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

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to one count of possession with intent to distribute 50 grams or more of a mixture or substance containing methamphetamine. The court held that the plea waiver that defendant entered into knowingly and voluntarily barred his challenge to the reasonableness of his sentence and whether the district court adequately explained its downward variance. However, in regard to his challenge to the criminal history determinations supporting the application of the career enhancements, the court held that the district court correctly counted each conviction as a predicate offense and properly applied the career offender enhancement. In this case, defendant's 2007 and 2010 convictions were separated by an intervening arrest and thus were properly counted separately. View "United States v. Grady" on Justia Law

The Eighth Circuit affirmed the district court's denial of plaintiff's request for declaratory and injunctive relief, seeking a ruling that the Missouri State Highway Patrol is forbidden to stop and inspect his 54,000-pound dump truck, used in furtherance of his private commercial venture, without probable cause. The court held that plaintiff is a member of the closely regulated commercial trucking industry, and that the patrol's random stops and inspections of his truck would comport with the Fourth and Fourteenth Amendments. Furthermore, Missouri's regulatory scheme advances a substantial government interest as applied to plaintiff, and warrantless inspections are necessary to further the regulatory scheme. View "Calzone v. Olson" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of TJN's 42 U.S.C. 1983 action against defendants, in an action arising from the Craighead County District Judges Boling and Fowler's implementation of an Amnesty Program forgiving all fees that probationers owed to TJN for probation services. The court held that Judges Boling and Fowler were entitled to absolute judicial immunity against all of TJN's claims, because Arkansas judges have authority to suspend the imposition of fines in criminal cases and may modify terms and conditions of supervision. Furthermore, TJN's request for declaratory relief was retrospective and thus it was not entitled to such relief under section 1983. The court also rejected the municipal liability claims and held that the judges are state government officials whose actions are not attributable to the county or city defendants. View "Justice Network Inc. v. Craighead County" on Justia Law

The Bankruptcy Appellate Panel affirmed the bankruptcy court's orders dismissing debtor's adversary proceeding and denying his post-dismissal motion. The panel held that the bankruptcy court properly dismissed debtor's adversary proceeding as a collateral attack on prior rulings. In this case, the post-dismissal motion repeated the same arguments already made by debtor. View "Raynor v. Walker" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1981 against K.C. Live for assault, battery, false imprisonment, negligence, and malicious prosecution. The district court granted K.C. Live's motion to dismiss after finding the claim was barred by res judicata in light of the state court's prior dismissal with prejudice.The Eighth Circuit affirmed, holding that the suit was barred by res judicata because plaintiff asserted the same cause of action against the same party in federal court that he did in the state court, which had jurisdiction and entered a final judgment. View "Brown v. Kansas City Live, LLC" on Justia Law

Lemartec appealed the district court's entry of judgment in favor of ACT on ACT's breach of contract claim. Lemartec argued that the district court erred in concluding that Lemartec's bid package was incorporated into the parties' contract. Although the bid package was not incorporated in so many words, the Eighth Circuit nonetheless affirmed the judgment, because when the contract is considered in light of the usage-of-trade evidence that the district court found credible, there is no error in the determination that Lemartec breached the purchase order. View "Advance Conveying Technologies v. Lemartec Corp." on Justia Law

The Eighth Circuit dismissed defendant's appeal of the district court's denial of his request for de novo resentencing. In this case, defendant pleaded guilty to one count of possession of methamphetamine with intent to distribute. Paragraph 7 of the plea agreement contained an appeal waiver. The court held that defendant's claim that trial counsel provided ineffective assistance by failing to file a notice of appeal fell squarely within the terms of his knowing and voluntary 28 U.S.C. 2255 appeal waiver. View "United States v. Floyd" on Justia Law

Plaintiff filed suit against her employees, alleging that they unlawfully terminated her in retaliation for exercising her rights under the Family and Medical Leave Act (FMLA) and the Missouri Human Rights Act (MHRA). Plaintiff's husband filed suit for loss of consortium.The Eighth Circuit held that the district court did not err in granting defendants summary judgment on the FMLA claim, because plaintiff's use of FMLA leave some half-year prior to her termination was insufficient to show her termination was an act of discrimination. The court also held that the district court did not err in granting summary judgment in favor of defendants on the MHRA claim, because plaintiff could not have had a reasonable good faith belief that the conduct she opposed had constituted disability discrimination in violation of the MHRA. For purposes of the MHRA, accusing an employee of racism does not constitute racial discrimination. Furthermore, evidence of general temporary work restrictions, without more, was insufficient to constitute a disability. Finally, the loss of consortium claim was properly dismissed. View "Lovelace v. Washington University School of Medicine" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he violated one of his supervised release conditions. Reviewing for substantive error, the court held that the district court did not abuse its discretion in mentioning the need to protect the public from further crimes and the need to promote respect for the law as additional reasons supporting its sentence. In this case, the district court used an excluded factor only as an insignificant justification and there was no substantive error. The court also held that there was no error in weighing defendant's record on supervised release, and there was no error in the district court's weighing of the sentencing factors where the conclusion that a sentence of further imprisonment would better reflect his record of intransigence than a sentence of further supervised release was reasonable. View "United States v. Hall" on Justia Law

Plaintiff, a minor, filed suit against the SWAT team officers, the detectives, and the Board under 42 U.S.C. 1983, after she suffered Post-Traumatic Stress Disorder (PTSD) from the blast of a flash-bang grenade. In this case, even though the SWAT team knew the suspect was already in custody, they broke open the screen door of the suspect's residence and threw a flash-bang grenade into the living room of the home before a young woman could open the door with the keys she was holding in her hand. The only people inside where three women and a two year old girl. The girl suffered PTSD from the officers' use of the flash-bang grenade.The Eighth Circuit held that the SWAT team officers were not entitled to qualified immunity because any reasonable officer would have known the use a flash-bang grenade under these circumstances constituted excessive force. It was clearly established at the time that use of a flash-bang grenade was unreasonable where officers have no basis to believe they will face a threat of violence and they unreasonably fail to ascertain whether there are any innocent bystanders in the area where the grenade is deployed. Therefore, the district court did not err by denying summary judgment based on qualified immunity. The court also held that detectives are entitled to summary judgment because there was probable cause to support the search warrant, even considering the omitted information, and because their decision to use a SWAT team, regardless of whether it was reasonable, did not violate clearly established law. Accordingly, the court reversed the district court's grant of summary judgment as to the detectives. Finally, the court held that it lacked appellate jurisdiction to review the district court's denial of summary judgment to the Board, and the court dismissed the appeal as to the Board. View "Z. J. v. Kansas City Board of Police Commissioners" on Justia Law