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

The Prison Litigation Reform Act's (PLRA) gatekeeper function against frivolous suits does not require a prison inmate to make a showing of a physical injury caused by an unconstitutional act. Rather, in the Eighth Amendment context, in order to recover compensatory damages, the PLRA requires a showing of harm caused by some unconstitutional conduct that amounted to deliberate indifference and an accompanying showing of physical injury.In this prisoner medical needs case, plaintiff appealed the district court's judgment awarding him only nominal and no punitive damages. The district court held that defendants violated plaintiff's Eighth Amendment rights by their deliberate indifference to his serious medical needs while he was in their custody, but that the PLRA precluded plaintiff's recovery of compensatory damages because he failed to meet 42 U.S.C. 1997e(e)'s physical injury threshold.The Eighth Circuit held that plaintiff's severe pain resulted from an actual physical injury when an officer's takedown move broke his shoulder, and thus plaintiff met the PLRA's physical injury requirement under section 1997e(e). Therefore, the court reversed and remanded with instructions for the district court to calculate compensatory damages that result from the pain differential, if any, that plaintiff experienced from having to take non-prescription pain relievers instead of the ten prescribed hydrocodone tablets. Finally, the district court did not abuse its discretion by denying punitive damages. View "McAdoo v. Martin" on Justia Law

The Eighth Circuit reversed the district court's grant of summary judgment to officers in a 42 U.S.C. 1983 action alleging unlawful arrest and excessive force. The court held that, accepting plaintiff's version of the events as true, the officers' use of force was objectively unreasonable. In this case, the officers suspected plaintiff of making a false statement, plaintiff was neither fleeing nor actively resisting arrest, plaintiff posed no threat to the security of the officers or the public, and the officers made the arrest by grabbing plaintiff by the throat and using a baton with sufficient force to break his arm. In regard to the unlawful arrest claim, the court also held that it was objectively unreasonable to believe that there was probable cause to arrest plaintiff where plaintiff's statement that his sister intentionally drove her car over his foot was not a false report justifying his arrest. The court remanded for further proceedings. View "Michael v. Trevena" on Justia Law

Plaintiffs brought a class action against Bluestem, alleging that the company engaged in unscrupulous business practices in violation of federal and state laws. The Eighth Circuit agreed with Bluestem that all of plaintiffs' claims fell within the scope of the arbitration clause. The court held that the agreements contained broad arbitration clauses and plaintiffs' state-law usury, state and federal financial disclosure and state-law unjust enrichment claims all fell within the scope of the arbitration agreements. Accordingly, the court remanded with directions to order arbitration on those claims. View "Parm v. Bluestem Brands, Inc." on Justia Law

Plaintiff Jeffery Oppedahl and his family filed suit against Mobile Drill after Jeffery was injured in an accident involving a truck-mounted drill auger that left him a quadriplegic. The Eighth Circuit affirmed the district court's grant of summary judgment to Mobile Drill on plaintiffs' negligent entrustment claim involving the auger and the related consortium claims. The court held that the refurbishment exception did not apply here and that the district court did not err in dismissing plaintiffs' negligence and strict liability claims based on the running of the Iowa statute of repose. Even if the exception applied, plaintiffs' claim would still be barred where the existing case law in which courts have adopted a refurbishment exception to statutes of repose requires that the refurbishment be completed by the party being held accountable for the harm. In this case, it was IDOT, not Mobile Drill, that conducted the auger refurbishment.The court also held that the Iowa Supreme Court likely would not apply negligent entrustment against a product manufacturer when the claim relates to the sale of the product. Assuming that negligent entrustment applied, plaintiffs' claim failed where there was insufficient evidence to support a claim that Mobile Drill had knowledge that IDOT would use the auger in a manner involving unreasonable risk of physical harm or that it was foreseeable to Mobile Drill that IDOT would use the auger in an unsafe way. View "Oppedahl v. Mobile Drill International Inc." on Justia Law

The Eighth Circuit reversed the district court's denial of a petition for habeas relief based on petitioner's claim that he is intellectually disabled. In this case, the district court did not have the benefit of the Supreme Court's decision in Moore v. Texas, 137 S. Ct. 1039 (2017), when it conducted its evidentiary hearing and issued its order. Accordingly, the court remanded for the district court to consider petitioner's claim in light of Moore. View "Jackson v. Kelley" on Justia Law

Under the removal statute, 28 U.S.C. 1447(c), if at any time before final judgment it appears that the district court lacks subject matter jurisdiction, the case shall be remanded. The Eighth Circuit vacated the district court's dismissal of a putative class action alleging that Nomax violated the Telephone Consumer Protection Act (TCPA), by transmitting twelve advertisements to the Heart Center by fax without including a proper opt-in notice on each advertisement. The court held that Heart Center lacked Article III standing, but that the proper disposition was remand to state court under section 1447(c). Accordingly, the court remanded with instructions to return the case to state court. View "St. Louis Heart Center, Inc. v. Nomax, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Union Pacific in an action brought by plaintiff under the Federal Railway Safety Act, alleging that he was terminated for engaging in a protected activity. The court held that, viewing the evidence in the light most favorable to plaintiff, a reasonable jury could not find that retaliation for his reporting of his workplace injury was a contributing factor to his separation from employment with Union Pacific. Rather, his employment ended because of his absenteeism and his inability to complete the steps necessary for reinstatement. The court also held that plaintiff did not provide proof by a preponderance of the evidence that his separation from employment with Union Pacific was the result of retaliation for his seeking medical treatment. View "Hess v. Union Pacific Railroad Co." on Justia Law

The Eighth Circuit affirmed defendant's conviction of two counts of abusive sexual contact. The court held that simply submitting a proposed instruction without objecting to the district court's refusal to give it did not preserve the issue for appeal and the issue was subject to plain error review; the district court did not plainly err in refusing defendant's proposed instruction regarding equal inferences in criminal cases where the instruction was another way of explaining reasonable doubt and the jury had been properly instructed on reasonable doubt; defendant failed to preserve his objection to a forensic examiner's testimony vouching for the truthfulness of the victim's statements and any prejudicial effect was cured by the district court's jury instructions; and, to the extent the forensic examiner's testimony was irrelevant, defendant failed to show plain error. View "United States v. Janis" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's complaint for failure to state a claim. Plaintiff alleged that his former employer, Wells Fargo, breached their fiduciary duty under the Employment Retirement Income Security Act (ERISA). The court held that the district court correctly determined that plaintiff's omission of any meaningful benchmark in his complaint meant that he failed to allege any facts showing the Wells Fargo Target Date Funds were an imprudent choice. In this case, plaintiff did not plead that the Funds were underperforming and his conclusory allegations of bad conduct did not save the complaint from its deficient pleading. Therefore, plaintiff failed to state a claim for relief under ERISA. View "Meiners v. Wells Fargo & Co." on Justia Law

The Eighth Circuit affirmed the district court's adverse grant of summary judgment to plaintiff on his claims under 42 U.S.C. 1983 and state law. The district court granted summary judgment to defendant, finding that he was entitled to qualified immunity because his use of deadly force was justified under the circumstances. The district court relied on plaintiff's criminal conviction for assaulting defendant and on defendant's testimony.The court rejected plaintiff's argument that the court should create an evidentiary presumption at the summary judgment stage against an officer who fails to use audio or video recording equipment that he has been issued; the court recognized the unique evidentiary problem of a case involving the use of force in which only one side can tell the story, but declined to adopt such a radical solution; and, even construing the record in plaintiff's favor, defendant's use of force was objectively reasonable where plaintiff posed an immediate threat to defendant's safety and was actively resisting arrest. Consequently, plaintiff's state law claims also failed. View "Church v. Anderson" on Justia Law