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

Defendant was convicted of two counts of sex trafficking by use of force, threat, fraud, or coercion; three counts of sex trafficking of a minor; twelve counts of producing child pornography of minors; two counts of receiving child pornography; and one count of commission of a felony offense involving a minor while required to register as a sex offender. The Eighth Circuit affirmed defendant's convictions and the order of restitution to K.M.L. In this case, the court held that the district court did not err in denying defendant's motion to suppress evidence from his cell phones and the evidence was sufficient for the jury to find him guilty of committing a felony offense involving a minor while required to register as a sex offender. Furthermore, there was sufficient evidence to show that defendant harmed K.M.L. and the request for restitution was appropriate. However, the court vacated the order of restitution to Anoka County, holding that the district court abused its discretion where there was no evidence that the County paid for K.M.L.'s residential treatment. View "United States v. Charles" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for attempted bank robbery and bank robbery. The court held that the evidence was sufficient to support the jury's guilty verdicts where the jury determined that defendant was the person who robbed the Charter Bank and attempted to rob the Wells Fargo Bank. The court also held that defendant's 150 month sentence was substantively reasonable where the district court had wide latitude to weigh the 18 U.S.C. 3553(a) factors and did not abuse its discretion in sentencing defendant for crimes that were quite serious. View "United States v. Tong Moua" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of the complaint, which alleged violations of the Individuals with Disabilities Education Act, the Rehabilitation Act of 1973, and 42 U.S.C. 1983. The court held that the Rehabilitation Act and section 1983 claims concerned the denial of a public education and thus plaintiffs were required to exhaust their administrative remedies first. Because plaintiffs failed to do so, these claims were properly dismissed. Likewise, the exhaustion requirement applied to the IDEA claim and no exception to the exhaustion requirement applied in this case. View "Smith v. Rockwood R-VI School District" on Justia Law

The Eighth Circuit affirmed the denial of plaintiff's claims for a period of disability, disability insurance benefits, and supplemental security income. The court held that Social Security Ruling (SSR) 00-4p makes clear that before relying on Vocation Expert (VE) evidence, adjudicators must identify and obtain a reasonable explanation for any conflicts between such evidence and the DOT. However, SSR 00-4p did not impose a duty on the ALJ to obtain a reasonable explanation when the VE simply testifies to information not found in the DOT—but that does not conflict with it. Therefore, the court agreed with the Commissioner that unless a VE's testimony appears to conflict with the DOT, there is no requirement that an ALJ inquire as to the precise basis for the expert's testimony regarding extra-DOT information. In this case, the ALJ described plaintiff's limitations to the VE, the VE responded with possible jobs, and the VE's testimony did not conflict with the DOT. Therefore, the ALJ was entitled to rely on the testimony and substantial evidence supported the agency's finding that plaintiff was not disabled. View "Courtney v. Commissioner" on Justia Law

Plaintiff sought a certificate of innocence under 28 U.S.C. 2513 and, simultaneously but separately, filed the instant case against Defendants Garrett and Sharp, among others, under 42 U.S.C. 1983. The jury subsequently returned a verdict in favor of plaintiff in the section 1983 action and defendants appealed. The Eighth Circuit affirmed, holding that the district court did not err in excluding evidence of plaintiff's prior arrests on drug offenses; in permitting limited testimony by the U.S. Attorney who prosecuted defendant Garrett as the evidence helped the jury understand the criminal charges which had been filed; and in permitting plaintiff to introduce expert testimony on police practices from a psychologist who was also a former police captain and police psychologist. The court also held that there was sufficient evidence to establish a conspiracy to violate plaintiff's civil rights and to support the jury's verdict on his state law claims for false imprisonment and malicious prosecution. Finally, the court rejected challenges to jury instructions on conspiracy, malicious prosecution, and damages. View "Holmes v. Garrett" on Justia Law

The Bankruptcy Appellate Panel held that it may not consider on appeal the merits of a matter for which there would not have been jurisdiction in the bankruptcy court and thus the panel did not consider the merits of the McDougalls' (defendants) arguments on appeal. In this case, the McDougalls did not bring a counterclaim or cross-claim and could not challenge a judgment in favor of defendant AgCountry and against debtors. The McDougalls only sought to determine whether they held title to a parcel of land free of AgCountry's lien and did not seek anything from the bankruptcy court on behalf of or from debtors or their estate. Therefore, the panel remanded with instruction to dismiss the claim regarding the validity of AgCountry's lien against the Home Quarter. View "McDougall v. Ag Country Farm Credit Services" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence recovered from a cell phone after he pleaded guilty to sexual exploitation of a child. The court held that defendant's girlfriend was acting as a private citizen, rather than a government agent, when she retrieved the phone from his vehicle. Therefore, the Fourth Amendment was not applicable in this case, because the retrieval of the phone amounted to private conduct rather than government action. The court reasoned that the girlfriend did not search the vehicle at the officer's request and there was insufficient evidence to show that she was motivated solely or even primarily by the intent to aid the officers. View "United States v. Highbull" on Justia Law

The Eighth Circuit affirmed the denial of social security disability insurance benefits on remand. The court held that the ALJ did not err in discounting the opinion of plaintiff's treating physician as not supported by objective medical evidence in the administrative record. Furthermore, the opinion was contrary to medically supported opinions of two specialists. The court agreed with the district court that the vocational expert identified another job plaintiff could perform with limited hand functioning, and there was nothing in the record suggesting that his impairments require that he be limited to occasional rather than frequent handling. View "Winn v. Commissioner" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence of unlawful possession of a firearm as a previously convicted felon. The court held that the district court did not err by admitting the testimony of a witness that she saw defendant carrying a handgun before the search because it was relevant and the jury could determine how much weight to give the testimony. The court also held that defendant's prior convictions for Minnesota second degree assault qualified as violent felonies under the Armed Career Criminal Act; the ACCA's force clause was not unconstitutionally vague; and the district court did not err in finding that defendant was an armed career criminal. View "United States v. Pendleton" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity at summary judgment for an officer in a 42 U.S.C. 1983 action alleging excessive force. The court held that the district court did not err in finding the officer's action in tasing plaintiff constituted a violation of his Fourth Amendment right to be free from excessive force and that the right was clearly established at the time. In this case, it was clearly established that intentionally tasering, without warning, an individual who has been stopped for a nonviolent misdemeanor and who was not resisting or fleeing while his hands were visible violated the Fourth Amendment right to be free from excessive force. View "Thompson v. Singleton" on Justia Law