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

The Eighth Circuit vacated defendant's 175 month sentence for conspiracy to distribute heroin. The court held that the district court clearly erred in including 17.5 grams of cocaine base in determining his base offense level, and committed plain error in assigning a criminal history point for an offense committed while he was a minor. The court held that the plain error placed defendant in the wrong criminal history category and affected his substantial rights. The court remanded for resentencing. View "United States v. Harris" on Justia Law

The Eighth Circuit affirmed defendant's resentence on both an Armed Career Criminal Act (ACCA) conviction and his drug trafficking conviction. The court held that, although the district court committed procedural err by using the 2013 Sentencing Guidelines on resentencing, the error was harmless. In this case, the district court repeatedly stated the sentence would be the same whether he sentenced on the vacated count or both counts. View "United States v. Kemp" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for second degree murder and related charges. The court held that the evidence was sufficient to support the second degree murder count; the district court did not err by instructing the jury on the elements of second degree murder; the government did not improperly vouch for the credibility of witnesses; although the admission of testimony concerning a sexual encounter that took place in the hours leading up to the murder was prejudicial, the error did not warrant reversal; and the district court did not err in calculating the criminal history points at sentencing. View "United States v. Cottier" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for possessing a gun and ammunition as a felon. The court held that the district court did not clearly err in denying defendant's motion to suppress bullets found in his pockets because there was probable cause to arrest him. In this case, defendant matched the material aspects of the shooter's description and a reasonable officer could have concluded that defendant was the shooter. The court also held that defendant's constitutional right to mount a defense was not violated; the district court did not abuse its discretion in limiting cross-examination or in its evidentiary rulings; the district court did not err in determining that first-degree aggravated robbery was a violent felony for purposes of sentencing defendant under the Armed Career Criminal Act; the district court did not err in treating the robbery and second-degree assault conviction as separate predicate offenses for ACCA purposes; and the district court did not err in counting the felony domestic assault as a violent felony. View "United States v. Perry" on Justia Law

Plaintiff filed suit alleging that a county deputy was deliberately indifferent to Jeffry Alan Barton's serious medical needs and that the county jail administrator failed to adequately train or supervise the deputy. Plaintiff also alleged that the county did not adequately train its detention facility workers and that its policies failed to ensure that detainees received adequate medical care.The Eighth Circuit affirmed the district court's denial of qualified immunity to the deputy where a jury could find that Barton was experiencing a medical need so obvious that a layperson would recognize the need for prompt medical attention, the deputy did not perform the healthcare screening the jail policies required, and it was clearly established at the time that booking Barton into jail would constitute deliberate indifference. The court reversed the denial of qualified immunity to the administrator and held that the administrator did not know that the deputy was inadequately trained or supervised. Finally, the court dismissed the county's appeal for lack of jurisdiction. View "Barton v. Ledbetter" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of a class action brought by over 52,000 experienced and student over-the-road truck drivers, alleging claims under federal and state wage and hour laws. The court held that judicial estoppel was not applicable in this case and that Werner was not bound to previous statements in such a way that affected the outcome of the case. The court also held that, under the Fair Labor Standards Act (FLSA), the mileage-based payments were remuneration for employment and should be included in Werner's minimum wage calculation. Finally, the state law claims were foreclosed as well. View "Baouch v. Werner Enterprises, Inc." on Justia Law

The EEOC filed suit alleging that North Memorial violated 42 U.S.C. 2000e-3(a), by unlawfully retaliating against an employee. The district court granted summary judgment for North Memorial and dismissed the claim, concluding that North Memorial did not violate section 2000e-3(a) because it did not discriminate against the employee.The Eighth Circuit affirmed and held that the EEOC failed to establish a prima facie case of opposition-clause unlawful retaliation because merely requesting a religious accommodation was not the same as opposing the allegedly unlawful denial of a religious accommodation. The court reasoned that, when an employee or applicant requested a religious accommodation, and the request was denied by an employer such as North Memorial that accommodated reasonable requests that did not cause undue hardship, there was no basis for an opposition-clause retaliation claim under Sec. 2000e-3(a). The court held that the employee or applicant's exclusive Title VII remedy was an unlawful disparate treatment or disparate impact claim under section 2000e-2(a)(1). View "EEOC v. North Memorial Health Care" on Justia Law

Plaintiff, by his parent and legal guardian, filed suit against the United States for negligence and negligent supervision, alleging that the Government knew or should have known of the sexual abuse history of a priest that was hired at the Tripler Army Medical Center, and that the Government was negligent in failing to warn families of the priest's sexual propensities.The Eighth Circuit affirmed the district court's dismissal of the action based on lack of subject matter jurisdiction because the United States was entitled to sovereign immunity. The court held that the decision whether to warn of the priest's sexual propensities or to take other action to restrict his contact with children was susceptible to policy analysis. The court explained that balancing safety, reputational interests, and confidentiality was the kind of determination the discretionary function exception was designed to shield and thus the Government's conduct was within the discretionary function exception. View "Croyle v. United States" on Justia Law

The Bankruptcy Appellate Panel vacated the bankruptcy court's order allowing Lariat's claim against debtor in the reduced amount of $308,805.00. The panel held that Lariat's predicate claim had been satisfied and Lariat cannot recover any additional amount from debtor's spouse. In this case, there were no preexisting creditor rights left for MINN. STAT. 513.41-513.51 to protect. Therefore, the panel remanded for entry of an order disallowing Lariat's claim in its entirety. View "Lariat Companies, Inc. v. Wigley" on Justia Law

The Eighth Circuit affirmed the district court's entry of judgment for the insured in a dispute over property coverage of a building that was destroyed by fire. The court held that the district court correctly entered judgment for the insured on the bad faith claim where Met could not prove misrepresentation or deception by the insured, or any reliance thereupon by Met. The court also held that the district court properly calculated the economic damages the insured suffered as a result of Met's bad faith refusal to pay pursuant to the provisions of the improperly rescinded contract. Furthermore, the district court did not abuse its discretion in awarding reasonable attorney fees. View "Hayes v. Metropolitan Property & Casualty Insurance" on Justia Law