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

The Eighth Circuit affirmed defendant's conviction and sentence for receipt of visual depictions of minors engaging in sexually explicit conduct and possession of child pornography. The court held that the evidence was sufficient to convict defendant of the crimes; the jury instructions and the verdict form did not violate defendant's Sixth Amendment right to a unanimous verdict; defendant's rights under the Double Jeopardy Clause were not violated when the district court instructed the jury on knowing receipt and possession of child pornography based on the same facts where the knowing possession charged was not a lesser included offense of knowing receipt as charged; and the district court did not err by imposing a two-level sentencing enhancement for knowing distribution. View "United States v. Smith" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after he pleaded guilty to being a felon in possession of a firearm. The court held that the officer had reasonable suspicion that criminal activity was afoot when he personally observed defendant place the gun in his waistband; the Supreme Court has already authorized police officers to frisk a suspect reasonably believed to be armed even where it could be that the suspect possesses the arms legally; and the frisk was not unreasonable even if defendant had been handcuffed because the handcuffs did not limit a person's ability to perform harmful acts. View "United States v. Pope" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Allina in an action brought by a former employer under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA), after she was terminated for refusing to fulfill a job requirement that she take necessary steps to develop immunity to rubella. The court held that, although the district court erred in denying plaintiff's inquiry claim based on a lack of injury, summary judgment was proper where Allina's decision to require employees with client contact to complete an inquiry and exam was job-related, consistent with business necessity, and no more intrusive than necessary. Therefore, the health screening that plaintiff was required to take as a condition of her employment complied with the ADA and the MHRAThe court also held that the evidence was insufficient to support plaintiff's claim that she was disabled under the ADA where the evidence was insufficient to support the conclusion that plaintiff's chemical sensitivities or allergies substantially or materially limited her ability to perform major life activities. Therefore, plaintiff's failure to accommodate claim failed. Likewise, her retaliation claim failed. View "Hustvet v. Allina Health System" on Justia Law

The Bankruptcy Appellate Panel dismissed appellants' appeal of the bankruptcy court's denial of their "Amended Motion for Determination that Confirmation Order Does Not Bar a State Court Action Relating to the Springfield, Illinois Coal Contract." The panel held that the bankruptcy court's order was not final, and thus the panel did not have jurisdiction to review it. In this case, the bankruptcy court did not direct entry of a final judgment or expressly determine there was no just reason for delay in entering a final judgment. View "Frakes v. Arch Coal, Inc." on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence after he conditionally pleaded guilty to being an unlawful user of a controlled substance in possession of a firearm. The court held that law enforcement officers had reasonable suspicion to conduct a Terry stop after they observed defendant loitering with known gang members and engaging in suspected criminal activity. Although the court disregarded part of an officer's testimony as incredible and implausible, there was nonetheless sufficient evidence to demonstrate that officers had probable cause to arrest defendant for illegally possessing a firearm. In this case, a reasonable officer could believe that defendant looked under 21 years old and the gun had been concealed prior to him discarding it. View "United States v. Polite" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Proctor and Gamble in an action brought by an employee under the Employee Retirement Income Security Act (ERISA) after his disability benefits were terminated. The court held that plaintiff possessed the information necessary to litigate his claim and was thus not prejudiced by any procedural irregularities; the company did not abuse its discretion in denying plaintiff's claim for benefits where the denial letter adequately stated the reasons for supporting its decision; and the company's interpretation of the plan was reasonable and there was substantial evidence to support its decision. The court held that plaintiff's remaining claims were unavailing and the district court did not abuse its discretion by denying plaintiff's request for statutory penalties. View "Leirer v. Procter & Gamble Disability Benefit Plan" on Justia Law

The Eighth Circuit denied a petition for review of the BIA's decision denying petitioner's motion to reconsider the BIA's previous order denying him a discretionary adjustment of status. The court noted that it had jurisdiction to review the petition for abuse of discretion. The court held that the district court did not abuse its discretion in denying the motion for reconsideration. In this case, the BIA satisfied its obligation to provide a "rational explanation" for its original decision to deny petitioner relief when it denied his motion to reconsider. In this case, the BIA's explanation that it did not violate the clear error standard of review in its weighing of the attempted suicide of one of petitioner's victims qualified as a "rational explanation." View "Camacho v. Whitaker" on Justia Law

The Eighth Circuit affirmed the district court's grant of Twin City's cross-motion for summary judgment, finding that Twin City did not owe Robert Mau or EWS a duty to defend under a Twin City insurance policy. Applying North Dakota law, the court held that Twin City owed no duty to defend Mau in his capacity as director and officer of MW because no claims were brought against him in that capacity and, in any event, the dual service exclusion applied. The court also held that Twin City did not owe a duty to defend EWS where the claims against it for breach of contract and fraud are based upon the Asset Purchase Agreement and liability could not have been incurred in absence of the Agreement. Furthermore, even if EWS's arguments had some validity, the contract exclusion would apply to any resulting liability. View "Mau v. Twin City Fire Insurance Co." on Justia Law

Plaintiffs sought class certification for their claims alleging that the MDOC and other related defendants violated the Eighth Amendment and Title II of the Americans with Disabilities Act (ADA) by providing inadequate medical screening and care for chronic Hepatitis C (HCV) viral infections. Plaintiffs alleged that the MDOC's policies exposed the class to a substantial risk of serious harm.The Eighth Circuit affirmed the district court's grant of class certification, holding that the evidence was sufficient to permit the district court to conduct a rigorous analysis into class certification; the numerosity, commonality, and typicality requirements were met in light of the prospective injunctive and declaratory relief sought; and sufficient evidence of a common policy existed to comply with Rule 23(b)(2). Finally, the court noted that federalism concerns could be considered after the district court imposed an equitable remedy if applicable, and ADA-reated arguments did not relate to the class certification. View "Postawko v. Missouri Department of Corrections" on Justia Law

The Eighth Circuit affirmed the district court's order certifying a class of Arkansas homeowners who alleged that State Farm improperly withheld amounts for labor depreciation when making payments under their insurance policies. The court held that the district court did not abuse its discretion by concluding that plaintiffs' claims shared a common, predominating question of law. In this case, plaintiffs' theory was that State Farm violated its contractual obligations by depreciating both materials and labor when calculating ACV, thereby reducing the size of their ACV payments.The court also held that the district court properly noted that the class members' claims were generally small and unlikely to be pursued individually; that concentrating the claims in a single forum was desirable; and that it did not anticipate unreasonable difficulty in managing the class action. The court explained that the fact that some plaintiffs may be unable to succeed on their claims did not necessarily mean that they lack standing to sue. Finally, the court modified the certification order to exclude those subject to another settlement from the class definition. View "Stuart v. State Farm Fire and Casualty Co." on Justia Law