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

Henry Dailey began a ten-year term of supervised release after serving a prison sentence for his involvement in a commercial sex trafficking ring. Four months into his supervised release, his Probation Officer filed a Violation Report alleging numerous violations of his release conditions. Dailey admitted to most of the violations, resulting in an advisory guidelines sentencing range of 6 to 12 months imprisonment. Despite a joint recommendation for 6 months imprisonment followed by ten years of supervised release, the district court sentenced Dailey to 12 months imprisonment followed by 240 months of supervised release.The United States District Court for the Western District of Missouri initially sentenced Dailey to 84 months imprisonment followed by 120 months of supervised release after he pleaded guilty to one count of Interstate Transportation for Prostitution. Upon completing his prison term, Dailey began his supervised release in November 2022. In March 2023, his Probation Officer reported multiple violations, including failing to register internet-capable devices and involvement in drug sales. At a preliminary revocation hearing, the magistrate judge found probable cause to proceed. Dailey later stipulated to most violations but contested some allegations.The United States Court of Appeals for the Eighth Circuit reviewed the case. Dailey appealed the new term of supervised release, alleging procedural errors and a substantively unreasonable sentence. The appellate court found no procedural error, noting that the district court did not base its sentence on unproven allegations and allowed Dailey ample opportunity to defend against the contested violations. The court also found the 240-month term of supervised release substantively reasonable, given Dailey's criminal history and repeated violations. The judgment of the district court was affirmed. View "United States v. Dailey" on Justia Law

Mychal Byrd was injured in an automobile accident caused by an unknown motorist and subsequently died from his injuries. Byrd's medical expenses, totaling $474,218.24, were covered by the Gilster-Mary Lee Corporation Group Health Benefit Plan, a self-funded plan subject to ERISA. Byrd had an automobile insurance policy with Nationwide Insurance Company, which provided $50,000 in uninsured-motorist coverage. After Byrd's death, his family sued Nationwide in state court to collect the insurance proceeds. The Plan intervened, removed the case to federal court, and claimed an equitable right to the insurance proceeds.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the Plan, determining that the Plan was entitled to the insurance proceeds under the plan document. The plaintiffs, initially proceeding pro se, did not respond to the motion for summary judgment. After obtaining counsel, they moved for reconsideration, which the district court denied. The plaintiffs then appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the district court lacked subject-matter jurisdiction. The appellate court determined that the plaintiffs' claim did not fall within the scope of ERISA's civil enforcement provisions because the plaintiffs were neither plan participants nor beneficiaries. Consequently, the claim was not completely preempted by ERISA, and the federal court did not have jurisdiction. The Eighth Circuit vacated the district court's judgment and remanded the case with instructions to return it to Missouri state court. View "Kellum v. Gilster-Mary Lee Corporation Group Health Benefit" on Justia Law

Christopher Lockhart, a licensed Arkansas bail bondsman and private investigator, was stopped by Siloam Springs police officer Zachary Ware around 3:30 AM on March 11, 2019, for alleged traffic violations. Lockhart was arrested and charged with DWI, careless driving, and driving left of center. After refusing a plea deal, Lockhart was tried for DWI but was found not guilty. Subsequently, Lockhart filed a § 1983 action against multiple defendants, including claims of unreasonable stop, unlawful arrest, and malicious prosecution.The United States District Court for the Western District of Arkansas granted summary judgment to the defendants on most claims but allowed Lockhart’s illegal stop and false arrest claims against Officer Ware and the malicious prosecution claim against Siloam Springs to proceed. The court found genuine disputes of material fact regarding whether Officer Ware had probable cause to stop Lockhart, as the dashcam video did not conclusively support Ware’s testimony. The court also denied summary judgment on the malicious prosecution claim, finding a material fact dispute about whether the prosecutor had probable cause to try Lockhart for DWI.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that Officer Ware had probable cause to stop Lockhart for careless driving, as Lockhart’s tires touched the centerline, which under Arkansas law constitutes a traffic violation. The court reversed the district court’s decision regarding the initial stop and remanded the case for further proceedings on the remaining issues. The court also affirmed the district court’s denial of summary judgment on the malicious prosecution claim, agreeing that Arkansas statutory immunity does not apply to intentional torts like malicious prosecution. View "Lockhart v. Siloam Springs, Arkansas" on Justia Law

In 2021, Missouri enacted the Second Amendment Preservation Act, which declared certain federal firearms regulations as infringements on the right to keep and bear arms and invalid within the state. The Act prohibited state officials from enforcing these federal laws and allowed private citizens to sue state entities that did so, imposing penalties for violations. The United States sued Missouri, arguing that the Act violated the Supremacy Clause of the U.S. Constitution.The United States District Court for the Western District of Missouri denied Missouri's motions to dismiss for lack of standing and failure to state a claim. The court granted summary judgment in favor of the United States, ruling that the Act violated the Supremacy Clause and enjoined its implementation and enforcement. Missouri appealed the decision.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 United States had standing to sue because the Act caused concrete and particularized injury by impairing federal law enforcement efforts. The court also ruled that the Act's attempt to invalidate federal law was unconstitutional under the Supremacy Clause. The court found that the Act was not severable, as its provisions were fundamentally interconnected with the invalidation of federal law. Consequently, the injunction against the Act's implementation and enforcement was upheld. View "United States v. State of Missouri" on Justia Law

Bruce Alexander and Terrence Gay were charged with conspiracy to distribute and possession with intent to distribute fentanyl. Gay pleaded guilty, while Alexander went to trial and was found guilty by a jury. Alexander appealed, challenging the exclusion of Gay’s exculpatory statement, the handling of government witnesses, and the trial court’s comments.The United States District Court for the Western District of Missouri excluded Gay’s exculpatory statement, ruling it hearsay under Federal Rule of Evidence 804(b)(3). The court found that the statement lacked sufficient corroborating circumstances to indicate its trustworthiness, given Gay’s close relationship with Alexander and Gay’s subsequent fugitive status. The court also held a three-day jury trial where it occasionally interjected to clarify witness testimony and maintain the trial’s pace.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decisions. The appellate court affirmed the exclusion of Gay’s statement, agreeing that it lacked trustworthiness. The court also found no plain error in the handling of government witnesses, noting that the officers’ dual-role testimony was appropriately managed and did not affect the trial’s outcome. Additionally, the court ruled that the district court’s comments during the trial were aimed at clarifying testimony and maintaining order, and did not deprive Alexander of a fair trial.The Eighth Circuit held that the district court did not abuse its discretion in its evidentiary rulings or trial management, and thus affirmed Alexander’s conviction and sentence. View "United States v. Alexander" on Justia Law

Covenant Construction Services, LLC was the prime contractor on a federal construction project for a U.S. Department of Veterans Affairs facility in Iowa City, Iowa. Covenant subcontracted with Calacci Construction Company, Inc. to supply carpentry labor and materials. Calacci had a collective bargaining agreement (CBA) with two regional unions, requiring it to pay fringe-benefit contributions to the Five Rivers Carpenters Health and Welfare Fund and Education Trust Fund (the Funds). Despite multiple demands, Calacci failed to remit the required contributions.The Funds filed a lawsuit under the Miller Act to collect the unpaid contributions, liquidated damages, interest, costs, and attorneys' fees from Covenant and its surety, North American Specialty Insurance Company. The United States District Court for the Southern District of Iowa granted summary judgment in favor of the Funds, concluding that the Funds had standing to sue and that the Miller Act notice was properly served and timely.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the Funds sufficiently complied with the Miller Act's notice requirements by sending the notice to Covenant's attorney, who confirmed receipt. The court also held that the notice was timely as it was filed within 90 days of the last day of labor on the project. Additionally, the court upheld the award of liquidated damages and attorneys' fees, finding that the CBA obligated Calacci to pay these amounts and that Covenant, as the prime contractor, was liable for the amounts due under the payment bond.The Eighth Circuit concluded that the Funds were entitled to recover the unpaid contributions, liquidated damages, and attorneys' fees from Covenant and its surety, affirming the district court's judgment. View "Five Rivers Carpenters v. Covenant Construction Services" on Justia Law

In July 2018, a tornado damaged Vermeer Corporation’s facilities in Pella, Iowa. Roger Paul Bradford was hired in January 2019 as the Director of Construction to oversee the reconstruction. Bradford conspired with Viorel Draghia to receive kickbacks in exchange for steering construction contracts to Draghia’s company. Bradford shared confidential information with Draghia, who inflated his bids to include kickbacks for Bradford. Vermeer accepted Draghia’s higher bids despite cheaper alternatives. The FBI investigated in 2020, and Draghia admitted to the kickbacks. Bradford was indicted for Conspiracy to Commit Wire Fraud.The United States District Court for the Southern District of Iowa accepted Bradford’s guilty plea, which included an appeal waiver for his conviction but allowed an appeal of his sentence. The court applied a 10-level enhancement under the United States Sentencing Guidelines, determining a loss of more than $150,000. Bradford was sentenced to 20 months in prison and ordered to pay $23,000 in restitution. Bradford appealed, arguing the district court lacked jurisdiction due to a defect in the indictment and challenged the loss calculation and denial of access to certain documents.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the appeal waiver was enforceable, and Bradford had not shown a miscarriage of justice. The court found no error in the district court’s loss calculation or its denial of access to Draghia’s Presentence Investigation Report and immigration file. The court also upheld the district court’s consideration of uncharged conduct in sentencing. Bradford’s post-sentencing motions were denied as they were based on the same grounds covered by the appeal waiver.The Eighth Circuit dismissed the appeal in part based on the waiver and affirmed the district court’s judgment. View "United States v. Bradford" on Justia Law

Union Pacific Railroad Company and the Association of American Railroads challenged the Surface Transportation Board's (Board) adoption of the Final Offer Rate Review (FORR) procedure for determining the reasonableness of rail carrier rates in smaller cases. Under FORR, the Board selects either the shipper’s or the rail carrier’s final offer without modification. The petitioners argued that the Board lacked statutory authority to implement FORR, that FORR was unconstitutionally vague, and that it was arbitrary and capricious.The Board is tasked with resolving rate disputes between rail carriers and shippers when rates are not set by private contract. The Board must hold a "full hearing" and give due consideration to specific statutory factors before determining the reasonableness of a rate. The Board adopted FORR to streamline the process for smaller disputes, allowing it to choose between the final offers submitted by the parties.The United States Court of Appeals for the Eighth Circuit reviewed whether the Board had statutory authority to implement FORR. The court concluded that FORR conflicted with the Board’s statutory duties. The court held that the Board must hold a "full hearing" and that the shipper must bear the burden of proof on the final offer, which FORR did not require. Additionally, the court found that FORR improperly limited the Board’s ability to prescribe the maximum rate, as required by statute, by forcing the Board to choose between the parties' final offers without modification.The Eighth Circuit granted the petitions for review and vacated the final rule, holding that the Board lacked statutory authority to implement FORR. View "Union Pacific Railroad Co. v. STB" on Justia Law

Tina Sully, a foster parent for the Yankton Sioux Tribe, was charged with multiple counts of abusing her three adopted children. The charges stemmed from an incident where 13-year-old C.S. ran away from home and reported to neighbors and authorities that Sully had physically abused her and withheld food. An investigation revealed similar allegations from two other foster children, D.F.H. and G.S. Sully was indicted on ten counts, including assault with a dangerous weapon and felony child abuse.The first trial in the United States District Court for the District of South Dakota ended in a mistrial due to a hung jury. The court scheduled a second trial to begin eighteen days later. Sully requested a continuance twice, citing her counsel's scheduling conflicts and the unavailability of key defense witnesses, but both motions were denied. The second trial proceeded, and Sully objected to the admission of several out-of-court statements under Federal Rules of Evidence 803(2) and 807, which the court admitted.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying Sully's motions for a continuance, as she failed to demonstrate how the denial prejudiced her defense. The court also found that even if the admission of the challenged hearsay statements was erroneous, it was harmless error given the overwhelming evidence against Sully, including testimony from C.S., medical professionals, and other witnesses.The Eighth Circuit affirmed the district court's decisions, upholding Sully's convictions on all counts related to C.S. The court concluded that the denial of the continuance and the admission of hearsay evidence did not warrant a new trial. View "United States v. Sully" on Justia Law

Norman Burch was convicted by a jury of attempting to sexually exploit a minor, attempting to receive and receiving child pornography, and committing a felony sex offense involving a minor while required to register as a sex offender. These actions also violated the terms of his supervised release from a prior conviction for possessing child pornography. Burch was sentenced to a combined 420 months of imprisonment for these convictions and violations.Previously, the United States District Court for the Southern District of Iowa presided over Burch’s case. The court admitted evidence of Burch’s 2014 conviction for child pornography under Federal Rules of Evidence 404(b) and 414(d)(2)(B). Burch objected to this evidence, but the court overruled his objection. The jury found Burch guilty on all counts, and the district court sentenced him to 420 months of imprisonment, followed by a lifetime of supervised release. The court also revoked Burch’s supervised release from his previous conviction, imposing an additional 24 months to run concurrently with some counts and consecutively with others.The United States Court of Appeals for the Eighth Circuit reviewed the case. Burch challenged the admission of his prior conviction, the sufficiency of the evidence for all counts, and the revocation of his supervised release. The Eighth Circuit held that the district court did not abuse its discretion in admitting the prior conviction under Rule 414, as it was relevant to show Burch’s propensity to be sexually interested in minors. The court also found sufficient evidence to support Burch’s convictions on all counts, including the attempted sexual exploitation of a minor and the receipt of child pornography. Consequently, the Eighth Circuit affirmed the district court’s judgment, including the revocation of Burch’s supervised release. View "United States v. Burch" on Justia Law