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

The Bankruptcy Appellate Panel dismissed debtor's appeal of the bankruptcy court's order granting a motion for relief from the automatic bankruptcy stay filed by Deutsche Bank. The panel held that a foreclosure and sale of the property at issue rendered the issues raised on appeal moot and therefore the panel lacked jurisdiction over the appeal. View "Marshall v. Deutsche Bank National Trust Co." on Justia Law

Plaintiff appealed the district court's dismissal of her 42 U.S.C. 1983 action alleging that the City deprived her of her constitutional rights. Plaintiff's amended complaint alleged that she was arrested, her car was towed, and she was held at the police station until it was discovered that she had paid certain fines.The Eighth Circuit held that the district court erred because, whether or not the clerk had absolute or qualified immunity, that immunity did not foreclose an action against the City if the complaint adequately alleged an unconstitutional policy or custom and an unconstitutional act by the clerk as a city employee. Although the record has not been developed with respect to the clerk's duties and responsibilities, the source of the clerk's pay, or the degree that state or local officials exercised over the clerk, the court held that the complaint at least stated a plausible claim of wrongdoing. Therefore, the court remanded for further proceedings. View "Evans v. City of Helena-West Helena" on Justia Law

The Eighth Circuit affirmed the district court's denial of petitioner's second motion to vacate his mandatory minimum fifteen-year sentence under the Armed Career Criminal Act (ACCA). The court held that the new rule in Johnson v. United States, 135 S. Ct. 2551 (2015), had no nexus to this claim. Furthermore, neither Mathis v. United States, 136 S. Ct. 2243 (2016), and Descamps v. United States, 570 U.S. 254 (2013), announced a new rule of law, made retroactive to cases on collateral review by the Supreme Court. Finally, in denying petitioner's first 28 U.S.C. 2255 motion, the district court held that his three class C felony burglary convictions fell within the ACCA's enumerated offenses clause and thus he could not raise these claims again. View "Winarske v. United States" on Justia Law

Defendant appealed his sentence after pleading guilty to aiding and abetting second degree murder. The Eighth Circuit held that the government did not breach the plea agreement when it recommended a sentence within the agreed-upon range. Furthermore, the government's statement that it adopted the amended presentence investigation report that included an enhancement for obstruction of justice did not breach the plea agreement. The court held that defendant's remaining claims fell within the scope of the appeal waiver. Finally, even if the court considered the merits of defendant's alleged procedural and substantive sentencing errors, the court would affirm the district court's judgment. In this case, the district court considered the sentencing factors, issued a within-Guidelines sentence that was presumptively reasonable, and did not abuse its discretion. View "United States v. St. Pierre" on Justia Law

The District filed suit alleging that an UV System installed at one of its treatment facilities had consistently failed to function in any working capacity. The Eighth Circuit affirmed the district court's grant of summary judgment dismissing the District's claims. The court held that the breach of warranty claim was properly dismissed because the District failed to present expert testimony to establish that the UV System's ongoing operational issues were caused by equipment defects. Furthermore, the express warranty provided that the District's exclusive remedy was replacement of the defective parts, but the District did not allow Evoqua, the UV System vendor, to repair or replace the warranty items. Finally, the district court did not err by dismissing the District's claim against Travelers, the project's contractor, under its Performance and Maintenance Bond. View "Iowa Great Lakes Sanitary District v. Travelers Casualty and Surety Co." on Justia Law

Plaintiffs filed a putative class action against the City, alleging several constitutional violations under 42 U.S.C. 1983 stemming from the City's alleged detention of plaintiffs for their inability to pay traffic fines. The City subsequently sought interlocutory review of the district court's denial of the City's motion to dismiss based on sovereign immunity. The Eighth Circuit dismissed the appeal for lack of jurisdiction because the City disclaimed any sovereign immunity for itself and sought only to invoke the sovereign immunity of a nonparty. View "Fant v. City of Ferguson" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Employers in an action brought by Employers, seeking a declaratory judgment to clarify whether Hartford had a duty to pay half of the expenses related to an underlying workers' compensation claim. The court held that Hartford's purported cancellation of an insurance policy, after a workers' compensation claim had arisen, was void under Missouri law. Furthermore, assuming that Hartford properly pleaded the affirmative defense of mutual mistake, the court held that the company failed to identify any mutual mistake during the formation of the contract. View "Employers Preferred Insurance Co. v. Hartford Accident & Indemnity Co." on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence from wiretaps after he pleaded guilty to drug-related offenses. The court held that the district court did not err in granting the wiretap applications without preauthorization from the Nebraska Attorney General. The court also held that, under Nebraska law, wiretap applications do not need to be sworn under oath before submission to the Nebraska Attorney General and there was no requirement that wiretap applications be submitted to the Attorney General by the principal county attorney.The court also held that the district court did not err in finding probable cause to wiretap defendant's co-conspirators; the district court did not err in finding the probable-cause information was not stale, because the criminal activity was continuous and ongoing; and the district court did not err in finding the wiretaps were necessary, and defendant had actual notice of the wiretaps within the 90-day period set out in Nebraska law. View "United States v. Terrell" on Justia Law

Plaintiffs filed a class action against the State of Missouri and others, alleging that the state failed to meet its constitutional obligation to provide indigent defendants with meaningful representation. The Eighth Circuit reversed the district court's denial of the State and the governor's motion to dismiss based on sovereign immunity and legislative immunity.The court held that the Missouri Supreme Court would apply long-established principles to cases involving prospective equitable relief and hold that the state was immune; neither the statute nor the Missouri Constitution's general-enforcement provision make the governor an Ex parte Young defendant; to the extent plaintiffs claim that the governor's general enforcement authority and appointment authority were non-legislative acts that lead to a constitutional violation, the governor was subject to sovereign immunity for those acts because they did not satisfy Ex parte Young; and even if the governor's appropriation-reduction authority was not shielded by sovereign immunity through Ex parte Young, legislative immunity, a separate defense, foreclosed suit against the governor. View "Church v. Missouri" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to unlawful possession of ammunition as a previously convicted felon. The court held that defendant's prior Missouri drug convictions qualified as serious drug offenses under the Armed Career Criminal Act and he therefore had three prior qualifying convictions to be sentenced as an armed career criminal. The court explained that United States v. Bynum, 669 F.3d 880 (8th Cir. 2012), held that a knowing offer to sell drugs in Minnesota is a crime "involving" the distribution of drugs, because it is "related to or connected with" drug distribution. View "United States v. Hill" on Justia Law