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

Continental appealed from a jury determination that it had tortiously interfered with the business relationship of plaintiff and CTAP. The Eighth Circuit affirmed and held that the evidence was sufficient to support a conclusion that Continental acted with intent to interfere in the plaintiff-CTAP business relationship, either by desiring to bring the interference about or knowing that the interference was substantially certain to occur; sufficient evidence existed to permit the jury to find that Continental’s interference was improper and that Continental was the legal cause of plaintiff's injury; substantial evidence supported the jury's award of punitive damages; and the district court did not err by denying Continental's motion for a new trial. The court also held that the district court did not abuse its discretion when instructing the jury on improper interference. View "Janvrin v. Continental Resources, Inc." on Justia Law

The Eighth Circuit affirmed the district court's imposition of a special condition of supervised release forbidding defendant, with one exception, to use a computer or the internet without the permission of the probation office. The court held that the district court did not abuse its discretion in fashioning the conditions of supervised release in light of defendant's convictions involving possession of child pornography and transporting lewd and lascivious materials for his own use. Furthermore, defendant demonstrated his incorrigibility by previously using a job center computer to seek child pornography, thus heightening the need for adequate deterrence and protection of the public. View "United States v. Spallek" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to unlawful possession of a firearm as a previously convicted felon. The court held that the district court did not err by determining that defendant's five convictions for selling cocaine base were serious drug convictions under the Armed Career Criminal Act (ACCA); an offer to sell in Missouri is categorically an offense involving distribution of a controlled substance under 18 U.S.C. 924(e)(2)(A)(ii); and defendant's contention that the district court impermissibly found that at least three of his Missouri offenses were committed on occasions different from one another was foreclosed by circuit precedents. View "United States v. Jones" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion seeking discharge from a civil commitment in a proceeding under 18 U.S.C. 4247(h). The court held that the specific requirements of section 4247(h) control over the general statutory right to proceed pro se. Therefore, the district court did not err in denying defendant's motion. The court also held that, under the well-established rule of statutory interpretation that specific statutory language controls over more general provisions, the general rule of 28 U.S.C. 1654 must give way to the specific requirement of section 4247(h) that motions for release from civil commitment be filed by an attorney or legal guardian for the committed person. View "United States v. O'Laughlin" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he was found guilty of possessing a firearm after being convicted of a felony. The court held that the district court did not err by applying a sentencing enhancement under the Armed Career Criminal Act, because his prior Missouri conviction for second degree robbery qualified as a violent felony under the force clause of 18 U.S.C. 924(e)(2)(B). View "United States v. Clark" on Justia Law

The Eighth Circuit denied the petition for review of the BIA's denial of petitioner's untimely motion to reopen. The court agreed with the Second Circuit's rejection of the argument that denial of an unopposed non-frivolous motion to reopen is presumptively an abuse of discretion because the burden is on the movant to establish his entitlement to reopening and there is no statutory or regulatory requirement that the Government file an opposition. The court held that the BIA did not abuse its discretion in ruling on the merits of petitioner's motion.The court also held that the BIA did not abuse its discretion in concluding that petitioner failed to show that former counsel's incompetence prejudiced his asylum and withholding of removal claims. Furthermore, there was no abuse of discretion in denying petitioner equitable tolling for his 17 month delay for filing the motion to reopen. Finally, there was no constitutional right under the Fifth Amendment to effective assistance of counsel in a removal proceeding. View "Mwangi v. Barr" on Justia Law

After plaintiff and her four children died from smoke inhalation as a result of a kitchen fire in their apartment, administrators of their estate filed suit against the JHA, the manufacturer of the smoke alarm, the City, the fire department, and others. Plaintiffs appealed the district court's judgment in favor of defendants.The Eighth Circuit affirmed, holding that the district court did not err in granting summary judgment to the Housing Authority Defendants and BRK, because no reasonable factfinder could determine, absent speculation, that the fire alarm failed to sound, causing the tragic deaths of plaintiffs; the district court did not err in granting summary judgment to the City Defendants, because there was lack of evidence showing that the firefighters' actions caused plaintiffs' deaths; the district court did not abuse its discretion by denying a motion to strike the affidavit of a defense expert; and the district court did not abuse its discretion by requiring one of plaintiff's counsel to pay for part of defendants' costs. View "Beavers v. Arkansas Housing Authorities Property & Casualty Self-Insured Fund, Inc." on Justia Law

Plaintiff filed suit against the City and Doc's Towing, alleging that defendants violated her rights under the Fourth and Fourteenth Amendments when her car was towed and stored without her consent or a warrant. The Eighth Circuit reversed the district court's grant of summary judgment in favor of defendants, holding that plaintiff has presented sufficient evidence to establish defendants' liability. In this case, a reasonable jury could find that plaintiff's truck was towed and held under the City's unwritten but widespread and persistent policy of reporting vehicles as wanted for the purpose of detaining them without a warrant. Furthermore, plaintiff has adduced evidence from which a reasonable juror could find that Doc's Towing was acting under color of law when it refused to allow her access to her truck. View "Meier v. St. Louis" on Justia Law

Kearney sought judicial review of the Board's decision denying its application to participate in the Medicare program. Although the facility later received approval, the initial denial prevented Kearney from participating in Medicare and receiving reimbursements for 87 days during 2014.The Eighth Circuit held that the Board failed adequately to explain the legal standard that it applied in resolving Kearney's administrative appeal. In this case, the court was unable to discern what meaning the Board attributed to 42 U.S.C. 1395x(e)(1) and the definition of "hospital." Furthermore, without an adequate explanation for what time period the agency considered in determining whether Kearney was primarily engaged in providing care to inpatients, the court was unable to resolve whether the Board's decision correctly applied the relevant legal standards. Therefore, the court reversed the district court's grant of summary judgment to the Department and remanded with directions. View "Kearney Regional Medical Center, LLC v. US Department of Health and Human Services" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to being a felon in possession of a firearm. The court held that defendant's argument that his prior drug conspiracy convictions did not fall within the definition of a "controlled substance offense" was foreclosed by United States v. Mendoza-Figueroa, 65 F.3d 691 (8th Cir. 1995) (en banc).The court reviewed defendant's alternative claim, that under the categorical approach 21 U.S.C. 846 conspiracy is broader than generic conspiracy because it does not require an overt act, for plain error. Because this court has not yet considered the issue, defendant failed to show any error that was clear or obvious under current law. View "United States v. Merritt" on Justia Law