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

The Eighth Circuit affirmed defendant's conviction for various crimes related to stealing funds from a medical practice while working as a bookkeeper. The court held that the district court did not err by excluding potentially exculpatory evidence regarding the medical practice's destruction of financial records where the records were of limited probative value and the destruction of the documents also had limited probative value. View "United States v. Espejo" on Justia Law

Plaintiff filed suit against defendants under 42 U.S.C. 1983, alleging claims of false arrest, excessive force, and denial of medical care. The court affirmed the district court's judgment and held that plaintiff failed to meet his burden of showing the necessity to disqualify the entire City of Lincoln Attorney's Office and thus the district court did not abuse its discretion by denying the motion to disqualify. The court also held that the district court did not err by granting qualified immunity to the officers and rejected plaintiff's claims of evidentiary errors. In this case, the false arrest claim failed because the officers had probable cause to arrest plaintiff for obstruction of justice; there were no genuine disputes of material fact regarding the excessive force claim; and the district court correctly dismissed plaintiff's claim against one of the officers from suit for denial of medical care. View "Awnings v. Fullerton" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for the school district in an action under Section 504 of the Rehabilitation Act. The court held that, where parents refuse special education services for their child under the Individuals with Disabilities Education Act (IDEA) and bring suit under another act, they must first exhaust their administrative remedies under the IDEA if the relief they seek in the suit is also available under the IDEA. Therefore, because plaintiffs failed to exhaust their administrative remedies under the IDEA in this case, the school district was entitled to summary judgment. View "E. D. v. Palmyra R-I School District" on Justia Law

American Family filed suit seeking a declaratory judgment against Vein Centers, its insured, disputing American Family's duty to defend and indemnify Vein Centers in a class action. St. Louis was the class representative in the underlying action against Vein Centers and later joined as a defendant in the declaratory judgment action.The Eighth Circuit affirmed the district court's grant of summary judgment for American Family, holding that the district court did not err in concluding that American Family satisfied its burden of establishing the minimum amount in controversy and summary judgment was proper because St. Louis Heart failed to provide any evidence that adequate notice of the policy exclusion was not provided to Vein Centers. View "American Family Mutual Insurance Co. v. St. Louis Heart Center, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for defendants in an action alleging racial discrimination in violation of 42 U.S.C. 1981 and 1983, Title VI of the Civil Rights Act of 1964, and the Equal Protection Clause of the Fourteenth Amendment. The court held that, even assuming that plaintiff successfully stated a prima facie case of discrimination, she could not survive summary judgment because she failed to rebut the nondiscriminatory reasons defendants offered for their conduct. In this case, defendants offered legitimate, non-discriminatory reasons for the differing airport lease terms at issue where the airport needed flexibility in its redevelopment efforts, and was concerned over the physical state of plaintiff's building and whether a hobby shop was an FAA-approved aeronautical use. View "Lucke v. Solsvig" on Justia Law

The Eighth Circuit affirmed the district court's grant of qualified immunity to defendant, a jailer, in an action alleging excessive force under 42 U.S.C. 1983 and assault and battery under Iowa law. The court held that the district court did not err in determining that the jailer was entitled to qualified immunity on the excessive force claim during the booking procedure where the amount of force the jailer used was objectively reasonable in light of the need to maintain order and institutional security, and the jailer's reasonable belief that plaintiff posed a security threat. Likewise, the court held that the district court did not err in granting summary judgment on the state law claim where the amount of force was objectively reasonable. View "Parrish v. Dingman" on Justia Law

The class representative of federal securities class actions appealed the dismissal of the unsecured creditor claim and amended claim he filed in the pending Chapter 7 bankruptcy proceeding of lead class counsel, Green Jacobson, P.C. The Eighth Circuit held that the claim for the cy pres distribution was no longer an issue because the distribution had been returned by the charity and deposited with the district court clerk for ultimate distribution for the benefit of the NationsBank class; the negligent supervision claim was time-barred; the disgorgement claim was not time-barred by Missouri's five year statute of limitations; and the bankruptcy court did not err in disallowing the bankruptcy claim as premature and lacking in supporting foundation. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Oetting v. Sosne" on Justia Law

Defendant appealed his conviction and sentence for producing child pornography. The Eighth Circuit held that the district court did not err in denying defendant's request for an instruction on the lesser-included offense of possession of child pornography; the district court did not abuse its discretion when it denied defendant's motion for a mistrial where the prosecutor told the jury in closing argument that the jury was the "voice" for the victim, because the improper comments were not so prejudicial as to deprive defendant of a fair trial; but the district court erred by imposing an obstruction of justice enhancement under USSC 3C1.1. Accordingly, the court remanded for resentencing. View "United States v. Gomez-Diaz" on Justia Law

The Eighth Circuit denied a petition for review of the BIA's decision affirming the IJ's denial of petitioner's application for asylum, withholding of removal, and relief under the Convention Against Torture. Petitioner, a native and citizen of Cameroon, claimed that he was persecuted on account of his political opinion based on his membership in the Southern Cameroon National Council.The court held that there was no basis for granting the petition for review where the undisputed harm petitioner claimed to have suffered did not rise to the level of persecution; petitioner lacked a well-founded fear of future persecution; and petitioner could not meet the more rigorous burdens for CAT relief. View "Njong v. Whitaker" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for wire fraud, filing for bankruptcy for the purpose of executing a scheme to defraud, and making false statements in relation to bankruptcy proceedings. The court rejected defendant's contention that the district court erred in denying his pretrial motion to sever the wire fraud counts from the bankruptcy-related counts, and held that joinder was appropriate here because the offenses were all connected to the common scheme. The court also held that the district court did not abuse its discretion in refusing to sever counts for trial under Federal Rule of Criminal Procedure 14; the convictions were supported by sufficient evidence; the district court did not abuse its discretion in denying defendant's post-trial motions to continue sentence and dismiss the superseding indictment; and the district court did not abuse its discretion by imposing sentencing enhancements for the amount of loss, use of sophisticated means, and abuse of a position of trust. View "United States v. Reichel" on Justia Law