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

The Eighth Circuit affirmed the district court's grant of summary judgment to the County and others in a 42 U.S.C. 1983 action alleging that plaintiff was sexually assaulted by former corrections officer Louis Campana. The court held that the claims against the County were properly dismissed where plaintiff failed to show that the County itself caused the constitutional violation at issue; nothing in the record established that any failure to train Campana caused him to assault plaintiff or that the County was deliberately indifferent to plaintiff's rights; two supervisors' negligence was not sufficient to establish section 1983 liability; a reasonable officer in Sheriff Samuelson's position would not have known that he needed to more closely supervise Campana, and the Sheriff was entitled to qualified immunity; and a reasonable officer in Defendant Gregg's position would not have concluded on this record that Campana posed an obvious risk to commit sexual assault. View "Marsh v. Phelps County" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of Robert McChesney's suit against the Commission after it imposed a civil penalty on him as treasurer of Bart McLeay's campaign for United States Senate in Nebraska. In this case, the Commission found that McChesney failed to file certain notices of campaign contributions that must be reported within 48 hours.As a preliminary matter, the court held that it was not reversible error for the district court to rule based on the record that was available to it, and the court rejected the Commission's contention that McChesney did not bring a proper challenge. On the merits, the court rejected McChesney's claim that the Commission failed to establish the 2014 penalty schedule and held that the statute did not require the Commission in 2014 to conduct the sort of evaluative review that McChesney sought; the district court properly declined to set aside the 2014 penalty schedule based on an alleged violation of the Sunshine Act or implementing regulations; and McChesney did not plead a plausible claim for relief based on alleged flaws in the Commission's voting procedure. View "McChesney v. Hunter" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the school district in an action filed by plaintiffs of a student, alleging violation of the student's rights under the Rehabilitation Act when the school district failed to make reasonable accommodations for her. The court held that the parents' complaint sought relief available under the Individuals with Disabilities Education Act (IDEA) -- relief for the denial of a free and appropriate public education-- and thus they must exhaust their administrative remedies unless an exception to the exhaustion requirement applied. In this case, none of the three exceptions to the exhaustion requirement applied. Therefore, the district court properly granted summary judgment for failure to exhaust administrative remedies under the IDEA. View "Nelson v. Charles City Community School District" on Justia Law

The Supreme Court remanded this case after holding that retroactive application of Minnesota's revocation-upon-divorce statute did not violate the Contracts Clause. In light of the Supreme Court's remand, the Eighth Circuit affirmed the district court's grant of summary judgment awarding the policy proceeds to the deceased's children. View "Metropolitan Life Insurance Co. v. Melin" on Justia Law

The Eighth Circuit dismissed a petition for review challenging the denial of her application for asylum as untimely. The court held that it lacked jurisdiction to review the BIA's determination that petitioner did not establish an excuse for her late filing based on changed circumstances. In this case, the IJ was making a case-specific materiality determination, not announcing a per se rule. Neither the IJ nor the BIA engaged in an analysis of the statute or otherwise elaborated on the meaning of "changed circumstances," which foreclosed the possibility that this case presented a question of statutory interpretation for the court to review. View "Burka v. Sessions" on Justia Law

The 2013 Public Employment Labor Relations Act (PELRA) did not infringe on the First Amendment rights of a group of parents who provide home care services to their disabled children. PELRA applied to persons who provide in-home care to disabled Medicaid recipients, and authorized covered employees to organize and to designate by majority vote an exclusive representative to negotiate employment terms with the state. The parents complained that the Act unconstitutionally compelled them to associate with the exclusive negotiating representative.Determining that the parents had Article III standing, the Eighth Circuit affirmed the district court's judgment and held that, under Minnesota State Board for Community Colleges v. Knight, the current version of PELRA allowed the homecare providers to form their own advocacy groups independent of the exclusive representative, and it did not require any provider to join the union. Therefore, the state did not impinge on the parents' right not to associate by recognizing an exclusive negotiating representative. View "Bierman v. Dayton" on Justia Law

In a previous appeal, the Eighth Circuit held that portions of Minnesota's Next Generation Energy Act were unconstitutional in North Dakota v. Heydinger, 825 F.3d 912 (8th Cir. 2016). The State appealed the district court's determination on remand that plaintiffs were entitled to attorney's fees and award of $1,310,088 in fees and costs. The court affirmed the district court's order without opinion. View "North Dakota v. Lange" on Justia Law

The Eighth Circuit affirmed defendant's 240 month sentence after he pleaded guilty to receipt of child pornography. The court held that defendant's sentence was substantively reasonable where the district court carefully considered several factors when deciding to impose the statutory maximum sentence, as recommended by the Sentencing Guidelines. In this case, the district court considered that the plea deal allowed defendant to escape a longer sentence for sexually exploiting his girlfriend's thirteen year old daughter; defendant's distribution of child pornography; and defendant's lack of violent criminal history and demonstrated remorse. The court also held that the special condition of supervised release prohibiting defendant from viewing or possessing erotica or pornographic materials was not constitutionally vague or overbroad under the court's precedents. View "United States v. Sebert" on Justia Law

Plaintiff filed suit against corrections officials at Crossroads Correctional Center for violation of his Eighth Amendment rights under 42 U.S.C. 1983. The Eighth Circuit affirmed the jury's finding that the officials were deliberately indifferent to plaintiff's serious medical need by failing to take reasonable steps to abate the risk of harm that secondhand smoke posed to him. In this case, there was sufficient evidence to show that the officials violated plaintiff's Eighth Amendment rights by being deliberately indifferent to the fact that plaintiff's asthma was exacerbated by offenders smoking indoors. However, there was insufficient evidence to justify an award of punitive damages where plaintiff failed to show that the officials were motivated by evil motive or intent or showed callous indifference to plaintiff's rights. Therefore, the court vacated the award of punitive damages and remanded for further proceedings. View "Washington v. Denney" on Justia Law

The Eighth Circuit affirmed defendant's three year sentence for violating his supervised release conditions. In this case, while defendant was on supervised release for a burglary covered by the Major Crimes Act, he had several encounters with police and eventually admitted to using marijuana. The court held that defendant's sentence did not exceed the statutory maximum because his original crime, burglary, was a Class B felony under 18 U.S.C. 3559(a)(2). The court also held that defendant's three year revocation sentence was within the statutory maximum provided by 18 U.S.C. 3583(e)(3). View "United States v. Steele" on Justia Law