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

A man was charged with several federal offenses, including being a felon in possession of a firearm, transporting a minor with intent to engage in prostitution, and possession of child pornography. The charges arose after he met a 16-year-old runaway through Craigslist, transported her across state lines, and engaged in a sexual relationship with her. Law enforcement discovered him with the minor, searched his residence, and found child sexual abuse material and multiple firearms. The defendant admitted to knowing the minor’s age and her mental health issues.He ultimately pled guilty to the firearm charge and one transportation count, with the remaining charges dismissed as part of a plea agreement. At sentencing in the United States District Court for the Southern District of Iowa, he received 292 months for transportation of a minor and 180 months for the firearm offense, to run concurrently. Thirteen days later, he moved to withdraw his guilty plea on the transportation count, arguing that he only learned at sentencing that the minor was missing and that this constituted exculpatory evidence the prosecution should have disclosed. The district court denied his motion, stating it lacked authority to consider post-sentencing withdrawal of a guilty plea except by direct appeal or collateral attack, and found that the minor’s unavailability was not exculpatory since public records of her status were available before the plea.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial under the abuse of discretion standard and affirmed. The appellate court held that Federal Rule of Criminal Procedure 11(e) barred post-sentencing withdrawal of a guilty plea except by direct appeal or collateral attack, and that no Brady violation occurred because the information about the minor’s status was publicly available. The court also declined to review the firearm sentence under the concurrent sentence doctrine, as any ruling would not affect the defendant’s time to be served. The judgment was affirmed. View "United States v. Adkins" on Justia Law

A railroad company headquartered in Nebraska provides track safety services known as “flagging,” often using its own employees. A third-party company, RailPros, also supplies flagging workers for outside projects that require access to the railroad’s property. A labor union, which represents some employees of the railroad but not RailPros workers, requested that a federal agency determine whether RailPros flagging workers should be considered covered employees under federal railroad retirement and unemployment statutes. The union argued that the railroad’s use of RailPros workers displaced union members and undermined the benefits system. The agency began an investigation, requested information from the railroad, and ultimately scheduled a hearing to decide the employment status of the RailPros workers. The agency also designated the union as a party to the hearing, which would give it access to confidential business information.The railroad objected to the union’s party status, arguing that it would result in disclosure of sensitive information to an adversarial party. After the agency declined to remove the union as a party or to sufficiently protect the railroad’s confidential information, the railroad filed a lawsuit in the United States District Court for the District of Nebraska. The railroad sought judicial review of the agency’s order under the Administrative Procedure Act (APA), alleging the order was unlawful and would cause irreparable harm. The district court dismissed the complaint for lack of subject matter jurisdiction, concluding that exclusive judicial review lay in the courts of appeals under the statutory schemes governing railroad retirement and unemployment benefits.The United States Court of Appeals for the Eighth Circuit reversed, holding that the agency’s order granting the union party status was a final agency action under the APA and not subject to exclusive review in the courts of appeals under the relevant statutes. The court ruled that the district court had subject matter jurisdiction to review the agency’s order immediately under the APA and remanded the case for further proceedings. View "Union Pacific Railroad Co. v. RRRB" on Justia Law

Suzan Taylor sought property insurance for her home in Hot Springs, Arkansas, using an application form provided by her insurance agent. In her application, Taylor answered “no” to a question about whether she had experienced a foreclosure in the past five years, though she had owned another property, the Fairfield Bay Property, that was sold in a foreclosure sale in 2016. Hiscox, a capital provider to an underwriting syndicate at Lloyd's of London, issued her the policy through its authorized agent, Burns & Wilcox, Ltd. After a fire destroyed the insured home, Hiscox investigated and discovered Taylor’s failure to disclose the earlier foreclosure. Hiscox rescinded the policy ab initio, refunded the premium, and denied coverage for the fire loss.The United States District Court for the Western District of Arkansas initially granted summary judgment to Hiscox, concluding Taylor’s failure to disclose foreclosure proceedings on the insured property itself was a material misrepresentation. On appeal, the United States Court of Appeals for the Eighth Circuit held the term “foreclosure” as applied to the insured property was ambiguous, reversed the district court’s judgment, and remanded for further proceedings on other alleged misrepresentations. On remand, the district court determined that Taylor’s failure to disclose the foreclosure sale of the Fairfield Bay Property was a material misrepresentation and not ambiguous in this context. The court found that Hiscox’s agent did not acquire relevant knowledge of the foreclosure while acting for Hiscox, so Hiscox was not precluded from asserting the misrepresentation.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The court held that Taylor’s failure to disclose the foreclosure was a material misrepresentation justifying rescission of the policy ab initio. The court also held that the policy’s Concealment or Fraud section independently precluded coverage due to Taylor’s false statement. Consequently, Taylor’s counterclaims for breach of contract and bad faith failed. View "Hiscox Dedicated Corp Member v. Taylor" on Justia Law

A federal grand jury charged the defendant with possessing methamphetamine with intent to distribute and being a felon in possession of a firearm. Task force officers at a bus station in Omaha, Nebraska identified the defendant’s suitcase as suspicious and removed it from the bus’s luggage compartment. After the defendant claimed and approached his bag, an officer questioned him about his travel plans and requested permission to search the suitcase, which the defendant consented to. The defendant then fled, prompting officers to detain him and search his belongings, ultimately discovering firearms and controlled substances.The defendant moved to suppress the evidence obtained from his suitcase, backpack, and person, arguing that the officers’ actions constituted unlawful searches and seizures under the Fourth Amendment. A magistrate judge recommended denying the suppression motion, concluding that the suitcase was not seized, the initial encounter was consensual, the consent to search was valid, and reasonable suspicion supported the later detention. The United States District Court for the District of Nebraska adopted the recommendation and denied the motion to suppress. At trial, a jury acquitted the defendant of possession with intent to distribute but found him guilty of simple possession and the firearms offense. The district court imposed consecutive sentences totaling 144 months’ imprisonment and a $2,500 fine, the latter without findings about the defendant’s ability to pay.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of the suppression motion, holding there was no Fourth Amendment seizure of the suitcase, the initial encounter was consensual, the defendant’s consent to search was voluntary, and reasonable suspicion justified the post-flight detention. The court also affirmed the custodial sentence as substantively reasonable but vacated the fine, remanding for proper findings on the defendant’s ability to pay. View "United States v. Clay" on Justia Law

Jay and Kendall Nygard, who have had a long history of disputes with the City of Orono regarding property matters, became involved in a conflict when Jay replaced their driveway without obtaining a permit as required by city code. Throughout the permitting process and subsequent communications with the City, Kendall was copied on email exchanges but did not perform the driveway work herself. After efforts by city officials to secure compliance failed, both Jay and Kendall were referred for prosecution for violating the permit requirement. However, a state court later dismissed the charge against Kendall, finding that the ordinance required only the person actually performing the work to obtain the permit, and Jay, not Kendall, had done the work.Following this dismissal, Kendall and Jay brought federal claims against the City, including a malicious prosecution claim. The United States District Court for the District of Minnesota dismissed all claims, but on appeal, the United States Court of Appeals for the Eighth Circuit allowed Kendall’s malicious prosecution claim to proceed, finding her complaint sufficiently alleged the City lacked probable cause. On remand, the district court declined to exercise pendent jurisdiction. Kendall then filed a new malicious prosecution claim based on diversity jurisdiction, but the district court again granted summary judgment to the City, concluding Kendall could not prove the City acted with malicious intent.Reviewing the case de novo, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s grant of summary judgment. The court held that Kendall failed to offer evidence that the City knowingly and willfully instituted a groundless prosecution against her, as required to establish malicious intent under Minnesota law. The court found that, even if probable cause was lacking, there was no evidence of malice, and that any deficiency in probable cause was not so blatant as to permit an inference of malicious intent. The judgment in favor of the City was therefore affirmed. View "Nygard v. City of Orono" on Justia Law

A non-Indian woman and a member of the Prairie Island Mdewakanton Dakota Indian Community married in Minneapolis and resided with their children in Edina, Minnesota, outside the reservation. Their marriage was supported financially by the husband’s “per capita payments” from the Community, and the wife received tribal insurance benefits, but neither spouse lived or owned property on the reservation. After more than thirteen years, both spouses filed for divorce on the same day—he in the Community’s Tribal Court, she in Minnesota state court. The state court stayed proceedings in favor of the Tribal Court, and after a trial, the Tribal Court dissolved the marriage, divided assets, awarded joint custody, and set child support. It did not award the wife spousal maintenance because under Community law, per capita payments are not marital property. The Community’s Court of Appeals affirmed the Tribal Court’s order.The wife then filed suit in the United States District Court for the District of Minnesota, seeking a declaration that the Tribal Court lacked jurisdiction and an injunction against enforcement of the order. The district court granted summary judgment in favor of the husband, holding that the Tribal Court had subject matter jurisdiction over the divorce under the “consensual relationship exception” from Montana v. United States, based on the marriage and the wife’s connections to the Community.On appeal, the United States Court of Appeals for the Eighth Circuit reversed. The Eighth Circuit held that the Tribal Court lacked subject matter jurisdiction over a divorce between a tribal member and a nonmember spouse who resided outside the reservation, because the consensual relationship exception did not apply in these circumstances. The court concluded that neither the marriage nor the wife’s limited connections to the Community provided a sufficient nexus to tribal lands or property, nor was tribal jurisdiction necessary to protect self-government or internal relations. The case was remanded with instructions to enjoin enforcement of the Tribal Court’s divorce order. View "Tix v. Tix" on Justia Law

Several former employees of a logistics company left their positions and later joined a competitor. The former employer alleged that, as a condition of their employment, these individuals had signed agreements containing restrictive covenants, including broad non-solicitation and business interference clauses. The company claimed the employees breached these restrictive covenants and further alleged that the competitor had tortiously interfered with its contractual relationships.Initially, the United States District Court for the District of Minnesota granted summary judgment for the defendants, holding that the agreements were unenforceable under California law, and thus the breach of contract and tortious interference claims failed. On the first appeal, the Eighth Circuit determined that Minnesota law rather than California law governed the agreements for all but one employee, remanding the case to the district court to reconsider the enforceability of the contracts under Minnesota law and to resolve related summary judgment motions. On remand, the district court again granted summary judgment to the defendants, holding the restrictive covenants were overly broad and unenforceable under Minnesota law, and denied the plaintiff’s motion for voluntary dismissal of certain claims.On appeal, the United States Court of Appeals for the Eighth Circuit held that the restrictive covenants in the agreements are unenforceable under Minnesota law, as they sweep more broadly than necessary to protect the former employer’s business interests, both in scope and geographic reach. The Eighth Circuit also affirmed the district court’s denial of voluntary dismissal, finding it would waste judicial resources and could prejudice the affected employee. The Eighth Circuit affirmed the district court's grant of summary judgment for the defendants, denial of the plaintiff’s summary judgment motion, and denial of the plaintiff’s motion for voluntary dismissal. View "C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc." on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

A member of the Sisseton Wahpeton Oyate tribe was observed by a tribal police officer driving erratically within the city limits of Sisseton, nearly causing multiple collisions and fleeing from law enforcement. He was apprehended in a tribal housing unit. Subsequently, the tribal prosecutor charged him in tribal court with driving under the influence (DUI) and resisting arrest, while South Dakota state court charged him with resisting arrest, reckless driving, and assaulting a law enforcement officer. He later pled guilty in state court to assault and was sentenced to two years in prison. The tribal court then dismissed the DUI charge without prejudice.He filed a federal lawsuit in the United States District Court for the District of South Dakota against various tribal officials, alleging that the DUI charge exceeded the tribe’s criminal jurisdiction and violated his rights under the Fourth Amendment and the Indian Civil Rights Act. The District Court dismissed the case for lack of subject matter jurisdiction, holding that the complaint failed to raise a federal question under 28 U.S.C. § 1331.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the dismissal. The court concluded that, even assuming it had jurisdiction to consider the scope of the tribe’s criminal authority, the case had become moot because the tribal DUI charge was dismissed and could not be refiled due to the expiration of the statute of limitations. The court found that neither the voluntary cessation exception nor the “capable of repetition, yet evading review” exception to mootness applied. Accordingly, the Eighth Circuit affirmed the district court’s judgment and vacated its decision, declining to address the underlying questions of tribal jurisdiction, sovereign immunity, or exhaustion of tribal remedies. View "LaBatte v. Gangle" on Justia Law

A police officer in Des Moines, Iowa attempted to stop a vehicle driven by Dylan Pettyjohn for lacking license plates or a temporary registration. Pettyjohn fled, leading the officer on a high-speed chase through a residential area before crashing. He then ran from the vehicle, discarding a loaded revolver and a fanny pack containing 54 fentanyl pills, $389 in small bills, marijuana, and about 85 grams of methamphetamine. A search of his vehicle yielded a digital scale with white residue, more marijuana, and shell casings. Pettyjohn was arrested, and a federal grand jury indicted him on multiple counts related to drug possession with intent to distribute, possession of a firearm in furtherance of a drug trafficking crime, and being a felon in possession of a firearm.The United States District Court for the Southern District of Iowa denied Pettyjohn’s motion to dismiss the felon in possession charge, rejecting his argument that 18 U.S.C. § 922(g)(1) violated the Second Amendment. The court also allowed limited admission of his prior felony convictions for impeachment purposes, after an agreement between Pettyjohn and the government. At trial, Pettyjohn moved for acquittal based on insufficient evidence, but the district court found the evidence sufficient and denied the motions. The jury found Pettyjohn guilty on all counts, and the court sentenced him to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the sufficiency of the evidence de novo, affirmed the district court’s evidentiary rulings under Rules 404(b) and 609, and upheld the constitutionality of § 922(g)(1) based on circuit precedent. The Eighth Circuit held that the evidence was sufficient to support the convictions, the district court did not abuse its discretion in admitting prior conviction evidence, and § 922(g)(1) is constitutional. The judgment of the district court was affirmed. View "United States v. Pettyjohn" on Justia Law