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

The Eighth Circuit vacated defendant's sentence and remanded for resentencing under the Armed Career Criminal Act (ACCA) after he pleaded guilty to being a felon in possession of a firearm. The court held that defendant's prior conviction under Minnesota law for simple robbery qualified as a violent felony for ACCA purposes because it required proof of the use, attempted use or threatened use of violent force. In this case, defendant had three simple robbery convictions and was subject to the enhanced sentence under the ACCA. View "United States v. Pettis" on Justia Law

The Eighth Circuit reversed the district court's grant of defendant's motion to suppress evidence found in his recreational vehicle (RV). The court held that the district court erred by finding that the search of the RV exceeded the scope of an otherwise valid search warrant. In this case, the officers were not objectively unreasonable in their belief that the RV fell within the warrant's authorization to search. The court explained that, although there was some evidence that the RV was being used as a temporary residence, the officers observed facts supporting their conclusion that it was a vehicle. View "United States v. Houck" on Justia Law

The Eighth Circuit reversed the district court's grant of summary judgment against plaintiff in an action alleging that Southern negligently maintained the roadway at a crossing where its three tracks intersected a state highway. The court held that, viewing the evidence in the light most favorable to plaintiff, he established a genuine issue of material fact as to whether Southern negligently maintained the pavement. Accordingly, the court remanded for further proceedings. View "Donaldson v. Kansas City Southern Railway Co." on Justia Law

The Eighth Circuit affirmed the district court's denial of an 18 U.S.C. 3582(c)(2) sentence reduction based upon Sentencing Guidelines Amendment 782. Amendment 782, in most cases, retroactively reduced the drug quantity determination by two base offense levels. In this case, the district court found that defendant was held accountable for 40 kilograms of cocaine base at his initial sentencing. The court held that the district court properly declined defendant's invitation to revisit that finding and concluded that Amendment 782 did not affect his base offense level of 38. View "United States v. Rashad" on Justia Law

The Committee, which represented more that 400 clergy sexual abuse claimants, appealed the district court's decision affirming the bankruptcy court's denial of the Committee's motion for substantive consolidation of debtor, the Archdiocese, and over 200 affiliated non-profit non-debtors (Targeted Entities). The Eighth Circuit held that the Targeted Entities were entitled to the protections under 11 U.S.C. 303(a), and could not be involuntarily substantively consolidated with the Archdiocese. In this case, the Committee failed to plausibly allege sufficient facts to negate the non-profit non-debtor status of the Targeted Entities. View "The Official Committee of Unsecured Creditors v. The Archdiocese of Saint Paul and Minneapolis" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to being a felon in possession of a firearm. The court held that the district court did not abuse its discretion in applying an enhancement under USSG 2K2.1(a)(2) based on defendant's previous Missouri convictions for second-degree assault on a law enforcement officer; the district court did not abuse its discretion by applying an enhancement under 2K2.1(b)(1)(A) based on its finding that defendant possessed between three and seven firearms; any error in imposing an enhancement for defendant's 2009 conviction for assault on a police officer was harmless; and defendant's conviction for second degree burglary under Missouri law was not a qualifying predicate offense under the Armed Career Criminal Act. View "United States v. Goldsberry" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to PWD on a trademark infringement claim filed by ZW, another company that sells plastic bags for picking up and disposing of dog waste. The court held that ZW failed to produce any evidence from which a jury could find that consumers were likely to confuse ZW's ONEPUL wicket bags with PWD's BagSpot "one-pull" wicket bags. In regard to PWD's counterclaim that ZW's marks were invalid, the court held that there was a fact dispute as to whether the ONEPUL mark was generic or descriptive. Therefore, the court reversed as to the validity claim and remanded for further proceedings. View "ZW USA, Inc. v. PWD Systems, LLC" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of an age discrimination claim. The court held that the district court did not abuse its discretion in deciding not to admit a Department of Corrections internal investigation report because plaintiff was allowed to elicit the content of the report during her questioning of the Warden and providing the report to the jury would have added little beyond the information already in evidence. Therefore, plaintiff failed to establish reversible error in how the district court handled this evidentiary issue. View "Parker v. Arkansas Department of Correction" on Justia Law

The Eighth Circuit affirmed the trial court's denial of defendant's motion to suppress evidence. The court held that the it was reasonable for officers to believe that defendant was a resident of the home; a protective sweep of the house was justified because the officers had information that defendant was armed; and the scope of the search was reasonable. The court also held that defendant was properly sentenced under the Armed Career Criminal Act because he had three qualifying predicate offenses: assault with a dangerous weapon on a peace officer, manufacturing methamphetamine, and possessing it with intent to distribute. View "United States v. Ford" on Justia Law

The Eighth Circuit affirmed the imposition of sanctions on Ross. H. Briggs for contempt of an order and for misleading the bankruptcy court. The court held that the bankruptcy court had authority to enter sanctions for events that occurred while trying to enforce the order compelling turnover and the show-cause orders; the bankruptcy court did not abuse its discretion in holding Briggs in contempt where the bankruptcy court gave Briggs multiple opportunities to comply with the order compelling turnover, specifically outlining methods of compliance; Briggs's contempt was a sufficient basis for the sanctions; not invoking Rule V of the district court's disciplinary-enforcement rules was not a due process violation; and neither Local Rule 2094(B) nor Rule VII provided a basis for the bankruptcy court's chief judge to hear Briggs's reinstatement motion. View "Briggs v. Hon. Charles Rendlen" on Justia Law