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

Justin Cutbank was charged with being a felon in possession of a firearm after an incident in which he, while intoxicated and under the influence of methamphetamine, threatened his girlfriend D.F. with a gun, held her in a closet, and struck her with the weapon. He also involved other residents of the home, including D.F.’s teenage sons and housemate, before fleeing with the gun and D.F.’s cell phone. Police later found Cutbank barricaded in a nearby garage, where he resisted arrest and assaulted an officer. A sawed-off Marlin .22 caliber rifle, matching DNA evidence to Cutbank, was recovered along the route between the two locations.The United States District Court for the District of Minnesota presided over Cutbank’s trial. The jury convicted him of being a felon in possession of a firearm and found he had at least three prior violent felony convictions, triggering enhanced sentencing under the Armed Career Criminal Act. The district court sentenced him to 292 months imprisonment, applying several sentencing enhancements, including a four-level increase for possessing the firearm in connection with another felony offense under USSG § 2K2.1(b)(6)(B).On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Cutbank’s claims of evidentiary and procedural errors, including objections to witness testimony, jury instructions, and the admission of certain statements. The appellate court found no abuse of discretion in the district court’s evidentiary rulings and determined that the sentencing enhancements were properly applied. The Eighth Circuit held that the district court correctly calculated the guidelines range, considered the relevant sentencing factors, and imposed a reasonable sentence. The judgment of the district court was affirmed. View "United States v. Cutbank" on Justia Law

The plaintiff, an hourly licensed attorney document reviewer, worked for a legal document review company with offices in Minnesota. In 2019, the company changed its overtime policy, eliminating premium overtime pay and stating that employees would be paid only their base rate for all hours worked. In 2020, the plaintiff filed a lawsuit on behalf of himself and similarly situated employees, alleging that the company failed to pay required overtime wages, in violation of the Minnesota Payment of Wages Act (MPWA), the Minnesota Fair Labor Standards Act (MFLSA), and the Minnesota Wage Theft Act (MWTA). The company subsequently paid the plaintiff and other affected employees all claimed overtime wages and liquidated damages, but the parties disagreed about the availability of statutory penalties.The United States District Court for the District of Minnesota granted summary judgment to the employer on all claims. The court did not address whether the employer had violated the statutes, as the parties had stipulated that the only remaining dispute concerned penalties. The plaintiff appealed, arguing that he was entitled to statutory penalties and injunctive relief.The United States Court of Appeals for the Eighth Circuit affirmed in part and vacated in part. The court held that only the Commissioner of Labor and Industry, not individual employees, may seek average daily wage penalties under the MPWA. Regarding the MFLSA claim, the court found that, because the plaintiff had received all owed wages and liquidated damages, and because penalties are payable to the Commissioner, there was a question of mootness and standing. The court vacated the summary judgment on the MFLSA claim and remanded for the district court to determine its jurisdiction. The court affirmed the dismissal of the MWTA claim and the denial of injunctive relief, finding no statutory basis for penalties and that the request for injunctive relief was not properly before the court. View "Cohen v. Consilio, LLC" on Justia Law

After being convicted of second-degree sexual assault in Garland County, Arkansas, Harl Garrett was sentenced to 20 years in prison. Garrett requested his attorney, Ben Hooten, to file an appeal, but instead, Hooten moved to withdraw as counsel without filing the notice of appeal. Garrett was not informed of the withdrawal order until after the 30-day window for filing a direct appeal had expired. Garrett attempted to file a pro se notice of appeal and later submitted motions for a belated appeal and to proceed in forma pauperis, but these were denied by both the Garland County Circuit Court and the Arkansas Supreme Court. Garrett subsequently filed a state postconviction petition, which was also denied as untimely.Garrett then filed a federal habeas corpus petition under 28 U.S.C. § 2254 in the United States District Court for the Eastern District of Arkansas, raising the claim that he was denied his constitutional right to a direct appeal due to counsel and court failures. The district court denied the petition as time-barred under the one-year statute of limitations set by the Antiterrorism and Effective Death Penalty Act (AEDPA), finding that the limitations period began when Garrett learned of his attorney’s abandonment and expired before the federal petition was filed. However, the district court granted a certificate of appealability on whether Garrett’s motion for a belated appeal tolled the AEDPA limitations period under 28 U.S.C. § 2244(d)(2).The United States Court of Appeals for the Eighth Circuit reviewed the case and held that a motion for belated appeal in Arkansas constitutes “collateral review” under AEDPA, thus tolling the statute of limitations while the motion is pending. The court reversed the district court’s judgment and remanded the case for further proceedings, concluding that Garrett’s federal habeas petition was timely. View "Garrett v. Payne" on Justia Law

Muhammad Arif, the owner of convenience stores in Arkansas, was accused of soliciting a fifteen-year-old girl, the daughter of his handyman, to engage in sexual acts in exchange for money on two occasions in 2019. Both incidents occurred while Arif was driving the girl home in his vehicle. The girl declined his advances, recorded the conversations, and later reported the incidents to her parents and the police. Arif was initially prosecuted under Arkansas state law, but the federal government took over, charging him under 18 U.S.C. § 1591(a)(1), which criminalizes commercial sex trafficking of a minor “in or affecting interstate or foreign commerce.”The United States District Court for the Eastern District of Arkansas presided over the trial. After the jury found Arif guilty, he moved for a judgment of acquittal, arguing that the government failed to prove the required element that his conduct affected interstate commerce. The district court agreed, granting the motion and concluding that merely driving a car manufactured out of state and giving money to the victim did not constitute an actual effect on interstate commerce as required by precedent.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo, considering whether the evidence was sufficient to establish the interstate commerce element of the federal statute. The appellate court held that the government’s evidence—Arif’s use of a car manufactured in another state, the transfer of $20, and the use of local roadways—was insufficient to show an actual effect on interstate commerce. The court distinguished this case from others where use of the internet, interstate travel, or communications had a clear impact on commerce. The Eighth Circuit affirmed the district court’s judgment of acquittal. View "United States v. Arif" on Justia Law

A U.S.-based multinational corporation filed a consolidated federal tax return for 2006, reporting royalty income received from its Brazilian subsidiary for the use of intellectual property. Brazilian law limited the amount the subsidiary could pay in royalties to its foreign parent, so the subsidiary paid and the parent reported only the amount permitted under Brazilian law. Years later, the Internal Revenue Service (IRS) issued a Notice of Deficiency, reallocating nearly $23.7 million in additional royalty income to the parent company, arguing that this reflected what an unrelated party would have paid for the intellectual property, notwithstanding the Brazilian legal restriction.The corporation challenged the IRS’s determination in the United States Tax Court. The Tax Court, in a closely divided decision, upheld the IRS’s position. A plurality of judges deferred to the IRS regulation that allowed such reallocation, finding the statute ambiguous and the regulation reasonable. Two concurring judges agreed with the result but believed the statute itself required the reallocation, regardless of the regulation. The dissenting judges argued that the statute unambiguously prohibited the IRS from reallocating income that the parent could not legally receive, and some also found the regulation procedurally invalid.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case in light of recent Supreme Court precedent clarifying that courts must independently interpret statutes without deferring to agency interpretations. The Eighth Circuit held that the relevant statute does not permit the IRS to reallocate income that the taxpayer could not legally receive due to foreign law restrictions. The court concluded that the IRS’s authority to allocate income under the statute is limited to amounts over which the taxpayer has dominion or control. The Eighth Circuit reversed the Tax Court’s decision and remanded for redetermination of the taxes owed. View "3M Company v. Commissioner of Internal Revenue" on Justia Law

Brandon King worked as a driver for United Parcel Service, Inc. (UPS) and believed he was hired for a Monday-to-Friday schedule. However, UPS assigned him to a Tuesday-through-Saturday schedule, which included weekend work he sought to avoid through various means, such as maximizing weekday hours, trading shifts, and calling in sick. UPS disciplined him for these actions, including written warnings and supervisor ride-alongs, and fired him multiple times, though the union secured his reinstatement. King alleged that UPS discriminated against him based on race and age, created a hostile work environment, and retaliated against him, claiming that younger, white employees were allowed to avoid Saturday shifts and were disciplined less harshly for similar conduct.King filed suit in Iowa state court under the Iowa Civil Rights Act. UPS removed the case to the United States District Court for the Southern District of Iowa, arguing that the Labor Management Relations Act (LMRA) completely preempted King’s state law claims because resolving them would require interpretation of the collective-bargaining agreement. The district court denied King’s motion to remand the case to state court and granted UPS’s motion for judgment on the pleadings, finding that King’s claims were preempted and that he failed to state a claim under federal law.The United States Court of Appeals for the Eighth Circuit reviewed both the refusal to remand and the judgment on the pleadings de novo. The court held that King’s discrimination and hostile work environment claims were substantially dependent on analysis of the collective-bargaining agreement and thus completely preempted by the LMRA, requiring dismissal. The retaliation claim failed because King did not plausibly allege a causal connection between protected activity and adverse employment action. The court also found no abuse of discretion in denying leave to amend. The judgment of the district court was affirmed. View "King v. United Parcel Service, Inc." on Justia Law

The plaintiffs, two banking organizations, challenged a guidance document issued by a federal agency that oversees insured banks. The guidance, known as FIL 32, addresses the practice of charging multiple non-sufficient funds (NSF) fees when a single transaction is presented for payment more than once. The guidance warns that such practices may pose a risk of being considered unfair or deceptive under federal law, particularly if customers are not adequately informed or given an opportunity to avoid additional fees. The plaintiffs argued that this guidance effectively acts as a binding regulation, requiring compliance measures and increasing their risk of enforcement, and that it was issued without following required rulemaking procedures.The United States District Court for the District of Minnesota dismissed the case, finding that the plaintiffs lacked standing to challenge the guidance. The court concluded that the plaintiffs’ alleged injuries were not redressable and that the guidance did not constitute a final agency action subject to judicial review.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the dismissal, but on the alternative ground that the plaintiffs’ claims were not ripe for judicial review. The appellate court held that the guidance was not a final agency action because it did not impose binding obligations or legal consequences, nor did it compel the banks to take or refrain from specific actions. The court found that the guidance merely outlined supervisory expectations and risk-mitigation practices, without creating enforceable rules or safe harbors. The court also determined that withholding judicial review would not cause significant hardship to the plaintiffs, as the enforcement risk existed independently of the guidance. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "Minnesota Bankers Assoc. v. FDIC" on Justia Law

Raymond Thompson purchased a custom Harley Davidson motorcycle and paid off all liens, but after the sale, the seller, Nathan Rench, fraudulently obtained a duplicate title, preventing Thompson from registering the motorcycle. Later, two individuals claiming to act for Rench arrived at Thompson’s home with Manchester, Missouri police officers, seeking to recover the motorcycle. The officers, after verifying the duplicate title and registration in Rench’s name, allowed the individuals to take the motorcycle from Thompson’s fenced backyard. Thompson was not home at the time. The next day, after Thompson reported the motorcycle stolen and provided evidence of his ownership, the officers instructed Rench to return the motorcycle, but Rench refused. The motorcycle was eventually recovered after Rench’s arrest.Thompson filed a lawsuit in the United States District Court for the Eastern District of Missouri, alleging that the officers violated his Fourth Amendment rights by entering his property and allowing the removal of his motorcycle, and his Fourteenth Amendment due process rights. He also sought sanctions for the police department’s failure to preserve body and dash camera footage. The district court granted summary judgment to the officers on the basis of qualified immunity, denied Thompson’s motion for sanctions, and denied his motion for partial summary judgment.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the officers did not violate a clearly established constitutional right by entering Thompson’s backyard or by allowing the motorcycle’s removal, as their actions were consistent with existing Eighth Circuit precedent regarding limited warrantless entries and peacekeeping roles. The court also found no evidence of joint action or coercion by the officers sufficient to establish state action for a due process claim. Finally, the court concluded that the district court did not abuse its discretion in denying sanctions, as Thompson failed to show prejudice from the loss of the recordings. View "Thompson v. Cockrell" on Justia Law

In the early morning hours, police responded to a 911 call from a woman who reported that her boyfriend, Shaquan Coffer, had damaged her car and was armed. Officers located the vehicle, separated the two individuals, and learned from the woman that Coffer was intoxicated and carrying a firearm. While speaking with an officer, Coffer attempted to conceal something in his waistband and then fled on foot. During the chase, officers saw him reach into his pants and heard a metallic sound; they recovered a loaded handgun, painted white, from the ground 11 seconds later. Coffer was apprehended shortly after.Following Coffer’s guilty plea to being a felon in possession of a firearm, the United States District Court for the Northern District of Iowa considered whether to apply a two-level sentencing enhancement for recklessly creating a substantial risk of death or serious bodily injury during flight from law enforcement under U.S.S.G. § 3C1.2. The Presentence Investigation Report did not recommend the enhancement, but the government objected. At sentencing, the district court found that, although accidental discharge was unlikely due to the firearm’s safety features, discarding a loaded gun in public created a substantial risk to others, particularly because of the gun’s appearance. The court applied the enhancement, increasing Coffer’s guideline range, and imposed a 71-month sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the district court erred in applying the enhancement, as the government failed to show that Coffer’s conduct created more than a speculative risk of harm; there was no evidence of bystanders or actual endangerment beyond the mere act of discarding the firearm. The appellate court vacated Coffer’s sentence and remanded for resentencing, finding the error in guideline calculation was not harmless. View "United States v. Coffer" on Justia Law

During an oil pipeline protest in Hubbard County, Minnesota, Matthew Locke and another protestor locked themselves to construction equipment using a device known as a “sleeping dragon,” which made removal difficult. Law enforcement officers, including Sheriff Cory Aukes and Chief Deputy Scott Parks, responded to the scene. In their efforts to remove Locke, the officers used several pain compliance techniques, applying pressure to various nerves on Locke’s head and neck. Locke alleges that as a result, he suffered facial paralysis, tinnitus, and emotional distress. After being removed from the device by extraction teams, Locke was evaluated by EMTs, taken to the hospital, and then jailed.The United States District Court for the District of Minnesota dismissed Locke’s claims under 42 U.S.C. § 1983 and Minnesota law. The court held that Sheriff Aukes and Deputy Parks were entitled to qualified and official immunity, and that Locke’s complaint did not state a claim for municipal liability against Hubbard County. The district court also dismissed Locke’s state law claims for assault and battery.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The Eighth Circuit held that, accepting the complaint’s allegations as true, Locke plausibly alleged a violation of his clearly established Fourth Amendment right to be free from excessive force, as the officers’ use of pain compliance techniques on a nonviolent, passively resisting misdemeanant was not objectively reasonable. The court also found that the district court erred in dismissing the official capacity claim without considering whether the sheriff was a final policymaker for the county. Additionally, the Eighth Circuit reversed the grant of official immunity on the state law claims, finding that the complaint sufficiently alleged willful violation of a known right. The court reversed and remanded for further proceedings. View "Locke v. County of Hubbard" on Justia Law