this case, Hartford Life found no disabling physical condition or mental illness based on the medical evidence and the opinions of treating, examining, and reviewing physicians. View "Miller v. Hartford Life & Accident Insurance Co." on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to wire fraud. The court held that the district court did not clearly err in calculating defendant's criminal history score where his prior tax-related conviction was not relevant conduct to his wire-fraud conviction. In this case, the convictions did not share victims, a common scheme, and charge in the indictment. Furthermore, the record reflected no nexus between the former and latter convictions. View "United States v. Smith" on Justia Law

The Eighth Circuit affirmed defendant's conviction after he pleaded guilty to possession of a firearm as a convicted felon. The court held that the district court did not err by determining that defendant's prior Mississippi conviction for burglary was a violent felony under the Armed Career Criminal Act. Therefore, the district court correctly classified defendant as a career offender. View "United States v. Silva" on Justia Law

The Eighth Circuit affirmed the district court's finding of a supervised release violation and revocation of defendant's sentence. The court held that the district court carefully explained objective facts and reasonable inferences supporting its finding that the witness' recantation was not credible. The court explained that it was not an improper factor to consider that the witness' recantation was influenced by family pressures, and that defendant had assaulted another woman under similar circumstances was a relevant corroborating circumstance. The court stated that when the district court concludes that a recantation was not believable, it was almost impossible for an appellate court to hold that a district judge's rejection, on credibility grounds, of the testimony of a live witness was clearly erroneous.The court also held that the district court did not abuse its discretion by imposing defendant's sentence, which was not substantively reasonable, where the district court carefully weighed the 18 U.S.C. 3553(a) sentencing factors. View "United States v. Lillybridge" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Anixter on plaintiff's claim that the company violated the Uniformed Services Employment and Reemployment Rights Act (USERRA), by discriminating and retaliating against him on the basis of his prior service in the military and exercise of rights protected under the statute.The court held that plaintiff failed to show a genuine dispute of material fact that his military status was a motivating factor in Anixter's decision to fire him. The court noted that most of Anixter's actions that plaintiff claimed violated USERRA were not independently actionable under the statute. The court held that the order for plaintiff to perform some manual labor did not exceed his disability restriction and was therefore not materially adverse; Anixter's denial of plaintiff's request for a service dog was not sufficiently adverse; and defendant's discharge from Anixter four days after requesting PTSD accommodation did not create sufficient evidence of a genuine dispute of material fact regarding Anixter's unlawful motivation to fire plaintiff. Rather, the undisputed evidence indicated that plaintiff's temperament played a part in Anixter's decision to fire him, which was consistent with the company's explanation that it fired him due to this disagreement. View "McConnell v. Anixter, Inc." on Justia Law

Vianney appealed the district court's summary judgment rulings on their Religious Land Use and Institutionalized Persons Act (RLUIPA) claims, Missouri Religious Freedom Restoration Act (Missouri RFRA) claim; and inverse condemnation claim under Missouri's Constitution.The Eighth Circuit affirmed as to the RLUIPA claims, holding that the city's lighting and sound regulations did not substantially burden, rather than merely inconvenienced, Vianney's religious exercise. In this case, Vianney has not demonstrated that a requirement that it avail itself of alternatives would substantially burden its religious exercise, and the record demonstrated that Vianney was not treated less favorably than other schools. The court also affirmed as to the inverse condemnation claim, holding that Missouri courts have held that the reasonable exercise of a city's police power does not constitute a taking and the regulations here did not impose unusually restrictive limitations. However, the court vacated as to the Missouri RFRA claim, because the district court abused its discretion in deciding this state law claim on the merits after granting the city summary judgment on the RLUIPA claims. Accordingly, the court remanded to the district court with instructions to dismiss the claim without prejudice. View "Marianist Province of the U.S. v. City of Kirkwood" on Justia Law

Defendant appealed from the district court's denial of his motion for a sentence reduction under the First Step Act of 2018, which made retroactive the lower penalties for cocaine base offenses established by the Fair Sentencing Act. The Eighth Circuit held that the district court erred by finding that defendant was ineligible for relief. In this case, defendant's conviction for distributing two ounces of cocaine base was a covered offense under section 404 of the Act and thus he was eligible for a sentence reduction. Accordingly, the court reversed and remanded. View "United States v. McDonald" on Justia Law

The Eighth Circuit affirmed the district court's directed verdict and the jury's verdict in favor of appellees in an action involving a dispute between landowners and herbicide damage. The court held that the district court did not err in directing a verdict against Keller Farms on it statutory trespass count. In this case, the district court properly interpreted the Missouri trespass statute to exclude Keller Farm's claim for crop damage, and the district court did not err in determining that Keller Farms had not presented sufficient evidence to make a submissible case for its statutory trespass claim concerning damage to its windbreak and ornamental trees.The court also held that the district court did not abuse its discretion by excluding a warning letter as well as testimony about it under Federal Rule of Evidence 403 because it was unfairly prejudicial; the district court did not abuse its discretion in denying the motion for a new trial on the ground that the verdict was against the weight of the evidence; and the district court did not abuse its discretion in denying the motion for a new trial on the ground that appellees' closing argument was improper. View "Keller Farms, Inc. v. Stewart" on Justia Law

The Eighth Circuit denied a petition for review of the BIA's decision denying petitioners' request for humanitarian asylum. Petitioners, seeking asylum for themselves and their children, contend that the district court erred in requiring that they show past persecution on account of a protected ground as a prerequisite for obtaining humanitarian asylum.The court held that petitioner's argument was foreclosed by this court's existing precedent in Kanagu v. Holder, 781 F.3d 912 (8th Cir. 2015), which held that the petitioner's failure to prove persecution on a protected ground made him ineligible for humanitarian asylum. Therefore, the BIA did not abuse its discretion in denying petitioners' requested relief. View "Mejia-Lopez v. Barr" on Justia Law