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

The Eighth Circuit affirmed the district court's denial of petitioner's motion to vacate his sentence under 28 U.S.C. 2255, holding that his prior conviction for Indiana burglary was a violent felony under the Armed Career Criminal Act. The court agreed with the Seventh Circuit and held that the definition of burglary in Indiana law is nearly identical to that of generic burglary. View "Faulkner v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's motion to vacate his sentence, holding that his prior Minnesota conviction for simple robbery is a violent felony under the force clause of the Armed Career Criminal Act. Therefore, the district court properly sentenced petitioner to the minimum 180 months in prison as an armed career criminal. View "Taylor v. United States" on Justia Law

The Eighth Circuit affirmed defendant's conviction for conspiracy to distribute and possess with intent to distribute a controlled substance, possession with intent to distribute a controlled substance, and possession of a firearm in furtherance of a drug trafficking crime. The court held that the district court did not abuse its discretion by admitting evidence of firearms in defendant's home because the evidence was probative of the charged drug offenses and was not unfairly prejudicial. The court also held that challenges to the statements made by four potential jurors were not raised during voir dire or after the jury was selected. In this case, the impartiality of the jurors who were seated was adequately supported by the record. View "United States v. Medrano" on Justia Law

Defendant moved to vacate his convictions under 28 U.S.C. 2255, arguing that they were unconstitutional in light of Johnson v. United States, 135 S. Ct. 2551 (2015). The Eighth Circuit affirmed the district court's denial of defendant's motion to vacate his convictions under 28 U.S.C. 2255, and held that his conviction for bank robbery and carjacking both qualified as a crime of violence under 18 U.S.C. 924(c)(3)(A). Furthermore, defendant's convictions and sentences under section 924(c)(1)(A) for using a firearm during and in relation to those crimes were not unconstitutional. View "Estell v. United States" on Justia Law

Plaintiff, a former employee of Semi, filed a derivative lawsuit on behalf of a defined-contribution retirement savings plan and, in the alternative, as a putative class action on behalf of plan participants, claiming that Semi and others breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA). The Eighth Circuit affirmed the district court's dismissal of the complaint for failure to state a claim and held that, under Fifth Third Bancorp v. Dudenhoeffer, 573 U.S. 409 (2014), plaintiff's allegations were insufficient to plausibly state a claim for breach of the duty of prudence. Finally, the court affirmed the denial of plaintiff's motion for leave to amend his complaint because he failed to submit a proposed amended complaint with his motion. View "Usenko v. MEMC LLC" on Justia Law

Defendant appealed his sentence after pleading guilty to being a felon in possession of a firearm. The Eighth Circuit dismissed defendant's appeal, holding that defendant's attempt to contest a sentencing enhancement unrelated to criminal history fell within the plain language of the appeal waiver. The court also held that defendant's waiver was knowing and voluntary where he signed the plea waiver of his own volition and heard the district court read it aloud. Finally, the court rejected defendant's argument that the agreement was void for lack of consideration and held that the mere misapplication of the Guidelines does not render the enforcement of an appeal waiver a miscarriage of justice. View "United States v. Guice" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging claims of excessive force, as well as failure to train and supervise. The Eighth Circuit affirmed the district court's grant of summary judgment to the officer on the excessive force claim based on qualified immunity, holding that a reasonable officer could have believed plaintiff was resisting arrest and posed a threat to his safety. In this case, the officer faced a tense and unpredictable situation where he was the only officer on the scene with two hostile intoxicated individuals. Furthermore, the amount of force the officer used was objectively reasonable when he employed an arm-bar takedown to restrain and handcuff plaintiff. View "Fischer v. Hoven" on Justia Law

The Eighth Circuit affirmed the district court's denial of summary judgment based on qualified immunity to a state trooper, in an action brought by plaintiff alleging claims of First Amendment retaliation and Fourth Amendment unreasonable seizure. The trooper arrested plaintiff for disorderly conduct after plaintiff yelled a two-word expletive at him from a moving vehicle. The trooper believed the shout constituted unreasonable or excessive noise in violation of state law.The court held that the trooper lacked even arguable probable cause for an arrest and thus violated plaintiff's Fourth Amendment right to be free from unreasonable seizure. In this case, plaintiff's conduct may have been offensive, but it was not an unreasonable or excessive noise. The court also held that the district court did not err as to the First Amendment retaliation claim where the trooper had neither probable cause nor arguable probable cause to arrest plaintiff, because plaintiff's profane shout was protected activity and the arrest was an action that would chill continued activity by a person of ordinary firmness. View "Thurairajah v. Hollenbeck" on Justia Law

A group of customers filed suit against SuperValu after hackers accessed customer financial information from hundreds of grocery stores operated by defendant. The Eighth Circuit previously affirmed the dismissal of all but one of the suit's named plaintiffs for lack of standing and, on remand, the district court dismissed the remaining plaintiff for failure to state a claim and denied plaintiffs' motion for leave to amend.The court affirmed, holding that the district court did not abuse its discretion by denying the motion for leave to amend because plaintiffs' postjudgment motion was untimely. The court also held that the remaining plaintiff's allegations fell short of stating a claim for relief under Illinois law for negligence, consumer protection, implied, contract, and unjust enrichment. View "Alleruzzo v. SuperValu, Inc." on Justia Law

The Eighth Circuit affirmed defendant's conviction for murder in furtherance of a drug trafficking conspiracy and other related charges. The court held that the district court did not err by admitting evidence of defendant's prior conviction and supervised release status; the district court did not plainly err by admitting a lab report without the analyst's testimony because defendant's substantial rights were not affected in light of the other evidence; the district court's finding that Lorie Ortiz was a coconspirator was neither an abuse of discretion nor clear error; there was no error in admitting a witness's testimony about being motivated to cooperate by someone else's cooperation; and defendant's counsel agreed to swap the juror at issue with the alternate juror and thus the juror substitution claim failed. View "United States v. Torrez" on Justia Law