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

Defendant appealed the district court's order vacating an arbitration award, contending that the district court did not properly defer to the arbitrator's decision. Plaintiff cross appealed. In this case, defendant issued a crop insurance policy to plaintiff, a South Dakota farmer, in 2015 and subsequently determined that the appraised value of plaintiff's crop exceeded his policy's guaranteed minimum crop production, denying his claim.The Eighth Circuit held that the arbitrator did not exceed his powers because the dispute about the interpretation of "appraised value" was not even before the arbitrator. Furthermore, the arbitrator's findings supported the denial of plaintiff's claims on a different ground -- that he abandoned his crop -- despite plaintiff's argument to the contrary in his cross appeal. The court also held that, even if the arbitrator did exceed his powers by making a good farming practices determination, the error was harmless because he did not exceed his powers in denying plaintiff's claim based on the appraised value of plaintiff's crop. Accordingly, the court reversed in part, affirmed in part, and remanded to the district court to enter an order confirming the arbitration award. View "Balvin v. Rain and Hail, LLC" on Justia Law

After plaintiff was terminated, she filed suit against the President of Henderson State University for employment discrimination. The Eighth Circuit affirmed the district court's grant of summary judgment for defendant, holding that plaintiff was an at-will employee at the time of her termination. In this case, passing a proposed budget including plaintiff's name, title, and salary, did not create an employment contract. Therefore, plaintiff had no property right in continued employment.In regard to plaintiff's claim that she has a protected liberty interest in her reputation, which entitled her to a name-clearing hearing, the court held that plaintiff presented no evidence of defendant directly accusing her of stealing or mismanagement. Furthermore, any claims that plaintiff was stigmatized by innuendo or defendant's commenting on any part of the audit report failed. Therefore, plaintiff failed to establish that she was deprived of a protected liberty interest in her reputation. View "Correia v. Jones" on Justia Law

The Eighth Circuit reversed the district court's grant of defendant's motion to suppress evidence found inside of a rental car in which defendant was the passenger. The court held that the officer acted on reasonable suspicion to extend the traffic stop and defendant was not unreasonably seized in violation of the Fourth Amendment. In this case, the officer found a loaded weapon in the car, and thus had probable cause to search the vehicle for evidence of criminal activity. Therefore, defendant had no standing to challenge the pretextual inventory search. Furthermore, because defendant lacked a reasonable expectation of privacy in the vehicle as a passenger, he could not assert a Fourth Amendment challenge to the vehicle search. View "United States v. Davis" on Justia Law

The bankruptcy appellate panel affirmed the bankruptcy court's orders granting a motion to dismiss an adversary proceeding; denying a motion for an extension of time to file a motion to reconsider and for rehearing; and denying a motion to declare that plaintiffs have a right to appeal as a right or to extend the time to appeal.The panel held that plaintiffs failed to show excusable neglect under Bankruptcy Rule 8002(d)(1)(B), and thus the bankruptcy court did not abuse its discretion in denying the motion to appeal out of time. The panel also held that, because plaintiffs did not file a motion of the type listed in Rule 8002(b)(1), nor a motion for extension of time in which to file a notice of appeal under Rule 8002(d)(1)(A), the period for appealing the dismissal order expired without a timely appeal being filed. Finally, the court held that the bankruptcy court did not abuse its discretion in denying the motion to declare that plaintiffs appeal was timely. View "Conway v. Heyl" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to reduce his sentence under the First Step Act, holding that section 404 of the Act does not require a hearing on the motion. Therefore, the district court can conduct a complete review without a hearing, as the district court did in this case. The court also held that the district court did not abuse its discretion by improperly weighing the 18 U.S.C. 3553(a) factors. Rather, the district court considered defendant's post sentence rehabilitation and arguments for a sentence reduction, and had a reasoned basis for rejecting them. View "United States v. Williams" on Justia Law

After the trustee discovered that debtor had withdrawn over $30,000 from an account more than one year prior to entering bankruptcy and had placed the cash in a home safe, the trustee objected to debtor's amendment of his schedules to reflect the cash as exempt. The bankruptcy court overruled the objection and held that the Bankruptcy Code did not grant the court the authority to bar an amendment to claimed exemptions based on bad faith. The bankruptcy appellate panel affirmed.The Eight Circuit affirmed and held that Law v. Siegel -- which held that bankruptcy courts could use neither statutory nor inherent sources of broad, general authority to contravene specific statutory provisions -- abrogated Kaelin v. Bassett -- which held that the bankruptcy court has the discretion to deny the amendment of exemptions if the amendment is proposed in bad faith or would prejudice creditors. Therefore, Law precluded the denial of an amendment to a schedule of claimed exemptions based on debtor's bad faith. View "Rucker v. Belew" on Justia Law

The Bankruptcy Appellate Panel dismissed debtor's appeal of the bankruptcy court's order granting the trustee's motion to approve her proposed sale of certain assets to the bank. The panel held that the sale authorized by the bankruptcy court could not be undone and thus the appeal was moot. Furthermore, the panel held that debtor did not have a financial stake in the bankruptcy court's order and thus lacked standing to appeal the order. View "Belew v. Rucker" on Justia Law

The Eighth Circuit affirmed defendant's 223 month sentence imposed after he pleaded guilty to one count of conspiracy to distribute methamphetamine after having been previously convicted of a felony drug offense. The court held that the district court expressly considered defendant's difficult upbringing, but refused to attribute his extensive criminal history solely to his harsh rearing experiences. In this case, the district court explained that defendant's criminal history outweighed his mistreatment. Accordingly, the district court did not abuse its discretion by denying defendant's request for a downward variance. View "United States v. Fitzpatrick" on Justia Law

The Eighth Circuit affirmed defendant's 240 month sentence imposed after he pleaded guilty to conspiracy to distribute 500 grams or more of a mixture and substance containing methamphetamine and 50 grams or more of actual methamphetamine. The court held that defendant's prior conviction for assault with intent to inflict serious injury in violation of Iowa Code 708.2(1) and 903.1(2) qualified as a crime of violence under the career-offender enhancement, because the crime necessarily involved the use, attempted use, or threatened use of physical force. View "United States v. Quigley" on Justia Law

Whether a conviction for a particular state offense qualifies as a basis for removability as an aggravated felony under 8 U.S.C. 1227(a)(2)(A)(iii) is a question of law under de novo review. The Eighth Circuit denied a petition for review of the BIA's final order of removal. The BIA granted DHS's appeal of an IJ's order granting petitioner deferral of removal under the Convention Against Torture (CAT).The Eighth Circuit held that defendant's conviction for willful injury causing bodily harm was a crime of violence in satisfaction of 18 U.S.C. 16(a) and a valid basis for removal under 8 U.S.C. 1227(a)(2)(A)(iii) because it was impossible to cause bodily injury without applying the force necessary to cause the injury. The court held that the BIA conducted a logical, clear error analysis and reached a permissible conclusion. View "Jima v. Barr" on Justia Law