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

The Eighth Circuit affirmed defendant's conviction of possession of a firearm by a prohibited person. The court held that defendant knowingly and voluntarily waived his right to a jury trial when he pleaded guilty to misdemeanor domestic abuse in 2013. Therefore, defendant was barred from possessing the firearm. View "United States v. Ler Wah Guide" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for CyberPower in an action alleging breach of contract, fraud, and unpaid wages. Plaintiff alleged that CyberPower breached a Compensation Agreement that secured his employment until the company reached a specific monetary sales threshold. The court held that there was no ambiguity on the question of whether CyberPower clearly intended to modify plaintiff's at-will status with the Compensation Agreement where the text of the agreement indicated that it governed only compensation. The court rejected plaintiff's remaining arguments. View "Ayala v. CyberPower Systems (USA), Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to a prosecutor and judge in a civil rights action alleging that defendants conspired to deprive plaintiff of his constitutional rights during criminal proceedings related to a 1990 homicide. The court held that the prosecutor was entitled to absolute immunity because the only supported instances of misconduct occurred after he was appointed special prosecutor and were intimately associated with the judicial phase of the criminal process. Likewise, the judge was entitled to absolute judicial immunity as any evidence of alleged misconduct on his part related directly to his official role as a judge. View "Woodworth v. Hulshof" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion for a sentence reduction under 18 U.S.C. 3582(c)(2). The court held that defendant was not eligible for a reduction where the district court correctly concluded that USSG 5G1.3(b) and a sentence adjustment for time served on an undischarged term of imprisonment did not enter into the calculation of Helm’s amended guideline range. Therefore, defendant's current sentence of 96 months was less than his amended guideline range of 110 to 137 months. View "United States v. Helm" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiffs' 42 U.S.C. 1983 complaint as time-barred. The court held that plaintiffs' claims accrued in October 2011, when they were notified of the allegedly discriminatory decision to install the grinder systems instead of gravity systems at their residences. As such, the installation of the pumps and plaintiffs' continuing responsibility for the additional expenses they entailed, were delayed but inevitable consequences of that decision. Consequently, plaintiffs were on notice as of 2011 and their limitations period expired in October 2014. Therefore, plaintiffs' complaint was time-barred because they did not file this action until May 2016. View "Humphrey v. Eureka Gardens Public Facility Board" on Justia Law

Defendant pleaded guilty to possession of a firearm as an unlawful user of a controlled substance and was sentenced to 31 months in prison and three years of supervised release. On appeal, defendant challenged the district court's imposition of two conditions that limited his freedom to have contact with his minor daughter and the daughter's mother. The court affirmed the district court's judgment, holding that the conditions were reasonably related to the relevant sentencing factors and were reasonably necessary restrictions on defendant's liberty. View "United States v. Stelmacher" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence obtained from his vehicle after he pleaded guilty to drug trafficking charges. In this case, a police drug dog instinctively lunged into defendant's vehicle and eventually found drugs in the car. The court held that, assuming for the sake of analysis that the dog's entry into the vehicle was a search under the Fourth Amendment, the search was justified by probable cause to believe that the car contained contraband. In this case, officers had no responsibility to close the car's door after defendant's companion opened it and voluntarily exited the car. The court explained that, insofar as the dog's ability to perceive the odor of drugs from outside the car was enhanced by the open door, the situation was created voluntarily by the passenger, and there was no unlawful search in leaving the door open. View "United States v. Pulido-Ayala" on Justia Law

The Eighth Circuit affirmed defendant's conviction of evasion of payment of taxes and corruptly endeavoring to impede enforcement of Internal Revenue laws. The court held that the district court adequately warned defendant of the dangers of self-representation and did not err in finding that he understood them and knowingly waived his right to counsel. The court also held that the district court did nor err giving Eighth Circuit Pattern Jury Instruction No. 2.23, which instructs the jury that where a defendant represents himself, it may only consider his testimony as evidence. View "United States v. Stanley" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment dismissing plaintiffs' Fourteenth Amendment and wrongful death claims, as well as plaintiffs' claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, et seq., and the Rehabilitation Act (RA), 29 U.S.C. 701, et seq. Plaintiffs filed suit after Jereme Hartwig committed suicide by hanging himself with a bed sheet in his cell when he was confined at the St. Louis County Justice Center. The court held that plaintiffs failed to show that any defendant was deliberately indifferent to a substantial risk that Hartwig would commit suicide; the clinical psychologist's professional judgment, even if negligent, fell well short of deliberate indifference; the corrections officer's failure to recall the details of her monitoring at a deposition three years later did not create a genuine issue that she failed to conduct the hourly monitoring of inmates under the jail's suicide prevention policy; in regard to the Missouri wrongful death claim, the jailer performed her duties in accordance with the suicide prevention policy and did not breach a ministerial duty; and the ADA and Rehabilitation Act claims failed to state a claim. View "A.H. v. St. Louis County, Missouri" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to making a false statement to a government agency and aggravated identity theft. The court held that the district court did not procedurally err by basing the sentence on erroneous findings and unconstitutional factors. In this case, the district court was not obligated to credit defendant's claim that he absconded from supervision in California because he feared the "mob" and defendant's argument that he was punished for indigence was unsupported. The court also held that the sentence was substantively reasonable where the district court weighed the 18 U.S.C. 3553(a) sentencing factors, and the district court's upward variance going from 12 months to 24 months when the statutory maximum was 60 months was reasonable. View "United States v. Marshall" on Justia Law