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

Sandra Jones, representing the estate of her deceased son Antonio Jones, filed a lawsuit under 42 U.S.C. § 1983 and Arkansas state law against Faulkner County, Arkansas, and jail officials Garry Stewart, Karen Grant, and Leanne Dixon. She claimed that the officials exhibited deliberate indifference to Antonio’s serious medical needs, violating his Fourteenth Amendment rights, and that Stewart committed medical malpractice. Jones also alleged that Faulkner County’s policies contributed to Antonio’s death.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The court found that the jail officials were not deliberately indifferent to Antonio’s medical needs and that Jones could not establish a medical malpractice claim against Stewart due to the absence of a doctor-patient relationship. The court also dismissed the municipal liability claim against Faulkner County, concluding that no jail policy caused Antonio’s death.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the actions taken by Grant and Dixon did not constitute deliberate indifference. Grant responded to Antonio’s symptoms by placing him on a medical watch and took appropriate actions based on the information available to her at the time. Dixon, who was not a medical professional, followed her superior’s instructions and did not disregard any substantial risk of harm. The court also affirmed the dismissal of the municipal liability claim, as there was no constitutional violation by the county employees. Lastly, the court found no abuse of discretion in the district court’s exercise of supplemental jurisdiction over the state law claim against Stewart. View "Jones v. Faulkner County, Arkansas" on Justia Law

Bob Robison Commercial Flooring Inc. (BRCF) was hired to install a vinyl gym floor at a middle school in Trumann, Arkansas. BRCF subcontracted the painting of volleyball and basketball lines to Robert Liles Parking Lot Services (Liles). Liles's work was faulty, leading to the rejection of the gym floor. BRCF had to remove and replace the floor, incurring a cost of $181,415.39. BRCF submitted a claim to RLI Insurance Company (RLI) under its builder’s risk policy, which RLI denied, citing an exclusion for losses caused by workmanship errors.BRCF filed a lawsuit in state court for declaratory judgment and breach-of-contract damages. RLI removed the case to the United States District Court for the Eastern District of Arkansas. The district court denied RLI’s motion to dismiss, finding that BRCF had stated plausible claims. However, after limited discovery, the district court granted RLI’s motion for summary judgment, concluding that the policy unambiguously excluded coverage for damage resulting from defective workmanship.The United States Court of Appeals for the Eighth Circuit reviewed the case. BRCF argued that the policy’s ensuing loss clause should restore coverage for the replacement cost of the vinyl gym floor. The Eighth Circuit affirmed the district court’s decision, holding that the policy was not ambiguous and that the ensuing loss clause did not apply because the damage was solely caused by the excluded peril of faulty workmanship. The court concluded that BRCF failed to identify a separate covered peril that would trigger the ensuing loss clause, and thus, the entire loss was excluded from coverage. View "Bob Robison Commercial Floor v. RLI Insurance Company" on Justia Law

James M. Saylor, an inmate, sued the Director of Nebraska’s Department of Correctional Services, alleging deprivation of accommodations, unlawful placement in solitary confinement, and discrimination based on his disability (PTSD). Saylor had previously been assaulted by other inmates in 2002, leading to his PTSD diagnosis. He had won a $250,000 judgment in 2010 for the Department's failure to prevent the attack and provide adequate care. Saylor had filed multiple lawsuits in federal and state courts regarding his confinement conditions, all of which were dismissed.The United States District Court for the District of Nebraska dismissed Saylor's current complaint, concluding that his claims were barred by res judicata. Saylor argued that his claims were based on new facts occurring after his previous lawsuits, specifically the rescission of accommodations and his placement in solitary confinement in 2018.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's dismissal. The court held that Saylor's claims were barred by res judicata because they arose from the same nucleus of operative facts as his previous lawsuits. The court noted that Saylor's proposed amended complaint in his earlier federal case (Saylor I) included an ADA claim based on the same facts, and thus, he could have brought the ADA claim at that time. The court also found that Saylor's new allegations did not constitute new specific discriminatory events but were merely additional evidence of the same ongoing issues.The court further held that the district court did not abuse its discretion in denying Saylor's motions for an extension of time to amend the complaint, to alter or amend the judgment, and for leave to file a third amended complaint, as these motions were either procedurally deficient or futile. The judgment of the district court was affirmed. View "Saylor v. Jeffreys" on Justia Law

Najawaun Quinn, Dimetri Smith, and three others were charged with 18 counts of racketeering and firearm offenses related to their association with the Savage Life Boys Gang (SLB Gang) in Davenport, Iowa. The other three defendants pleaded guilty. After a trial, Quinn was found guilty of assault with a dangerous weapon in aid of racketeering, use of a firearm in relation to a crime of violence, and being a felon in possession of a firearm or ammunition. Smith was found guilty of two counts of assault with a dangerous weapon in aid of racketeering and two counts of use of a firearm in relation to a crime of violence. The district court denied their motions for judgment of acquittal.The United States District Court for the Southern District of Iowa reviewed the case and found no reversible error. The court held that the SLB Gang constituted an "enterprise" under the racketeering statute, as it had a common purpose, relationships among members, and sufficient longevity. The court also found that Quinn and Smith committed the violent assaults to maintain or increase their positions within the gang. The court rejected the argument that the SLB Gang lacked the necessary structure to be considered an enterprise.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that the evidence was sufficient to prove that the SLB Gang was an enterprise engaged in racketeering activity and that Quinn and Smith committed the violent assaults to maintain or increase their positions within the gang. The court also upheld the jury instructions and sentencing decisions, finding no abuse of discretion or plain error. The court concluded that the district court's factual determinations were supported by the evidence and that the defendants were not entitled to a reduction for acceptance of responsibility. View "United States v. Quinn" on Justia Law

A native and citizen of Mexico, Lilia Salinas, who became a lawful permanent resident of the United States in 2007, was convicted in North Dakota state court in 2011 for possession of marijuana with intent to deliver. She received a suspended sentence of 360 days’ imprisonment. In 2021, she was convicted again in North Dakota state court for two counts of aggravated assault of a victim under 12 years of age, receiving a 10-year sentence with one year suspended. Based on these convictions, the Department of Homeland Security initiated removal proceedings against her in 2022, charging her with removability under 8 U.S.C. § 1227(a)(2)(B)(i) for a controlled substance violation and 8 U.S.C. § 1227(a)(2)(E)(i) for a crime of child abuse.An immigration judge (IJ) found Salinas removable under both charges, applying the categorical approach to determine that her marijuana conviction qualified as a controlled substance offense under federal law. The IJ compared the North Dakota definition of marijuana at the time of her conviction with the federal definition in effect at that time, concluding they were substantially similar. The IJ also pretermitted her application for cancellation of removal, as her 2011 conviction stopped the clock on her period of continuous residence, making her ineligible for relief.Salinas appealed to the Board of Immigration Appeals (BIA), arguing that the IJ should have compared the state statute to the federal definition in effect at the time of her removal proceedings. The BIA affirmed the IJ’s decision, agreeing that the appropriate comparison was with the federal definition at the time of conviction and that the state and federal definitions were a categorical match.The United States Court of Appeals for the Eighth Circuit reviewed the case and upheld the BIA’s decision. The court held that the proper comparison for determining removability under § 1227(a)(2)(B)(i) is between the state statute at the time of conviction and the federal Controlled Substances Act in effect at that time. The court also rejected Salinas’s argument that the North Dakota definition of marijuana was overbroad compared to the federal definition. Consequently, the petition for review was denied. View "Salinas v. Bondi" on Justia Law

Roberto Williams was convicted by a jury of two counts of being a felon in possession of a firearm, in violation of federal law. The charges stemmed from two separate incidents. In the first incident, on July 31, 2020, St. Cloud police officers stopped a car in which Williams was a passenger and found a handgun in the glove compartment. In the second incident, on November 13, 2020, after a fatal shooting involving Williams's fiancée's son, police found two firearms in a garbage bin outside Williams's home.The United States District Court for the District of Minnesota denied Williams's pretrial motions to suppress evidence obtained during the July 31 stop and from a warrant search of his cell phone. The court also denied his motion to exclude evidence of five prior Illinois convictions, which Williams argued were invalid and could not serve as predicates for the felon-in-possession charges. Williams was sentenced to concurrent 120-month sentences on each count.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's denial of Williams's motion to suppress evidence from the July 31 stop, concluding that the stop was supported by reasonable suspicion. The court also upheld the denial of the motion to suppress evidence from the cell phone search, applying the Leon good faith exception. Additionally, the court rejected Williams's argument that his prior Illinois convictions were invalid, holding that his motion was an impermissible collateral attack on the state convictions, which had not been vacated by an Illinois court.The Eighth Circuit affirmed the district court's judgment, maintaining Williams's convictions and sentences. View "United States v. Williams" on Justia Law

Pollyann Sorcan, a member of the Rock Ridge School District board, was excluded from committee assignments and meetings by the board. The board alleged that Sorcan undermined the District’s mission and violated policies and data privacy laws. Sorcan filed a 42 U.S.C. § 1983 action against the District and Bill Addy, the board chair, claiming retaliation for her protected speech under the First Amendment.The United States District Court for the District of Minnesota dismissed Sorcan’s case. The court concluded that Addy was entitled to legislative immunity and that Sorcan failed to state a claim against the District under Monell v. Department of Social Services, 436 U.S. 658 (1978). The court found that Sorcan did not identify a persistent pattern of unconstitutional behavior by the District.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Addy, sued in his official capacity, was not entitled to legislative immunity because such immunity does not extend to local officials in their official capacities. The court also found that the district court erred in requiring Sorcan to identify a persistent pattern of unconstitutional misconduct. Instead, a single decision by authorized decisionmakers can represent an official policy under Monell. The court reversed the district court’s dismissal and remanded the case for further proceedings. View "Sorcan v. Rock Ridge School District" on Justia Law

Dontavius R. Sharkey was convicted by a jury of two counts of felon in possession of a firearm and two counts of a straw-purchasing conspiracy. The district court sentenced him to 360 months in prison. Sharkey appealed his conviction and sentence, arguing that the statutes under which he was convicted were unconstitutional and that the district court improperly used acquitted conduct to enhance his sentence.The United States District Court for the Southern District of Iowa found Sharkey's acquitted conduct proven by a preponderance of the evidence and used it to increase his Guidelines range. Sharkey's arguments against the constitutionality of 18 U.S.C. § 922(g)(1) and the use of acquitted conduct were rejected based on existing precedent. The district court also applied enhancements for using a firearm in connection with another felony and for his role as an organizer in the criminal activity.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The court held that Sharkey's constitutional challenges were foreclosed by precedent, specifically citing United States v. Jackson. The court also upheld the use of acquitted conduct in sentencing, referencing United States v. Watts and United States v. Bullock. Additionally, the court found no procedural error in the application of the Guidelines enhancements and determined that the district court did not abuse its discretion in imposing an above-Guidelines sentence. The court concluded that the district court properly considered the relevant factors and did not give undue weight to any improper or irrelevant factors. View "United States v. Sharkey" on Justia Law

Robert Peck, Jr. entered a conditional guilty plea to charges of possession with intent to distribute marijuana and possession of a firearm after a felony conviction. He reserved the right to appeal the denial of his motions to suppress evidence and to dismiss one of the charges. The case arose from an investigation in July 2020, where officers, acting on anonymous tips, used a drug-sniffing dog to detect drugs outside Peck's apartment. Based on the dog's alert, they obtained a warrant and found drugs and firearms in Peck's apartment.The United States District Court for the District of Nebraska denied Peck's motions to suppress the evidence obtained from his apartment and cell phone, as well as his motion to dismiss the firearm possession charge. The court ruled that the officers did not trespass on Peck's curtilage and that the good-faith exception to the exclusionary rule applied. The court also found that applying the firearm possession statute to Peck did not violate the Second Amendment, despite his prior nonviolent drug conviction.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the good-faith exception applied, as the officers reasonably relied on existing precedent when using the drug-sniffing dog. The court also upheld the constitutionality of the firearm possession statute as applied to Peck, citing precedent that supports prohibiting firearm possession by individuals with felony convictions, regardless of the nature of the prior offense. View "United States v. Peck" on Justia Law

Joe May was indicted for conspiracy to commit wire fraud, mail fraud, and violations of the Anti-Kickback statute, among other charges, related to defrauding TRICARE. May, a medical doctor, was recruited to sign prescriptions for compounded drugs without evaluating patients. He signed 226 prescriptions, mostly without determining medical necessity. May received cash payments for his participation. When investigated, May created false medical records and lied to the FBI.The United States District Court for the Eastern District of Arkansas convicted May on all counts and sentenced him to 102 months imprisonment, ordering restitution of over $4.6 million. May appealed, challenging the admission of business records, limitations on cross-examination, jury instructions, the government's closing argument, and the sufficiency of evidence for certain charges.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no abuse of discretion in admitting business records or limiting cross-examination. The court upheld the jury instructions and found no error in the government's closing argument. The court determined there was sufficient evidence for the conspiracy, mail fraud, and kickback charges. However, the court found plain error in one count of aggravated identity theft related to Perry Patterson, as the jury was not instructed on the correct underlying offense.The Eighth Circuit reversed the conviction on the aggravated identity theft count related to Patterson, remanded to vacate the special assessment for that count, and affirmed all other aspects of the case. View "United States v. May" on Justia Law