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

After police officers shot and killed Ahmed Guled, Guled's father filed suit against the City and the officers under 42 U.S.C. 1983, alleging excessive force. The Eighth Circuit affirmed the district court's grant of summary judgment for the City, holding that the father lacked standing to bring a section 1983 claim because he was not a trustee under Minnesota's wrongful death statute. In this case, the father had an opportunity to obtain compensation resulting from Guled's death: He was able to obtain trustee status, though it was later revoked. Had the father obtained the consent of Guled's brother, he could have secured trustee status again. The court also held that Minnesota's statutory scheme generally provides the opportunity for a trustee to pursue a section 1983 claim, and therefore was not inconsistent with section 1983's purpose of compensating injured parties or preventing abuses of power. View "Estate of Ahmed M. Guled v. Minneapolis" on Justia Law

Twin City filed suit seeking to recover unpaid fringe-benefit contributions allegedly due under a collective bargaining agreement (CBA). The district court granted summary judgment for the Association on the ground that WQS was precluded by a previous lawsuit from disputing liability for the contributions as an alter ego of a signatory of the agreement. The Eighth Circuit affirmed the district court's determination that WQS was liable for the unpaid fringe-benefit contributions where all of the elements required to apply issue preclusion were present. The court held that the Association has a right to collect contributions under the CBA, but that two categories of damages were not authorized by the Employee Retirement and Income Security Act, 29 U.S.C. 1132, 1145, and that the award should be reduced accordingly. The court also upheld the district court's grant of injunctive relief. The court remanded for the district court to exclude contributions due to the Working Fee and Industry Fund from the damages award, and to reduce the award of interest accordingly. View "Twin City Pipe Trades Service Assoc. v. Wenner Quality Services, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in an action filed by LNV against OSM to recover its share of sales proceeds from a promissory note. The court held that the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA), 12 U.S.C. 1821, barred the district court from exercising jurisdiction over OSM's counterclaim; post-receivership claims and claims arising after the claims-bar date were subject to exhaustion; OSM's alleged common-law defense for not paying LNV the net proceeds was ineffective because the contract addressed LNV's alleged prior material breach and OSM must comply with the contract; there was no right of setoff and thus BF-Negev breached the Bahia Agreement by withholding LNV's share of collections; and the court declined to exercise its discretion by reversing the district court's attorney fee award. View "LNV Corp. v. Outsource Services Management, LLC" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity to police officers in plaintiff's suit alleging violation of his First and Fourth Amendment rights. Determining that it had jurisdiction over the interlocutory appeal, the court held that, under Minnesota law, it was not objectively reasonable for the officers to believe they had probable cause to arrest plaintiff for obstruction. In this case, plaintiff stood in his own lighted doorway 30-40 feet from the officers and plaintiff's wife, and exercised directed verbal criticism at the officers while conveying a message that his wife was disabled and could not follow police instructions. The court held that plaintiff's criticism did not amount to anything resembling "fighting words" and that plaintiff's communications were protected First Amendment activity. The officers' actions had a chilling effect on defendant's right to free speech, and a jury must decide whether plaintiff has shown a causal connection between his verbal conduct and the adverse actions taken against him. View "Hoyland v. McMenomy" on Justia Law

Petitioner challenged the district court's denial of his motion to vacate his sentence under 28 U.S.C. 2255 based on ineffective assistance of counsel. Petitioner pleaded guilty to a charge that he conspired to distribute 100 kilograms or more of marijuana in South Dakota and elsewhere, and was sentenced to 60 months in prison. The Eighth Circuit affirmed the judgment, holding that the district court did not abuse its discretion in denying defendant's motion without an evidentiary hearing, because the record showed conclusively that counsel did not render ineffective assistance and that petitioner was not prejudiced by the performance of counsel. View "Adams v. United States" on Justia Law

The Eighth Circuit affirmed the district court's application of a fifteen-year mandatory minimum sentence under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1), to defendant's sentence after he pleaded guilty to possessing with intent to distribute methamphetamine. The court held that defendant's prior Minnesota conviction for third-degree criminal sexual conduct with force or coercion qualified as a predicate felony under the ACCA. View "United States v. Mata" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to vacate his conviction for attempted transportation of a minor with intent to engage in sexual activity under the Mann Act, 18 U.S.C. 2423. The court rejected defendant's contention that his proposed sexual activity was legal in Texas under Texas Penal Code 43.25(b). In this case, the victim's age at the time of defendant's inducement -- 17 years old -- brought defendant's conduct within section 43.25(b). Furthermore, defendant's attempted inducement of the victim was not protected speech because it was used as an integral part of conduct in violation of a criminal statute. View "Goodwin v. United States" on Justia Law

The Eighth Circuit affirmed defendant's 188 month sentence after he pleaded guilty to one count of bank robbery. The court held that the district court did not abuse its discretion by concluding that defendant was a career offender under USSG 4B1.1(a), and that he was subject to enhanced punishment under that section of the advisory sentencing guidelines. In this case, defendant's current conviction and two prior convictions for bank robbery were crimes of violence under the force clause of USSG 4B1.2(a)(1). View "United States v. Harper" on Justia Law

The Eighth Circuit affirmed defendant's convictions for three counts of soliciting or receiving an illegal kickback related to a federal health-care program and one count of making a false statement to federal agents. The court held that there was sufficient evidence to convict defendant of three charges under the anti-kickback statute. In this case, the district court identified one element of the charges as proof that defendant solicited or received a payment that was paid primarily in order to induce the referral of patients insured by Medicare or Medicaid. Then the district court found that the evidence showed, beyond a reasonable doubt, that defendant solicited kickbacks, represented that he could control the referrals, and actually received money for the few referrals that were made through his efforts. Finally, defendant's challenge to his false statement conviction failed. View "United States v. Iqbal" on Justia Law

The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss plaintiff's suit seeking reimbursement of premiums, enhanced damages and fees, alleging claims of unjust enrichment, breach of contract, and civil conspiracy. The court held that plaintiff had standing because, if the policy was deemed void ab initio due to non-compliance with state law, then plaintiff will have suffered a compensable economic injury fairly traceable to defendants' actions. Even if the policies were not void, standing still existed because plaintiff had described a concrete and redressable economic injury properly alleged to have been caused by defendants. The court also held that plaintiff's unjust enrichment was time-barred under Arkansas' three-year statute of limitations and tolling of the statue of limitations was not applicable in this case; plaintiff's breach of contract claim was not time-barred; but the breach of contract claim failed as a matter of law because the policy unambiguously granted the insurer an unconditional right to terminate the policy on thirty-days' notice. View "Graham v. Catamaran Health Solutions LLC" on Justia Law