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

An arbitration agreement lacking a valid delegation clause leaves the remaining arbitration agreement, as a whole, open to review for validity. The Eighth Circuit affirmed the district court's denial of PrimeLending's motion to compel arbitration against plaintiff. Plaintiff filed suit under the Fair Labor Standards Act (FLSA), alleging that she was not paid for all earned wages and overtime pay.The court held that the parties never entered into a contract relating to the arbitration provision and the delegation provision. In this case, the arbitration provision was not a validly formed contract due to a lack of acceptance. Therefore, plaintiff did not contract with PrimeLending to arbitrate any disputes between them, nor was a contract formed to delegate this decision to an arbitrator. View "Shockley v. PrimeLending" on Justia Law

A proceeding in the district court under 8 U.S.C. 1447(b) does not become moot when the USCIS purports to deny a naturalization application after the applicant has already initiated the court proceeding. In this case, after USCIS failed to reach a decision in plaintiff's citizenship application within 120 days, he filed suit under section 1447(b) to seek a decision in the matter. While the action was pending, USCIS denied the application.Looking to the text and context of the statute, the Eighth Circuit held that USCIS's purported denial of plaintiff's naturalization application after he initiated a district court proceeding under section 1447(b) did not render the case moot. Accordingly, the court reversed and remanded for further proceedings. View "Haroun v. DHS" on Justia Law

The Eighth Circuit affirmed the district court's orders requiring it to deposit $21 million in disputed insurance proceeds to maintain its federal statutory interpleader claim and dismissing Ronald Gean and the Estate of Jean Carol Gean for lack of personal jurisdiction in its declaratory judgment claims. The Geans are citizens of Michigan and were injured in an automobile accident in Illinois by a truck operated by Rex, a Missouri company.The court agreed with the district court that subject matter jurisdiction was lacking because Acuity did not deposit the disputed amount into the court's registry. The court rejected Acuity's argument that the district court had personal jurisdiction over the Geans. Rather, the court held that the district court lacked personal jurisdiction over the Geans in the remaining declaratory judgment action. View "Acuity v. Rex, LLC" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress after he conditionally pleaded guilty to possession with intent to distribute 50 grams or more of methamphetamine. The court held that plaintiff failed to show that the officer failed to follow the tow policy in a manner that rendered the tow and subsequent search of the vehicle unreasonable.In this case, it was undisputed that the vehicle required towing and the officer decided he needed to act immediately, reasonably questioning the propriety of releasing the vehicle to defendant's control. Therefore, his actions were consistent with his role as a community caretaker and his decision was largely based on concerns related to the purposes of an impoundment. The court also held that the officer did not violate the "Non-custody Tow" provisions. Because the impoundment was valid and the officer's sole purpose for impounding was not to investigate criminal activity, the corresponding inventory search was reasonable. View "United States v. Green" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the deputy warden, alleging that the deputy warden failed to protect him from harm by fellow inmates. The Eighth Circuit affirmed the district court's grant of the deputy warden's motion for judgment as a matter of law, and held that the evidence did not establish that the deputy warden acted with deliberate indifference. In this case, plaintiff's statements to the deputy warden were speculative and non-specific, and plaintiff's stated suspicions were insufficient to show that the deputy warden knew of a specific risk to plaintiff if he returned to general population. View "Blair v. Terry" on Justia Law

Plaintiffs filed a 42 U.S.C. 1983 action against the City, the County, and officials, alleging violations of their constitutional right to privacy and of Arkansas tort law in connection with defendants' decisions to release information identifying them as victims of childhood sexual abuse. Plaintiffs are sisters and stars of the popular reality show 19 Kids and Counting. Plaintiffs were interviewed along with others as part of a police investigation into sexual misconduct by plaintiffs' brother.The Eighth Circuit affirmed the district court's denial of qualified immunity to the defendant officials. In this case, the information released about the minors interviewed in the investigation was highly personal and involved the most intimate aspects of human affairs. Furthermore, the information was inherently private and entitled to constitutional protection. Therefore, the court held that plaintiffs have stated a plausible claim for the violation of their constitutional right to confidentiality, and the right of minor victims of sexual abuse not to have their identities and the details of their abuse revealed to the public was clearly established at the time. Because plaintiffs have sufficiently pleaded intentional torts, the officials are not entitled to statutory or qualified immunity on plaintiffs' state law claims at this stage of the proceedings. View "Dillard v. Hoyt" on Justia Law

The Eighth Circuit affirmed defendant's conviction for attempting to entice a minor to engage in sexual activity. The court held that the evidence was sufficient to convict defendant because he took a substantial step to accomplish the offense.The court also held that the district court did not err by rejecting the entrapment defense or by instructing the jury it could not allow the fact that the government used deceptive means during the sting operation to affect its verdict. The court noted that it shared the Seventh Circuit's concern that the instruction could signal indirect judicial approval of the government's management of the investigation. However, in this case, the evidence was so overwhelming that any possible error would be harmless. Although the court did not endorse or encourage giving this instruction. Finally, the court declined to vacate defendant's special conditions on plain error review because they were not obviously impermissible. View "United States v. Strubberg" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to distributing less than 50 grams of methamphetamine. The court held that defendant's 200 month sentence did not come close to violating the gross disproportionality Eighth Amendment standard. In this case, his sentence was within the advisory guidelines range and well within the statutory range of punishment for his offense. Furthermore, an extensive criminal history such as defendant's was a factor justifying the imposition of lengthy sentences. Accordingly, the district court did not commit plain error in sentencing defendant. The court denied as moot the government's motion to dismiss the appeal. View "United States v. Garth" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he was convicted of conspiring to file false tax returns, aiding and assisting in the preparation of false tax returns, and failing to appear at a pretrial conference. The court held that the district court did not err by applying a three-level sentencing enhancement under USSG 3B1.1(b) for his role as a manager or supervisor in a criminal activity involving five or more participants.The court also held that the record supported the district court's imposition of a special condition of supervised release restricting defendant's computer use, because the use of computers and the internet was central to the criminal operation. Furthermore, the computer restriction did not impose an unnecessary deprivation of liberty. Finally, the court held that the district court did not err by applying a two-level sentencing enhancement under USSG 2B1.1(b)(10)(C) & cmt. n.9(B) for the use of sophisticated means; the district court adequately explained its within-Guidelines sentence; and there was sufficient evidence to support the loss amounts and restitution. View "United States v. Osman" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute methamphetamine and possession with intent to distribute 500 grams or more of methamphetamine. The court held that the affidavits supporting each of the GPS warrant applications provided probable cause to believe that defendant was involved in methamphetamine trafficking and that the location data from the vehicles would lead to evidence of that trafficking. Furthermore, the applications were not stale. Therefore, the warrants were supported by probable cause and there was no basis for disturbing defendant's convictions or his revocation of supervised release. View "United States v. Petruk" on Justia Law