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

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to possession with intent to distribute 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine. The court held that the district court's determination that defendant had not been complete and truthful in his safety-valve interview was not clearly erroneous. In this case, while the district court did not rely heavily on some of the minor inconsistencies between the interviews, it did emphasize some of the more significant aspects of defendant's changing stories. Therefore, the district court did not clearly err by denying safety valve relief. View "United States v. Cervantes" on Justia Law

The Eighth Circuit affirmed the denial of social security disability insurance benefits and supplemental security income (SSI) benefits to claimant. The court held that substantial evidence supported the ALJ's findings that claimant's physical and mental impairments did not meet or equal the severity of any of the listed impairments. Furthermore, substantial evidence supported the ALJ's residual functioning capacity determination and the mental limitations included in that finding. The court also held that the vocational expert's testimony did not conflict with the Dictionary of Occupational Titles and the ALJ was entitled to rely on the expert's testimony. View "Twyford v. Commissioner" on Justia Law

Plaintiff, a pretrial detainee, filed suit against defendants under 42 U.S.C. 1983, alleging that defendants deprived him of dental care in violation of the Eighth Amendment. In this case, plaintiff suffered from multiple cavities and tooth pain. The district court ultimately granted summary judgment to defendants.The Eighth Circuit affirmed, holding that the district court did not abuse its discretion in setting aside the entry of default against Defendant Collier where Collier had a meritorious defense and plaintiff was not significantly prejudiced. The court also held that plaintiff failed to meet the substantial evidentiary threshold required to show that the MEND Defendants and Collier were deliberately indifferent. In this case, defendants regularly responded to plaintiff's sick calls and followed protocol. Furthermore, any delay in permanently filling plaintiff's cavities did not show any unnecessary and wanton infliction of pain that was sufficiently harmful to evidence deliberate indifference to his serious medical needs. View "Johnson v. Leonard" on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment on plaintiff's Fourth Amendment claims against law enforcement officers, Defendants Lesan and Hein, for unlawful seizure, unlawful arrest, and excessive force. In this case, Lesan responded to a citizen's report and encountered plaintiff in Hickman, Nebraska. Plaintiff was known by officers as a dangerous individual who had made threats against law enforcement in the past and had access to weapons. Based on plaintiff's prior encounters with the police, Lesan asked for his license and registration. Lesan then discovered that a police department broadcast was issued for plaintiff due to a disturbance that had occurred in Lincoln city limits.The court held that Lesan did not seize plaintiff in Hickman and that, therefore, he has shown no violation of his Fourth Amendment rights; Hein and Lesan did not violate plaintiff's Fourth Amendment rights by arresting him outside of the Lincoln city limits; excessive force arguments were raised for the first time on appeal and would not be considered; and the exhibits submitted in support of defendants' motion for summary judgment were properly admitted. View "Oglesby v. Lesan" on Justia Law

After a police officer shot and killed 17 year old Keagan Schweikle, his parents and others filed suit against the officer, the Chief of Police, and the City under 42 U.S.C. 1983 and Arkansas law. The district court granted qualified immunity to the officers and judgment on the pleadings.The Eighth Circuit affirmed in part and reversed in part, holding that, in light of the circumstances, the officer's actions were not objectively reasonable and Keagan's right to be free from excessive force was clearly established at the time. In this case, the officer shot a non-resisting, non-fleeing minor as he moved his gun in compliance with the officer's commands to drop his gun. Therefore, no reasonable officer could conclude that Keagan posed an immediate threat of serious physical harm. Consequently, the court reversed the dismissal of the Monell claims and vacated the dismissal of the state law claims. Finally, the court held that the parents failed to allege a due process claim under the Fourteenth Amendment to a familial relationship, where they failed to allege that the shooting was directed at their relationship with their son. View "Partridge v. City of Benton" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to MBI in an action brought by MBI seeking reimbursement of the benefits it paid to defendant under a self-funded employee benefit plan sponsored and administered by MBI. The court held that the Employee Retirement Income Security Act allows a fiduciary such as MBI to bring an action for equitable relief to enforce the terms of an employee benefit plan.The court also held that MBI was entitled to reimbursement because the Summary Plan Description was the plan's written instrument and defendant did not dispute that its reimbursement provision required him to pay MBI if it was an enforceable part of the plan. The court rejected defendant's remaining claims. View "MBI Energy Services v. Hoch" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he conditionally pleaded guilty to escaping from prison and conspiracy to escape. The court held, after weighing all the relevant factors, that the time lapse between defendant's indictment and guilty plea did not violate his Sixth Amendment right to a speedy trial. In this case, while the 22 month delay was presumptively prejudicial, the responsibility for the delay and the prejudice factors weighed against defendant.The court declined to address defendant's ineffective assistance of counsel claim on direct review. Finally, the court held that the district court did not abuse its discretion in sentencing defendant to 36 months in prison and expressly weighed all the 18 U.S.C. 3553(a) sentencing factors. Therefore, defendant's above-Guidelines sentence was not substantively unreasonable. View "United States v. Saguto" on Justia Law

Petitioner moved to correct his sentence under 28 U.S.C. 2255(a), arguing that several Supreme Court decisions had cast doubt on whether his second degree burglary conviction qualified as a violent felony. Applying de novo review and setting aside the timeliness and other procedural objections that the government has waived, the Eighth Circuit held that petitioner's 1977 conviction for second degree burglary was not a violent felony for purposes of the Armed Career Criminal Act. Accordingly, the court remanded for resentencing. View "Brown v. United States" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he was convicted of eight counts of production or attempted production of child pornography and one count of possession of child pornography. The court held that the district court did not abuse its discretion in admitting the audio components of the videos defendant took because they were probative of his intent to produce lascivious footage and whether the videos on their face were of a sexual nature; the district court did not abuse its discretion in issuing jury instructions on finding lascivious exhibition; and the district court did not err by denying defendant's motions for acquittal and new trial. View "United States v. Petroske" on Justia Law

The Supreme Court vacated and remanded this case for further consideration in light of the position asserted by the Solicitor General in his brief for the United States filed on March 21, 2019.The Eighth Circuit reaffirmed defendant's sentence imposed after he pleaded guilty to being a felon in possession of a firearm. The court held that defendant's prior conviction for first degree terroristic threatening under Arkansas law was a violent felony under 18 U.S.C. 924(e) because it has as an element the threatened use of physical force against the person of another. View "United States v. Myers" on Justia Law