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

The Eighth Circuit affirmed the district court's grant of summary judgment to defendants in a 42 U.S.C. 1983 action filed by plaintiffs and a nonprofit alleging that their arrests were without probable cause and violated the First Amendment, that the Arkansas disorderly conduct statute and a permit ordinance were unconstitutional, and that the County unconstitutionally detained plaintiffs. The court held that officers had probable cause to arrest plaintiffs for violating the Arkansas disorderly conduct statute based on their personal observations, as well as information provided to them; plaintiffs have standing to challenge the constitutionality of Arkansas's disorderly conduct statute, but the statute was not void for vagueness nor overbroad; plaintiffs did not have standing to challenge the constitutionality of Little Rock's Permit Ordinance, on its face and as applied, because they were not arrested or charged under the ordinance and they were not prohibited from protesting even though they had lacked a permit; and any delay in plaintiffs' release from jail did not violate their Fourth Amendment rights and was not unreasonable. View "Duhe v. City of Little Rock" on Justia Law

The Eighth Circuit held that the procedural element of the new substantive rule of constitutional law made retroactive in Montgomery v. Louisiana did not apply in this case and the district court did not err in denying successive habeas relief. The court held that petitioner's life sentence for conspiracy was based on conspiratorial conduct which extended well into his adult years and the sentence was imposed under an advisory guidelines regime that allowed the district court to consider his early participation as a juvenile, as well as other relevant mitigating factors. The court also held that petitioner's sentence of life plus 60 years did not violate the Eighth Amendment and the district court did not abuse its discretion in denying more comprehensive resentencing after it vacated his mandatory life sentence on one count under Miller v. Alabama and resentenced him. View "Wright v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of plaintiff's motion for appointed counsel and adverse grant of summary judgment on plaintiff's failure to protect claims against various corrections officials after he sustained injuries when a fellow inmate attacked him. The court held that the district court had the discretion to appoint plaintiff counsel on this record, and it did not abuse this discretion in declining to do so. The court also held that insofar as plaintiff alleged that defendants failed to protect him from a specific threat posed by the inmate, his own inability to anticipate the surprise attack and his decision not to report his altercation with the inmate the previous afternoon defeated liability. Finally, assuming that plaintiff satisfied the objective component of his failure-to-protect claim, the record was devoid of evidence suggesting that any of defendants were subjectively aware of, or deliberately indifferent to, a substantial risk of harm to inmate safety. View "Patterson v. Kelley" on Justia Law

Plaintiffs, both of whom are hearing-impaired, and their daughter filed suit against Fairview, alleging that the hospital failed to provide meaningful access to auxiliary aids and services in the form of American Sign Language (ASL) interpreters and a teletypewriter (TTY) during the course of plaintiffs' son's terminal hospital stay. The Eighth Circuit affirmed the district court's grant of Fairview's motion for summary judgment, holding that Fairview did not fail to discharge its duty to provide effective communication. In this case, the evidence showed that plaintiffs were provided access to information, through interpreters, before and during their son's final hospitalization and provided ample opportunities for plaintiffs to ask questions that may have clarified their understanding of their son's condition. Furthermore, the facts were sufficient to establish that Fairview provided plaintiff with the requested auxiliary aid and offered assistance, which was declined, in setting up the device. The court also held that the daughter did not qualify for associational standing and Fairview was entitled to summary judgment as to her claims. View "Durand v. Fairview Health Services" on Justia Law

Plaintiffs filed suit against GFA, alleging that GFA solicited charitable donations to benefit the poorest of the poor while covertly diverting the money to a multi-million dollar personal empire. The district court denied GFA's motion to compel arbitration.The Eighth Circuit held that the district court interpreted the scope of the arbitration agreements too narrowly, reasoning that, since none of the mission statements or pledges found in the agreements reach donations made to the church, the dispute was entirely unrelated to the parties' agreements. The court held that, even if the agreements did not reach donations made to GFA, the district court erred because the arbitration agreements did not apply only to disputes arising out of the agreements. Rather, they applied by their terms to any and all disputes of any kind arising out of the relationship between plaintiffs and GFA. Because the court could not say with positive assurance that the donations plaintiffs made to GFA did not arise out of that relationship, the court reversed and remanded. View "Dickson v. Gospel for ASIA, Inc." on Justia Law

The Eighth Circuit affirmed the district court's revocation of defendant's supervised release. The court held that there was sufficient evidence to support the district court's judgment where defendant admitted to violating two of the special conditions of release. The court also held that the special condition prohibiting defendant from participating in any organizational financial activities was reasonably related to the 18 U.S.C. 3583(d) sentencing factors, and was not overbroad nor did it prohibit him from contributing financially to religious organizations. View "United States v. Henderson" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of an action brought by four taxicab drivers against Uber, alleging that Uber tortiously interfered with a valid business expectancy. The court held that it need not decide whether there was a valid business expectancy because plaintiffs failed to allege the absence of justification under Missouri law. In this case, there was no evidence that the legislature intended to create a private cause of action based on violation of the Missouri Taxicab Commission's code and requirements. View "Vilcek v. Uber Technologies, Inc." on Justia Law

The Eighth Circuit affirmed defendant's conviction of one count of transportation of a minor to engage in prostitution; two counts of attempted transportation of a minor to engage in prostitution; and six counts of transportation of an individual with intent to engage in prostitution. The court held that the search of defendant's van was warranted under the community-caretaker exception where police officers knew that a minor was missing; the officer developed probable cause to search the van under the automobile warrant exception when he opened the door and discovered marijuana and an apparently comatose young woman; and thus the district court properly denied defendant's motion to suppress evidence. The court also held that the district court did not err in admitting evidence that defendant had asked two of the women to have sex with him and provided drugs to them. Finally, the evidence was sufficient to enable a reasonable jury to find that defendant transported all six women in interstate commerce with the intent to have them engage in prostitution. View "United States v. Parks" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the county and to two sheriffs in an action brought by plaintiff under 42 U.S.C. 1983, alleging the use of excessive force. In this case, plaintiff was stopped by law enforcement after he stole items from a local Walmart. Plaintiff was kicked by one of the officers without provocation and that officer resigned and was terminated the next day. That officer subsequently pleaded guilty to criminal charges.The court held that plaintiff failed to prove the existence of an unconstitutional custom or policy; failed to show causation assuming there was such a custom or policy; and thus could not establish municipal liability. Therefore, the district court properly granted summary judgment for the sheriffs in their official capacities. The court rejected plaintiff's failure to train claim and held that one of the sheriffs was entitled to qualified immunity. Finally, the district court did not abuse its discretion in calculating attorneys' fees and costs. View "Brewington v. Keener" on Justia Law

Employees of a chicken processing plant filed a class action lawsuit, alleging their employer failed to pay certain wages in violation of Arkansas state law and the Fair Labor Standards Act (FLSA), 29 U.S.C. 201. More than 1,000 workers opted in. The class was subsequently decertified and claims were subjected to the two-year FLSA limitations period. The parties eventually settled their dispute out-of-court for a confidential amount made known to the court, which approved the agreement but declined to award the agreed-upon $87,500.00 in attorneys’ fees, costs, and expenses. The district court, sua sponte, reduced the fees awarded to $22,500.00. The Eighth Circuit remanded with instructions to award the agreed-upon fees. The attorneys’ fees-to-recovery ratio alone is not the sole determining factor. In light of the need to focus on multiple factors and not just one, and in light of the strong likelihood that the parties’ agreement is reasonable, any required review by the district court is light and the agreed-upon award is not outside the range of what would be approved. View "Melgar v. OK Foods" on Justia Law