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

The North Dakota Secretary of State filed a motion to stay an order of the district court that enjoined parts of the North Dakota elections statutes. The district court enjoined the Secretary from enforcing a provision that required a voter to present at the polls a valid form of identification that provides the voter's current residential street address.The Eighth Circuit granted the motion and held that the Secretary demonstrated a likelihood of success on the merits in his challenge to this aspect of the injunction, the State would be irreparably harmed by the injunction during the general election in November, and a stay should be granted after consideration of all relevant factors. View "Brakebill v. Jaeger" on Justia Law

Six siblings dispute over ownership and control of OKISDA, a family corporation their mother established. The district court concluded that nearly all the claims hinge on whether the transfer of Class A stock from the mother's trust to defendant was valid.The Eighth Circuit affirmed the district court's grant of summary judgment to defendants and dismissal of all the claims. The court held that transfer of two Class A shares did not violate the transfer restriction of OKISDA's bylaws. Furthermore, the validity of the stock transfer established that plaintiffs' other claims were foreclosed. View "Rains v. Jones" on Justia Law

Under United States v. Boyle, 469 U.S. 241 (1985), an agent's failure to fulfill his duty to his principal to file tax returns and make payments on behalf of the principal does not constitute reasonable cause for the principal's failure to comply with its tax obligations unless that failure actually rendered the principal disabled with regard to its tax obligations. Disability is a high bar that is not satisfied if the errant agent is subject to the control of his principal, whether that principal sufficiently exercised that control or not.The Eighth Circuit affirmed the district court's dismissal with prejudice of Deaton's suit seeking refund, abatement, and recovery of delinquent tax penalties assessed against it. The court held that the facts set forth in the complaint did not support a finding of reasonable cause. In this case, the facts, whether considered singularly or together, did not excuse Deaton's tax law compliance failures. View "Deaton Oil Co., LLC v. United States" on Justia Law

The Eighth Circuit affirmed the district court's judgment granting petitioner's application for habeas corpus relief from his death sentence pursuant to 28 U.S.C. 2254. The court held that, because the district court's partial grant of petitioner's rule 59(e) motion was not subject to this appeal, the court did not address the merits of the district court's application of Martinez v. Ryan, 132 S.Ct. 1309 (2012), and its finding of extraordinary circumstances.The court also held that the district court's finding that petitioner was prejudiced by counsel's deficient performance was supported by the evidence. Therefore, the district court properly concluded that petitioner established ineffective assistance of counsel. The court agreed with the district court that, as to Ground I, petitioner's Rule 60(b) motion was not a successive claim under 28 U.S.C. 2244(b). Finally, the district court did not err in denying respondent's Rule 59(e) motion; the judgment granting habeas relief was not the result of any manifest error; and the motion was not supported by any showing of extraordinary circumstances. View "Barnett v. Roper" on Justia Law

This appeal stemmed from a dispute over who was the rightful owner of a Martin D-35 guitar that Elvis Presley played during his final tour in 1977. The Eighth Circuit affirmed the district court's judgment in favor of the Museum, holding that the Museum was not bound by a prior Tennessee judgment between defendant and the guitar donor because the Museum was not a party to that action and was not in privity with the donor. In this case, the donor had already delivered the guitar to the Museum at the time defendant commenced the Tennessee action. Therefore, the donor had title to the Martin D-35 guitar when he transferred the guitar to the Museum and the Museum owned the guitar. View "National Music Museum v. Moss" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to vacate his sentence. Defendant argued that he did not have the requisite three prior violent felony convictions under the Armed Career Criminal Act (ACCA) because his two Arkansas convictions for first-degree terroristic threatening were not violent felonies. The court held that it's decision in United States v. Myers, 896 F.3d 866 (8th Cir. 2018), that Section 5-13-301(a)(1)(A), the Arkansas first-degree terroristic threatening statute, is divisible and requires the modified categorical approach was controlling in this case where the state court documents that may be examined established that defendant was twice convicted of the ACCA violent felony of threatening to use physical force against another person. The court also held, in the alternative, that Descamps v. United States, 570 U.S. 254 (2013), and Mathis v. United States, 136 S. Ct. 2243 (2016), did not announce a new rule of constitutional law made retroactive to cases on collateral review. View "Martin v. United States" on Justia Law

At issue in this case was whether the Labor Management Relations Act completely preempts a Minnesota Human Rights Act claim for disability discrimination brought by a former employee of a nuclear power plant. The Eighth Circuit reversed the district court's denial of remand to state court and grant of judgment on the pleadings to the employer, holding that the employee's claim could not be resolved without interpreting a collective-bargaining agreement. The court held that section 301 of the Act completely preempted plaintiff's disability discrimination claim under the Minnesota Human Rights Act; the district court had jurisdiction over the removed matter; and the judgment on the pleadings was properly granted because the section 301 claim was time-barred. View "Boldt v. Northern States Power Co." on Justia Law

The Eighth Circuit reversed the district court's order finding that the trustee's claim under the Carmack Amendment against Canadian Pacific was untimely. This appeal stemmed from a train accident killing 47 people and destroying an entire town in Quebec. The court held that WFE's claim based on a claim letter and denial in April 2014 made the trustee's April 2016 lawsuit timely. In regard to Irving Oil, the court held that there was a genuine dispute over the very existence of contractual terms in the bill of lading providing for a nine-month notice period and a two-year suit limitation, precluding both dismissal on the pleadings or summary judgment as a matter of law. Accordingly, the court remanded for further proceedings. View "Whatley v. Canadian Pacific Railway Ltd." on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983, challenging procedures used in proceedings brought by the State to remove Native American children temporarily from their homes in exigent circumstances. The district court denied defendants' motion to dismiss on jurisdictional grounds and granted partial summary judgment for plaintiffs. The district court then entered a declaratory judgment and permanent injunction.The Eighth Circuit held that the district court should have abstained from exercising jurisdiction under principles of federal-state comity articulated in Younger v. Harris, 401 U.S. 37 (1971), and later cases. In this case, even setting aside the question of “ongoing” temporary custody proceedings, plaintiffs may not circumvent the abstention doctrine by attempting to accomplish the same type of interference with state proceedings through a claim for prospective relief. Therefore, the court vacated the district court's order and remanded with instructions to dismiss the claims that gave rise to the orders. View "Oglala Sioux Tribe v. Vargo" on Justia Law

Defendant was convicted and sentenced for attempted exploitation of a child, attempted receipt of images depicting sexual exploitation of a child, possession of counterfeit obligations, two counts of attempted witness tampering, and attempted travel with intent to engage in illicit sexual conduct. The Eighth Circuit rejected all of defendant's challenges to the convictions but one. The court held that there was insufficient evidence to support defendant's conviction for attempted travel. Therefore, the court remanded for resentencing based on the remaining five counts. View "United States v. Bernhardt" on Justia Law