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

The Eighth Circuit held that defendant's challenge to his revocation sentence was moot because he had served the sentence and been release from custody. The court vacated the mandatory condition of supervised release requiring defendant to participate in an approved program for domestic violence, holding that there was lack of evidence supporting the condition and a complete lack of explanation for its imposition. Therefore, the district court erred and the error affected defendant's substantial rights. View "United States v. Hill" on Justia Law

The Eighth Circuit affirmed defendant's conviction of being a felon in possession of a firearm. The court held that evidence regarding the firearm's operability was properly excluded because it would have yielded substantial juror confusion without having significant probative value regarding the issue of weapon design; the firearm, a .380 Cobra, qualified as a firearm for purposes of the statute despite its missing pieces and broken parts; and proof that the firearm was operable was not required because the language of 18 U.S.C. 921(a)(3) requires only that the weapon was designed to expel a projectile by the action of an explosive. The court held however that the district court erred by sentencing defendant under the Armed Career Criminal Act in light of the court's en banc decision in United States v. Naylor, 887 F.3d 397 (8th Cir. 2018) (en banc). Therefore, the court vacated the sentence and remanded for resentencing. View "United States v. Hardin" on Justia Law

The Eighth Circuit affirmed Defendants Benton, Tate, and Kesari's conviction of causing false records, causing false campaign expenditure reports, engaging in a false statements scheme; and conspiring to commit these offenses. Benton served as campaign chairman in Ron Paul's 2012 presidential campaign, Tate served as campaign manager, and Kesari served as deputy campaign manager. The court held that there was sufficient evidence to convict defendants; the jury was entitled to infer from the facts that Benton and Tate had knowingly and willfully caused Commission reports to be filed which falsely reported the payments to a senator for his endorsement as payments to ICT for audio/visual services; the court rejected defendants' arguments that the reporting requirements were so vague or confusing that the court should either apply the rule of lenity or determine that criminal enforcement was not appropriate in this case; Kesari's counts were not multiplicitious; the district court did not abuse its discretion in denying Tate's motion to sever his trial from his codefendants; and the court rejected challenges to the jury instructions, evidentiary challenges, and a Jencks Act claim. View "United States v. Benton" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to unlawful reentry as a removed alien after an aggravated felony conviction. The court held that the district court did not plainly err by increasing defendant's base offense level by eight under USSG 2L1.2(b)(1)(C), based on his previous burglary convictions under California law. The court upheld the aggravated felony enhancement under section 2L1.2(b)(1)(C), and held that defendant could not maintain his vagueness challenge under the reasoning in Johnson v. United States, 135 S. Ct. 2551 (2015), and Beckles v. United States, 137 S. Ct. 886 (2017). The court also held that the sentence was not substantively unreasonable where the district court weighed the 18 U.S.C. 3553(a) factors. View "United States v. Sanchez-Rojas" on Justia Law

The Eighth Circuit granted rehearing en banc and vacated the panel opinion in Faidley v. United Parcel Serv. of Am., Inc., 853 F.3d 447 (8th Cir. 2017).The court affirmed the district court's grant of summary judgment for UPS in an action alleging that UPS violated the Iowa Civil Rights Act (ICRA) when it placed him on medical leave from his long time position as a package car driver and then failed to reasonably accommodate his physical disability. The court held that UPS did not violate the Americans with Disabilities Act (ADA) or ICRA by refusing plaintiff's request for an eight-hour work day because that accommodation would have made him unqualified to perform the essential job functions of a package car driver. The court also held that no reasonable jury could find that UPS's decision to instead pursue reassignment to full-time jobs which plaintiff had suggested, and for which he was immediately qualified, was disability discrimination; UPS did not violate the ADA when it refused to accommodate an expert's restrictions of working certain hours per day; and a reasonable jury could not find that UPS acted in bad faith. View "Faidley v. United Parcel Service" on Justia Law

The Eighth Circuit reversed the district court's denial of defendant's motion for summary judgment based on qualified immunity and state statutory immunity. Plaintiff had filed suit against defendant and others, alleging claims under 42 U.S.C. 1983 for deliberate conduct that shocks the conscience and a state law claim for outrage. The court held that plaintiff failed to demonstrate sufficient facts to give rise to a triable question as to an alleged violation of a constitutional right. In this case, while law enforcement corruptly conducting an investigation with a view towards presenting knowingly false charges against an innocent person might well represent an instance of conscience-shocking behavior, plaintiff has not presented any evidence beyond surmise that would allow a reasonable finder of fact to conclude that this happened. Therefore, the district court erred in denying qualified immunity to defendant. Likewise, plaintiff's state law claim failed for the same reasons as the federal claim. The district court did not err in denying summary judgment for defendant on the ground of state statutory immunity. View "Williams v. Mannis" on Justia Law

Plaintiffs filed separate class action complaints against TD Ameritrade, alleging that the company breached its duty of best execution when it routed client orders to buy and sell securities to trading venues that paid TD Ameritrade top dollar for its order flow. The Eighth Circuit affirmed the district court's dismissal of the complaint because the state law claims were precluded by the Securities Litigation Uniform Standards Act of 1998 (SLUSA). In this case, the gravamen of plaintiffs' claims involved a misrepresentation or omission of a material fact in connection with the purchase or sale of a covered security. View "Zola v. TD Ameritrade, Inc." on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to drug and firearms charges. The court held that no plain procedural error occurred, and any such error would have been harmless because the district court sentenced defendant to the statutory minimum. Furthermore, the sentence was not subject to review for reasonableness because it was statutorily imposed. In this case, there was no basis for defendant's claim that his guilty plea to all three counts was not knowing and voluntary or that the district court denied his Sixth Amendment right to a jury trial. Finally, the court granted counsel's motion to withdraw. View "United States v. Padilla" on Justia Law

The Eighth Circuit affirmed on remand the district court's conclusion that Exemption 4 of the Freedom of Information Act (FOIA) did not apply to SNAP redemption information. The court rejected the USDA's claim that release of the relevant information would cause competitive injury among the covered grocery retailers and held that the claim was speculative. In this case, evidence showed that the contested data—which was nothing more than annual aggregations of SNAP redemptions—lacked the specificity needed to gain material insight into an individual store's financial health, profit margins, inventory, marketing strategies, sales trends, or market share. Furthermore, there was no meaningful evidence that retailers would end their SNAP participation if the contested data were released. View "Argus Leader Media v. Food Marketing Institute" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to defendant in an action alleging claims of negligent misrepresentation, unjust enrichment, and denial of equitable relief. The court held that the district court did not err in granting defendant's summary judgment motion on the negligent misrepresentation claim because Lonesome Dove had not alleged any specific damage from the misrepresentation; the district court did not err by granting summary judgment as to the unjust enrichment claim because Lonesome Dove failed to present specific facts to illustrate any benefit to defendant other than the list of things in the contract; the district court did not abuse its discretion by denying Lonesome Dove equitable relief where Lonesome Dove had an adequate remedy at law in this case; and the district court did not err by denying Lonesome Dove's motion for a new trial where the verdict was not against the clear weight of the evidence. View "Lonesome Dove Petroleum, Inc. v. Holt" on Justia Law