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

Booker Deon McKinney pleaded guilty to possession of ammunition as an unlawful drug user, violating 18 U.S.C. §§ 922(g)(3) and 924(a)(2). He was sentenced to 120 months in prison followed by three years of supervised release. McKinney later moved to withdraw his guilty plea and dismiss his indictment, arguing that § 922(g)(3) violated the Second Amendment. The district court denied his motion.The United States District Court for the Northern District of Iowa initially reviewed the case. McKinney was indicted in January 2023 and pleaded guilty in June 2023. In January 2024, he filed a motion to withdraw his plea and dismiss the indictment, which the district court denied. McKinney was sentenced on January 26, 2024, and subsequently appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. McKinney argued that the district court erred in denying his motion to withdraw his guilty plea and dismiss the indictment, miscalculated his base offense level, relied on inadmissible hearsay evidence, and improperly weighed the § 3553(a) factors at sentencing. The Eighth Circuit found no abuse of discretion in the district court's decisions. The court held that there was no intervening change in the law that justified McKinney's belated request to withdraw his plea. The court also upheld the district court's calculation of the base offense level and its reliance on hearsay evidence, finding it sufficiently reliable. Finally, the court found McKinney's sentence substantively reasonable, noting that the district court had appropriately considered the § 3553(a) factors. The Eighth Circuit affirmed the district court's judgment. View "United States v. McKinney" on Justia Law

Summit Carbon Solutions, LLC plans to build an interstate pipeline through Iowa, passing through Shelby and Story Counties. Both counties enacted ordinances imposing various requirements on pipelines, including setback, emergency response plan, and local permit requirements. Summit challenged these ordinances, arguing they were preempted by the federal Pipeline Safety Act (PSA) and Iowa law. The district court granted summary judgment in favor of Summit, permanently enjoining the enforcement of the ordinances.The United States District Court for the Southern District of Iowa reviewed the case and ruled in favor of Summit, finding that the PSA and Iowa law preempted the counties' ordinances. The court issued a permanent injunction against the enforcement of the ordinances. The counties appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the PSA preempts the Shelby and Story County ordinances' setback, emergency response, and abandonment provisions. The court found that the ordinances were safety standards, which are preempted by the PSA. Additionally, the court held that the ordinances were inconsistent with Iowa law, as they imposed additional requirements that could prohibit pipeline construction even if the Iowa Utilities Commission (IUC) had granted a permit. The court affirmed the district court's judgment in both cases but vacated and remanded the judgment in the Story County case to the extent it addressed a repealed ordinance. View "Couser v. Shelby County" on Justia Law

Matthew Kale sued his employer, Aero Simulation, Inc. (ASI), alleging religious and disability discrimination under Title VII of the Civil Rights Act, the Americans with Disabilities Act (ADA), the Religious Freedom Restoration Act (RFRA), the Constitution, and state law. ASI required all employees to receive the Covid-19 vaccine, with non-compliance resulting in disciplinary action, including termination. Kale requested a religious exemption, citing his belief that his body is a temple of the Holy Spirit and should not be subjected to unwanted intrusions. ASI denied his request, and Kale was terminated. He filed a charge with the EEOC, which issued a right to sue letter.The United States District Court for the District of South Dakota dismissed Kale’s claims, ruling that he failed to plausibly plead religious beliefs conflicting with ASI’s Covid-19 policy, did not allege that ASI regarded him as disabled due to his unvaccinated status, and that his proposed amended complaint was futile. Kale appealed the dismissal of his federal law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court’s dismissal, holding that Kale failed to allege facts showing that ASI’s testing requirement conflicted with his bona fide religious beliefs. The court noted that Kale’s complaint did not adequately connect his objection to testing with specific religious principles. Additionally, the court found that Kale did not exhaust his administrative remedies for his ADA claim, as he only asserted religious discrimination in his EEOC charge. The court also upheld the denial of Kale’s motion to amend his complaint, deeming it futile as it contained the same deficiencies as the original complaint. The judgment was affirmed. View "Kale v. Aero Simulation, Inc." on Justia Law

Clayton Stewart was involved in a police incident where Officer Victor Garcia of the Jonesboro, Arkansas police department tased him while he was climbing a fence. Stewart fell and was paralyzed as a result. Stewart filed a 42 U.S.C. § 1983 action against Garcia, Jonesboro Chief of Police Rick Elliot, and the City of Jonesboro, alleging violations of his Fourth and Fourteenth Amendment rights. The district court granted summary judgment in favor of the defendants on all claims, and Stewart appealed.The United States District Court for the Eastern District of Arkansas granted summary judgment to the defendants, finding no genuine disputes of material fact that would preclude summary judgment. Stewart argued that Garcia lacked probable cause to arrest him, used excessive force, and was deliberately indifferent to his medical needs. He also claimed that Elliot was liable as Garcia’s supervisor and that the police department’s policies were unconstitutional.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Garcia had at least arguable probable cause to arrest Stewart for misdemeanor assault and fleeing. Regarding the excessive force claim, the court found that while tasing Stewart in an elevated position could be considered deadly force, Stewart’s right to be free from such force was not clearly established at the time of the incident, entitling Garcia to qualified immunity. On the deliberate indifference claim, the court concluded that although a reasonable jury could find Garcia was aware of Stewart’s serious medical needs, Stewart failed to show that the right was clearly established, granting Garcia qualified immunity. The court also affirmed the dismissal of the supervisory liability claim against Elliot and the municipal liability claim against the City of Jonesboro, finding no evidence of a pattern of unconstitutional acts or inadequate policies. The Eighth Circuit affirmed the district court’s judgment in full. View "Stewart v. Garcia" on Justia Law

Julie Sprafka underwent knee replacement surgery in August 2016 using the ATTUNE knee replacement system designed by DePuy Orthopaedics, Inc. Four years later, she required revision surgery due to the debonding of the tibial baseplate. Sprafka filed a lawsuit against DePuy, claiming strict liability, negligent products liability, and breach of warranties. She later withdrew the warranty claims and proceeded with the products liability claims, alleging defective design and failure to warn.The United States District Court for the District of Minnesota reviewed the case. DePuy moved to exclude the opinions of Sprafka’s design defect expert, Dr. Mari S. Truman, and for summary judgment. The district court granted DePuy’s motions, excluding Dr. Truman’s opinions for failing to meet the requirements of Rule 702 and Daubert standards. Consequently, the court granted summary judgment in favor of DePuy, as Sprafka could not prove her design defect claim without expert testimony.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, agreeing that Dr. Truman’s opinions were unreliable and speculative. The appellate court noted that Dr. Truman’s opinions were not based on independent research and lacked scientific scrutiny. The court also found that Sprafka did not preserve the argument that Dr. Kristoffer Breien’s expert opinion alone could support her design defect claim. Additionally, the court concluded that the district court did not err in granting summary judgment, as Sprafka failed to provide sufficient expert testimony to support her claims. The judgment of the district court was affirmed. View "Sprafka v. Medical Device Bus. Services" on Justia Law

In June 2022, law enforcement officers in Sarpy County received a tip that Rolando Midder was sex trafficking a 16-year-old girl, J.C. Officers met with J.C., who showed signs of physical abuse, and took her to a hospital for a sexual assault exam. After two weeks of investigation, Midder was arrested and charged with one count of sex trafficking a minor and two counts of sexually exploiting a minor. A jury convicted him on all counts.The United States District Court for the District of Nebraska admitted social media evidence and witness testimony during the trial. Midder appealed, arguing that the district court abused its discretion by admitting this evidence and that there was insufficient evidence to support his convictions. He also challenged the scope of testimony given by a nurse who performed J.C.'s sexual assault exam, but he failed to provide any argument on this issue, resulting in a waiver of appellate review.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary rulings for abuse of discretion and found that the government presented sufficient evidence connecting Midder to the cellphone and social media accounts used in the crimes. The court also upheld the admission of testimony from Eran Peatrowsky under Rule 404(b), finding it relevant to proving Midder’s knowledge, intent, and motive. Additionally, the court found sufficient evidence to support Midder’s convictions for sex trafficking a minor and sexual exploitation of a minor, based on the evidence presented at trial.The Eighth Circuit affirmed the district court’s rulings and upheld Midder’s convictions on all counts. View "United States v. Midder" on Justia Law

Leslie Torgerson filed a lawsuit in federal district court against Roberts County, South Dakota, and several individuals, including County Sheriff Tyler Appel, County Deputies Zachary Angerhofer and Wesley Bowsher, his adopted son Ross Torgerson, and his ex-wife Terri Torgerson. Torgerson alleged violations of his substantive and procedural due process rights under the Fourteenth Amendment and civil conspiracy. He also asserted a Monell claim against the County, a state-law claim for common law battery against Ross, and a state-law intentional-infliction-of-emotional distress claim against Deputy Angerhofer, Deputy Bowsher, Ross, and Terri. These claims stemmed from a domestic dispute involving Torgerson, Ross, and Terri.The defendants moved for summary judgment on Torgerson’s claims. The United States District Court for the District of South Dakota granted the defendants' motions for summary judgment and declined to exercise jurisdiction over the remaining state-law claims. The court concluded that Torgerson failed to state a claim for a Fourteenth Amendment violation, as he did not plead that he possessed a constitutional interest that had been violated. The court also determined that Torgerson’s civil conspiracy claim failed due to the lack of a stated constitutional interest and insufficient facts showing a conspiracy. Consequently, Torgerson’s Monell claim against the County also failed. The court declined to exercise supplemental jurisdiction over the state-law claims, considering them to be purely state-related issues.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Torgerson did not suffer a deprivation of liberty as he was not charged or prosecuted for any crime, thus failing to establish a Fourteenth Amendment violation. The court also upheld the summary judgment on the civil conspiracy and Monell claims, as there was no underlying constitutional violation. Finally, the court found no abuse of discretion in the district court’s decision to decline supplemental jurisdiction over the state-law claims. View "Torgerson v. Roberts County of South Dakota" on Justia Law

Evan Brown Bull was convicted by a jury of conspiracy to distribute 500 or more grams of methamphetamine. The government presented evidence from thirteen witnesses and various forms of documentation, including videos and Facebook messages, detailing Brown Bull's drug dealings from 2016 to 2023. The Probation Office's Presentence Investigation Report (PSR) recommended a base offense level of 32, with adjustments that increased the total offense level to 40, resulting in an advisory guidelines sentencing range of 360 months to life imprisonment. Brown Bull objected to the PSR's findings and requested a downward variance to 180 months.The United States District Court for the District of South Dakota overruled Brown Bull's objections and applied three sentencing enhancements: a two-level increase for obstruction of justice, a four-level increase for being an organizer or leader of a criminal activity involving five or more participants, and a two-level increase for committing the offense as part of a pattern of criminal conduct engaged in as a livelihood. The court ultimately sentenced Brown Bull to 400 months imprisonment and five years of supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court found no clear error in the district court's application of the sentencing enhancements. The court held that Brown Bull's pretrial jail messages and Facebook post constituted obstruction of justice, that he was an organizer or leader of the drug conspiracy, and that his criminal conduct was part of his livelihood. The court concluded that the district court's findings were supported by the evidence and upheld the 400-month sentence. View "United States v. Bull" on Justia Law

Karla Smith and Holly Bladel sued Iowa state officials and the State of Iowa after Iowa opted out of federal unemployment programs established during the Covid-19 pandemic. These programs, created under the CARES Act, provided various unemployment benefits. Iowa initially participated in these programs but decided to end its participation in June 2021. Smith and Bladel claimed that this decision violated the U.S. Constitution, the Iowa Constitution, and Iowa state law.The United States District Court for the Southern District of Iowa dismissed the case, ruling that the defendants were immune from suit under the Eleventh Amendment and that the plaintiffs lacked a constitutionally protected property interest in the CARES Act benefits. Smith and Bladel appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The court held that the Eleventh Amendment barred Smith's official-capacity claims against Iowa and its officials, as the claims did not fall under the Ex parte Young exception for ongoing violations of federal law. The court also found that Smith lacked a protected property interest in the CARES Act benefits because Iowa had the discretion to opt out of the programs. Consequently, Smith's due process claim against the Governor and Director in their individual capacities failed. Additionally, the court ruled that Smith's state law claim was barred by the Eleventh Amendment, and her request for declaratory relief was inappropriate as it sought to address past actions rather than future conduct. The court concluded that the district court correctly dismissed all of Smith's claims. View "Smith v. Reynolds" on Justia Law

Shawn Russell Sorensen was convicted of conspiracy to distribute methamphetamine and sentenced to mandatory life imprisonment based on prior state convictions for drug offenses. He filed a motion under 28 U.S.C. § 2255 to vacate, set aside, or correct his sentence, arguing ineffective assistance of counsel for not contesting the qualification of his prior convictions as "felony drug offenses" under 21 U.S.C. § 841’s sentencing enhancement scheme.The United States District Court for the District of South Dakota dismissed Sorensen's motion. The court found that his counsel's performance was not deficient, as the argument regarding the categorical approach to his prior convictions was considered novel at the time of sentencing. Sorensen appealed, and the United States Court of Appeals for the Eighth Circuit granted a certificate of appealability on the ineffective assistance of counsel claim.The Eighth Circuit affirmed the district court's decision. The court held that even if counsel's performance was deficient, Sorensen failed to demonstrate prejudice. The court applied the categorical and modified categorical approaches to determine that Sorensen's prior convictions under Arizona and South Dakota statutes qualified as felony drug offenses. The Arizona statute was found to be divisible, and Sorensen's conviction for possession of methamphetamine matched the federal definition of a felony drug offense. Similarly, the South Dakota statute was also deemed divisible, and Sorensen's conviction for possession of methamphetamine under this statute qualified as a felony drug offense. Therefore, Sorensen's sentence was upheld, and the district court's judgment was affirmed. View "Sorensen v. United States" on Justia Law