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

The Eighth Circuit affirmed the district court's dismissal of a petition for habeas corpus under 28 U.S.C. 2254 where petitioner was convicted of two counts of first-degree rape and two counts of sexual contact with a child under the age of 16. The court held that petitioner failed to exhaust his remedies in regard to his claim that admission of a video of the victim implicated his rights under the Confrontation Clause; petitioner also failed to raise the Confrontation Clause issue before the district court; and the evidence at trial, including the video, provided an adequate basis for conviction. View "Brende v. Young" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of defendant in an action brought by Lincoln Life for damages it incurred in a lawsuit brought by a policyholder who purchased a Lincoln policy through defendant. Defendant counterclaimed, seeking withheld commissions and bonuses from the sale of that policy. The court held that the district court did not err in granting Wilson summary judgment on Lincoln's claim for damages on the ground the claims were collaterally estopped by the New York judgment finding coverage under the policies; by precluding Lincoln from asserting as a defense against defendant's counterclaim for commissions that he breached his agent's contract in connection with the sale of the policies; and in granting defendant prejudgment interest on his liquidated damage claims. View "Lincoln Benefit Life v. Wilson" on Justia Law

The Bankruptcy Appellate Panel affirmed the bankruptcy court's judgment denying debtors' discharge under Bankruptcy Code 727(a). The panel held that debtors failed to maintain and preserve adequate records, and such failure made it impossible to ascertain their financial condition and material business transactions. Therefore, the trustee met his burden of proving that debtors' discharge should be denied under section 727(a)(3). View "Snyder v. Dykes" on Justia Law

The Eighth Circuit affirmed defendant's revocation sentence of 60 months in prison after defendant pleaded guilty in state court to first degree computer child pornography and computer exploitation of a child. The court held that the district court did not plainly err in failing to expressly state the applicable sentencing range where the district court considered related guidelines provisions and the discussions reflected an assessment that the offense warranted revocation and a substantial prison sentence; the statutes under which defendant was convicted provided a sufficient basis for the district court's factual findings; the district court did not plainly err in considering the 18 U.S.C. 3553(a)(2)(A) factors and did not violate the Double Jeopardy Clause; and defendant's sentence was not substantively unreasonable. View "United States v. Trung Dang" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for drug-related crimes. The court held that the district court did not err by denying defendant's motion to suppress evidence because the facts set forth in the warrant affidavit supported probable cause; the district court did not err in denying defendant's motion to dismiss where there was no Speedy Trial Act violation; the district court did not abuse its discretion in admitting into evidence a poor quality recording because it was sufficient to provide the jury with the gist of the conversation and there was no plain error in giving the jury the limiting instruction to prevent consideration of inadmissible hearsay; the district court did not err by admitting text messages because the witness qualified as a coconspirator and the messages were not hearsay; and the evidence was sufficient to support the convictions. View "United States v. De La Torre" on Justia Law

Plaintiffs filed suit against defendants after plaintiff's son, Michael, was killed by cardiac arrhythmia after an altercation with officers in the setting of acute methamphetamine intoxication. When officers responded to a domestic disturbance call, they found Michael brutally attacking his girlfriend.The Eighth Circuit affirmed the district court's grant of summary judgment for defendants, holding that unsworn statements from paramedics to law enforcement were properly excluded and the district properly disregarded them; Iowa's false statement statute did not implicitly swear a declarant making a statement to law enforcement; there was no genuine dispute of material fact that Michael posed a threat to the safety of the officers and the victim and no competent, admissible evidence rebutted the officers' version of the events; because there was no constitutional violation, the court need not consider whether the rights at issue were clearly established. The court also affirmed the district court's decision not to exercise jurisdiction over the state law claims. View "Zubrod v. Hoch" on Justia Law

The Bankruptcy Appellate Panel affirmed the bankruptcy court's order dismissing plaintiffs' adversary complaint and an order denying their motion to reconsider the dismissal order. The panel held that plaintiffs failed to state a claim upon which relief can be granted under 11 U.S.C. 523(a)(19). In this case, a prior Consent Order requiring debtor to pay a fine and costs did not result in a debt owed to plaintiffs. Plaintiffs were not a party to or a signatory on the Consent Order and the debt to plaintiffs did not result from the Consent Order. View "Conway v. Heyl" on Justia Law

The Bankruptcy Appellate Panel affirmed the bankruptcy court's order disallowing debtor's claimed exemptions in his ex-wife's Wells Fargo 401K and an IRA account. The panel held that any interest debtor held in the accounts resulted from nothing more than a property settlement and thus they were not retirement funds that qualified as exempt under federal law. View "Lerbakken v. Sieloff and Associates, PA" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to a police officer in an action brought by plaintiff under 42 U.S.C. 1983, alleging that the officer used excessive force in violation of her Fourth Amendment rights. The court held that a jury could find that a reasonable officer in defendant's position would not have interpreted plaintiff's actions as noncompliance and would have known that plaintiff posed neither an immediate threat to anyone's safety nor a flight risk. The court also held that it was clearly established that an officer could not forcefully take down plaintiff -- who was a nonviolent, nonthreatening misdemeanant who was not actively resisting arrest or attempting to flee -- in the violent and uncontrolled manner that defendant did. View "Karels v. Storz" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for defendant in an action alleging that plaintiff's injuries were caused by defendant's negligence in driving a tractor trailer truck. The court held that the workers' compensation benefits plaintiff received were his exclusive remedy against defendant. In this case, defendant and plaintiff entered into an employment relationship in which Swift and Johnson were joint employers mutually liable under Iowa law to provide plaintiff workers' compensation benefits when he suffered a work-related injury, an obligation Swift has fully performed. View "Quiles v. Johnson" on Justia Law