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

The Eighth Circuit affirmed the district court's imposition of a 24 month supervised release revocation sentence. The court held that the district court did not commit plain procedural error by basing its sentence on a fact not supported by the record. In this case, the district court's finding that defendant committed the crime of viewing child pornography was directly contradicted by the record, and the district court's statement, "crime is committed," viewed in context, either meant "a violation is committed," referring to the admitted supervised release violations, or referred to a string of facts well established by the record -- defendant's initial child pornography offense, his persistent refusal to comply with a legal obligation to participate in and complete sex offender treatment, and his repeated violations of conditions limiting his access to computers and pornographic websites.The court also held that the district court adequately explained its sentencing decision, considered defendant's mitigation claims, and did not impose an unduly harsh penalty. Accordingly, the sentence was not substantively unreasonable. View "United States v. Kocher" on Justia Law

Plaintiffs appealed the district court's denial of their motion for judgment as a matter of law in an action seeking reimbursement from State Farm after their house was destroyed by fire. The district court found that there was sufficient evidence to allow a reasonable juror to conclude that plaintiffs overstated the value of items lost in the fire by thousands of dollars and thus no expert was required to explain to the jury that fraudulent statements of this magnitude would be material to an insurer.The Eighth Circuit affirmed and held that the record contained sufficient evidence to sustain the jury's determination that plaintiffs made material misrepresentations relating to their insurance claims and thus these material misrepresentations regarding the personal property lost in the fire voided their right to recover at all under the policy. View "Borchardt v. State Farm Fire and Casualty Co." on Justia Law

The Eighth Circuit affirmed the denial of social security disability benefits to plaintiff. The court held that plaintiff clearly suffered from back pain, but substantial evidence supported the ALJ's finding that plaintiff had the residual functional capacity to perform light work. Furthermore, the ALJ did not err by failing to order a consultative examination, because the evidence in the record provided a sufficient basis for the ALJ's decision, and substantial evidence supported the ALJ's credibility determination on the record as a whole. View "Swink v. Saul" on Justia Law

The Eighth Circuit reversed the district court's order granting summary judgment to the Commissioner, in an action brought by Farm Wineries seeking a declaration that the Minnesota Farm Wineries Act's in-state requirements violates the dormant Commerce Clause. The court held that the Farm Wineries had Article III standing, because they established an injury in fact by alleging that they were presently injured by the Act because they cannot plan for and expand their businesses. Furthermore, the Farm Wineries' injuries were fairly traceable to the in-state requirement, because the Commissioner has the authority to enforce the Act against the Farm Wineries. Finally, Farm Wineries' injuries can be redressed by a declaratory judgment. Accordingly, the court remanded for further proceedings. View "Alexis Bailly Vineyard, Inc. v. Harrington" on Justia Law

After a child fell 50 ft. from a zipline at Bible camp, the parties dispute who potentially bears financial responsibility for her injuries. The Eighth Circuit held that, under the plain language of the insurance policy, the camp's insurer was not responsible for the conference center's alleged negligence. In this case, the insurer's potential liability for the child's injuries could not possibly have arisen out of the use of the premises leased to the insured. Accordingly, the court reversed and remanded for the entry of summary judgment for the insurer. View "Great American Alliance Insurance Co. v. Windermere Baptist Conference, Inc." on Justia Law

Plaintiff filed suit alleging that defendants were responsible for his delayed release from jail following the dismissal of criminal charges against him. The Eighth Circuit reversed the district court's denial of qualified immunity to the St. Louis Circuit Attorney, holding that she did not violate plaintiff's constitutional rights because the law did not clearly establish that the attorney, or prosecutors in her office, must go beyond the filing of a nolle prosequi to ensure the release of those against whom no charges are pending. Even assuming that the attorney had such a duty, plaintiff has not actually alleged that the attorney did not satisfy that responsibility.The court also held that plaintiff's false-imprisonment claim against the attorney should be dismissed where the complaint did not plausibly show that the attorney was personally involved in plaintiff's delayed release. Accordingly, the court remanded for further proceedings. View "Lewis v. Gardner" on Justia Law

The Eighth Circuit denied a petition for review of the BIA's decision upholding the IJ's determination that petitioner was removable. The court held that petitioner failed to exhaust his administrative remedies with regard to his challenge to the determination that his firearm offense was a particularly serious crime; petitioner's argument regarding the purported futility of raising the issue to the BIA was unpersuasive; the IJ acted within its authority by considering the facts and circumstances set forth in the criminal complaint; the unlawful-possession-of-a-firearm offense qualified as a particularly serious crime and barred withholding of removal; and there was no reviewable claim of error in regard to the BIA's denial of relief under the Convention Against Torture. View "Marambo v. Barr" on Justia Law

The Eighth Circuit affirmed the denial of plaintiff's application for supplemental security income, holding that substantial evidence supported the ALJ's determination that plaintiff had only a moderate restriction on his activities of daily living. In this case, while the ALJ could have weighed the evidence differently, substantial evidence supported the ALJ's determination that the psychological expert's review of all the evidence should be credited over the counselor's observations as a non-medical, other source. View "Dols v. Saul" on Justia Law

Defendant appealed the district court's imposition of a $5000 restitution order imposed after he pleaded guilty to selling eagle feathers. The Eighth Circuit reversed the order of restitution and modified the judgment to decrease the restitution amount to $130, because, based on the existing record, the actual loss caused by defendant's offense of conviction was limited to the amount of money that the government expended to buy the eagle feathers. The court remanded for the limited purpose of giving the district court the opportunity to consider in the first instance whether, based on the existing record, a fine is warranted in light of the reduced restitution award. View "United States v. Sheldon Tree Top" on Justia Law

The bankruptcy trustee filed suit against parties involved in the sale of a bankruptcy estate's assets under 11 U.S.C. 363. The Eighth Circuit affirmed the bankruptcy appellate panel's decision affirming the bankruptcy court's dismissal of the trustee's claims and denial of leave to amend the second amended complaint (SAC).The court held that the trustee's claims were impermissible collateral attacks on an earlier order approving the sale in bankruptcy that was consummated under section 363. In the alternative, the trustee was not entitled to relief from the sale order, because the amended complaint failed to state a plausible claim for fraud on the court. The court also held that the trustee was not entitled to relief from the sale order under Federal Rule of Civil Procedure 60, and the district court properly denied leave to amend the complaint based on futility. View "Fulmer v. Fifth Third Equipment Finance Co." on Justia Law