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

Judy Brown, a biracial woman, was hired by Conagra Brands, Inc. in October 1997. After a workplace injury in 2015, she became disabled and filed a workers' compensation claim in 2017. Conagra temporarily transferred her to a different position as an accommodation and continued paying her at the higher rate until July 2020, when her work restrictions became permanent, and her pay was reduced. Following the death of a colleague, Conagra posted job openings, and Brown applied for a position but was not selected. She was assigned to less favorable shifts and subsequently filed discrimination charges. Brown was fired in December 2021 and sued Conagra, alleging race and disability discrimination, retaliation, and violation of Nebraska common law.The United States District Court for the District of Nebraska granted Conagra’s motion to dismiss for failure to state a claim. Brown did not challenge the district court’s finding that her race and disability discrimination claims based on the July 2020 pay reduction were time-barred.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The court affirmed the dismissal, finding that Brown failed to plead sufficient facts to support her claims. Specifically, she did not provide enough details to infer race discrimination, did not plausibly allege a disability under the ADA or NFEPA, and did not establish a causal connection for her retaliation claims. Additionally, the court found that Brown did not state a plausible claim for common law unlawful retaliation, as she did not allege any immediate precipitating events or facts that could infer a causal nexus between her workers' compensation claim and the adverse employment actions. View "Brown v. Conagra Brands, Inc." on Justia Law

Plaintiffs Tiffaney Whitt, on behalf of her minor children, and Jeremiah Parker, Whitt’s adult son, filed a lawsuit against Kearney School District and Durham School Services, L.P., due to racial harassment experienced by Parker and his siblings on a school bus operated by Durham. Plaintiffs alleged a 42 U.S.C. § 1981 claim against Durham, asserting they were third-party beneficiaries of the contract between Kearney and Durham, which required safe, harassment-free transportation.The United States District Court for the Western District of Missouri denied Durham’s motion to dismiss and motion for summary judgment, which challenged the validity of Plaintiffs’ § 1981 claim. Durham then filed a motion to compel arbitration based on an arbitration clause in its contract with Kearney. The district court denied this motion, concluding that Durham waived its right to enforce the arbitration clause by not raising it earlier in the litigation. Durham appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Durham knew of its right to arbitrate, as it possessed the contract containing the arbitration clause, and acted inconsistently with that right by engaging in extensive litigation and discovery before filing the motion to compel arbitration. The court also noted that the district court’s consideration of prejudice to Plaintiffs, although erroneous, did not affect the substantial rights of the parties. The appellate court rejected Durham’s argument that it could not have known to seek arbitration until the district court’s summary judgment ruling and found that Durham’s actions were inconsistent with preserving its right to arbitrate. The court also denied Plaintiffs’ request to adopt a process for certifying interlocutory appeals as frivolous and their request for costs under Fed. R. App. P. 38. View "Parker v. Durham School Services, L.P." on Justia Law

Mohammad Al Sharairei and his wife owned and operated Puff N Stuff II, a shop in Cedar Rapids, Iowa, which sold various products, including synthetic cannabinoids labeled as "potpourri" and "incense." In May 2013, law enforcement conducted an undercover purchase at the store, and subsequent testing revealed the presence of synthetic cannabinoids. A search warrant executed in June 2013 led to the seizure of products and sales records indicating that synthetic cannabinoids constituted a significant portion of the store's revenue. Al Sharairei admitted to being a major seller of these products and described methods to avoid law enforcement detection.The government charged Al Sharairei with maintaining a premises for the distribution of controlled substance analogues and conspiracy to distribute controlled substance analogues. After failing to appear for a scheduled guilty plea hearing, Al Sharairei absconded and was later extradited from Brazil. In September 2022, a jury convicted him on both counts, and the district court sentenced him to 240 months in prison and ordered a forfeiture of $425,000.The United States Court of Appeals for the Eighth Circuit reviewed the case. Al Sharairei challenged the district court's willful blindness instruction, the sufficiency of the evidence, the denial of his motion for a new trial, the forfeiture order, and the calculation of his advisory Guidelines range. The Eighth Circuit held that the willful blindness instruction was appropriate, as the evidence supported an inference that Al Sharairei was aware of the high probability that the substances were controlled and took deliberate actions to avoid learning the facts. The court also found sufficient evidence to support the jury's verdict and upheld the district court's decisions on the forfeiture order and sentencing enhancements. The judgment of the district court was affirmed in all respects. View "United States v. Sharairei" on Justia Law

Barton Hankins was hired by Crain Automotive Holdings, LLC in 2019 as Chief Operating Officer and was offered a deferred compensation plan (DCP). After four years, Hankins resigned and sought compensation under the DCP, which Crain denied. Hankins then filed a lawsuit under the Employee Income Retirement Security Act of 1974 (ERISA) to claim his benefits. The DCP stipulated that Hankins could earn a percentage of Crain’s fair market value upon his exit, with full vesting at five years. Having served four years, Hankins was entitled to 80% of the benefits.The United States District Court for the Eastern District of Arkansas granted judgment in favor of Hankins, concluding that the DCP did not require the creation of an Employment Agreement or a Confidentiality, Noncompete, and Nonsolicitation Agreement for enforceability. The court found that Crain’s claims of misconduct by Hankins were unsubstantiated and awarded Hankins attorney’s fees, determining that Crain’s conduct was sufficiently culpable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s judgment, holding that Crain’s interpretation of the DCP was unreasonable. The court found that the DCP’s Article 4, which mentioned the Employment and Confidentiality Agreements, did not create a condition precedent but rather a condition subsequent. The court also upheld the award of attorney’s fees, noting that Crain’s actions lacked merit and were raised only after Hankins sought his vested compensation. The appellate court concluded that the district court did not abuse its discretion in its rulings. View "Hankins v. Crain Automotive Holdings, LLC" on Justia Law

Jaylyn McGhee was involved in a shooting outside his home in Davenport, Iowa, where his six-year-old son was injured. Law enforcement responded to the scene and found shell casings, suspected narcotics, and money outside McGhee's house. Officers observed blood spatter and a powdery substance on the deck and stairs leading to a side door of the house. Based on these observations, they obtained a search warrant and found drugs and firearms inside McGhee's home. McGhee was charged with drug and firearm offenses, pled guilty, and was sentenced to 60 months in prison and 3 years of supervised release.The United States District Court for the Southern District of Iowa denied McGhee's motion to suppress the evidence found in his home, ruling that the officers' observations from the front yard were lawful and that exigent circumstances justified their entry into the side yard. The court also applied a four-level sentencing enhancement for possessing a firearm in connection with drug trafficking, based on evidence from controlled buys and the proximity of the drugs and firearms found in McGhee's home.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's denial of the motion to suppress, agreeing that the officers' initial observations were lawful and that exigent circumstances justified their further actions. The court also upheld the sentencing enhancement, finding that the district court did not err in relying on the commentary to the Sentencing Guidelines and that the evidence supported the connection between the firearms and drug trafficking. The judgment of the district court was affirmed. View "United States v. McGhee" on Justia Law

Deidre Parker, a black woman, was employed as a Program Management Assistant by the Risk Management Agency (RMA) of the USDA starting in March 2011. She filed an EEOC complaint in 2013, which was settled in 2015. Parker alleged that after the settlement, she experienced race and gender discrimination, retaliation, constructive discharge, and a hostile work environment. Her duties diminished after a change in the timekeeping system, and she was tasked with cleaning out file cabinets. She requested additional work and development opportunities but did not act on them. Parker received two letters of counseling for disruptive conduct and filed EEOC complaints in 2017 and 2018, alleging discrimination and retaliation.The United States District Court for the Western District of Missouri granted summary judgment in favor of the USDA on all counts. The court limited its review to events occurring after the 2015 settlement agreement, finding that Parker had waived claims arising before that date. The court found that Parker failed to establish a prima facie case of discrimination or retaliation under the McDonnell Douglas framework, as most of the conduct did not constitute an adverse employment action, and there was no evidence supporting an inference of discrimination. Her hostile work environment claims failed due to a lack of causal link between the USDA’s conduct and her race or gender, and her constructive discharge claim failed because she did not prove that her workplace was intolerable or that the USDA intended for her to quit.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that the district court did not abuse its discretion in limiting the scope of Parker’s claims to conduct occurring after the settlement agreement. The court also found that Parker failed to demonstrate a causal nexus between the alleged adverse actions and her race or gender, and that her claims of hostile work environment, constructive discharge, and retaliation were unsupported by sufficient evidence. View "Parker v. United States" on Justia Law

Donglan Xia, a U.S. citizen, filed a Form I-130 Petition for Alien Relative on behalf of her adopted nephew, Tian "Tim" Xia, who was born in China and entered the U.S. on a temporary visitor visa in 2011. Tim's parents relinquished their parental rights, and Xia adopted him in 2012. Xia filed the I-130 petition in 2018 to classify Tim as an immediate relative for preferential immigration status. USCIS denied the petition, stating Xia did not prove Tim's adoption fell outside the Hague Adoption Convention, that Tim did not enter the U.S. for adoption, or that Tim had compelling ties to the U.S. before his adoption.The Board of Immigration Appeals (BIA) dismissed Xia's appeal, agreeing with USCIS that Xia failed to show Tim's adoption was outside the Hague Adoption Convention and that Tim had not established compelling ties to the U.S. before his adoption. The BIA noted Tim's activities in the U.S. but concluded they did not demonstrate habitual residence. Xia sought judicial review, and the district court granted summary judgment in favor of the government, finding substantial evidence supported the BIA's decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and found the BIA's decision lacked sufficient reasoning for meaningful judicial review. The court noted the BIA did not explain which specific facts and circumstances it considered or how they negated Tim's documented connections to the U.S. The Eighth Circuit reversed the district court's judgment and remanded the case to the BIA for further proceedings, requiring a more detailed explanation of the BIA's decision regarding Tim's habitual residence and ties to the U.S. View "Xia v. Scott" on Justia Law

Dewey Austin Barnett, II, acting pro se, sued a Missouri county and a jail administrator, Brenda Short, alleging that they refused to allow him to have a Bible while he was in administrative segregation at the Jefferson County jail. Barnett claimed that the lack of a Bible caused him anxiety, stress, and depression, and led him to feel guilt and shame. He sought damages and injunctive relief. Barnett attached a grievance and a letter to his complaint, detailing his requests for a Bible and the jail's responses.The United States District Court for the Eastern District of Missouri dismissed Barnett's case. The court held that Barnett's RLUIPA claim could not succeed because RLUIPA does not permit plaintiffs to recover money damages, and his request for injunctive relief was moot due to his transfer to another facility. The court also dismissed Barnett's § 1983 claim, stating that he did not adequately plead Short's personal involvement in the decision to deprive him of his Bible and that the decision did not substantially burden his free exercise of religion. Additionally, the court dismissed the § 1983 claim against the county, explaining that Barnett failed to allege a policy of denying Bibles to inmates in administrative segregation.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed in part and reversed in part. The court held that RLUIPA permits claims for damages against the county, as "appropriate relief" includes damages. However, the court concluded that RLUIPA does not allow claims for damages against individuals in their personal capacities. The court also found that Barnett sufficiently alleged Short's personal involvement and that the deprivation of a Bible for a month substantially burdened his religious exercise. The court remanded the case for further proceedings on the RLUIPA claim against the county and the § 1983 claim against Short. View "Barnett v. Short" on Justia Law

Christopher Black pleaded guilty to three counts of production of child pornography, one count of receipt of child pornography, and one count of possession of child pornography. He was sentenced to 720 months’ imprisonment. Black appealed, arguing that the district court erred by denying his motion to suppress evidence obtained through two warrantless searches and challenging the substantive reasonableness of his sentence.The FBI began investigating the disappearance of a fourteen-year-old girl, A.W., in December 2021. They traced her phone to Keokuk, Iowa, and linked it to Black, who had a history of sex crimes involving juveniles. The FBI conducted a warrantless search of an Airbnb in Keokuk where Black and A.W. were believed to be staying, finding evidence suggesting A.W. was there. Later, Black and A.W. were found at another Airbnb in Minneapolis, leading to another warrantless search. Evidence from these searches led to Black’s indictment.The United States District Court for the Southern District of Iowa denied Black’s motion to suppress, finding the warrantless searches justified by exigent circumstances. Black entered a conditional guilty plea, preserving his right to appeal the suppression ruling. He was sentenced to 720 months, below the advisory guidelines term of 1,560 months.The United States Court of Appeals for the Eighth Circuit reviewed the case. They upheld the district court’s denial of the motion to suppress, agreeing that exigent circumstances justified the warrantless searches. The court also found no abuse of discretion in the district court’s sentencing, noting that the sentence was already below the guidelines range and that the district court did not err in its judgment. The Eighth Circuit affirmed the judgment of the district court. View "U.S. v. Black" on Justia Law

In the summer of 2021, the Southeast Iowa Narcotics Task Force (SEINT) received tips about heroin distribution in Burlington, Iowa. Following a search warrant at Michael Brown’s home, detectives found evidence of narcotics distribution. Subsequent investigations and controlled buys revealed that Gilbert Ellis, Christopher Ellis, and Joshua Townsen were involved in distributing methamphetamine and heroin. Gilbert, who used a wheelchair, directed others in drug transactions. Christopher and Townsen also participated in the distribution network, with Townsen procuring methamphetamine for Gilbert.The United States District Court for the Southern District of Iowa handled the initial proceedings. Gilbert pled guilty to multiple counts of drug distribution and conspiracy without a plea agreement. The court applied a “manager or supervisor” enhancement to his sentence, resulting in 240 months’ imprisonment. Christopher, classified as a career offender, received 200 months’ imprisonment. Townsen, deemed ineligible for safety-valve relief due to a prior burglary conviction, was sentenced to 120 months’ imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s judgments. It found no clear error in applying the “manager or supervisor” enhancement to Gilbert’s sentence, as evidence showed he directed drug transactions. The court also upheld the career-offender enhancement for Christopher, rejecting his argument that his prior marijuana conviction did not qualify as a controlled substance offense. Finally, the court confirmed Townsen’s ineligibility for safety-valve relief, consistent with the Supreme Court’s decision in Pulsifer v. United States. The appellate court concluded that the sentences were procedurally and substantively reasonable. View "United States v. Ellis" on Justia Law