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

The Eighth Circuit affirmed defendant's conviction of bank robbery, holding that the district court did not err by failing to suppress an in-court identification. The court explained that, even if the district court erred in not conducting a reliability analysis under Neil v. Biggers, 409 U.S. 188 (1972), defendant's arguments failed because the error was not plain under current law where the courts were divided as to whether a reliability analysis was required to admit an in-court identification. View "United States v. Shumpert" on Justia Law

Plaintiff, a former MLB player, filed suit alleging violations of the Driver's Privacy Protection Act (DPPA), 18 U.S.C. 2721-25, after an audit revealed that officers from over thirty departments had accessed his information more than 125 times. After the issuance of the Eighth Circuit's opinions in McDonough v. Anoka County, 799 F.3d 931 (2015), and Tichich v. City of Bloomington, 835 F.3d 856 (2016), plaintiff conceded that only his claims against the City of Bloomington and the City of Shakopee were timely and plausible. With respect to these claims, the court affirmed the district court's grant of defendants' motion to dismiss because plaintiff failed to plead sufficient facts to show an impermissible purpose by defendants. View "Berenguer v. Anoka County" on Justia Law

The Eighth Circuit affirmed defendant's 180 month sentence after he pleaded guilty to being a felon in possession of a firearm. The court held that the district court did not err in concluding that defendant's prior conviction for aggravated assault on a family member in violation of Ark. Code Ann. Sec. 5-26-306(a)(3) was a violent felony for purposes of sentencing under the Armed Career Criminal Act. Therefore, defendant had three prior violent felony convictions and could be sentenced under the mandatory minimum sentence pursuant to the Act. View "United States v. Pyles" on Justia Law

Smoky II filed a breach of contract suit against the city when it did not receive payment from the city on invoices related to curtailed energy (wind energy that was not actually produced because the producer was directed to reduce production). The Eighth Circuit affirmed the district court's judgment and held that the parties' contract provided that the city could be billed for economic curtailments; the district court did not err in holding the city liable for certain charges that it found to be "timely-billed;" the plain language of the Renewable Energy Purchase Agreement (REPA) supported the district court's interpretation of the meaning of "Emergency Curtailment;" the trial evidence clearly supported the district court's rejection of the city's theory regarding over-allocation of energy; and Smoky II waived the issue of substantial performance. View "Smoky Hills Wind Project II v. Independence, Missouri" on Justia Law

The Eighth Circuit affirmed the district court's denial in part of the University's motion to dismiss an action alleging violations of Title IX of the Education Amendments of 1972. The district court refused to dismiss the Title IX claims on the basis of sovereign immunity. The court agreed that the University waived its sovereign immunity under the Remedies Equalization amendment by accepting federal funds. View "Fryberger v. University of Arkansas" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to conspiracy to violate 18 U.S.C. 922(g)(1) (felon in possession of a firearm), in violation of 18 U.S.C. 371. The court held that the district court did not abuse its discretion in determining that defendant's federal sentence should be consecutive to the undischarged portion of his state sentence. The court also held that defendant waived his argument that the sentence was substantively unreasonable because he raised the argument for the first time in his reply. View "United States v. Benson" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to conspiracy to violate 18 U.S.C. 922(g)(1) (felon in possession of a firearm), in violation of 18 U.S.C. 371. The court held that the district court did not abuse its discretion in determining that defendant's federal sentence should be consecutive to the undischarged portion of his state sentence. The court also held that defendant waived his argument that the sentence was substantively unreasonable because he raised the argument for the first time in his reply. View "United States v. Benson" on Justia Law

The Eighth Circuit affirmed defendant's 228 month sentence after he pleaded guilty to attempted distribution of child pornography, attempted receipt of child pornography, and possession of child pornography. The court held that the district court properly concluded that defendant's sex-crimes convictions triggered an enhanced statutory sentencing range for each offense and that he qualified for a pattern-of-activity enhancement pursuant to USSG 2G2.2(b)(5). View "United States v. Grimes" on Justia Law

The Eighth Circuit affirmed defendant's 228 month sentence after he pleaded guilty to attempted distribution of child pornography, attempted receipt of child pornography, and possession of child pornography. The court held that the district court properly concluded that defendant's sex-crimes convictions triggered an enhanced statutory sentencing range for each offense and that he qualified for a pattern-of-activity enhancement pursuant to USSG 2G2.2(b)(5). View "United States v. Grimes" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence of the methamphetamine that an investigator found in defendant's luggage on an Amtrak train. The court held that the district court did not err in finding that the initial encounter with the investigator was consensual and did not constitute an unlawful seizure. Furthermore, the district court did not err in finding that defendant voluntarily consented to the search of his bag. View "United States v. Garcia" on Justia Law