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

The Eighth Circuit affirmed the district court's decision affirming the bankruptcy court's finding that funds investors transferred to TSF were part of TSF's Chapter 7 bankruptcy estate. The court held that Judge Hastings, the new bankruptcy judge, did not exceed the scope of the BAP's mandate by revisiting Judge Mahoney's, the retired bankruptcy judge, factual findings; Judge Hastings did not abuse her discretion by declining to apply the law-of-the-case doctrine; and Judge Hastings did not clearly err in finding that the investors failed to show, by clear and convincing evidence, that TSF held the funds in trust. View "Allison v. Centris Federal Credit Union" on Justia Law

The Eighth Circuit affirmed Defendant Espinoza and Tizoc's conviction and sentence for distributing methamphetamine and Espinoza's conviction for being a prohibited person in possession of a firearm. The court held that there was sufficient evidence to convict Espinoza and the district court did not abuse its discretion in denying him a new trial; based on the totality of the circumstances, the district court did not clearly err in finding that Espinoza voluntarily consented to the pat-down search and thus the district court did not clearly err in denying his motion to suppress evidence; the court declined to review Tizoc's ineffective assistance of counsel claims on direct appeal; the court rejected Espinoza's sentencing claim as meritless; the district court did not err by applying an importation and role enhancement to Tizoc's sentence; and the district court did not procedurally nor substantively err in sentencing Tizoc. View "United States v. Espinoza" on Justia Law

The Eighth Circuit affirmed the denial of a 28 U.S.C. 2255 petition to vacate a sentence in light of Johnson v. United States, 135 S. Ct. 2551, 2563 (2015). The court held that petitioner's prior Arizona conviction for exhibiting a deadly weapon qualified as a predicate offense under the force clause of the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). Therefore, petitioner remained an armed career criminal without reliance on the now-invalidated residual clause. View "Boaz v. United States" on Justia Law

The Eighth Circuit affirmed the district court's denial of intervenor's motion to unseal certain judicial records. The underlying litigation involved an omnibus Eighth Amendment challenge to Missouri's execution protocol where state government agencies filed documents under seal in order to be able to carry out executions. The court held that, under common law, the district court did not abuse its discretion in deciding that the documents at issue should remain sealed and that there was not way to redact the information to preserve certain identities. The court also held that intervenor has not established a First Amendment right to unseal the information where there was no historic tradition of accessibility, and public access to the documents in the instant case would not play a significant positive role in the function of Missouri's execution protocol. Finally, the court held that the district court did not abuse its discretion in electing to review the supplemental briefing in camera, and denying intervenor's subsequent request to review it. View "Flynt v. Lombardi" on Justia Law

The Eighth Circuit reversed the district court's grant of summary judgment in favor of defendant, a police officer, in a 42 U.S.C. 1983 action. The court held that the district court erred in granting summary judgment on the ground that plaintiff brought his claims against the officer in his official capacity only. In this case, the officer acquiesced in an unexpressed motion to amend the complaint to include individual-capacity claims against him, that a formal motion to so amend the complaint was not necessary, and that the complaint was correspondingly amended. View "Stephens v. Jessup" on Justia Law

The Eighth Circuit reversed the district court's grant of summary judgment in favor of defendant, a police officer, in a 42 U.S.C. 1983 action. The court held that the district court erred in granting summary judgment on the ground that plaintiff brought his claims against the officer in his official capacity only. In this case, the officer acquiesced in an unexpressed motion to amend the complaint to include individual-capacity claims against him, that a formal motion to so amend the complaint was not necessary, and that the complaint was correspondingly amended. View "Stephens v. Jessup" on Justia Law

Russell Bucklew was sentenced to death after being convicted of murder, kidnapping, and rape. At issue on appeal was whether the Eighth and Fourteenth Amendments, as applied, barred Missouri officials from employing a procedure that was authorized by Missouri statute to execute Bucklew. The Eighth Circuit held that the summary judgment record contained no basis to conclude that Bucklew's risk of severe pain would be substantially reduced by use of nitrogen hypoxia instead of lethal injection as the method of execution. Therefore, Bucklew failed to establish the second prong of the Glossip/Baze standard. In this case, Bucklew failed to establish that lethal injection, as applied to him, constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments. Finally, the district court did not err in denying Bucklew's requests for discovery relating to two members of the lethal injection execution team. View "Bucklew v. Precythe" on Justia Law

The Eighth Circuit affirmed defendant's conviction for conspiracy to possess and distribute 100 grams or more of PCP and conspiracy to commit money laundering. The court remanded for correction of defendant's sentence on the money laundering count. The court held that the district court did not clearly err in calculating a base offense level of 30, and the district court properly applied a two-level increase for reckless endangerment during flight under USSG 3C1.2. However, the court vacated the sentence on the money laundering conspiracy count because it exceeded the 20-year statutory maximum. Therefore, the court remanded for the district court to limit the term of imprisonment on that count to 240 months. View "United States v. Robertson" on Justia Law

Plaintiff filed suit against defendants, alleging claims under 42 U.S.C. 1983 for use of excessive force, unreasonable search and seizure based on his arrest, failure to protect, conspiracy to deprive him of constitutional rights, unconstitutional policy, procedure, or widespread practice, and danger creation. The Eighth Circuit affirmed the district court's order granting the motion to dismiss by individual defendants where plaintiff made no allegations that these defendants had knowledge of unconstitutional acts by subordinates nor did he make any allegations from which such knowledge could be inferred. Furthermore, the district court previously dismissed the same claims on the grounds that they were conclusory and not supported by factual allegations. The court also held that the district court did not err in granting summary judgment to other defendants, named only in their official capacities, and in concluding the record lacked sufficient facts necessary to impose liability on a municipality. View "Mick v. Raines" on Justia Law

The Eighth Circuit affirmed defendant's conviction for two offenses related to his participation in a drug trafficking conspiracy. The court held that there was sufficient evidence to convict defendant of conspiracy to distribute more than 100 grams of heroin and possession with intent to distribute 100 grams or more of heroin. In regard to defendant's evidentiary challenges, the court held that the district court did not err by admitting statements made by a coconspirator; defendant was precluded from raising the issue of whether a prior conviction was properly admitted for impeachment purposes; the district court did not abuse its discretion by permitting testimony from a drug trafficking expert; and the district court did not err when it precluded defendant from questioning two police officers. View "United States v. Peebles" on Justia Law