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

COR, a securities clearing and settlement firm, filed suit against Calissio seeking to recover losses resulting from a dividend transaction that it has not already recovered in other proceedings. The Eighth Circuit affirmed the district court's grant of summary judgment dismissing all claims against SST (the transfer agent) and the Broker Defendants. The court held that the transfer agent had no knowledge of a misrepresentation in the use of a seemingly appropriate "CUSIP" number for additional shares of the same class as existing shares and the transfer agent reasonably relied on attorney opinion letters in issuing the new shares. Furthermore, COR failed to show it reasonably relied on the transfer agent's alleged misrepresentation. Accordingly, the transfer agent was entitled to judgment on plaintiff's fraudulent misrepresentation claims.The court also held that the district court properly dismissed claims against the Broker Defendants. In this case, COR has no conversion claim against the Broker Defendants, who simply acted as pass-through agents of the buyers in receiving and distributing due bill credits. Likewise, COR's unjust enrichment claim failed because the Broker Defendants received due bill credits from DTC for the benefit of their account holders and passed the benefit to their account holders without delay. View "COR Clearing, LLC v. Calissio Resources Group, Inc." on Justia Law

Hospitals challenged the method the Secretary used to calculate the volume-decrease adjustment (VDA) for certain fiscal years during the mid-2000s, as well as the Administrator's classification of certain costs as variable costs when calculating the adjustment.The Eighth Circuit affirmed the district court's decision to uphold the Secretary's actions and held that the Secretary's interpretation of the relevant regulations was a reasonable interpretation of the plain language of the Medicare statute. Given the lack of guidance in the statute and the substantial deference the court affords to the agency, the Secretary's decision reasonably complied with the mandate to provide full compensation. That the Secretary has prospectively adopted a new interpretation was not a sufficient reason to find the Secretary's prior interpretation arbitrary or capricious. The court also held that the Secretary's interpretation of the relevant regulations in these cases was clearly consistent with their text, and the costs at issue were reasonably classified as variable costs. View "Unity HealthCare v. Azar" on Justia Law

The Eighth Circuit affirmed defendant's conviction for corruptly endeavoring to obstruct and impede the due administration of the internal revenue laws, in violation of 26 U.S.C. 72121(a). After defendant's trial, the Supreme Court decided Marinello v. United States, 138 S. Ct. 1101 (2018), which held that, for a section 7212(a) offense, the government must show that there is a nexus between the defendant's conduct and a particular administrative proceeding. The government conceded that, post Marinello, the jury instruction in defendant's trial was erroneous. Nonetheless, the court held that the error was harmless because the evidence supporting the jury's verdict was so overwhelming that no rational jury could find otherwise.The court also held that the district court did not abuse its discretion in admitting expert testimony; the district court did not err in denying defendant's motion to suppress evidence obtained during a civil audit; and the district court did not err in denying defendant's motion for mistrial. View "United States v. Beckham" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment against plaintiff in a 42 U.S.C. 1983 action alleging that he was unlawfully arrested in violation of his Fourth Amendment rights. The court held that law enforcement had probable cause to arrest plaintiff where the totality of the circumstances at the time of the arrest were sufficient for the detective to believe that plaintiff had committed or was committing the offense of possessing child pornography. Therefore, the law enforcement agents were entitled to qualified immunity. Finally, because there was no constitutional violation, no municipal liability attached to the county and the city. View "Nader v. City of Papillion" on Justia Law

The Eighth Circuit reversed the district court's denial of summary judgment to the acting county sheriff and the county in an action brought by plaintiff alleging violation of her First Amendment right to intimate association. Plaintiff contended that the sheriff had terminated her based on her marriage to her husband, who had been terminated shortly before plaintiff.The court held that the sheriff's termination of plaintiff did not amount to a constitutional violation, because the fact that the marriage was a motivating factor in the decision to terminate plaintiff did not mean that the sheriff directly and substantially interfered with their marriage. In this case, the husband was terminated for sexually harassing other employees. Plaintiff was placed on administrative leave before the sheriff determined that her return would create a hostile work environment due to her loyalty to her husband. The court also held that, because the sheriff did not commit an unconstitutional act, no municipal liability attached to the county. View "Muir v. Decatur County, Iowa" on Justia Law

At issue in this appeal were the pleading requirements for a verified claim in a civil forfeiture proceeding. The Eighth Circuit previously held that a claimant who contests a forfeiture must state its interest in the disputed property "with some level of specificity," and that "a general assertion" of an interest in property is insufficient to satisfy the governing rule of procedure.The court held that the "specificity" requirement imposed by the court's prior decision was not supported by Supplemental Rule G(5), and that LNG's claim was sufficient to comply with Rule G(5). In this case, LNG satisfied the Rule G(5) requirement by stating that it was the owner of the currency at issue and it had a claim to, interest in, and right to the property. The court reasoned that, to impose a mandate that the claimant must provide more detail or specificity, such as information about how it obtained the funds at issue, would go beyond the sparse terms of the rule. Therefore, the court reversed the district court's order striking LNG's claim and remanded for further proceedings. View "United States v. LNG Express, Inc." on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to conspiracy to distribute methamphetamine. The court held that defendant's prior Illinois conviction for aggravated battery on a public way was a crime of violence. The court applied the categorical approach and held that the Illinois conviction involved causing bodily injury, which has as an element the use, attempted use, or threatened use of force. Accordingly, the district court correctly calculated defendant's offense level and defendant was a career offender under USSG 4B1.1. View "United States v. Roman" on Justia Law

Correction officers who disregard visible and self-reported symptoms medical professionals believe to be flu symptoms are not deliberately indifferent to an obvious need for immediate medical attention. The Eighth Circuit affirmed the district court's grant of summary judgment dismissing plaintiff's 42 U.S.C. 1983 claims against correctional officers, alleging that they were deliberately indifferent to his medical needs after he suffered a stroke. In this case, while the officers were less than sympathetic to plaintiff's continuing illness, they were not deliberately indifferent to an obvious need for immediate medical attention that was sufficient to establish a cognizable claim under the Eighth Amendment. View "Roberts v. Kopel" on Justia Law

Two male students filed suit against Minnesota's high school athletic league and others, alleging that the league unlawfully discriminated against them on the basis of sex through its rule prohibiting boys from participating on high school competitive dance teams. The Eighth Circuit reversed the district court's denial of the students' motion for preliminary injunction and directed the district court to enter a preliminary injunction.The court held that the heightened, likely-to-prevail standard did not apply to the boys' preliminary injunction motion, but instead, whether the boys have a fair chance of prevailing. On the merits, the court held that the boys had more than a fair chance of prevailing on the merits of their equal protection claim where the league has not asserted an exceedingly persuasive justification for keeping them from participating on high school competitive dance teams. Furthermore, the remaining Dataphase factors favored a preliminary injunction. View "D.M. v. Minnesota State High School League" on Justia Law

The Controlled Substance Analogue Enforcement Act is not unconstitutionally vague where the statute's "knowingly or intentionally" scienter requirement alleviates vagueness concerns by narrowing the scope of its prohibition, and limiting prosecutorial discretion.The Eighth Circuit affirmed Defendant Palmer and Leinicke's convictions for several conspiracy crimes related to their participation in a conspiracy to distribute synthetic narcotics. The court declined to apply the categorical approach and held that defendants failed to show that the Act was unconstitutionally vague as applied to them. Finally, the court held that the indictment alleged sufficient facts to show Palmer's knowledge that his conduct violated the Act. View "United States v. Palmer" on Justia Law