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

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

The Eighth Circuit affirmed defendant's conviction and 120 month sentence of being a prohibited person in possession of a firearm and ammunition. The court affirmed the denial of defendant's motion to suppress evidence seized from his home where officers had a reasonable belief that defendant's girlfriend had apparent authority to consent to their entry into the house with her, and that entry to accompany the girlfriend while she collected her belongings to move elsewhere was directly related to the entry that defendant's grandmother authorized in her initial call for assistance; the district court did not abuse its discretion by admitting a jail recording of a telephone conversation between defendant and his girlfriend; the evidence was sufficient to support the jury's verdict; the district court did not abuse its discretion in considering the jail calls and grand jury testimony in finding that defendant was a habitual domestic abuser with a history of displaying weapons; the district court did not clearly err in finding that defendant was a habitual domestic abuser who had brandished firearms on multiple occasions; and the district court did not abuse its substantial sentencing discretion. View "United States v. Cross" on Justia Law

Plaintiff filed suit alleging that he was improperly rejected for the position of Criminal Investigator with the USPS in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and that he should have been given preference for the position due to his status as a veteran. The district court granted the Postmaster General’s motion to dismiss the action under Federal Rule of Civil Procedure 12(b)(6). The Eighth Circuit held that the district court erred in dismissing the ADEA claim because plaintiff alleged a prima facie case of discrimination where he demonstrated that he had the educational and professional experience required for the position. Accordingly, the court reversed as to the ADEA claim and remanded for further proceedings. The court affirmed in all other respects. View "McPherson v. Brennan" on Justia Law

The Eighth Circuit considered this trademark dispute on remand. In the previous appeal, the court asked the district court to address state-law questions pertaining to the availability of attorney's fees and the ownership of a contested trademark. The district court entered orders on those questions and this appeal followed. The court held that the district court erred in determining plaintiff was entitled to attorney's fees under Iowa common law. In this case, defendant's misrepresentation to the patent office was improper, but its conduct did not rise to the level of being tyrannical, cruel, or harsh under Iowa common law. Finally, the briefs and oral arguments lead the court to conclude that defendant owned a license to use the PAKSTER mark in connection with injection-molded chicken coops, injection-molded egg baskets, and injection-molded egg flats. Accordingly, the court reversed and remanded with instructions. View "East Iowa Plastics, Inc. v. PI, Inc." on Justia Law

Defendant was committed to the custody of the Missouri Department of Mental Health for treatment after he was found not guilty by reason of insanity under Missouri state law when he fired shots in the direction of two officers. Plaintiff filed a 42 U.S.C. 1983 action against defendants, alleging that he had been deprived of his substantive due process right to liberty during his in-patient commitment as well as during his period of conditional release. The Eighth Circuit affirmed the district court's grant of summary judgment for defendants based on qualified immunity, holding that the evidence viewed in the light most favorable to plaintiff did not show that defendants' actions "shocked the conscience." In this case, plaintiff gave no reason to believe any medical opinion was offered in bad faith and the evidence did not suggest that any of defendants' representations to the circuit court were inspired by malice or otherwise untruthful. Furthermore, the ultimate decision to grant release lay with the circuit court and it repeatedly declined to grant release. View "Andrews v. Schafer" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for NPS, in an action alleging violation of the Administrative Procedure Act (APA), 5 U.S.C. 706, in establishing the boundaries of the Niobrara Scenic River Area (NSRA), both generally and with respect to his property. The court held that NPS engaged in a methodical, time-consuming boundary-drawing process, and it used the appropriate statutory standard to identify oustandingly remarkable values and it drew a boundary line that sought to protect those values. Furthermore, there was no evidence in the record that would lead the court to conclud that NPS subjected plaintiff to disparate treatment or acted in bad faith. View "Simmons v. Smith" on Justia Law

The Eighth Circuit affirmed the district court's order transferring defendant for criminal prosecution as an adult under 18 U.S.C. 5032. The court held that the district court did not abuse its discretion by deciding to transfer where the district court made specific findings with respect to each statutory factor. In this case, the juvenile's age, nature of the offenses, his role in the offenses, and his intellect and maturity weighed in favor of transfer. The court also held that it was not required to hold an evidentiary hearing where the district court accepted the magistrate judge's credibility findings and independently weighed the statutory factors. View "United States v. Juvenile Male" on Justia Law

The Eighth Circuit affirmed the Commissioner's denial of disability benefits and dismissal of plaintiff's complaint under 42 U.S.C. 405(g). The court held that the record overwhelmingly supported the determination that plaintiff was not disabled, and the court found no legal error in the ALJ's analysis. In this case, plaintiff was a stay-at-home father married to a physician; he cared for and transported his four young children, performed housekeeping tasks, managed the sale of the family's house, and negotiated with the builders of a new house; and the record demonstrated that not only did he participate in these varied activities, but that he was able to navigate the obvious stresses inherent in these activities when compliant with his prescribed medications. The court held that the ALJ's statements in the step-two and three analyses was not inconsistent with the ALJ's step-four Residual Functional Capacity determination. View "Chismarich v. Berryhill" on Justia Law

Plaintiff filed suit against defendants, asserting wrongful death claims under the public liability provision of the Price-Anderson Nuclear Industries Indemnity Act, alleging exposure to nuclear radiation during World War II and the Cold War. The district court granted defendants' motion to dismiss claims brought on behalf of persons who passed away more than three years prior to the filing of suit. The Eighth Circuit affirmed, holding that the claims were untimely under Missouri's statute of limitations, Mo. Rev. Statutes Section 537.100, which did not permit tolling. The court also held that, to the extent equitable estoppel due to fraudulent concealment might be permitted under Missouri law, plaintiffs failed to raise the issue of fraudulent concealment in the district court. Finally, the provisions in the Comprehensive Environmental Response, Compensation, and Liability Act governing actions brought under state law were inapplicable to the present claims. View "Halbrook v. Mallinckrodt, LLC" on Justia Law

The Eighth Circuit affirmed defendant's conviction for one count of receiving child pornography and one count of possessing child pornography. The court held that the district court properly admitted defendant's statements that he viewed child pornography; even if the evidence was admitted as prior bad acts, the evidence was relevant and showed that he acted knowingly; and the evidence was sufficient to convict defendant because the existence of thumbnails was sufficient to establish possession of child pornography. View "United States v. Moberg" on Justia Law