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

The Eighth Circuit vacated a jury verdict in favor of plaintiff in an action alleging that plaintiff's decedent contracted acute myeloid leukemia from benzene exposure while working as a truck driver. The court held that the district court erred by determining that plaintiff's claim for damages was not discharged by defendant's bankruptcy because defendant violated plaintiff's due process rights by not providing sufficient notice of the bankruptcy. In this case, plaintiff was an unknown creditor and defendant conducted a reasonably diligent search for creditors. Furthermore, the publication notice of bankruptcy provided was sufficient to meet the decedent's due process rights. View "Dahlin v. Lyondell Chemical Co." on Justia Law

Plaintiffs filed suit against the superintendent of the school district under Section 504 of the Rehabilitation Act, 29 U.S.C. 794, after their son committed suicide, alleging that the school had discriminated against their son on the basis of disability by failing to adequately protect him from being bullied by other students. The Eighth Circuit affirmed the district court's grant of summary judgment for defendant, holding that there was nothing in the record to establish that school officials knew of any specific instance of bullying before the son's death, aside from an October 7 altercation, which the school district responded to immediately and there were no further issues. Even crediting the evidence discovered after the son's death that he was being harassed at school, there was no evidence that the school district knew or even should have known about it. The court further held that, even under the deliberate indifference standard, plaintiffs failed to meet the standard articulated by the Supreme Court in Davis v. Monroe Cnty. Bd. of Educ., 526 U.S. 629 (1999). Finally, there was no authority for plaintiffs' claim that a school district can discriminate against a disabled student in violation of Section 504 after his death by failing to investigate harassment that might have occurred before he died. View "Barnwell v. Watson" on Justia Law

The Eighth Circuit affirmed defendant's sentence of 160 months in prison after he pleaded guilty to one count of bank robbery. The court found no error, plain or otherwise, in the district court's imposition of defendant's sentence and the sentence was substantively reasonable. In this case, the district court adequately explained the sentence imposed and its deviation from the Guidelines range; considered all of the 18 U.S.C. 3553(a) sentencing factors; had substantial latitude to determine how much weight to give the various factors; and was permitted to conclude that the Guidelines failed to adequately account for defendant's prior criminal history and his likelihood to reoffend. View "United States v. Murphy" on Justia Law

After plaintiff was injured by a load of boxes he was hauling, he filed suit against IP and John Doe, an employee of IP, alleging that Doe negligently failed to secure the load and that IP negligently supervised the loading and inspecting of the trailer and was vicariously responsible for Doe's negligence. The Eighth Circuit affirmed the district court's denial of plaintiff's motion for reconsideration of the district court's grant of summary judgment for IP. The court held that the district court correctly noted that plaintiff made no evidentiary showing that IP or Doe had breached a duty of care owed to him, so there was no evidence that anyone committed a negligent act. Furthermore, plaintiff failed to produce any evidence showing that negligence in the loading process caused his injuries, and that he was deemed to have admitted that causes other than negligence could well have caused the load to fall on him. View "Bedford v. Doe" on Justia Law

The Eighth Circuit affirmed defendant's sentence, holding that defendant's previous conviction for Oklahoma voluntary manslaughter qualified as a crime of violence under both versions of the Guidelines (2015 and 2016). In this case, defendant was convicted of sex trafficking of a child and sentenced as a career offender. The court explained that the Oklahoma voluntary manslaughter satisfied the generic definition of manslaughter. Furthermore, there was no Ex Post Facto Clause issue as to defendant's sentence and he was properly sentenced as a career offender. View "United States v. Steward" on Justia Law

Plaintiff filed suit alleging that a court administrator discriminated against him on the basis of his race when plaintiff applied to represent indigent murder defendants. The court held that plaintiff's second amended complaint did not adequately allege an injury in fact, and therefore did not vest the district court with jurisdiction. Accordingly, the court denied as moot plaintiff's pending motions to take judicial notice, vacated the judgment of the district court, and remanded with instructions to dismiss the case without prejudice. View "Ashford v. Does" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute controlled substances and controlled substance analogues, as well as conspiracy to commit money laundering. The court held that the evidence was sufficient to convict defendant; the district court did not err by denying defendant's motion for a new trial based on the improper testimony from a witness that defendant had previous legal troubles and a federal prosecution because the evidence of defendant's guilt was overwhelming and the district court gave a proper instruction to the jury; defendant's sentence was procedurally reasonable where the district court properly calculated the total offense level under the Sentencing Guidelines; and defendant's sentence was substantively reasonable where the district court spent substantial time considering and discussing the 18 U.S.C. 3553(a) factors. View "United States v. Anwar" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for conspiracy to distribute controlled substances and controlled substance analogues, as well as conspiracy to commit money laundering. The court held that the evidence was sufficient to convict defendant; the district court did not err by denying defendant's motion for a new trial based on the improper testimony from a witness that defendant had previous legal troubles and a federal prosecution because the evidence of defendant's guilt was overwhelming and the district court gave a proper instruction to the jury; defendant's sentence was procedurally reasonable where the district court properly calculated the total offense level under the Sentencing Guidelines; and defendant's sentence was substantively reasonable where the district court spent substantial time considering and discussing the 18 U.S.C. 3553(a) factors. View "United States v. Anwar" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion for judgment of acquittal or a new trial after she was convicted of possession of methamphetamine with the intent to distribute and conspiracy to distribute methamphetamine. The court held that a DEA agent's statement was not hearsay because it was properly admitted under Federal Rule of Evidence 702; even if the agent's statement was hearsay, the admission of the statement had slight or no influence on the outcome of the trial; the agent's testimony did not violate defendant's Sixth Amendment confrontation rights; the district court did not abuse its discretion in giving a jury instruction permitting an inference of "intent to distribute" based on drug purity; the district court did not abuse its discretion in finding that the government met its burden of proof for venue; and the evidence was sufficient to convict defendant. View "United States v. Lopez" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion for judgment of acquittal or a new trial after she was convicted of possession of methamphetamine with the intent to distribute and conspiracy to distribute methamphetamine. The court held that a DEA agent's statement was not hearsay because it was properly admitted under Federal Rule of Evidence 702; even if the agent's statement was hearsay, the admission of the statement had slight or no influence on the outcome of the trial; the agent's testimony did not violate defendant's Sixth Amendment confrontation rights; the district court did not abuse its discretion in giving a jury instruction permitting an inference of "intent to distribute" based on drug purity; the district court did not abuse its discretion in finding that the government met its burden of proof for venue; and the evidence was sufficient to convict defendant. View "United States v. Lopez" on Justia Law