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

Following heavy snowfall in Pine Bluff, Arkansas, the roofs of several chicken houses at ten poultry farms collapsed. Norfolk & Dedham Mutual Fire Insurance Company, which insured the farms, sued Rogers Manufacturing Corporation, the manufacturer of the roof trusses used in the chicken houses, claiming strict product liability, negligence, and breach of warranties. Rogers moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6), arguing that Norfolk’s claims were barred by the Arkansas statute of repose.The United States District Court for the Eastern District of Arkansas agreed with Rogers and dismissed the complaint. Norfolk appealed the dismissal, arguing that the statute of repose did not apply to Rogers because the roof trusses were standardized goods, not custom-designed for the farms.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo, accepting the allegations in the complaint as true and drawing all reasonable inferences in Norfolk’s favor. The court found that Norfolk’s complaint plausibly supported an inference that the roof trusses were standardized goods, which would not be covered by the Arkansas statute of repose. The court emphasized that at this early stage, the complaint should not be dismissed if it allows for a reasonable inference of liability.The Eighth Circuit reversed the district court’s dismissal of the complaint and remanded the case for further proceedings, noting that the facts and legal arguments could be further developed as the case progresses. View "Norfolk & Dedham Mutual Fire Insurance Company v. Rogers Manufacturing Corporation" on Justia Law

Anthony Lemicy was convicted by a jury on four counts of sexual exploitation of a minor under 18 U.S.C. § 2251(a), (e). The district court sentenced him to consecutive 30-year terms for each count, totaling 120 years. Lemicy appealed, raising several claims including improper waiver of his right to counsel, violation of his right to a fair trial due to appearing in an orange jumpsuit and restraints, improper jury instructions, insufficient evidence, incorrect calculation of criminal history points, and an unreasonable sentence.The United States District Court for the Eastern District of Missouri initially appointed a federal public defender for Lemicy, but after conflicts, he chose to represent himself with standby counsel. The court repeatedly informed him of the risks and limitations of self-representation, which he acknowledged. During the trial, Lemicy appeared in jail-issued clothing by choice, despite the court offering him the opportunity to change. The jury was instructed to disregard his appearance.The United States Court of Appeals for the Eighth Circuit reviewed the case. It found that Lemicy knowingly and voluntarily waived his right to counsel, and the district court did not err in its handling of standby counsel. The court also determined that Lemicy was not compelled to wear the orange jumpsuit and any error was invited by him. The jury instructions were deemed appropriate, and the evidence was sufficient to support the convictions. The court upheld the calculation of criminal history points and found the sentence reasonable, given the severity of the offenses and the involvement of multiple victims.The Eighth Circuit affirmed the district court’s judgment, concluding that there were no violations of Lemicy’s constitutional rights and that the sentence imposed was within the court’s discretion. View "United States v. Lemicy" on Justia Law

Lester Brown was convicted by a jury of conspiracy to commit cyberstalking, cyberstalking resulting in death, and being a felon in possession of a firearm. Brown, who dealt marijuana in Kansas City, had a history of conflict with his associates, including the disappearance and murder of Ryan Cobbins. In 2018, Brown sent threatening messages to Christopher Harris and Antwon Tolefree, including demands for money and threats of violence. Brown used tracking devices to monitor Harris's movements, ultimately leading to Harris's murder in front of his daughter.The United States District Court for the Western District of Missouri sentenced Brown to life plus 180 months in prison. Brown appealed, challenging several evidentiary rulings and the sufficiency of the evidence for two of his convictions. He argued that certain hearsay statements were improperly admitted and that evidence of his prior wrongful conduct should have been excluded under Federal Rules of Evidence 404(b) and 403.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court did not abuse its discretion in admitting the contested hearsay statements, as they either fell under exceptions or were not hearsay. The court also determined that evidence of Brown's prior wrongful conduct was intrinsic to the charged crimes and highly probative, thus not subject to exclusion under Rule 404(b) or Rule 403. Finally, the court held that there was sufficient evidence to support Brown's convictions for conspiracy to commit cyberstalking and cyberstalking resulting in death, given the threats, use of tracking devices, and the fatal shooting of Harris.The Eighth Circuit affirmed the district court's judgment, upholding Brown's convictions and sentence. View "United States v. Brown" on Justia Law

Mar Maluoth was convicted by a jury of unlawful possession of a machinegun in violation of federal law. During a police surveillance operation, officers observed suspicious behavior involving Maluoth, leading to a traffic stop. During the stop, officers found a loaded Glock handgun modified to be a machinegun under the front passenger seat where Maluoth was sitting. Maluoth denied placing the gun there and claimed his movements were due to searching for his lighter and cigarettes. However, the jury found him guilty based on the evidence presented.The United States District Court for the District of Nebraska sentenced Maluoth to 70 months in prison, which was an upward variance from the advisory guidelines range of 41 to 51 months. The court considered factors such as the obliterated serial number on the firearm and Maluoth's history of obstructing justice. Maluoth appealed, arguing that the evidence was insufficient to convict him and that the sentence was substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the evidence was sufficient for a reasonable jury to find Maluoth guilty beyond a reasonable doubt. The court noted that Maluoth's furtive movements and the location of the firearm supported the jury's verdict. Regarding the sentence, the court found that the district court did not abuse its discretion. The district court properly considered the relevant sentencing factors, including the obliterated serial number and Maluoth's criminal history. The appellate court affirmed the district court's judgment, concluding that the sentence was not substantively unreasonable. View "United States v. Maluoth" on Justia Law

Robert J. Hall, an inmate in the Missouri Department of Corrections (MDOC), filed a lawsuit against MDOC and Corrections Officer Paul Woodruff, in his individual capacity, for injuries he sustained from an attack by a fellow inmate, Ahmad Townsend. Hall had previously submitted an "Enemy Listing/Protective Custody Declaration" form indicating he felt threatened by Townsend. Despite this, Woodruff placed Townsend in Hall's cell while Hall was asleep, leading to the attack and resulting in mental and physical injuries.The United States District Court for the Western District of Missouri denied Woodruff’s motion to dismiss based on official immunity. Woodruff appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo, accepting all factual allegations as true and viewing them in the light most favorable to Hall. The court examined whether Woodruff was entitled to official immunity under Missouri state law, which protects public officials from liability for discretionary acts performed during their official duties. The court found that the MDOC policies cited by Hall did not create a ministerial duty because they allowed for discretion in how and when enemy declarations were checked and safeguards implemented.The Eighth Circuit concluded that Woodruff's actions were discretionary, not ministerial, and thus he was entitled to official immunity. The court reversed the district court's decision and remanded the case for further proceedings consistent with this opinion. View "Hall v. Woodruff" on Justia Law

Eric Virrueta pleaded guilty to possession with intent to distribute a controlled substance but reserved the right to appeal the denial of his motion to suppress evidence found in a warrantless search of his vehicle after a traffic stop. The evidence included methamphetamine and marijuana. Virrueta challenged the validity of the traffic stop, the extension of the stop, and the search of the vehicle, arguing that the search was not supported by probable cause and that the consent given by his parole agent was invalid.The United States District Court for the District of South Dakota denied Virrueta's motion to suppress. The court found that the initial traffic stop was valid based on reasonable suspicion and probable cause, as Corporal Fischer had identified Virrueta driving without a valid license. The court also concluded that the extension of the stop was justified by the strong odor of raw marijuana emanating from the vehicle, which provided probable cause for the search. Additionally, the court upheld the search based on the consent given by Virrueta's parole agent, who had been informed of multiple parole violations.The United States Court of Appeals for the Eighth Circuit reviewed the district court's factual findings for clear error and its legal conclusions de novo. The appellate court affirmed the district court's rulings, agreeing that the traffic stop was valid, the extension of the stop was justified by reasonable suspicion of additional criminal activity, and the search of the vehicle was supported by probable cause. The court also held that the parole agent's consent provided an independent basis for the search. The judgment of the district court was affirmed. View "United States v. Virrueta" on Justia Law

Tremonti Perry, while incarcerated at Southeast Correctional Center, experienced a severe medical emergency that resulted in him being placed in a medically induced coma for a month. Several years after recovering, Perry filed a lawsuit under 42 U.S.C. § 1983 against the prison's warden, the Missouri Department of Corrections Director, and two medical-care contractors, alleging Eighth Amendment violations due to deliberate indifference to his medical needs. Perry admitted he did not use the prison’s administrative remedy, which required filing a complaint within fifteen days of the incident, but argued that his coma made it impossible to meet this requirement.The Defendants moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6), arguing that Perry had not exhausted his available remedies as required by the Prison Litigation Reform Act (PLRA). They acknowledged that the grievance process was unavailable to Perry during his coma and a reasonable period afterward but contended that Perry should have made a diligent effort to exhaust his claims once he recovered. The district court agreed with the Defendants and dismissed the complaint, concluding that Perry could have filed a grievance after his medical conditions resolved.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The appellate court determined that the prison’s administrative grievance process was unavailable to Perry due to his physical incapacity during the coma and the prison’s rules not allowing late filings. The court rejected the Defendants' arguments that Perry could have filed an untimely grievance or that the grievance deadline was perpetually renewed due to ongoing medical issues. The court also denied the Defendants' motion to supplement the record with new evidence. Consequently, the Eighth Circuit reversed the district court’s dismissal of Perry’s complaint and remanded the case for further proceedings. View "Perry v. Precythe" on Justia Law

Ethan Driskill and Marchello Oliver were charged with multiple drug-related offenses, including distribution of fentanyl and possession of firearms. Driskill was charged with distribution resulting in death, among other counts, while Oliver faced charges including possession with intent to distribute fentanyl and cocaine. Both defendants entered plea agreements; Oliver pleaded guilty to possession with intent to distribute fentanyl, and Driskill pleaded guilty to distribution resulting in death.The United States District Court for the Western District of Arkansas sentenced Oliver to 168 months, an above-guidelines sentence, and Driskill to 456 months, a within-guidelines sentence. Both defendants appealed, arguing their sentences were substantively unreasonable.The United States Court of Appeals for the Eighth Circuit reviewed the sentences for procedural errors and substantive reasonableness. For Oliver, the court found no procedural errors in the district court's application of an upward departure under USSG § 5K2.1, which was based on the finding that Oliver's distribution of fentanyl resulted in a death. The court also found the sentence substantively reasonable, noting that the district court had appropriately considered the relevant factors and the extent of the departure.For Driskill, the court noted that his within-guidelines sentence was presumed reasonable. The court found that the district court had properly considered mitigating factors and the significant differences between Driskill and Oliver, including their criminal histories and the specific charges to which they pleaded guilty. The court concluded that the district court did not abuse its discretion in sentencing Driskill.The Eighth Circuit affirmed the sentences imposed on both Oliver and Driskill. View "United States v. Driskill" on Justia Law

J.V. & Sons Trucking, Inc. ("J.V. & Sons") is a Utah corporation that hauls crude oil in Texas. Asset Vision Logistics, LLC ("AVL") is a logistics broker coordinating crude oil transportation. In June 2019, J.V. & Sons agreed to haul oil for AVL. In August 2019, J.V. & Sons signed AVL's Quick Pay Agreement ("QPA") to receive faster payments. Relations soured, and in February 2020, AVL stopped paying J.V. & Sons for completed hauls. J.V. & Sons terminated their relationship and demanded payment for unpaid invoices, which AVL acknowledged but did not pay. J.V. & Sons filed a lawsuit in Texas state court for breach of contract, which AVL removed to the Northern District of Texas and then transferred to the District of Minnesota.The District of Minnesota court denied AVL's motion for summary judgment, concluding that the non-solicitation and non-disclosure provisions in the QPA were unenforceable under Texas law. The court granted J.V. & Sons's motion in part, finding that AVL breached an implied contract by failing to pay eight invoices. After J.V. & Sons dismissed its remaining claim, the court entered final judgment in favor of J.V. & Sons.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's judgment. The appellate court agreed that the QPA's non-solicitation and non-disclosure provisions were unenforceable under Texas law. The court also upheld the finding of an implied contract based on the parties' course of dealing and the negotiated rate sheets, concluding that AVL's failure to pay the invoices constituted a breach of contract. The court rejected AVL's arguments regarding the enforceability of the QPA and the existence of an implied contract, affirming the district court's decision in favor of J.V. & Sons. View "J.V. & Sons Trucking, Inc. v. Asset Vision Logistics, LLC" on Justia Law

National Presto Industries, Inc. ("Presto") designed and sold a personal electric heater called "HeatDish" since 1989. The product was sold at Costco, where Presto used a specific merchandising strategy to boost sales. In 2017, Costco sought a new supplier and contacted U.S. Merchants Financial Group, Inc. ("U.S. Merchants"), which developed a similar heater called "The Heat Machine." Presto claimed that U.S. Merchants infringed on its unregistered trade dress under the Lanham Act.The United States District Court for the District of Minnesota handled the initial proceedings. Presto filed a complaint with multiple claims, including trade dress infringement and copyright infringement. The district court dismissed some claims and denied others, leading to a bench trial for the trade dress claim and a jury trial for the copyright claim. The district court ruled that Presto was not entitled to a jury trial for the trade dress claim, as the remedy sought was equitable, not legal. After a six-day bench trial, the court found that Presto failed to prove that its trade dress had acquired secondary meaning, an essential element for trade dress protection.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Presto was not entitled to a jury trial for the trade dress claim because the remedy sought was equitable. The appellate court also upheld the district court's finding that Presto failed to prove secondary meaning for its trade dress. Without secondary meaning, Presto's trade dress infringement claim could not succeed. The judgment of the district court was affirmed. View "National Presto Industries, Inc. v. U.S. Merchants Financial Group, Inc." on Justia Law