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

The Eighth Circuit affirmed defendant's conviction of conspiracy to distribute and possess with intent to distribute 50 grams or more of methamphetamine, possession with intent to distribute 5 grams or more of methamphetamine, and distribution of and possession with intent to distribute 50 grams or more of methamphetamine.The court held that there was probable cause to issue a search warrant of the Folsom St. garage; because the camper was not noticeably separate from the garage, it was covered by the search warrant, whether or not it was a vehicle for Fourth Amendment purposes; and, because the April 2 search was legally conducted pursuant to a valid search warrant, the information the police gained from the April 2 search could be relied upon for the April 22 search warrant. The court also held that the district court did not abuse its discretion in denying a Franks hearing; denying an in camera review of the officer's personnel file; and admitting bad acts evidence. Finally, there was no error in the jury instruction for the lesser included offense of simple possession, and sufficient evidence supported the verdict. View "United States v. Mazzulla" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to being a felon in possession of ammunition. The court held that the district court did not plainly err by applying USSG 5G1.3(d) and concluding that a consecutive sentence was required in this instance. Furthermore, the district court's discussion of the prison system in practical terms was not in error and, even if defendant could show error, his claim failed at step three of plain error review because he failed to show a reasonable probability that but for the error he would have received a more reasonable sentence. In this case, the district court imposed a sentence at the low end of the Guidelines after thoroughly reviewing defendant's criminal history, mental health, career aspirations, family circumstances, parole options, and need for the sentence imposed. View "United States v. Bonnell" on Justia Law

The Eighth Circuit affirmed the district court's order granting judgment for GEICO in an action seeking a declaratory judgment that the stacking provisions of other liability coverage in the insurance policy were not applicable to the claims at issue. The court held that the district court did not err in ruling on the declaratory judgment action, because the insurance policy unambiguously did not allow stacking under Missouri law. The court also held that the district court did not abuse its discretion in refusing further discovery, because Missouri law does not permit courts to consider extrinsic evidence in interpreting an unambiguous contract. View "GEICO Casualty Co. v. Isaacson" on Justia Law

After JetMidwest filed suit against JMG for breaching a loan agreement, the district court granted summary judgment to JetMidwest but denied its motion for reimbursement of its attorneys' fees under the agreement.As a preliminary matter, the Eighth Circuit held that a Hong Kong limited company is equivalent to a U.S. corporation under 28 U.S.C. 1332. Therefore, the district court properly exercised subject matter jurisdiction under section 1332 and the court had appellate jurisdiction under 28 U.S.C. 1291. On the merits, the court disagreed with the district court's interpretation of the agreement, holding that the use of the sweeping language "all costs and expenses" reflects the parties' intent that JMG would pay Jet Midwest's attorneys' fees and other costs for enforcing as well as preparing the agreement. Accordingly, the court reversed and remanded for consideration of an appropriate award. View "Jet Midwest International Co., Ltd. v. Jet Midwest Group, LLC" on Justia Law

The Eighth Circuit affirmed the district court's grant of a preliminary injunction enjoining North Dakota Senate Bill 2289, which regulates relationships between manufacturers and farm equipment dealers. The court held that the State has not carried its burden of showing a significant and legitimate public purpose underlying Senate Bill 2289. Therefore, the district court did not err in concluding that the manufacturers were likely to succeed on the merits of their Contract Clause claim. In this case, the manufacturers cannot reasonably be said to have had a fair and appreciable warning of an impending intervention into their agreements. View "Association of Equipment Manufacturers v. Burgum" on Justia Law

The Eighth Circuit affirmed the district court's denial of a 28 U.S.C. 2255 habeas corpus petition, seeking relief from a mandatory minimum sentence imposed in 2008. The court held that petitioner's 2014 motion was time-barred under section 2255(f)(4). In this case, the issuance of the Commission's 2011 Report was what triggered petitioner's duty to act with diligence, and he failed to do so because he did not file until almost three years later. View "Ingram v. United States" on Justia Law

The Eighth Circuit denied a petition for review of the determination that petitioner was removable under 8 U.S.C. 1227(a)(2)(A)(iii) because he was convicted in Iowa of committing an aggravated felony. Determining that it had jurisdiction, the court held that DHS was correct when it concluded that petitioner's Iowa forgery conviction qualified as an aggravated felony for purposes of section 1227(a)(2)(iii). The court held that, although DHS erred by issuing a Final Administrative Removal Order before petitioner's deadline to respond expired, petitioner failed to show prejudice. In this case, petitioner's state law crime unarguably qualified as an aggravated felony and there was nothing petitioner could have offered that would change the result. View "Salazar v. Barr" on Justia Law

Allstate filed suit seeking a declaratory judgment that the insureds violated the intentional acts exclusion of their insurance policy and that Allstate was entitled to recover its payment to the mortagees. Allstate concluded that the insureds' property was set on fire by or at the direction of one of the insureds. The district court denied the insureds' motion for summary judgment, and Allstate prevailed at trial.The Eighth Circuit affirmed, holding that the district court did not make a clear and prejudicial error affecting the outcome of the proceeding by admitting the expert opinions; the district court did not err in denying the insureds' motion for judgment as a matter of law, because the combination of Allstates' expert testimony regarding the possible causes of the fire, the rapid nature of the blaze, evidence of the insureds' financial incentives, and potential negative credibility determinations by the jury against the insureds suffices to meet the burden of submissibility; the denial of the insureds' motion for a new trial was not a miscarriage of justice in light of the evidence; the district court was entitled to order restitution of the amount paid the mortgagees as a means of effectuating the verdict in favor of Allstate in a declaratory judgment action; and judgment was properly entered against the co-insured, even where the verdict director focused on the other insured. View "Allstate Indemnity Co. v. Dixon" on Justia Law

The Eighth Circuit affirmed defendant's conviction of five counts of sex trafficking and attempted sex trafficking, and one count of conspiracy to commit an offense against the United States, specifically facilitating the promotion and management of a business enterprise involving prostitution.The court held that the search of defendant's cell phone did not violate the Fourth Amendment because, under the totality of the circumstances, he did not have a reasonable expectation of privacy in it. In this case, defendant was on restrictive supervised release and suspected of engaging in illicit activities, and he was on notice due to the conditions of his supervised release. The court also held that the district court did not abuse its discretion in instructing the jury; defendant's waiver to his Sixth Amendment right to counsel was not involuntary; and defendant's remaining claims of trial error failed View "United States v. Collier" on Justia Law

Plaintiff, a 7 year old elementary school student, filed a 42 U.S.C. 1983 suit against KCPS, Officer Craddock, and Principal Wallace for violations of his rights under the Fourth and Fourteenth Amendments. Plaintiff's claims arose when he was handcuffed in school after an outburst in the classroom against a classmate that was incessantly teasing him. The district court determined that disputed material facts precluded dismissal of the student's claim against the officer and principal, and denied summary judgment to KCPS.The Eighth Circuit held that neither the officer nor the principal violated the student's constitutional rights, and they were entitled to qualified immunity on plaintiff's claim of unreasonable seizure and excessive force. In this case, a reasonable officer could conclude that, based on the student's recent resistance, keeping him in handcuffs for 15 minutes until a parent arrived was a reasonable course of action and was necessary to prevent him from trying to leave and posing harm to himself. Furthermore, the principal's failure to intervene and have the officer remove the handcuffs was reasonable in light of her previous experience with the student. Even if the reasonableness of the officer and the principal's actions were questionable, the student could not show that a reasonable official would have been on notice that their conduct violated a clearly established right. The court also held that, because there was no violation of the student's constitutional rights, the student's municipal liability claims failed. Therefore, the court reversed the district court's denial of summary judgment for the officer, principal, and KCPS, remanding for entry of summary judgment in their favor on the student's claims. View "K.W.P. v. Kansas City Public Schools" on Justia Law