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

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to being a felon in possession of a firearm. The court held that the district court did not err in determining that defendant committed the Iowa felony of harboring a runaway; in imposing a four-level enhancement under U.S.S.G. 2K2.1(b)(6)(B) where he used his firearm to facilitate the Iowa felony; and in imposing an upward variance based on defendant's extensive criminal history and the need to protect the public. View "United States v. Mathis" on Justia Law

The Eighth Circuit affirmed defendant's conviction of possession of a firearm by an alien unlawfully in the United States after having been previously convicted of a misdemeanor crime of domestic violence. The court held that, although defendant should have been allowed to introduce an officer's testimony regarding her conversation with defendant's wife for impeachment purposes, the district court's error was harmless because the government introduced substantial evidence of defendant's guilt. The court also held that there was no prosecutorial misconduct where there was no improper burden shifting during closing arguments. View "United States v. Naholi" on Justia Law

The Eighth Circuit denied a petition for review of the USDA's 2017 orders withdrawing an interim final rule and two proposed regulations promulgated under the Packers and Stockyards Act (PSA). The court held that the USDA actions were not arbitrary nor capricious where the USDA provided legitimate regulatory and substantive concerns. In this case, the USDA explained that it was withdrawing the interim final rule and taking no further action on the proposed regulations because the proposed regulatory change of course would generate protracted litigation, adopt vague and ambiguous terms, and might prevent innovation and foster vertical integration that would hinder new market entrants. The court held that the USDA did not unlawfully withhold action by failing to comply with an absolute congressional deadline in Section 11006 of the 2008 Farm Bill. View "Organization for Competitive Markets v. U.S. Department of Agriculture" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of Hargis in an action brought by B&B, alleging a trademark infringement claim involving B&B's SEALTIGHT mark and Hargis' SEALTITE mark. The court found no plain error in the district court's determination that B&B willfully failed to disclose a prior adverse decision and thus the district court did not err in its determination that B&B committed fraud on the PTO and that Hargis was therefore entitled to the affirmative defense of fraud under 15 U.S.C. 1115(b)(1). The court also held that B&B's claims were barred by collateral estoppel because B&B failed to present evidence of any significant intervening factual change from the date of the 2000 jury verdict. In regard to Hargis' cross-appeal, the court affirmed the district court's denial of Hargis' motion for attorney fees and nontaxable litigation costs. The court held that the district court did not abuse its discretion in finding this an unexceptional case. View "B&B Hardware, Inc. v. Hargis Industries, Inc." on Justia Law

The Eighth Circuit reversed and remanded the district court's denial of disability insurance benefits and supplemental security income to plaintiff. The court held that the ALJ failed to provide a good reason for disregarding the treating physician's opinion when, after noting that the patient's subjective complaints formed the basis for the doctor's opinion, the ALJ stated only that she declined to accept portions of the treating physician's functional capacities assessment. View "Walker v. Commissioner, Social Security Administration" on Justia Law

The Eighth Circuit affirmed defendant's sentence after she pleaded guilty to second degree murder. The court held that the district court clearly considered potential sentence disparity and weighed the 18 U.S.C. 3553(a) factors in justifying the sentence imposed in light of the seriousness of the offense. In this case, the district court considered defendant's need for treatment, the interest in deterring similar criminal conduct, and the need to protect the public from further crimes. Therefore, the district court did not abuse its discretion in varying upward. View "United States v. Wisecarver" on Justia Law

The district court affirmed the denial of social security disability benefits to claimant, holding that substantial evidence supported the ALJ's finding that claimant had the residual functional capacity to perform sedentary work. In this case, the ALJ did not err by discounting the treating physician's opinions because they conflicted with claimant's treatment records. View "Adkins v. Commissioner, Social Security Administration" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Cargill in an action alleging that the company discriminated against a former employee in violation of the Americans with Disabilities Act (ADA) and the Iowa Civil Rights Act (ICRA). The court held that plaintiff failed to present direct and indirect evidence of disability discrimination; plaintiff was not a qualified individual protected by the ADA because she failed to demonstrate that at the time of her termination she could regularly and reliably attend work, an essential function of her employment; and the ADA's protections did not extend to providing plaintiff with her desired accommodation of more time off following her 194 days of unplanned absences. View "Lipp v. Cargill Meat Solutions Corp." on Justia Law

Plaintiff filed suit against his former employer for race and age discrimination under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act (ADEA), the Arkansas Civil Rights Act, and for promissory estoppel. The Eighth Circuit affirmed the district court's grant of the company's motion to strike portions of plaintiff's statement of material disputed facts and grant of summary judgment.The court held that the district court did not abuse its discretion in striking paragraphs of plaintiff's statement of material fact as unsupported by the record or irrelevant and immaterial; the district court properly granted the employer summary judgment on claims arising more than 180 days before plaintiff filed his EEOC charges; the district court properly granted the employer summary judgment on the failure to rehire claim because plaintiff took no action, never applied for reemployment, and believed he could not perform the duties of the position; the Arkansas Civil Rights Act claims were time-barred; and there was no factual basis for the promissory estoppel claim. View "Kirklin v. Joshen Paper & Packaging of Arkansas Co." on Justia Law

The Eighth Circuit affirmed defendant's conviction for one count of sex trafficking of a minor under the age of 18, one count of sex trafficking of a minor under the age of 14, and three counts of distribution of crack cocaine to a person under the age of 21. The court held that the district court did not err in limiting defendant's cross-examination of one of the victims; in excluding evidence under Federal Rule of Evidence 412 that the victims of defendant's sex trafficking continued to exchange sex for crack after his arrest, because defendant failed to give notice of his intent to introduce the evidence and the evidence was inadmissible as irrelevant; and there was no error in admitting other bad acts evidence. View "United States v. Betts" on Justia Law