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

James Hess filed an employment discrimination lawsuit against Union Pacific Railroad Company, claiming he was unlawfully terminated due to his disability. Union Pacific has a "Fitness-for-Duty" policy requiring employees to disclose certain health conditions. Hess, who began working for Union Pacific in May 2013, was prescribed Xanax for post-traumatic stress disorder in 2015. In 2016, Union Pacific prohibited medications like Xanax, and in January 2017, Hess was removed from service and later disqualified from his job following a fitness-for-duty evaluation.The District Court for the District of Nebraska dismissed Hess's action as untimely, agreeing with Union Pacific that the statute of limitations was not tolled while the Harris class action was pending because Hess was not a member of the certified class. The Harris class action, filed in 2016, alleged that Union Pacific's fitness-for-duty policy discriminated against employees with disabilities. The class was initially defined broadly but was later certified under a narrower definition, excluding Hess. The class was decertified by the Eighth Circuit in March 2020, after which Hess filed an EEOC charge and received a right-to-sue letter.The United States Court of Appeals for the Eighth Circuit reviewed the case. Citing its recent decision in DeGeer v. Union Pacific Railroad Co., the court held that Hess was entitled to American Pipe tolling because he was not unambiguously excluded from the certified class. Therefore, the statute of limitations was tolled until the class was decertified. The Eighth Circuit reversed the district court's dismissal and remanded the case for further proceedings, concluding that Hess's lawsuit was timely filed. View "Hess v. Union Pacific Railroad Co." on Justia Law

Robert L. Palmer, a long-time employee of Union Pacific, alleged that the company discriminated against him due to his disability, diabetes, which led to diabetic retinopathy. After undergoing surgery for his right eye in 2011, Palmer continued working until November 2013, when his left eye developed blurred vision. Union Pacific then initiated a fitness-for-duty evaluation, resulting in a February 2014 letter from Dr. Holland, the Chief Medical Officer, imposing permanent work restrictions on Palmer. Despite submitting medical information from his eye doctor in May 2014, which cleared him for work, Palmer received a December 2014 letter reaffirming the permanent restrictions and stating that no further medical information would be considered.Palmer was part of a putative class action (Harris class) filed in February 2016, which alleged that Union Pacific's fitness-for-duty policy discriminated against employees with disabilities. The class was certified in February 2019 but decertified in March 2020. Palmer then filed an individual charge of discrimination with the EEOC in April 2020 and subsequently filed this action under the ADA, claiming his suit was timely due to tolling during the class action.The United States District Court for the District of Nebraska dismissed Palmer's claims as time-barred, concluding that the only adverse employment action occurred in February 2014, outside the class definition period. Palmer's motion to reconsider or amend was denied, as the court found the December 2014 letter was not a separate adverse action but a consequence of the February 2014 action.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the district court relied on an outdated standard for adverse employment actions. Under the new standard from Muldrow v. City of St. Louis, Palmer's allegations that the December 2014 letter caused him harm by denying future review opportunities were sufficient to constitute an adverse employment action. The appellate court reversed the district court's denial of reconsideration and leave to amend, remanding for further proceedings. View "Palmer v. Union Pacific Railroad Co." on Justia Law

The Association for Accessible Medicines (AAM), representing generic drug manufacturers, challenged a Minnesota law regulating drug prices, Minn. Stat. § 62J.842, arguing it violated the dormant Commerce Clause. The law prohibits manufacturers from imposing excessive price increases on generic or off-patent drugs sold in Minnesota. The district court granted AAM's motion for a preliminary injunction, finding the law likely violated the dormant Commerce Clause.The United States District Court for the District of Minnesota concluded that AAM was likely to succeed on the merits of its claim, faced a threat of irreparable harm, and that the balance of harms and public interest factors were neutral. Minnesota appealed, contesting the likelihood of success on the merits and the balance of harms/public interest.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s ruling for abuse of discretion and its legal conclusions de novo. The court found that the Minnesota law had the impermissible extraterritorial effect of controlling prices outside the state, similar to laws previously struck down by the Supreme Court. The court rejected Minnesota's argument that the law did not control out-of-state prices, noting that it effectively regulated out-of-state transactions if the drugs ended up in Minnesota.The Eighth Circuit affirmed the district court’s decision, agreeing that AAM was likely to succeed on the merits of its dormant Commerce Clause claim. The court also found no abuse of discretion in the district court’s assessment of the balance of harms and public interest, noting that protecting constitutional rights is always in the public interest. The preliminary injunction against the Minnesota law was upheld. View "Ass'n for Accessible Medicines v. Ellison" on Justia Law

SWT Global Supply, Inc. (SWT Global), a Missouri-based manufacturer of electronic nicotine delivery system (ENDS) vaping products, sought review of the U.S. Food and Drug Administration's (FDA) denial of market authorization for its menthol-flavored ENDS products. The FDA denied the premarket tobacco product applications (PMTAs) submitted by SWT Global, citing insufficient evidence that the products would benefit adult users enough to outweigh the risks to youth.The FDA's decision was based on the Family Smoking Prevention and Tobacco Control Act of 2009, which requires new tobacco products to receive FDA authorization before being sold. The FDA determined that SWT Global's PMTAs lacked product-specific evidence demonstrating that the menthol-flavored ENDS products would attract adults away from combustible cigarettes and reduce overall harm. The FDA also found SWT Global's marketing plan insufficient to prevent youth access to the products.The United States Court of Appeals for the Eighth Circuit reviewed the case. SWT Global argued that the FDA's denial was arbitrary and capricious, claiming the FDA changed its position on the required scientific evidence and failed to justify its finding that the marketing plan was insufficient. The court referenced the Supreme Court's decision in Food & Drug Administration v. Wages & White Lion Investments, L.L.C., which held that the FDA's denial of PMTAs for flavored ENDS products was consistent with its guidance and did not violate the change-in-position doctrine.The Eighth Circuit found that the FDA did not change its position regarding the scientific evidence required for PMTAs and provided a satisfactory explanation for its decision. The court also determined that the FDA's treatment of menthol-flavored ENDS products was reasonable and consistent with its approach to other non-tobacco-flavored ENDS products. Consequently, the court denied SWT Global's petition for review. View "SWT Global Supply, Inc. v. U.S. Food & Drug Administration" on Justia Law

On March 15, 2022, law enforcement responded to a drug overdose in Rapid City, South Dakota, where they found K.S. conscious but sluggish after receiving Narcan. Officers suspected two individuals, including a woman with purple hair, of distributing fentanyl to K.S. Surveillance at a hotel led to a traffic stop of a red Ford Fiesta, where officers found Anthony Ward in the backseat. Ward was arrested for false impersonation after providing false names. A search of the vehicle revealed drugs, a stolen gun, and cash. Ward was charged with distribution of a controlled substance resulting in serious bodily injury and conspiracy to distribute fentanyl.The United States District Court for the District of South Dakota denied Ward's motions to suppress evidence from the traffic stop and to dismiss the indictment for failure to preserve evidence. After a five-day trial, the jury convicted Ward on both counts, and the court imposed concurrent 360-month sentences. Ward appealed the district court's decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the district court's denial of Ward's motions to suppress and dismiss, finding no unreasonable extension of the traffic stop and no bad faith in the handling of evidence. The court also found sufficient evidence to support Ward's convictions. The court concluded that the evidence showed Ward distributed fentanyl that caused K.S.'s serious bodily injury and that Ward was involved in a conspiracy to distribute fentanyl. The judgment of the district court was affirmed. View "United States v. Ward" on Justia Law

A Missouri state trooper stopped the defendant for minor traffic violations, during which the defendant disclosed his status as a registered sex offender. The trooper invited the defendant into his patrol car while checking his license and registration. During this time, the trooper learned that the defendant had not registered any social media accounts as required by Missouri law. The trooper then asked for and received consent to search the defendant’s vehicle. While searching, the trooper picked up the defendant’s cell phone, which illuminated to reveal social media app icons. The trooper questioned the defendant about the phone and, after repeated requests, obtained the defendant’s verbal consent to search the phone. The search revealed images suspected to be child pornography, leading to the defendant’s arrest. After being read his Miranda rights, the defendant made further incriminating statements. A subsequent warrant-based search of the phone uncovered additional illegal material.The United States District Court for the Western District of Missouri denied the defendant’s motion to suppress the evidence from the cell phone and his statements to law enforcement, adopting a magistrate judge’s recommendation. The defendant waived his right to a jury trial, proceeded to a bench trial, and was convicted of receiving child pornography.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the trooper’s brief questioning and request for consent did not unlawfully prolong the traffic stop. The court found that moving the cell phone during a consensual vehicle search did not constitute an unlawful search or seizure, and that the defendant voluntarily consented to the phone search. The court also determined that the defendant was not in custody for Miranda purposes during pre-arrest questioning, so suppression of his statements was not warranted. The district court’s judgment was affirmed. View "United States v. Puckett" on Justia Law

Nicholas Nesdahl, posing as a teenager, used social media to contact several minor girls and solicit sexually explicit images and videos. In one instance, he directed a 13-year-old girl to record herself sexually abusing her 6-year-old stepsister. The abuse was discovered by the older girl’s mother, who notified authorities. Law enforcement identified Nesdahl as the recipient and found he had received similar material from at least seven other minors across the country. Nesdahl was indicted in both the District of North Dakota and the Western District of Pennsylvania, with the latter case transferred to North Dakota. He entered a plea agreement, pleading guilty to two counts from the Pennsylvania indictment (involving receipt of child pornography and sexual exploitation of a minor) and seven counts from the North Dakota indictment (all for sexual exploitation of a minor).The United States District Court for the District of North Dakota adopted the Presentence Investigation Report, which recommended the statutory maximum sentence and identified nine victims, triggering mandatory restitution under 18 U.S.C. § 2259(b)(2). Nesdahl did not object to the restitution order. At sentencing, the court imposed 600 months’ imprisonment and ordered $3,000 in restitution for each of the nine victims.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the restitution order for plain error and found that mandatory restitution under § 2259(b)(2) applies only to certain trafficking offenses, not to convictions under 18 U.S.C. § 2251(a). The court held that restitution was only authorized for the two victims associated with the § 2252(a)(2) conviction, not for the other seven victims. The Eighth Circuit vacated the restitution award and remanded for a new order reflecting only the two qualifying victims. The court affirmed the 600-month sentence, finding it substantively reasonable and within the district court’s discretion. View "United States v. Nesdahl" on Justia Law

Dr. Jeffery Weisman filed a lawsuit after resigning from Washington University’s residency program, alleging that he was forced to resign due to hostile treatment and that Washington University and Barnes Jewish Hospital prevented him from transferring to another residency program. Weisman brought claims for breach of contract, tortious interference, fraudulent inducement, and defamation under Missouri law. Washington University and Barnes Jewish Hospital counterclaimed for a violation of the Missouri Computer Tampering Act (MCTA).The United States District Court for the Eastern District of Missouri dismissed Weisman’s tortious interference and fraudulent inducement claims, and some of his breach of contract claims. The court granted summary judgment in favor of Barnes Jewish Hospital on the remaining breach of contract claims and the defamation claim. The court also dismissed the MCTA counterclaims and the defendants’ request for attorneys’ fees. Weisman appealed the adverse judgments on his claims, and the defendants cross-appealed the dismissal of the MCTA counterclaims and denial of attorneys’ fees.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decisions. The appellate court held that the statute of frauds barred Weisman’s breach of contract claim related to the Lab-Residency Contract, as it was an oral agreement for a term of five years. The court also affirmed the dismissal of the tortious interference claims, concluding that Evers and Benzinger, as agents of Washington University, were not third parties to the contracts. Additionally, the court upheld the dismissal of the fraudulent inducement claims, as the alleged Separation Agreement did not exist. Finally, the court affirmed the dismissal of the MCTA counterclaims for lack of subject matter jurisdiction, as Weisman’s tender of full payment rendered the claims moot. View "Weisman v. Barnes Jewish Hospital" on Justia Law

Nathan Rinne sued Camden County and two of its commissioners, Greg Hasty and Donald Williams, Jr., alleging violations of his First and Fourteenth Amendment rights after Hasty and Williams voted to ban him from all County property for one year. The defendants sought summary judgment on the defenses of qualified and legislative immunity and on the merits of the issue of punitive damages. The district court denied these motions in full.The United States District Court for the Western District of Missouri denied the defendants' motions for summary judgment. The defendants then appealed the denial of legislative immunity, qualified immunity, and the issue of punitive damages.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the denial of legislative immunity, holding that the commissioners' decision to ban Rinne from county property was administrative, not legislative, in nature. The court found that the act of banning Rinne did not concern the enactment or promulgation of public policy but was an effort to monitor and discipline his presence and conduct at future commission meetings. Consequently, the commissioners were not entitled to legislative immunity. The court dismissed the remainder of the appeal, including the issues of qualified immunity and punitive damages, for lack of jurisdiction, as these involved genuine disputes of fact that could not be resolved at the appellate level. View "Rinne v. Hasty" on Justia Law

Jacob McWaters was stopped by law enforcement in January 2023, and they found 19,910 grams of methamphetamine in his vehicle. During a post-Miranda interview, McWaters admitted to transporting methamphetamine from Texas to Minnesota and had done so on two prior occasions. He pleaded guilty to possession with intent to distribute 50 grams or more of methamphetamine.The United States District Court for the Southern District of Iowa sentenced McWaters to 240 months in custody, followed by five years of supervised release. McWaters objected to the Presentence Report’s (PSR) calculation of his Guidelines range, arguing for a reduction in his offense level due to his mitigating role. The district court overruled his objection and calculated his Guidelines range at 292 to 365 months. However, the court granted a partial downward variance, resulting in a 240-month sentence.McWaters appealed to the United States Court of Appeals for the Eighth Circuit, arguing that the district court erred in not applying a role reduction under USSG § 3B1.2. The Eighth Circuit reviewed the district court’s factual finding for clear error. The court noted that McWaters needed to prove his conduct involved more than one participant and that his culpability was minor compared to others. McWaters emphasized his role as a low-level courier with minimal knowledge of the drug operation but failed to provide evidence comparing his conduct to other participants. The court found no clear error in the district court’s decision and upheld the denial of the role reduction.The Eighth Circuit affirmed the district court’s judgment, maintaining McWaters’s 240-month sentence. View "United States v. McWaters" on Justia Law