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

Vernon Holland was fatally injured by a rewinder machine at his workplace. Robert Cearley, Jr., representing Holland’s estate, filed a wrongful death lawsuit against Bobst Group North America, Inc. (Bobst NA), the company responsible for delivering and installing the rewinder. The lawsuit sought damages based on several tort claims.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of Bobst NA. The court ruled that Arkansas’s statute of repose, which limits the time frame for bringing claims related to construction or design defects, barred Cearley’s claims. Cearley appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court examined whether Bobst NA was protected under Arkansas Code § 16-56-112(b)(1), which is a statute of repose for claims arising from personal injury or wrongful death caused by construction defects. The court concluded that Bobst NA’s involvement in the delivery, installation, integration, and commissioning of the rewinder constituted the construction of an improvement to real property. The court also determined that the rewinder was an improvement to real property because it was affixed to the plant, furthered the purpose of the realty, and was designed for long-term use.As the lawsuit was filed more than four years after the installation of the rewinder, the court held that the claims were barred by the statute of repose. Consequently, the Eighth Circuit affirmed the district court’s judgment in favor of Bobst NA. View "Cearley v. Bobst Group North America Inc." on Justia Law

First Baptist Church, located in Fort Smith, Arkansas, had property insurance policies with Zurich American Insurance Company. The church experienced leaks over the years and hired roofing companies to repair portions of its roofing system in 2016, 2017, and 2018. In 2022, a roofing company representative determined the roofing system had hail damage, and First Baptist filed a claim with Zurich, alleging the damage occurred on April 28, 2017. Zurich denied the claim, citing no damage from the alleged hail event and evidence of excluded causes such as wear and tear. First Baptist sued Zurich for breach of contract and insurance bad faith.The United States District Court for the Western District of Arkansas granted summary judgment in favor of Zurich, concluding that First Baptist failed to comply with the prompt notice provision in the insurance policy. The court based its decision on evidence first discussed in Zurich’s reply brief, which indicated that First Baptist knew of past loss or damage to its property as early as 2016. The court held that no reasonable jury could find that First Baptist promptly notified Zurich of the loss or damage nearly six years later in January 2022. First Baptist filed a motion to reconsider, which the district court denied.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that there were potential genuine disputes of material fact not properly litigated. The court noted that First Baptist did not have a fair opportunity to counter Zurich’s evidence and arguments about past leaks and repairs. The court reversed the district court’s grant of summary judgment and remanded the case for further consideration of the issues related to past loss or damage and the effect on First Baptist’s claims. The court also reversed and remanded the grant of summary judgment on First Baptist’s bad faith claim. View "First Baptist Church v. Zurich American Insurance Co." on Justia Law

Aziz El Manyary, a Moroccan citizen, entered the U.S. in 2006 on a K-1 visa and married a U.S. citizen. He applied to adjust his status but failed to attend a USCIS interview, leading to the denial of his petition. Subsequently, USCIS initiated removal proceedings, and an immigration judge (IJ) ordered him removed in absentia when he failed to appear at a hearing. Seven years later, El Manyary filed a motion to reopen the proceedings, which was denied as untimely by both the IJ and the Board of Immigration Appeals (BIA). Five years later, he filed a second motion to reopen, which the BIA also denied as untimely.The IJ denied El Manyary's first motion to reopen, citing untimeliness and lack of diligence. The BIA affirmed this decision. El Manyary's second motion to reopen was also denied by the BIA, which found it untimely and declined to toll the deadline due to lack of diligence. The BIA rejected his argument of lack of notice, noting that he had received proper notice of his hearing.The United States Court of Appeals for the Eighth Circuit reviewed the case and denied El Manyary's petition for review. The court held that the BIA did not abuse its discretion in denying the motion to reopen based on untimeliness and lack of notice. The court also found that the BIA's decision not to reopen the case sua sponte was discretionary and not subject to judicial review. The petition for review was denied, and the BIA's decision was upheld. View "Manyary v. Bondi" on Justia Law

Tennessee and sixteen other states challenged a regulation by the Equal Employment Opportunity Commission (EEOC) under the Pregnant Workers Fairness Act, which mandates reasonable accommodations for pregnancy-related conditions, including abortion. The states argued that the regulation unlawfully required them to accommodate employees seeking abortions, conflicting with their policies. They sought an injunction and a declaratory judgment against the rule, claiming it was arbitrary, exceeded EEOC's authority, violated the First Amendment and federalism principles, and was unconstitutional under Article II.The United States District Court for the Eastern District of Arkansas dismissed the case, ruling that the states lacked standing as they did not demonstrate an imminent injury or that the alleged injuries were redressable. The court found the risk of enforcement speculative and compliance costs not directly traceable to the rule. The court also dismissed the states' motion for a preliminary injunction as moot and for failing to show irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that the states had standing as they were the direct objects of the EEOC's regulation, which imposed new obligations on them. The court found that the states were injured by the regulatory burden itself and that setting aside the rule would remedy this injury. The court concluded that the states' need to comply with the rule constituted an injury in fact, caused by the EEOC's action, and redressable by a favorable judicial decision. The case was remanded for further proceedings without addressing the merits of the claims. View "State of Tennessee v. EEOC" on Justia Law

Jeremy Young was convicted by a jury of possessing an unregistered firearm and being a felon in possession of a firearm. He was also convicted by a separate jury of assaulting a federal officer. Young received a total sentence of 84 months’ imprisonment and 3 years of supervised release. He appealed, challenging the Government’s use of peremptory strikes against Native American venirepersons, the district court’s decision to admit certain evidence as res gestae, and the sufficiency of the evidence at both trials.The United States District Court for the District of South Dakota denied Young’s Batson challenges, finding the Government’s reasons for striking the Native American jurors to be legitimate and race-neutral. The court also admitted excerpts of Young’s recorded interview with Agent Kumley, where Young discussed his plans to transport methamphetamine, as relevant res gestae evidence. The jury found Young guilty on all counts.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court found no clear error in the district court’s Batson analysis, noting that the Government provided race-neutral reasons for striking the jurors and that Young failed to demonstrate pretext. The court also upheld the admission of the recorded interview, agreeing that it provided relevant context for Young’s possession of the shotgun. Finally, the court concluded that the evidence was sufficient to support Young’s convictions, as the jury reasonably found that Young had both actual and constructive possession of the firearm and that he intentionally assaulted Sergeant Antoine. View "United States v. Young" on Justia Law

Police discovered 788 pounds of marijuana and related paraphernalia in a Minnesota warehouse, where Danny Gehl and five others were present. Gehl was charged with conspiracy to distribute marijuana and possession with intent to distribute marijuana. Evidence included surveillance, searches of Gehl’s home, and his phone, revealing marijuana, cash, and drug paraphernalia. Gehl was convicted and sentenced to 120 months’ imprisonment, the mandatory minimum.The United States District Court for the District of Minnesota handled the initial trial. Gehl was convicted on both counts, and the court sentenced him to the mandatory minimum of 120 months. Gehl appealed, arguing insufficient evidence for his conviction and improper denial of safety-valve relief and a minor-participant downward adjustment at sentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the evidence was sufficient to support Gehl’s conviction, noting his involvement in the conspiracy and the substantial amount of marijuana involved. The court also found no error in the district court’s denial of safety-valve relief, as Gehl’s proffer was not truthful. Lastly, the court deemed the issue of the minor-participant adjustment moot, as Gehl’s sentence would remain the same due to the mandatory minimum. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Gehl" on Justia Law

Seven states challenged a rule by the Department of Education that modified an existing income contingent repayment (ICR) plan for federal student loans, known as the Saving on a Valuable Education (SAVE) plan. This plan altered payment thresholds, stopped interest accrual, and forgave loan balances after as little as ten years of repayment. The states argued that the Secretary of Education exceeded statutory authority by forgiving loans through an ICR plan.The United States District Court for the Eastern District of Missouri found that the states were likely to succeed on their claim and issued a preliminary injunction against the rule’s early loan forgiveness provisions. Both parties appealed: the federal officials sought to vacate the preliminary injunction, while the states requested a broader injunction.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the states were likely to succeed in their claim that the Secretary’s authority to promulgate ICR plans does not include loan forgiveness at the end of the payment period. The court held that the statute requires ICR plans to be designed for borrowers to repay their loan balances in full through payments that can fluctuate based on income during the payment term. The court determined that the Secretary had exceeded this authority by designing a plan where loans are largely forgiven rather than repaid.The Eighth Circuit affirmed the entry of the preliminary injunction but concluded that the district court erred by not enjoining the entire rule. The court remanded the case with instructions to modify the injunction to cover the entire SAVE Rule and the revived forgiveness provisions under the previous REPAYE plan. View "State of Missouri v. Trump" on Justia Law

The Ferchichi family, natives and citizens of Algeria, sought asylum in the United States due to their son T.F.'s severe spina bifida condition. After being denied adequate medical treatment in Algeria, they raised funds and traveled to the U.S. for T.F.'s surgery. They filed for asylum, withholding of removal, and protection under the Convention Against Torture (CAT) in 2009, claiming persecution based on T.F.'s disability and fear of future persecution due to their public criticism of the Algerian medical system.The Immigration Judge (IJ) denied their claims in 2011, finding that the lack of treatment was due to Algeria's inadequate healthcare system and not persecution based on T.F.'s condition. The IJ also found no evidence of future persecution, noting that their family members in Algeria had not been harmed. The Board of Immigration Appeals (BIA) affirmed the IJ's decision in 2022, agreeing that the refusal to treat T.F. was due to the government's desire to avoid international treatment costs and not persecution.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court upheld the BIA's decision, finding substantial evidence that the lack of medical care was due to Algeria's healthcare inadequacies and not persecution. The court also agreed that the Ferchichis did not demonstrate a well-founded fear of future persecution, as their family members in Algeria had not been harmed and the country condition reports did not directly link to their situation. Consequently, the court denied the Ferchichis' petition for review. View "Ferchichi v. Bondi" on Justia Law

Kira Zielinski took her minor child to Mexico to deprive her ex-husband of his parental rights. Upon returning to the United States, she was indicted for international parental kidnapping under 18 U.S.C. § 1204(a). After a bench trial, the United States District Court for the Southern District of Iowa found her guilty and sentenced her to 36 months in prison. Zielinski appealed, arguing that the district court wrongly prevented her from presenting evidence that she fled to protect her child from sexual abuse by the father.The district court ruled that 18 U.S.C. § 1204(c)(2), which provides an affirmative defense for fleeing domestic violence, did not apply because Zielinski did not claim she was a victim of domestic violence herself. The court interpreted the statute to mean that the defense only applies if the defendant, not a third party like Zielinski’s child, suffered domestic violence. Zielinski contended that the statute should cover situations where the defendant aids a third party in escaping domestic violence, but the district court disagreed.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s interpretation of § 1204(c)(2) de novo and affirmed the lower court’s decision. The appellate court held that the statute’s plain language does not include defense of a third party and that Congress could have explicitly included such language if intended. The court also rejected Zielinski’s arguments that the statute is void for vagueness and that the district court’s interpretation violated the rule of lenity, finding the statute’s language clear and unambiguous. Consequently, the appellate court affirmed the district court’s judgment. View "United States v. Zielinski" on Justia Law

Clint Schram was convicted by a jury of multiple offenses related to his operation of child pornography websites. He was sentenced by the district court to a life term and four concurrent thirty-year terms of imprisonment. Schram appealed, arguing that the evidence was insufficient to support his convictions, that the district court improperly admitted multiple images of child pornography into evidence, and that the district court erred in calculating his guidelines sentencing range and imposing an overlong sentence.The United States District Court for the Western District of Missouri initially reviewed the case. The court found Schram guilty on five counts: four counts of advertising child pornography and one count of engaging in a child exploitation enterprise. The court admitted multiple images of child pornography into evidence and calculated Schram's guidelines sentencing range, ultimately imposing a life sentence and four concurrent thirty-year terms.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the evidence was sufficient to support Schram's convictions, as the jury could reasonably determine that the images depicted real children. The court also found no reversible error in the district court's admission of multiple images of child pornography, as they were highly probative and not unduly prejudicial. Additionally, the court upheld the district court's calculation of Schram's guidelines sentencing range and found his sentence to be substantively reasonable, given the seriousness of his offenses and his dangerous behavior.The Eighth Circuit affirmed Schram's convictions and sentence, concluding that there was no reversible error in the district court's decisions. View "United States v. Schram" on Justia Law