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

The Eighth Circuit affirmed defendant's consecutive sentences for witness tampering and drug trafficking. The court held that the district court explained its decision based on the 18 U.S.C. 3553(a) factors; there was no factual or legal basis for defendant's contention that 18 U.S.C. 3584(a) prohibits consecutive sentences in this case; the consecutive sentence for witness tampering, which was substantially below the guidelines, was reasonable; and the prosecutor's sentencing argument did not violate the plea agreement. View "United States v. Baskin" on Justia Law

The Eighth Circuit affirmed defendant's sentence on remand after he was convicted of multiple child-pornography related offenses, holding that defendant's sentence was substantively reasonable and the district court did not abuse its discretion. The court rejected defendant's Eighth Amendment claim and held that his 300 month sentence was not grossly disproportionate considering his frequent use of child pornography websites located on the Thor network. Furthermore, defendant's sentence did not violate due process because it was the same as the original sentencing amount. View "United States v. DeFoggi" on Justia Law

The Eighth Circuit reversed the district court's grant of a petition for habeas relief, holding that Martinez v. Ryan, 566 U.S. 1 (2012), does not excuse a procedural default that occurs in the appeal of a collateral state court proceeding. The court reasoned that Martinez was inapposite to this case because petitioner's default occurred during the appeal from the initial-review proceeding rather than during the proceeding itself, and petitioner did not complain about his ability to present his claim to the state circuit court, only that his inability to timely appeal that court's decision constitutes cause because he was not represented by an attorney. View "Franklin v. Hawley" on Justia Law

The Eighth Circuit affirmed the district court's imposition of a sentencing enhancement under USSG 2K2.1(a)(4) because defendant had a previous conviction for Missouri second-degree assault that the district court determined was a crime of violence. The court held that Mathis v. United States, 136 S. Ct. 2243 (2016), did not change the court's previous holding that the Missouri second-degree assault statute was divisible because it defined multiple offenses. Defendant's conviction qualified as a crime of violence because he must knowingly cause physical injury to another person by means of a deadly weapon or dangerous instrument. View "United States v. Welch" on Justia Law

The Eighth Circuit dismissed petitioners' challenge to the FMCSA's final rule entitled "Medical Examiner’s Certification Integration." Petitioners are the Owner-Operator Independent Drivers Association (OOIDA) and an OOIDA member. Petitioners alleged that the new administrative rule means that OOIDA members were being subjected to more onerous sleep apnea tests, which in turn has led to delays, or worse, denials of medical certification to drive commercial motor vehicles. The court held that petitioners have not provided any evidence to support the second element of standing: causation. The court found that the two affidavits submitted by petitioners to prove that they have standing either contained generalized allegations or were not fairly traceable to the final rule. View "Owner-Operator Independent Drivers Assoc. v. U.S. Department of Transportation" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to withdraw his guilty plea for drug-related offenses. The court held that the district court did not abuse its discretion in denying the motion to withdraw because defendant failed to show that his counsel's advice was linked to an actual conflict of interest; defense counsel's advice concerning willful blindness was not deficient and did not prejudice defendant; the guilty plea rested on an adequate factual basis; and, because the evidence elicited at sentencing neither rehabilitated defendant's credibility nor undermined the evidence of his guilt, the district court did not plainly err in failing to reconsider the motion to withdraw the guilty plea sua sponte. View "United States v. Sharp" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to at-will employees in an action alleging breach of contract against Panera. Plaintiffs filed suit on behalf of themselves and a class of similarly situated store managers, alleging that Panera violated employee agreements by imposing a bonus cap. The court noted that under Missouri law, the agreements amounted to offers by Panera to enter into an unilateral contract; the court held that the Supreme Court of Missouri would conclude that an offerree must merely begin performance; and since each of the managers in the class here had at least begun performing under the offer, Panera could not modify the offer terms as to any manager. The court rejected Panera's contention that it reserved the power to modify or terminate its bonus offer before the managers began performing in accordance with that offer, and Panera's derivative argument that the district court should have revisited its decision to certify the class after determining that the bonus offers were offers to make a unilateral contract. Finally, the court affirmed the district court's rejection of Panera's novation, waiver, estoppel, and commercial frustration defenses. View "Boswell v. Panera Bread Co." on Justia Law

The Insurer appealed the district court's grant of summary judgment for the insured in a dispute regarding damage from a hailstorm to windows in the insured's home. An appraisal panel issued an appraisal award but the parties disputed the meaning of the award. The Eighth Circuit held that the appraisal award was ambiguous and the district court should have returned the matter to the appraisal panel for clarification. Accordingly, the court vacated the judgment and remanded. View "Herll v. Auto-Owners Insurance Co." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of ConAgra in an action seeking to recover severance benefits under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that ConAgra's financial conflict of interest was still a relevant factor the court considered in determining whether ConAgra abused its discretion in denying plaintiff's claim; ConAgra did not abuse its discretion in determining that plaintiff lacked good reason to self-terminate; and because ConAgra's decision was reasonable, ConAgra did not abuse its discretion in denying plaintiff's claim for benefits. Furthermore, ConAgra did not breach its fiduciary duty to plaintiff by misstating or omitting certain material information when communicating with him. Finally, the court held that plaintiff's claims were not frivolous and affirmed the award of attorney's fees incurred by plaintiff. View "Boyd v. ConAgra Foods, Inc." on Justia Law

The Eighth Circuit granted Borowiak's petition for mandamus in an underlying action involving claims related to a supply agreement between the parties. Borowiak sought to vacate an order of the district court that granted a motion to strike Borowiak's jury demand and to require the district court to reinstate a jury trial. The court held that Borowiak's right to a jury trial was clear and indisputable under the rules of civil procedure on the record in this case and it had no other means to attain the relief desired. Accordingly, the court directed the district court to reinstate the jury trial consistent with AFM/AWG's jury trial demand. View "In re: Borowiak IGA Foodliner, Inc." on Justia Law