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

The Eighth Circuit held that the district court erred in holding that the misstatement clause in the contested life insurance policy did not apply where it might (or would) reduce the benefits of an incontestable policy to zero. In this case, the policy contained a provision that the policy was incontestable after two years, as well as a provision which permitted the insurer to reduce the benefit to the amount the premium would have purchased at the insured's correct age. The court explained that it was not apparent from the language in the policy that the amount payable was limited to the benefits available under the policy the insured actually purchased if she was ineligible for it at her age. Therefore, the court affirmed the district court's denial of summary judgment to Farmers, but reversed its grant of summary judgment to plaintiff, remanding for further proceedings. View "Yang v. Farmers New World Life Insurance Co." on Justia Law

The DOL obtained a pre-bankruptcy judgment against debtor, providing that debtor breached his fiduciary duty under the Employee Retirement Income Security Act (ERISA). The DOL filed an adversary proceeding in debtor's Chapter 7 bankruptcy to have that judgment debt declared nondischargeable as a debt for defalcation while acting in a fiduciary capacity under 11 U.S.C. 523(a)(4).The Eighth Circuit affirmed the grant of summary judgment for the DOL. The court held that debtor had fiduciary obligations regarding the funds that had been withheld from wages for payment to HealthPartners. The court also held that the undisputed facts and unchallenged factual findings supported the conclusion that debtor committed defalcation in late March 2009 when he chose to use plan assets to pay himself and other corporate expenses instead of remitting those assets to HealthPartners. View "U.S. Department of Labor v. Harris" on Justia Law

The Eighth Circuit affirmed the district court's denial of habeas relief for petitioner, who received the death sentence after being convicted of murder and burglary. The court held that the district court did not err in concluding that petitioner was not entitled to relief on this Fifth Amendment self-incrimination claim under the Antiterrorism and Effective Death Penalty Act (AEDPA); the state courts did not unreasonably apply Strickland v. Washington in concluding that trial counsels' penalty phase efforts were not constitutionally deficient and the court need not address whether the state courts unreasonably concluded that there was no Strickland prejudice; the district court did not abuse its discretion in denying petitioner's motion to stay the habeas proceedings and file a second amended petition; the state court did not unreasonably apply clearly established federal law applying the Ex Post Facto Clause by permitting the victim's mother to give impact evidence; the state court's decision to reject the claim of ineffective assistance of appellate counsel because Simmons v. South Carolina, 512 U.S. 154 (1994), did not apply was not contrary to or an unreasonable application of clearly established federal law; the jury found three valid aggravating circumstances that clearly encompassed the facts and circumstances supporting its additional depravity-of-mind finding; and the court denied the application to file a second or successive petition. View "Rhines v. Young" on Justia Law

On remand from the United States Supreme Court, the Eighth Circuit reversed the district court's grant of summary judgment to defendants in light of Minnesota Majority v. Mansky, 849 F.3d 749, 753 (8th Cir. 2017).Plaintiffs filed suit against the Minnesota Secretary of State and others, challenging a statute prohibiting the wearing of political insignia at a polling place, Minnesota Statute 211B.11. This court reversed the dismissal of defendants' as-applied First Amendment claim. On remand, the district court granted summary judgment for defendants and this court affirmed. The Supreme Court then reversed and remanded, holding that the statute violates the Free Speech Clause of the First Amendment. View "Minnesota Voters Alliance v. Mansky" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to American Family in an action alleging breach of contract, negligent misrepresentation, and violation of Minnesota's consumer fraud statutes. The court held that American Family did not breach the contract because nothing in the policy imposed on American Family a contractual obligation to make objectively reasonable or accurate replacement cost estimates; American Family did not negligently misrepresent the replacement cost of plaintiffs home where, regardless of any breach of duty, no genuine dispute existed as to justifiable reliance upon the estimates; and plaintiffs could point to any promise, misrepresentation, or false statement made by American Family, let alone one that they relied upon, justifiably or unjustifiably, in deciding to purchase or renew the policy. View "Nelson v. American Family Mutual Insurance Co." on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for being a felon in possession of a firearm, possession with intent to distribute marijuana, and possession of a firearm in furtherance of a drug trafficking crime. The court held that the district court did not err by refusing to give a theory of defense jury instruction where the proposed instruction misstated the law, there was a lack of evidence negating defendant's specific intent, and the district court instructed the jury, without objection, as to the knowledge and intent elements of all three offenses. The court rejected defendant's Brady claim and held that there was no abuse of discretion in denying a new trial because there was no reasonable probability that the result of the proceeding would have been different had the lab reports been produced; defendant's claims of prosecutorial misconduct failed because the district court did not abuse its discretion by sustaining objections and the evidence of defendant's guilt was overwhelming; the district court did not err by sentencing defendant as a career offender; and, even had the district court erred in sentencing defendant as a career offender, the district court would have imposed the same sentence based on the 18 U.S.C. 3553(a) factors. View "United States v. Garrett" on Justia Law

The Eighth Circuit affirmed Defendant King's sentence and Defendant Raines' conviction and sentence for charges related to their involvement in the operation of a pill mill. The court rejected Raines' evidentiary challenges; the district court did not abuse its discretion by giving a willful blindness jury instruction; the district court did not abuse its discretion by refusing to provide Raines' good faith instruction; the evidence was sufficient for a jury to easily find that Raines was involved in a conspiracy to distribute controlled substances without an effective prescription; the district court did not clearly err in making its drug quantity calculations; the district court did not err by applying an abuse of trust enhancement to Raines' sentence; and both defendants' sentences were substantively reasonable. View "United States v. King" on Justia Law

The Eighth Circuit affirmed the district court's denial of social security disability benefits to plaintiff. The court held that the ALJ properly relied on testimony from the vocational expert's testimony that a certain needed modification is part of the functional workplace. In this case, the vocational expert testified based on her expertise that bariatric chairs were commonly provided to individuals in the workplace and identified jobs that an individual who, like plaintiff, needs a bariatric chair, could perform. Therefore, substantial evidence supported the ALJ's finding that jobs exist in the national economy that plaintiff could adjust to, and that finding did not result from an error of law. View "Higgins v. Commissioner" on Justia Law

In 2011, movant's 2006 sentence for drug and firearm possession was vacated. In this appeal, movant challenged the district court's denial of a certificate of innocence. The Eighth Circuit affirmed, holding that the district court's decision to credit a witness and find that movant did not prove his actual innocence was not completely capricious and without rational basis. The court also held that the district court did not abuse its discretion when it chose to rely on the trial record and other relevant facts presented by affidavits rather than conducting an evidentiary hearing. Finally, the district court did not err by denying a motion for relief from judgment under Federal Rule of Civil Procedure 60(b)(2) and (6). View "Holmes v. United States" on Justia Law

Plaintiff, an inmate at an Arkansas prison, filed suit against three prison officials for requiring him to work with deadly chlorine gas without proper training and safety gear. The district court granted summary judgment to the officials based on plaintiff's failure to exhaust his administrative remedies under the Prison Litigation Reform Act (PLRA).The Eighth Circuit, accepting plaintiff's declaration as true, held that Defendant Perry misled plaintiff and thus the formal grievance procedure was unavailable to plaintiff. Therefore, the court reversed the district court's judgment as to Defendant Murphy where plaintiff did not file his formal grievance in time. In regard to Defendant Romine and White, the court held that the informal complaint process was capable of use and could have provided some relief and thus the administrative exhaustion requirement applied regardless of whether the formal grievance procedure was later available to plaintiff. In the alternative, plaintiff failed to exhaust his remedies against Romine and White. Accordingly, the court affirmed the district court's judgment as to these two defendants. View "Townsend v. Murphy" on Justia Law