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

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

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to being a felon in possession of a firearm and ammunition. The court held that defendant's prior conviction for second degree domestic assault in violation of Mo. Rev. Stat. 565.073 qualified as a crime of violence under the Sentencing Guidelines, and that the government's evidence at sentencing was sufficient to show that defendant was convicted of violating Mo. Rev. Stat. Sec. 565.073.1(1), a crime of violence under Guidelines Sec. 4B1.2(a)(1)'s force clause. View "United States v. Doyal" on Justia Law

The Eighth Circuit affirmed the district court's judgment for Wells Fargo in a third lawsuit arising between the parties involving the foreclosure of plaintiff's property. Plaintiff alleged that the bank violated Minn. Stat. 582.043 when it continued with foreclosure proceedings after he had submitted an application for a loan modification, and Wells Fargo brought a counterclaim against him for breach of a prior settlement agreement. The court held that plaintiff's claim was barred by res judicata because he could have brought the claim during the 2013 foreclosure litigation and he had an opportunity to litigate the claim fairly and fully if he had timely raised it. The court also held that the district court did not err in granting judgment on the pleadings for Wells Fargo on the bank's counterclaim where plaintiff was not discharged from his obligation to perform under the settlement agreement. Finally, the district court did not abuse its discretion by denying leave to amend on futility grounds. View "Lansing v. Wells Fargo Bank, N.A." on Justia Law

Charter school parents sought to intervene in the St. Louis public school desegregation litigation to enforce a 1999 Desegregation Settlement Agreement. The Eighth Circuit reversed the district court's denial of the charter parents' motion to intervene, holding that the charter parents had standing. In this case, their pleading alleged that the charter schools will suffer a loss of funding and a decline in funding if plaintiffs prevailed and tens of millions of dollars could be transferred from the charter schools. Therefore, such an injury was neither conjectural nor hypothetical, and was sufficiently imminent to constitute an injury in fact. The court also held that the charter parents have established the elements of traceability and redressability. The court remanded for the district court to determine in the first instance whether the charter parents meet the requirements under Federal Rule of Civil Procedure 24 for intervention as of right or for permissive intervention. View "Ross v. Special Administrative Board of the Transitional School District of the City of St. Louis" on Justia Law

The Eighth Circuit affirmed the bankruptcy appellate panel's ruling affirming the bankruptcy court's order determining that Starion Financial was entitled to $83,122.95 in attorney fees and costs incurred to collect on its secured debt in the course of debtors' bankruptcy proceedings. The court held that the parties had an agreement for fees within the meaning of 11 U.S.C. 506(b), and the bankruptcy court did not err in finding that Starion Financial's application for attorney fees, while untimely, was not abusively so. Because no prejudice to debtors resulted, the fee application was properly allowed. View "McCormick v. Starion Financial" on Justia Law

This appeal arose from the DOL's investigation of possible violations of the Fair Labor Standards Act by La Piedad. The Eighth Circuit reversed the district court's grant of the DOL's motion to hold La Piedad in civil contempt for failing to produce documents identifying other businesses owned by La Piedad's shareholders. The court held that the DOL failed to meet its burden to introduce evidence that would support a subpoena to produce documents not in La Piedad's possession, custody, or control. View "Hugler v. La Piedad Corp." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to State Farm on plaintiff's bad faith tort claim and on an evidentiary ruling on the underinsured motorist coverage claim. The court held that the district court applied the proper legal standard of Arkansas substantive law, and that there was no genuine issue of material fact that State Farm's conduct did not constitute bad faith. The court also held that the district court did not err in excluding plaintiff's proposed evidence regarding State Farm's practice of denying claims as that evidence had no bearing on the amount of damages on plaintiff's underinsured motorist claim. View "Sims v. State Farm Mutual Automobile Insurance Co." on Justia Law

The NAACP filed suit against the school district for voter dilution under section 2 of the Voting Rights Act of 1965 (VRA). The Eighth Circuit affirmed the district court's finding that (1) the NAACP had proved the preconditions for a section 2 vote dilution claim, and (2) the totality of the circumstances indicated that the district's black voters had less opportunity to elect their preferred candidate than other members of the electorate. The court held that the district court found a section 2 violation after engaging in the requisite precondition analysis and conducting a thorough totality-of-the-circumstances balancing. View "NAACP v. Ferguson-Florissant School District" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for DFJ on his age discrimination and retaliation claims brought under the Age Discrimination in Employment Act (ADEA); (2) disability discrimination and retaliation claims brought under the Americans with Disabilities Act (ADA); and (3) state-law claim for age and disability discrimination and retaliation brought under the Arkansas Civil Rights Act of 1993 (ACRA).The court held that plaintiff failed to exhaust his administrative remedies as to his federal claims where his termination played no part in the initial EEOC charge because the right-to-sue letter preceded the date of the termination; plaintiff's ACRA claim failed because no genuine issues of material fact exist on whether plaintiff was qualified to do the essential job functions of his position and whether the termination was due to his disability. The court also held that plaintiff's hostile work environment claim failed because the alleged harassment was not severe enough to support his claim, and plaintiff's ADA claims also failed because he was unable to perform the essential functions of his job, with or without accommodation, and he failed to show but-for causation as to retaliation. View "Moses v. Dassault Falcon Jet Corp." on Justia Law