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

Bradley Bolin was arrested in the early hours of April 1, 2020, on several misdemeanor and felony charges and was taken to the Benton County Detention Center. While in custody, Bolin was involved in multiple encounters with law enforcement officers. These included incidents in the booking area where he was tased after resisting orders, in a cell where he was shot with pepper balls while standing with his arms raised, another hallway incident where a deputy slammed him to the ground and struck him, and finally, a cell incident where he was again subjected to force, including knee strikes and taser stuns, resulting in significant injuries.The United States District Court for the Western District of Arkansas denied summary judgment to several officers who argued they were entitled to qualified immunity from Bolin’s claims under 42 U.S.C. § 1983, based on alleged excessive force in violation of the Fourteenth Amendment, as well as related state law claims. The officers appealed, challenging the denial of qualified immunity on legal grounds, including whether the evidence showed they violated clearly established rights.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s order de novo, considering the evidence in the light most favorable to Bolin. The appellate court reversed the denial of qualified immunity to Deputy Loya for his use of a taser in the Booking Lobby, finding the audio recording clearly contradicted the claim that Bolin was not resisting. However, the court affirmed the denial of qualified immunity for the other uses of force, holding that it was clearly established law that officers could not use significant force—such as pepper balls, violent takedowns, or taser stuns—against a non-threatening or non-resisting detainee under the circumstances presented. View "Bolin v. Wilkins" on Justia Law

A group of pharmacy benefit managers and related companies, including both benefit managers and mail-order pharmacies, were sued by the State of Arkansas in state court. The State alleged that these companies contributed to the opioid epidemic by facilitating and encouraging the misuse, abuse, and over-prescription of opioids, particularly through their negotiations with drug manufacturers for placement of opioid drugs on insurance formularies in exchange for rebates and fees. The State’s complaint asserted claims for public nuisance, negligence, and unjust enrichment under state law, and included allegations that the companies prioritized profits from rebates over public health concerns.After being sued, the defendant companies removed the case to the United States District Court for the Eastern District of Arkansas, citing the federal officer removal statute, 28 U.S.C. § 1442(a)(1), as well as the general removal statute. They argued that their actions were taken under the direction of federal officers, particularly in their roles administering federal health care programs, such as those governed by the Federal Employees Health Benefits Act (FEHBA). The State moved to remand, asserting that the complaint disclaimed any claims against federal officers or persons acting under them. The district court found the disclaimers sufficient and remanded the case to state court.On appeal, the United States Court of Appeals for the Eighth Circuit held that removal was proper under the federal officer removal statute. The court concluded that the defendant companies acted under the direction of federal officers when administering federal health plans and negotiating drug rebates, and that these actions were sufficiently related to the claims in the complaint. The court determined that the State’s disclaimers could not sever the connection between the challenged conduct and federal duties, given the indivisibility of negotiations on behalf of both federal and private clients. The Eighth Circuit therefore reversed the district court’s remand order. View "Griffin v. OptumRx, Inc." on Justia Law

Congress passed the Infrastructure Investment and Jobs Act, which included the Digital Equity Act of 2021, allocating $65 billion to expand affordable, high-speed broadband access across the United States, especially in underserved areas. The Act directed the Federal Communications Commission (FCC) to adopt rules to “facilitate equal access to broadband” and prevent “digital discrimination of access” based on characteristics such as income, race, and national origin. In response, the FCC adopted a final rule that prohibited both intentional discrimination (disparate treatment) and unintentional discrimination with disproportionate effects (disparate impact), applied to a broad range of entities influencing broadband access—not just internet service providers.Numerous telecommunications and broadband industry groups challenged this rule in several federal appellate courts. These cases were consolidated in the United States Court of Appeals for the Eighth Circuit. The industry petitioners argued that the statute did not authorize the FCC to impose liability based on disparate impact, nor to regulate entities beyond broadband providers. Public interest groups intervened to defend the rule, but also argued it did not go far enough.The Eighth Circuit reviewed the FCC’s rule under the Administrative Procedure Act. The court applied the Supreme Court’s most recent guidance on agency deference and statutory interpretation, emphasizing that courts must independently interpret statutes. It found that the statutory text did not authorize disparate impact liability and that the FCC exceeded its authority by applying the rule to entities other than broadband providers. As a result, the court held that the FCC’s rule was not in accordance with law and vacated the rule in its entirety. The court granted in part the industry petitioners’ request, denied the public interest groups’ petition, and left the FCC with the ongoing obligation to adopt lawful rules facilitating equal broadband access. View "Minnesota Telecom Alliance v. FCC" on Justia Law

The defendant pleaded guilty to conspiring to commit wire fraud. From inside a Georgia prison, he and others targeted women in the medical profession, convincing them by phone that they had failed to appear in court and faced arrest unless they paid a bond. The scheme involved spoofing local police department phone numbers, impersonating police officers, meticulous research of victims, and coordinating with coconspirators outside the prison to collect money at bail bond companies. Over two years, two dozen victims across the country were defrauded, including some in the Southern District of Iowa.The United States District Court for the Southern District of Iowa calculated a sentencing range under the Sentencing Guidelines of 130–162 months, applying enhancements for “sophisticated means,” impersonating police officers, and for the defendant’s leadership role in a conspiracy involving at least five participants. The court denied a motion for a downward departure, finding that the defendant’s criminal history category was not substantially over-represented. The defendant challenged the application of the enhancements and the substantive reasonableness of the sentence, arguing that the scheme was not sufficiently sophisticated, that applying both enhancements for impersonation and sophistication was double counting, and that he was not an organizer or leader.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and the substantive reasonableness of the sentence for abuse of discretion. The appellate court held that the scheme was sufficiently sophisticated to warrant the enhancement, that applying both enhancements did not constitute double counting, and that the defendant’s role justified the leadership enhancement. The court found no abuse of discretion in the district court’s assessment of criminal history and concluded the sentence was reasonable. The judgment of the district court was affirmed. View "United States v. Weatherspoon" on Justia Law

In 2000, Briley Piper and two others committed the murder of Chester Allan Poage in South Dakota, resulting in Piper being charged with multiple offenses, including first-degree felony murder. Prior to trial, Piper pled guilty to five crimes and was sentenced to death by the state circuit court. Over the years, Piper’s case returned to the South Dakota Supreme Court several times, both on direct appeal and in habeas proceedings. The South Dakota Supreme Court initially affirmed his conviction and sentence, later vacated the death sentence due to an invalid jury waiver, and remanded for jury resentencing. The jury again imposed a death sentence, which was affirmed. Piper then filed successive state habeas applications, challenging the validity of his guilty pleas and the effectiveness of his counsel, all of which were ultimately denied.After exhausting state remedies, Piper filed a federal habeas corpus petition in the United States District Court for the District of South Dakota, advancing thirteen claims; the district court denied relief on all, granting a certificate of appealability for several. The United States Court of Appeals for the Eighth Circuit expanded the certificate to include six claims. The court reviewed issues including the constitutionality of AEDPA deference after Loper Bright Enterprises v. Raimondo, South Dakota’s application of res judicata to preclude Piper’s challenge to his guilty pleas, the denial of an evidentiary hearing regarding alleged ineffective assistance of counsel, the adequacy of impeachment of a key witness, alleged failures to rebut a prosecution assertion about a defense witness, and cumulative prejudice.The Eighth Circuit held that AEDPA’s deference requirement remains constitutional and applicable after Loper Bright. It found Piper’s challenge to his guilty pleas procedurally defaulted under South Dakota’s consistently applied res judicata rules. The court concluded the district court did not err in denying an evidentiary hearing, found no prejudice in counsel’s performance regarding impeachment or rebuttal evidence, and reaffirmed that cumulative error does not warrant habeas relief in this circuit. The court affirmed the district court’s denial of habeas relief. View "Piper v. A.G." on Justia Law

Two brothers, who are co-founders, directors, and major shareholders of a company, were involved in a business arrangement with a venture capital investor who was also a director and significant shareholder in the same company. The parties executed two option agreements and a partnership agreement related to the creation of a venture capital fund, which was to be capitalized with company shares. The brothers signed option agreements giving a corporate entity managed by the investor the right to acquire a portion of their shares. These agreements were twice amended, with the second amendment doubling the shares to be transferred—an action the brothers allege was done without their knowledge. Separately, a partnership agreement established the venture fund as a limited partnership under Delaware law, with all partners being corporate entities associated with the brothers and/or the investor. The partnership agreement included an arbitration clause governed by JAMS rules.When the investor’s entity tried to exercise its right to purchase shares, the brothers refused, disputing the validity of the second amendment. The investor and his entities initiated arbitration under the partnership agreement, prompting the brothers to sue for injunctions to stop arbitration. The defendants responded by moving to compel arbitration. The United States District Court for the Western District of Missouri denied all motions, including the motion to compel arbitration.The United States Court of Appeals for the Eighth Circuit reviewed the denial de novo. It held that the district court properly decided the question of arbitrability because the brothers, as non-signatories to the partnership agreement, were not bound by its arbitration clause. The appellate court further found that principles of equitable estoppel and agency law under Delaware law did not require the brothers to arbitrate, as they had not directly benefited from the agreement nor acted as agents of the signatories. The Eighth Circuit affirmed the district court’s decision. View "Schlacks v. Chheda" on Justia Law

Robert Ward brought a lawsuit against Officer Matt Harris, alleging that Harris violated his constitutional rights during an arrest that took place after officers responded to a noise complaint at Ward’s home. When the officers requested information for a report, Ward questioned their authority, used profanity, and repeatedly ignored requests to stop using foul language in the presence of children. The situation escalated, and after Ward made a reference to “Code 3,” a law enforcement term associated with urgent response, Harris arrested Ward. During the arrest, Ward resisted, leading Harris to use a takedown maneuver that resulted in Ward’s head injury. Ward was charged with disorderly conduct, resisting arrest, and public intoxication. The charges were dismissed after a year with no further violations.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of Officer Harris on all claims, finding that Harris was entitled to qualified immunity. The court concluded that Harris had at least arguable probable cause for the arrest and that his conduct did not violate clearly established statutory or constitutional rights.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether Harris’s actions violated Ward’s clearly established rights. The Eighth Circuit held that Harris had arguable probable cause to arrest Ward for disorderly conduct under Arkansas law, as Ward’s actions could reasonably be viewed as threatening or tumultuous. The court also found no First Amendment violation, as Ward failed to provide objective evidence that others engaging in similar conduct were not arrested. Regarding the use of force, the court held that the takedown maneuver in response to resistance did not violate a clearly established right. The court further determined that the public intoxication charge did not result in a seizure to support a malicious prosecution claim. The judgment granting summary judgment to Harris was affirmed. View "Ward v. City of Sherwood, Arkansas" on Justia Law

An employee of a Minnesota company purchased a third-party replacement battery for her cellphone through an online marketplace. The battery, sold by a Chinese company and shipped via the marketplace’s fulfillment program, malfunctioned and caused a fire, resulting in significant property damage. The employer’s insurer covered the loss and then pursued recovery from the online marketplace, the battery’s seller, and the manufacturer. The insurer’s claims against all parties except the online marketplace were eventually dropped.After the case was removed to the United States District Court for the District of Minnesota, the insurer sought to have the court certify to the Minnesota Supreme Court the question of whether the online marketplace could be strictly liable for the defect under Minnesota law. The district court, however, declined to certify the question and instead made its own prediction (“Erie guess”) that Minnesota law would not hold the marketplace strictly liable for third-party goods it fulfills but does not sell.On appeal, the United States Court of Appeals for the Eighth Circuit determined that the issue presented is novel, unsettled under Minnesota law, and implicates significant public policy concerns. The appellate court decided it was appropriate to certify the legal question to the Minnesota Supreme Court, rather than attempt its own prediction. The court certified the question of whether, under Minnesota law, an e-commerce company that allows an unrelated party to sell a defective product through its website and provides order-fulfillment services is strictly liable for harm caused by the defect. The Eighth Circuit stayed further proceedings pending the Minnesota Supreme Court’s response. The holding is that the court will certify this question to the Minnesota Supreme Court and not decide the merits of strict liability itself. View "Berkley Regional Ins. Co. v. Amazon.com, Inc." on Justia Law

Oscar Hudspeth, a member of the Oglala Sioux Tribe, was convicted by a jury of two sex abuse offenses involving his young stepdaughter, D.J., which occurred when she was between five and seven years old and living in his home. The prosecution’s evidence included D.J.’s testimony about the abuse and statements Hudspeth made during a post-polygraph interview with an FBI agent, where he admitted to inappropriate touching. Prior to trial, both parties agreed to exclude any reference to the polygraph test from evidence, and the district court admitted a redacted version of the interview transcript omitting mention of the polygraph.In the United States District Court for the District of South Dakota, Hudspeth moved to either exclude the entire interview or, alternatively, to ensure all polygraph references were redacted. When it became clear that a redacted version would be admitted, Hudspeth changed his position, seeking to admit the entire interview, including polygraph references, to provide context for his admissions. The district court admitted the redacted interview and excluded polygraph references, noting that Hudspeth had earlier agreed to the exclusion. Hudspeth was ultimately found guilty and sentenced to the mandatory minimum term.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether excluding polygraph references violated Hudspeth’s constitutional right to present a complete defense. The court held that the exclusion did not violate his constitutional rights or constitute an abuse of discretion. It found that polygraph evidence is generally unreliable and disfavored, and that the exclusion was neither arbitrary nor disproportionate. The court concluded that even if there was error, it was harmless beyond a reasonable doubt due to the strength of the prosecution’s case. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Hudspeth" on Justia Law

Police in Bloomington, Minnesota, stopped a vehicle after observing a suspended object hanging from the rearview mirror and learning that the vehicle’s registered owner, Damion Kent Hallmon, had a suspended license. Hallmon was driving, accompanied by his fiancée, Ieisha McGrone, and their two children. During the stop, police observed a bag that appeared to contain marijuana, prompting a search of the vehicle. In a handbag on the front passenger seat, officers found a loaded pistol. Both Hallmon and McGrone made statements regarding the gun, with Hallmon ultimately admitting ownership and describing the firearm. Hallmon was arrested and charged with being a felon in possession of ammunition.Before trial in the United States District Court for the District of Minnesota, Hallmon moved to suppress the evidence and statements from the stop, and to dismiss the indictment on Second Amendment grounds. A magistrate judge recommended denial of the suppression motions, and the district court adopted this recommendation and denied the dismissal motion. At trial, the government presented testimony that the ammunition traveled in interstate commerce. Hallmon attempted to introduce recorded jail calls with McGrone, but the district court excluded them as hearsay. The jury found Hallmon guilty, and the district court imposed a two-level sentencing enhancement for obstruction of justice, sentencing him to 74 months’ imprisonment and three years’ supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that the stop, search, and seizure were constitutional; Hallmon was not in custody for Miranda purposes when making statements; sufficient evidence supported the interstate commerce element; exclusion of the jail calls was proper; the obstruction of justice enhancement was warranted; and existing circuit precedent foreclosed Hallmon’s Second Amendment challenge. View "United States v. Hallmon" on Justia Law