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

Plaintiff filed suit against a police deputy, alleging that the deputy violated plaintiff's rights under the First Amendment, Fourth Amendment, and the Equal Protection Clause of the Fourteenth Amendment. The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the deputy based on qualified immunity. The court held that the initial encounter at the rest stop presented no colorable claim that plaintiff's Fourth Amendment rights were violated where an objectively reasonable officer would have articulable suspicion to conduct a Terry stop; the seizure of plaintiff on the highway exit ramp did not run afoul of the Fourth Amendment and was reasonably related in scope to the circumstances which justified the interference; pointing a firearm at plaintiff for a few seconds while removing him from his vehicle did not constitute excessive force, and did not violate the Fourth Amendment; and, in light of the deputy's legitimate motive to investigate, plaintiff failed to draw the requisite causal connection to state a First Amendment retaliation claim. View "Clark v. Clark" on Justia Law

The Eighth Circuit affirmed Defendants Williams and Jefferson's sentences imposed after they each pleaded guilty to possessing a firearm after being convicted of a felony. The court held that Williams' prior Minnesota conviction for simple robbery qualified as a crime of violence, and his prior conviction for possession of a firearm in furtherance of a drug trafficking crime qualified as a controlled substance offense for purposes of sentencing under USSG 4B1.2(b)cmt. n. 1.The court also held that Jefferson's within-guidelines sentence was not substantively unreasonable, because it was not unconstitutional and the district court did not abuse its discretion by imposing a three-year term of supervised release. View "United States v. Williams" on Justia Law

The FTC and the State of North Dakota moved to enjoin Sanford Bismarck's acquisition of Mid Dakota, alleging that the merger violated section 7 of the Clayton Act. The district court determined that plaintiffs would likely succeed in showing the acquisition would substantially lessen competition in four types of physician services in the Bismarck-Mandan area.The Eighth Circuit affirmed the district court's grant of a preliminary injunction, holding that the district court did not improperly shift the ultimate burden of persuasion to defendants and properly followed the analytical framework in U.S. v. Baker Hughes, Inc., 908 F.ed 981 (D.C. Cir. 1990); the district court did not clearly err in defining the relevant market; and the district court's finding on merger-specific efficiencies was not clear error. View "Federal Trade Commission v. Sanford Health" on Justia Law

Defendant was found guilty by a jury of two drug crimes. The Eighth Circuit affirmed the district court's refusal to exclude testimony of a police detective regarding the value of the methamphetamine. The court assumed without deciding that the government's notice was deficient and held that defendant knew ahead of time that one of the expected topics of the detective's testimony would be the dollar values of the methamphetamine and defense counsel had the opportunity to question the detective beforehand. Finally, counsel never explained how the incomplete disclosure prejudiced his client or why only a more drastic remedy like exclusion would cure any harm. View "United States v. Kessler" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to making a false statement to the firearms dealer. The court held that the district court's explanation of why it varied significantly upward, though perhaps testing brevity's acceptable limits, was sufficient. In this case, the district court showed that it had considered the 18 U.S.C. 3553(a) factors, defendant's memorandum, and mitigating factors. Therefore, the court held that the sentence was not substantively unreasonable in light of the uncharged conduct and the danger he posed to the community. View "United States v. Anderson" on Justia Law

The Eighth Circuit reversed a commitment order under 18 U.S.C. 4246, which authorizes commitment proceedings for prisoners whose sentences are about to expire. In this case, due to an error in calculating defendant's release date, the government did not begin the commitment process until months after defendant's sentence had already expired. Therefore, the court held that a necessary condition for his commitment was missing. View "United States v. Clark" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of the school district in an action originally alleging that plaintiff's daughter, a young student with autism and significant intellectual deficits, was not provided a free appropriate public education (FAPE) under the Individuals with Disabilities Education Act (IDEA). Plaintiff also brought additional claims for constitutional violations under 42 U.S.C. 1983, disability discrimination and retaliation under section 504 of the Rehabilitation Act, disability discrimination under Title II of the Americans with Disabilities Act (ADA), and violations of Arkansas law.The court found no clear error in the district court's factual findings and gave due weight to the hearing officer's credibility determinations, concluding that the child was not denied a FAPE. The court also held that the district court did not abuse its discretion in denying plaintiff's motions for extensions of time and her motion to accept her summary judgment response out of time. The court also held that some of plaintiff's claims were barred for failure to exhaust and that her retaliation claim based on a violation of the IDEA also failed. View "Albright v. Mountain Home School District" on Justia Law

The Constitution does not imply a cause of action under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), if a federal law-enforcement officer lies, manipulates witnesses, and falsifies evidence. In this case, the allegations were that a federally deputized officer duped prosecutors and a grand jury into believing that plaintiffs were part of a multistate sex-trafficking conspiracy.The Eighth Circuit declined to extend Bivens and remanded with respect to the 42 U.S.C. 1983 claims against defendant for the district court to consider the applicability of section 1983 in the first instance. In regard to the unlawful arrest claim, the court held that defendant was not entitled to qualified immunity because her actions constituted a violation of a clearly established right. In this case, a reasonable officer would know that deliberately misleading another officer into arresting an innocent individual to protect a sham investigation was unlawful, regardless of the difficulties presented by the case. View "Farah v. Weyker" on Justia Law

Plaintiff filed suit against defendants, alleging that they violated her son's constitutional rights when two officers used deadly force against him. The Eighth Circuit affirmed the district court's grant of summary judgment for defendants, holding that there was no potentially admissible evidence in the record supporting plaintiff's allegations that the decedent was unarmed, did not point his gun at officers, and did not shoot at an officer. The court also held that the district court correctly ruled that the officers were reasonable in using deadly force. Therefore, the district court properly rejected the assault, battery, and wrongful death claims, as well as properly dismissed the Monell claim. Finally, because the individual officers fulfilled their constitutional obligations, the Board and the Police Chief cannot be liable for failing to train them. View "Smith v. Kilgore" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to one count of unlawful possession of a firearm as a previously convicted felon. The court held that defendant's prior conviction for first degree aggravated robbery under Minnesota Statutes 609.245 was a crime of violence under the sentencing guidelines, resulting in a base offense level of 20.The Supreme Court's decision in Stokeling v. United States, 139 S. Ct. 544 (2019), held that the term "physical force" in 18 U.S.C. 924(e)(2)(B)(i) includes the amount of force necessary to overcome a victim's resistance. The court held that Stokeling reinforced its precedent and was consistent with United States v. Libby, 880 F.3d 1011 (8th Cir. 2018), which concluded that first degree aggravated robbery in Minnesota has as an element a threatened use of violent force. View "United States v. Robinson" on Justia Law