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

A nonprofit organization, which hosts an annual art auction, held its 2022 event virtually. To facilitate the livestreamed auction and online bidding, it contracted with two vendors: one to provide the video feed and another to supply bidding software. The video vendor created a YouTube link for attendees to view the auction, and the bidding software synced with this feed, enabling participants to watch and bid on a single screen. Minutes before the event, the video vendor lost its internet connection, causing the YouTube link to break and severing the connection between the video feed and the bidding platform. As a result, auction attendees could neither view the auction nor place bids through the intended system. The auction was hurriedly redirected to a different platform, which resulted in a less effective, asynchronous experience and significantly lower fundraising.The nonprofit threatened legal action against the video vendor for breach of contract and negligence. The vendor, unable to pay, assigned its insurance claim to the nonprofit. The vendor’s insurer, Auto-Owners Insurance Company, had issued a general liability policy that covered certain types of property damage but contained a specific exclusion for damages arising out of the loss or inability to access electronic data. Auto-Owners filed for a declaratory judgment in the United States District Court for the Western District of Missouri, seeking a ruling that its policy did not provide coverage. The district court granted summary judgment to Auto-Owners, holding that the policy’s electronic-data exclusion barred recovery.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s interpretation of Missouri law de novo. The appellate court held that the policy’s electronic-data exclusion clearly and unambiguously applied to the circumstances, barring coverage for the losses. Therefore, the Eighth Circuit affirmed the district court’s grant of summary judgment in favor of Auto-Owners Insurance Company. View "Auto-Owners Insurance Company v. Halo Foundation: Helping Art Liberate Orphans" on Justia Law

Lucas Alzu and Amy Nichole Huff met in Colombia in 2018 and began a romantic relationship that led to Huff becoming pregnant. Both led highly nomadic lives, moving frequently and attending international gatherings. In July 2019, due to expiring Colombian visas, they decided to relocate to Argentina, where Alzu’s family lived, for the birth of their child. Huff moved to Argentina when six months pregnant, but soon left Alzu’s family home because of physical assault and lived independently before Alzu joined her again. Their child was born in March 2020, and the COVID-19 pandemic shortly thereafter restricted travel. Following a breakdown in their relationship in 2021, Huff was granted an order of protection and, after travel restrictions were lifted, obtained permission from an Argentinian court to travel with the child. Instead of returning, Huff remained in the United States and began working full-time.The United States District Court for the Western District of Missouri bifurcated proceedings to first determine the child’s habitual residence under the Hague Convention and International Child Abduction Remedies Act. After a two-day evidentiary hearing, the district court found that Alzu had not established Argentina as the child’s habitual residence and dismissed his petition for return of the child.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s determination for clear error, applying the totality-of-the-circumstances standard as required by Supreme Court precedent. The appellate court found that the district court properly weighed factors such as parental intentions, immigration status, the child’s age, residency, family relationships, and pandemic-related restrictions. The Eighth Circuit held that Alzu had not met his burden to show Argentina was the child’s habitual residence and affirmed the district court’s judgment. View "Alzu v. Huff" on Justia Law

A man engaged in sexually explicit exchanges with a 13-to-14-year-old girl, during which he solicited and received images and videos depicting the minor’s genitalia and acts of self-penetration with a sex toy. His communications included explicit language suggesting rough and anal sex and requesting increasingly graphic content. After he received sexually explicit media from the minor, he was arrested and charged with several offenses, including sexual exploitation of a minor, receipt and possession of child pornography, and transfer of obscene material to a minor. He ultimately pled guilty to the receipt of child pornography.The United States District Court for the Southern District of Iowa applied a four-level sentence enhancement under U.S.S.G. § 2G2.1(b)(4)(A), reasoning that the material he received depicted sadistic or masochistic conduct or other depictions of violence, specifically the minor’s self-penetration with a foreign object. The court sentenced him to 240 months in prison. The defendant appealed, contending that the enhancement did not apply because the victim was not prepubescent, used a sex toy rather than another object, and appeared to experience sexual pleasure rather than pain.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and its application of the Sentencing Guidelines de novo. The appellate court held that, under its precedent including United States v. Starr, acts of self-penetration by a minor with a foreign object constitute "violence" under the guideline, regardless of the minor’s age, the type of object, or whether the minor experienced pain. The appellate court affirmed the district court’s judgment, upholding the four-level enhancement. View "United States v. Vannausdle" on Justia Law

After the death of his father, Richard, the plaintiff, Rich, brought suit against his stepbrother, Tim, and his stepmother, Patti, regarding the management of Richard’s IRA funds. Richard had named Rich and Patti as the primary beneficiaries of his IRA, with 75% and 25% interests, respectively. When Richard’s health declined due to dementia, Tim obtained a power of attorney and was later appointed conservator by an Iowa state court, but Rich was not notified of these proceedings. Tim subsequently withdrew funds from Richard’s IRA, transferred assets between brokerage accounts, and, after Richard’s death, facilitated distributions to Patti. Rich alleged he was not informed about these transfers and was unable to access his inherited share for several months, during which time the funds lost value.Following a three-day trial in the United States District Court for the Northern District of Iowa, a jury found in favor of Rich on claims of fraud and conversion against Tim and unjust enrichment against both Tim and Patti, but found no liability on certain other claims. The jury awarded compensatory and punitive damages. Both parties filed post-trial motions. The district court declined to give a jury instruction on undue influence, reasoning that the evidence did not support such a claim, and amended the judgment to prevent duplicative recovery by making Tim and Patti jointly liable for part of the award.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. It held that the refusal to instruct the jury on undue influence was not an abuse of discretion, given the record and Iowa law. The appellate court also upheld the district court’s decision to amend the judgment to avoid double recovery. Furthermore, it rejected Tim’s argument that there was insufficient evidence to support the fraud verdict, concluding that the jury’s findings of justifiable reliance and damages were supported by the trial record. View "Jeffery v. Townsend" on Justia Law

Patrick J. Newcomer was serving supervised release for two separate federal convictions related to burglary of a Post Office and possession of a firearm by a felon. After completing his prison terms and beginning supervised release, he was again convicted in state court of two counts of burglary and possession of a firearm by a prohibited person. These new convictions constituted violations of his federal supervised release conditions.Following Newcomer’s state convictions, the United States District Court for the District of Nebraska revoked his supervised release for both federal cases. The court imposed 24 months’ imprisonment for each federal conviction, to run concurrently, and ordered these terms to be served after his state sentences. Additionally, the district court imposed two terms of supervised release—12 months each—set to run consecutively upon his release from imprisonment. Newcomer appealed, arguing that under 18 U.S.C. § 3624(e), the new terms of supervised release should run concurrently.The United States Court of Appeals for the Eighth Circuit reviewed the legality of the district court’s revocation sentence de novo. It held that 18 U.S.C. § 3624(e) governs only the commencement of original supervised release terms and does not apply to supervised release imposed following revocation. Instead, 18 U.S.C. § 3583 provides the relevant authority, permitting a district court to impose additional supervised release upon revocation, and does not require such terms to run concurrently. The Eighth Circuit found that the district court acted within its discretion in imposing consecutive supervised release terms and affirmed the judgment. View "United States v. Newcomer" on Justia Law

Randy Granger was severely injured in an automobile accident while driving a company truck. The at-fault driver’s insurance paid its policy limit of $25,000, which was insufficient to cover Randy’s injuries. Randy then made a claim under his own underinsured-motorist policy with Auto-Owners Mutual Insurance Company, which paid him up to its per-person limit of $250,000. Beverly Granger, Randy’s wife, subsequently filed her own underinsured-motorist claim with Auto-Owners for loss-of-consortium damages, seeking compensation for the decline in affection, care, companionship, and services resulting from Randy’s injuries.Auto-Owners refused Beverly’s claim, treating it as derivative of Randy’s and asserting that the $250,000 per-person limit for underinsured-motorist benefits had already been exhausted by Randy’s claim. Auto-Owners then sought a declaratory judgment in the United States District Court for the Western District of Missouri, arguing it owed no further payment. Beverly counterclaimed for breach of contract. The district court granted summary judgment to Auto-Owners, concluding that Beverly’s loss-of-consortium claim was inseparable from Randy’s bodily injury claim and thus subject to the same per-person limit.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the insurance policy’s language de novo, applying Missouri law. The court found the policy ambiguous regarding whether Beverly’s loss-of-consortium claim was subject to the same per-person limit as Randy’s bodily injury claim or whether each spouse could recover under separate per-person limits for their distinct losses. Resolving the ambiguity in favor of the insured, as required by Missouri law, the Eighth Circuit held that Beverly may recover loss-of-consortium damages and is not barred by the per-person limit applied to Randy’s claim. The court reversed the district court’s judgment and remanded for entry of judgment in Beverly’s favor. View "Auto-Owners Mutual Insurance Company v. Granger" on Justia Law

Deputy Brian Williams responded to a domestic-violence call at Tina Hight’s residence, where two dogs ran out toward him as Hight opened her door. Williams shouted warnings and fired a shot that caused the dogs to retreat. As Hight attempted to bring her dogs inside, a small Pomeranian mix ran toward Williams, prompting him to fire again in the dog’s direction. The shot missed the dog but ricocheted and struck Hight, leaving a bullet fragment in her leg.Hight filed suit in the United States District Court for the Western District of Arkansas, alleging excessive force under 42 U.S.C. § 1983 and the Fourth and Fourteenth Amendments. The district court granted summary judgment to Deputy Williams on the basis of qualified immunity, concluding that Williams did not violate Hight’s constitutional rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo, making all reasonable inferences in favor of Hight. The appellate court considered whether Deputy Williams’s actions constituted a Fourth Amendment seizure of Hight. Applying the requirement that a seizure by force must involve an officer’s objectively manifested intent to restrain the person affected, the court found no evidence that Williams intended to restrain Hight; his actions and statements were aimed at stopping the dog. The court held that accidental force, or force directed at another target, does not satisfy the Fourth Amendment’s seizure standard as articulated in Torres v. Madrid and related precedents.The Eighth Circuit affirmed the district court’s judgment, holding that Deputy Williams did not seize Hight within the meaning of the Fourth Amendment and thus did not violate her constitutional rights. The court declined to address arguments raised for the first time on appeal. View "Hight v. Williams" on Justia Law

Several senior financial advisors resigned from a national investment advisory firm’s Des Moines branch to join a competitor that was opening a new local office. After their departure, nearly all remaining advisors at the branch also resigned en masse and joined the competitor, which offered substantial incentives. The resignations occurred despite restrictive covenants in the former advisors’ employment contracts, which limited their ability to solicit clients, disclose confidential information, and recruit other employees. The competitor and the departing advisors soon began servicing many of their former clients, resulting in a substantial loss of business for their previous employer.Following these events, the original firm filed suit in the United States District Court for the Southern District of Iowa, alleging breach of contract, tortious interference, and theft of trade secrets. The district court initially denied a temporary restraining order but later granted a broad preliminary injunction. This injunction prohibited the former advisors from servicing or soliciting covered clients, using confidential information, or recruiting employees, and it barred the competitor from using confidential information or interfering with employment agreements. The defendants sought a stay but were denied by both the district court and the appellate court.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the preliminary injunction. The appellate court determined that the record did not show a likelihood of irreparable harm that could not be compensated by money damages, as required for preliminary injunctive relief. The court found that the alleged financial harms were calculable and that the claimed destruction of the Des Moines branch had already occurred, rendering injunctive relief ineffective for preventing future harm. The Eighth Circuit therefore vacated the preliminary injunction and remanded the case for further proceedings. View "Choreo, LLC v. Lors" on Justia Law

Abrahim Fofana, a Liberian national, attempted to enter the United States with fraudulent documents in 2001. After disclosing his fundraising activities for the United Liberation Movement of Liberia for Democracy (ULIMO) and claiming fear of persecution due to his affiliation, he was granted asylum by an immigration judge. In 2002, Fofana applied to adjust his status to lawful permanent resident. In 2018, the United States Citizenship and Immigration Services (USCIS) denied his application, determining he was inadmissible because he had solicited funds for ULIMO, which was classified as a Tier III terrorist organization under federal law.Fofana challenged the denial in the United States District Court for the District of Minnesota, arguing that USCIS’s decision was arbitrary and capricious and that collateral estoppel precluded his inadmissibility finding. The district court initially ruled in his favor on collateral estoppel grounds, but the United States Court of Appeals for the Eighth Circuit reversed and remanded the case. On remand, the district court again granted summary judgment to Fofana, rejecting the government’s argument that it lacked jurisdiction, and finding that Fofana was not inadmissible for engaging in terrorist activity. The court also concluded that USCIS’s determination regarding ULIMO was arbitrary and capricious and that the record did not support the finding that Fofana knew or should have known of ULIMO’s terrorist activities.On appeal, the United States Court of Appeals for the Eighth Circuit held that the district court lacked jurisdiction to review the Secretary’s decision on adjustment of status, finding that federal law precludes judicial review of both discretionary and non-discretionary determinations made by the Secretary regarding such applications. The appellate court reversed the district court’s judgment and remanded with instructions to dismiss the complaint for lack of jurisdiction. View "Fofana v. Noem" on Justia Law

On December 25, 2019, a patrol sergeant noticed a van idling in a driveway, twice encountered it, and approached the vehicle. The driver, Raymond Kelley, identified himself and his residence. The sergeant observed signs of alcohol and learned Kelley had a prior DUI and an active warrant. Kelley exited, was patted down, and sat on a wall; after asking to call his wife and being denied, Kelley ran up the driveway. The sergeant pursued and tackled Kelley, gaining control of his wrist. A deputy arrived after Kelley was tackled and assisted with handcuffing. Kelley complained of an arm injury, received medical attention, and was cited for public intoxication and resisting law enforcement before being released. Disputed facts center on the degree of Kelley’s resistance and the force used during handcuffing.Kelley sued under 42 U.S.C. § 1983, alleging unlawful arrest and excessive force against the officers in both their official and individual capacities. The United States District Court for the Eastern District of Arkansas granted summary judgment to the officers on the false arrest claim and on all claims against them in their official capacities. However, the court denied qualified immunity to both officers on the excessive force claim in their individual capacities, finding that disputed facts about Kelley’s conduct and the techniques used precluded summary judgment and should be resolved by a jury.Reviewing this interlocutory appeal, the United States Court of Appeals for the Eighth Circuit determined that the district court erred by failing to construe disputed facts in the light most favorable to Kelley and by not completing the required two-prong qualified immunity analysis. The Eighth Circuit vacated the district court’s order denying qualified immunity and remanded the case for a more detailed assessment, instructing the district court to consider both prongs of the qualified immunity analysis after properly construing the facts. View "Kelley v. Pruett" on Justia Law