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

The Bankruptcy Appellate Panel affirmed the bankruptcy court's order denying debtor's request for discharge of her student loan obligations to the DOE. The panel held that the bankruptcy court applied the correct totality of the circumstances standard and properly held that debtor failed to meet her burden of proving an undue hardship under 11 U.S.C. 523(a)(8). In this case, debtor had no problem making (and did make) full student loan payments when she was employed as a full-time bank branch manager, she voluntarily left that employment and chose part time work; no medical evidence was presented to indicate that debtor was unable to work on a full time basis; and debtor's financial restraints were the result of choices she made and were not long term. View "Kemp v. U.S. Department of Education" on Justia Law

The Eighth Circuit affirmed the district court's denial of summary judgment based on qualified immunity to a police officer and summary judgment based on official immunity to the City. The court held that the officer lacked arguable probable cause to arrest plaintiff where the totality of the circumstances suggested that the officer had reason to know that plaintiff could not deliver the type of pain he felt (a kick) and he had no information suggesting that she was even in a position to do so. Furthermore, the arguable probable cause undergirding the warrantless arrest here was missing a fundamental element: observation—either by the officer or a witness who relayed that information to him—of a criminal act. The court also held that unlawfulness of the officer's conduct was clearly established at the time. Finally, the court held that a factfinder could determine the officer had reason to believe that he arrested plaintiff without probable cause, and the City, therefore, was not entitled to official immunity. View "Johnson v. City of Minneapolis" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of Thompson's complaint claiming a refund of excise taxes for its diesel particulate filters under Internal Revenue Code 4051(a)(1). The court held that the phrase "part or accessory" in section 4051(a)(1) was not ambiguous and the filters were properly taxed as either parts or accessories, both of which fell within the scope of the statute. View "Thompson Truck & Trailer v. United States" on Justia Law

The Eighth Circuit reversed the district court's judgment against Liberty Life in an action filed by plaintiff under the Employee Retirement Income Security Act (ERISA), alleging that the company's denial of long-term disability benefits under his employer's welfare plan was an abuse of discretion. The court held that Liberty Life's decision was not an abuse of discretion because the medical opinions the district court rejected were supported by medical evidence and were sufficiently reliable to provide a reasonable basis for defendant to deny the claim. The court also vacated the award of attorney's fees. View "Zaeske v. Liberty Life Assurance Company of Boston" on Justia Law

Plaintiffs filed suit against Anderson Excavating under 29 U.S.C. 185(a), 29 U.S.C. 1132, and 29 U.S.C. 1145, requesting that the district court order Anderson Excavating to pay the contributions it allegedly owed to the Welfare Plan and Pension Plan, along with interest, liquidated damages, and attorneys' fees and costs.The Eighth Circuit held that the district court erred in determining damages for unpaid contributions, prejudgment interest, liquidated damages, and attorneys' fees; the district court legally erred in applying the alter ego doctrine to justify an award of unpaid contributions for an alleged employee's work; and thus the court reversed the judgment of the district court and remanded for further proceedings. View "Marshall v. Anderson Excavating & Wrecking" on Justia Law

Plaintiffs, three shareholders, filed suit claiming that the federal agency Congress created to serve as conservator of Fannie Mae and Freddie Mac exceeded its powers under the Housing and Economic Recovery Act (HERA) and acted arbitrarily and capriciously by agreeing to a "net worth sweep."The Eighth Circuit joined four sister circuits that have already rejected materially identical arguments from other shareholders. The court interpreted the anti-injunction provision to apply only to equitable relief, and only where FHFA has acted within its statutory powers. Such a reading was consistent with the presumption of reviewability. The court held that FHFA did not exceed its powers in assenting to the net worth sweep and thus HERA's anti-injunction provision was applicable. View "Saxton v. Federal Housing Finance Agency" on Justia Law

The Eighth Circuit affirmed the district court's partial grant of summary judgment for Children's Hospitals and decision to vacate a Medicaid policy, Frequently Asked Question 33, which explained how to calculate a hospital's uncompensated medical care costs. The court held that by imposing new reporting requirements for private insurance payments, Question 33 expanded the footprint of 42 C.F.R. 447.299 and thus constituted a substantive change in the regulation. The court explained that section 447.299 has specific language explicitly stating what payments must be deducted from each hospital's "total cost of care," and the Secretary's own definition of "uncompensated care costs" did not include private insurance payments. The court declined to read substantive changes into the regulation under the guise of interpretation. Furthermore, the court joined the First and Fourth Circuits in concluding that Question 33 was a legislative rule that was not adopted in accordance with the procedure required by law and thus must be set aside, notwithstanding the Secretary's policy arguments to the contrary. View "Children's Health Care v. Centers for Medicare and Medicaid Services" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to correction center officials in a 42 U.S.C. 1983 action brought by a former inmate alleging that the officials failed to protect him from sexual and physical harassment, threats, and assault. The court held that sufficient factual allegations from the verified complaint remained pending to support the district court's finding of material factual disputes. Therefore, the court dismissed the appeal for lack of jurisdiction. View "Berry v. Doss" on Justia Law

In 2016, the Eighth Circuit granted petitioner authorization for a successive 28 U.S.C. 2255 motion, in which he claimed that his prior Missouri convictions for burglary of an inhabitable structure no longer qualified him as an armed career criminal. The district court denied relief and this court granted a certificate of appealability.The court agreed with those circuits that required a movant to show by a preponderance of the evidence that the residual clause led the sentencing court to apply the Armed Career Criminal Act (ACCA) enhancement, and the mere possibility that the residual clause was relied on was insufficient to satisfy the burden. Because whether the residual clause provided the basis for ACCA enhancement was a factual question, the court remanded for the district court to make that determination in the first instance. View "Walker v. United States" on Justia Law

Plaintiff, who is paralyzed from the waist down and uses a wheelchair for mobility, filed suit against Holiday, alleging that the company discriminated against him in violation of the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA) by failing to have an accessible parking lot at one of its stores. The district court granted Holiday's motion for summary judgment.The Eighth Circuit vacated the district court's judgment with instructions to remand plaintiff's access-aisle and vertical-signage claims to state court. In regard to these two claims, plaintiff suffered no injury and thus could not establish Article III standing. The court also remanded for the district court to consider whether to exercise supplemental jurisdiction over the remaining garbage-can claim. In this case, plaintiff established an injury in fact by offering specific evidence that the allegedly dangerous circumstances caused him not to enter the store. The district court erred in treating a photograph that plaintiff submitted along with his declaration as definitive proof that he had plenty of room to maneuver around the garbage can. View "Hillesheim v. Holiday Stationstores, Inc." on Justia Law