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

The Eighth Circuit affirmed the district court's denial, on remand, of Qwest's unjust enrichment claim against FC. The court held that the district court did not abuse its discretion by concluding that it would not be inequitable for FC to retain the benefit conferred by Qwest. In this case, the district court explained that FC earned the benefit conferred by Qwest because it provided conference-calling services, 24-hour customer support, and access to a website in exchange for two cents per minute for calls placed to FC's conferencing bridges at Sancom. Furthermore, Qwest paid its own conference-calling vendor between two and four-and-a-half cents per minute. View "Qwest Communications Corp. v. Free Conferencing Corp." on Justia Law

Plaintiff, on behalf of his minor sons and a class of current and former students of the school district who were videotaped in the nude by Defendant Hansen, filed suit under 42 U.S.C. 1983 against several district defendants. The district court entered default judgment against Hansen in his individual capacity and summary judgment for the district defendants.The Eighth Circuit affirmed, holding that the district's failure to provide more supervision and training did not rise to the level of a constitutional violation where plaintiff presented no evidence of a pattern of misconduct that would alert the district that its training and supervision were insufficient to prevent Hansen's conduct, and, without notice, the district's failure to provide more training or supervision was not deliberately indifferent. The court also held that plaintiff waived his Child Abuse Victims Rights Act of 1986 (CAVRA) claim because CAVRA is not a predicate statutory violation for a section 1983 claim. View "Doe v. Fort Zumwalt R-II School District" on Justia Law

The Eighth Circuit affirmed defendant's conviction of four counts of sexual abuse involving three young female relatives. The court held that the district court did not err in allowing the government to play video recordings of the victims' forensic interviews for the jury. In this case, defendant opened the door to the admission of one of the videos, defendant did not object to the admission of the other videos, and the admission did not affect his substantial rights where the videos were cumulative and the evidence of his guilt was strong overall. View "United States v. Lonnie Dale Spotted Bear" on Justia Law

The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss the amended complaint in an action brought by plaintiff and his wife after plaintiff refused to allow Menards home supply store employees, pursuant to posted store policy, to search the trunk of his vehicle as he exited a Menards lumberyard in Coon Rapids, Minnesota. The court held that the officers were entitled to qualified immunity on the Fourth Amendment seizure claims because they had arguable reasonable suspicion in detaining plaintiff when he refused to open his vehicle's trunk; there was no unreasonable delay or unreasonable force in the detention and the officers did not arrest plaintiff; and it was reasonable for the officers to briefly handcuff plaintiff in light of his unpredictability, evasiveness, argumentative demeanor, refusal to disobey legitimate officer commands, and the size difference between plaintiff and the officers.The court also held that the officers were entitled to qualified immunity on the wife's Fourth Amendment seizure claim where the wife was a passenger in the car and the officers had reasonable suspicion for detaining her; a de minimis use of force could not, as here, form the basis for a Fourth Amendment excessive force claim; plaintiff failed to adequately plead a compensatory damages claim under 42 U.S.C. 1983 arising from the officers' search of the vehicle's trunk; and plaintiff's remaining First Amendment and state law claims were rejected. View "Waters v. Madson" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to distribution of heroin to a person under the age of twenty-one. The court held that the district court did not abuse its discretion by departing upward, in light of the applicable policy statements and USSG 5K2.1, because death resulted from the offense of conviction. In this case, the district court found defendant's conduct most akin to involuntary manslaughter, and sentenced him to the maximum punishment available under the federal involuntary manslaughter statute. The district court noted defendant's youth and acknowledged the hardship of addiction during adolescence, but reasonably concluded that other factors such as the seriousness of the offense and the need for deterrence warranted a longer sentence than what defendant proposed. View "United States v. Reif" on Justia Law

This appeal stemmed from a dispute over a business deal between Management Registry, a large Kentucky staffing company, and a smaller staffing company it acquired under the brand "AllStaff." Some of the participants then formed a rival company, A.W. Companies.The Eighth Circuit affirmed the denial of preliminary injunctive relief to Management Registry and held that the district court did not abuse its discretion by determining that Management Registry had not met its burden of showing irreparable harm. Rather, Management Registry presented evidence suggesting the opposite: that an award of money damages would fully compensate it because its losses were quantifiable. Furthermore, Management Registry also failed to establish that it was likely to succeed on the merits of the ten claims it raised. View "Management Registry, Inc. v. A.W. Companies, Inc." on Justia Law

The Eighth Circuit reversed the district court's denial of petitioner's motion to vacate his conviction under 28 U.S.C. 2255, based on the ineffective assistance of counsel under Strickland v. Washington. Taking petitioner's assertions as true, the court held that counsel provided false assurance that petitioner's conviction for robbery would not result in his removal from this country and nothing in the record contradicted petitioner's factual assertions about counsel's advice. Furthermore, petitioner showed prejudice by asserting that he would have rejected the plea and insisted on trial but for counsel's misadvice.Therefore, the court held that the record did not conclusively show that petitioner was entitled to no relief and the district court abused its discretion by denying relief without an evidentiary hearing. Accordingly, the court remanded for an evidentiary hearing. View "Dat v. United States" on Justia Law

The Eighth Circuit affirmed the district court's finding, on remand, that Dico and Titan violated the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). The court held that the clear error standard of review governed this appeal and that ample evidence supported the district court's factual findings that defendants intended to dispose the PCB contamination by selling contaminated buildings to SIM.The court affirmed the punitive damages award because it now could affirm the finding that the sale violated CERCLA. The court held that the district court properly held that Dico and Titan were jointly and severally liable for enforcement costs where defendants failed to establish that the harm was divisible. View "United States v. Dico, Inc." on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence and sentence imposed after he pleaded guilty to being a felon in possession of a firearm. The court held that police pursuit in attempting to seize defendant did not amount to a seizure within the meaning of the Fourth Amendment; the seizure of items from defendant's pockets after he was detained was not unconstitutional under the Terry stop because his flight from the officers in an area known for gun-related crime was sufficient to justify a reasonable suspicion of criminal activity. Furthermore, the stop occurred in the middle of the night and an observer had previously observed a pistol in defendant's hand.The court also held that the officers were entitled to conduct a pat down search; after the discovery of the brass knuckles, the officers had probable cause to arrest defendant for carrying a dangerous weapon under Iowa state law; the seizure of the items in defendant's pockets was lawful as a search incident to arrest; and the place where the pistol was found, a ravine beyond the property line of defendant's residence, did not implicate defendant's Fourth Amendment rights. Finally, the district court did not err by applying a four-level sentencing enhancement under USSG 2K2.1(b)(6)(B). View "United States v. Houston" on Justia Law

The Eighth Circuit reversed the district court's order vacating an arbitration award reinstating a union member to his former position without back pay after he was discharged by the company. The court held that the arbitrator was at least arguably construing the contract between the parties in making the award. In this case, the arbitrator explained at length why he interpreted the contract to allow for review of the discipline and, even if there was serious error in the analysis, the arbitrator was arguably construing the contract.Furthermore, under the arbitrator's decision, the absolute cause provision established conduct for which the company has an absolute right to impose discipline, even though it did not give the company unfettered authority to select discharge as the appropriate penalty. Accordingly, the court remanded with directions to confirm the arbitration award. View "CenterPoint Energy Resources Corp. v. Gas Workers Union" on Justia Law