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

Kujali Strawther was stopped by a South Dakota Highway Patrol officer for speeding. During the stop, the officer claimed to smell burnt marijuana emanating from the vehicle. Strawther admitted to having smoked marijuana in the vehicle while in California. A search of the vehicle revealed over two pounds of raw marijuana and a firearm. Strawther was subsequently arrested and charged with possessing a firearm after being convicted of a felony.In the United States District Court for the District of South Dakota, Strawther filed a motion to suppress the evidence found during the search, arguing that the traffic stop and subsequent search were unlawful. The district court denied the motion, finding that the traffic stop was justified based on the officer's observation of speeding and that the search was lawful due to the smell of marijuana providing probable cause.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, holding that the initial traffic stop was constitutionally sound based on the officer's credible testimony that Strawther was speeding. The court also found that the officer did not unreasonably prolong the stop and that the smell of burnt marijuana provided probable cause for the search. The court concluded that the district court did not err in denying Strawther's motion to suppress the evidence. View "United States v. Strawther" on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely for payments going back five years under Kansas’s statute of limitations. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, interpreting the policy against Kansas City Life. The conversion claim was dismissed. A jury awarded over $5 million in damages, which was reduced to $908,075 due to the statute of limitations. Both parties appealed.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s class certification, finding that common questions of law and fact predominated. The court also upheld the application of Kansas law for both the conversion claim and the statute of limitations. The court agreed with the district court’s interpretation of the insurance policy, concluding that the cost of insurance should not include profits and expenses. The court found that the jury’s damages award was supported by reasonable evidence and did not warrant an increase.The Eighth Circuit affirmed the district court’s judgment, including the class certification, the application of Kansas law, the partial summary judgment in favor of Meek, and the damages award. View "Meek v. Kansas City Life Ins. Company" on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely under Kansas’s five-year statute of limitations for breach-of-contract claims. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, concluding that the policy's cost-of-insurance provision was ambiguous and should be construed against Kansas City Life. The jury awarded over $5 million in damages, which was reduced to $908,075 under the statute of limitations. Both parties appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the cost-of-insurance provision in the policy did not include profits and expenses, as these were not listed factors. The court also upheld the class certification, finding that common questions of law and fact predominated over individual issues. Additionally, the court agreed with the district court's application of Kansas law for the conversion claim and the statute of limitations for the breach-of-contract claim. The court found that the jury's damages award was supported by sufficient evidence and did not warrant an increase. View "Meek v. Kansas City Life Ins. Company" on Justia Law

The City of Hillsboro, Missouri, enacted ordinances prohibiting new private wells within city limits and requiring residences to connect to the city water system. The Antoinette Ogilvy Trust, owning a 156-acre property within Hillsboro, claimed these ordinances constituted an uncompensated regulatory taking under the Fifth and Fourteenth Amendments. The trustees, William Becker and Darcy Lynch, argued that the regulations made developing the property financially unfeasible due to the high costs of connecting to the city water system.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the City, rejecting the trustees' claims. The court found that the regulations did not constitute a per se taking, as they did not involve a physical invasion of the property or deprive it of all economic value. The court also determined that the regulations did not fail the Penn Central balancing test for regulatory takings.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the regulations did not mandate a permanent physical invasion of the property, as the trustees were not compelled to build structures or dedicate land to the City. The court also found that the property retained substantial value, thus not constituting a taking under Lucas v. South Carolina Coastal Council. Additionally, the court declined to consider the trustees' exaction claim, as it was not sufficiently raised in the lower court.Under the Penn Central test, the court concluded that the economic impact on the trustees was not significant enough to constitute a taking, and the regulations did not interfere with reasonable investment-backed expectations. The character of the governmental action was deemed a legitimate exercise of the City's police powers to prevent water contamination and protect the aquifer. Therefore, the court affirmed the district court's summary judgment in favor of the City. View "Becker v. City of Hillsboro" on Justia Law

George Harper, Jr. was indicted for being a felon in possession of ammunition following a shooting incident in Davenport, Iowa. After two unsuccessful suppression motions, he pled guilty. At sentencing, the district court applied the attempted murder cross-reference and sentenced Harper to 67 months’ imprisonment. Harper appealed the application of the cross-reference and the denial of one of his suppression motions.The United States District Court for the Southern District of Iowa denied Harper’s motion to suppress A.H.’s eyewitness identification, concluding that A.H. knew Harper before the incident and that his reluctance to identify Harper initially was due to fear of involvement in a police investigation. The court also found that Detective Reeves’s thumb placement on Harper’s photograph was not impermissibly suggestive. Harper pled guilty but preserved his right to appeal the denial of his motion to suppress and the district court’s sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the identification procedure did not create a substantial likelihood of irreparable misidentification, as A.H. knew Harper and identified him from surveillance footage before the photo array. The court also found that the district court did not err in applying the attempted murder cross-reference, as Harper fired multiple rounds at X.B., demonstrating an intent to kill or callous disregard for human life. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Harper" on Justia Law

In January 2020, Detective Josh Winter of the Clinton, Iowa, Police Department stopped Johnathon Lawrence Rose for having heavily-tinted windows, which violated Iowa law. During the stop, Rose's behavior made Winter nervous, prompting him to request a canine unit. The drug-detection dog alerted to the presence of drugs, leading to a search of Rose's car, where officers found drug paraphernalia and suspected drug residue. Rose was arrested, and further searches at the police department and his residence revealed more drugs, ammunition, and firearms. Rose was indicted for possessing methamphetamine with intent to distribute and unlawfully possessing a firearm as a felon.The United States District Court for the Southern District of Iowa held an evidentiary hearing and denied Rose's motion to suppress the evidence. Rose entered a conditional guilty plea, reserving his right to appeal the denial of the motion to suppress. The district court determined Rose was a career offender and sentenced him to 210 months of imprisonment. Rose appealed, and the United States Court of Appeals for the Eighth Circuit affirmed his sentence. Rose then filed a motion for relief under 28 U.S.C. § 2255, alleging ineffective assistance of counsel. The district court agreed, vacated his sentence, and reimposed it, allowing Rose to appeal again.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's denial of the motion to suppress, finding no constitutional violations in the traffic stop, searches, or Rose's incriminating statements. However, the court reversed Rose's sentence, agreeing with the government's concession that the case must be remanded for resentencing in light of a recent decision in United States v. Daye, which impacted the classification of Rose as a career offender. The case was remanded for further proceedings consistent with this opinion. View "United States v. Rose" on Justia Law

Larry Hayward was convicted by a jury of five counts related to heroin offenses. He subsequently filed a motion for acquittal or a new trial, which was denied. On appeal, Hayward contended that the district court erred by admitting evidence of an uncharged controlled buy involving heroin and fentanyl and argued that the evidence was insufficient to support his convictions for conspiracy to distribute drugs and aiding and abetting drug distribution.The United States District Court for the Western District of Missouri oversaw Hayward's trial. The court admitted evidence of an uncharged controlled buy from August 2019, which involved fentanyl, over Hayward's objections. Hayward was convicted on all counts and sentenced to 240 months in prison. He then appealed the district court's decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in admitting the evidence of the uncharged controlled buy. The court found that the evidence was relevant to Hayward's intent, was sufficiently similar to the charged crimes, was supported by sufficient evidence, and that its probative value was not substantially outweighed by the risk of unfair prejudice.The appellate court also found that there was sufficient evidence to support Hayward's convictions. The court noted that multiple witnesses testified about Hayward's involvement in a heroin distribution operation with his partner, Jasmine Steed. The court concluded that a reasonable jury could infer that Hayward was part of a conspiracy to distribute heroin and that he aided and abetted the distribution of heroin by Steed and another individual, Demario Brown.The Eighth Circuit affirmed the district court's judgment, upholding Hayward's convictions and sentence. View "United States v. Hayward" on Justia Law

Amity Dimock, the mother of Kobe Dimock-Heisler, sued the City of Brooklyn Center and four police officers, alleging unconstitutional warrantless entry and use of deadly force. The incident began when Kobe's grandfather, Erwin Heisler, called 911 reporting that Kobe had threatened him with a knife and hammer. When officers arrived, they entered the home without a warrant, leading to a confrontation where Kobe, holding a knife, was shot and killed by officers.The United States District Court for the District of Minnesota granted summary judgment in favor of the officers, citing qualified immunity. The court found that the officers reasonably believed exigent circumstances justified their warrantless entry and that they had probable cause to believe Kobe posed an immediate threat, justifying the use of deadly force. Dimock appealed the decision, challenging the grant of qualified immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the officers were entitled to qualified immunity. The court determined that the officers' belief in the existence of exigent circumstances was reasonable given the information they had, including Kobe's previous threats and mental health history. Additionally, the court found that the use of deadly force was justified as the officers had probable cause to believe Kobe posed an immediate threat to his grandmother and the officers, even though Kobe was only holding the knife and not actively attacking anyone at the moment of the shooting. The court concluded that the rights asserted by Dimock were not clearly established in this context, thus affirming the summary judgment in favor of the officers. View "Dimock v. City of Brooklyn Center" on Justia Law

Ann Jones filed lawsuits against Bloomingdales.com, LLC, and Papa John's International, Inc., alleging that their websites used "session replay" technology to record her electronic communications, including mouse movements, clicks, and keystrokes, without her knowledge. She claimed this technology invaded her privacy by creating a detailed record of her website visits, which could be used for targeted advertisements and website improvements.In the Eastern District of Missouri, the district court dismissed Jones's complaint against Bloomingdales for lack of subject-matter jurisdiction, citing a lack of concrete injury as she did not allege the capture of sensitive information. In the case against Papa John's, the district court dismissed the complaint for lack of personal jurisdiction. Jones appealed both dismissals.The United States Court of Appeals for the Eighth Circuit reviewed the cases and consolidated them for oral argument. The court held that Jones did not plausibly allege a concrete injury in either case, affirming the lower courts' judgments. The court noted that Jones's allegations did not demonstrate that the session-replay technology captured any private or sensitive information, such as social security numbers, medical history, or financial details. The court compared the situation to a security camera in a physical store, where customers do not have a reasonable expectation of privacy regarding their general movements.The Eighth Circuit concluded that Jones lacked standing to sue because her allegations did not show a concrete harm to her privacy. The court emphasized that merely asserting an invasion of privacy without supporting facts is insufficient to establish standing. Therefore, the court affirmed the dismissals of both cases. View "Jones v. Bloomingdales.com, LLC" on Justia Law

Brandon Phillips, who had several Missouri marijuana-possession convictions, pleaded guilty to a federal felon-in-possession charge. Despite Missouri legalizing marijuana and planning to expunge certain convictions, the district court sentenced him to 120 months in prison and imposed a lifetime ban on federal benefits.The United States District Court for the Eastern District of Missouri overruled Phillips's objection that his criminal history was overstated due to Missouri's legalization of marijuana. The court stated it would have imposed the same sentence regardless of the marijuana convictions. Phillips's marijuana convictions were still on record at the time of sentencing, although they were later expunged. Phillips argued that the expungement should require resentencing.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that Phillips did not preserve the expungement issue for appellate review, as he did not clearly state the grounds for his objection in the district court. The court also determined that even if the issue had been preserved, the district court would have imposed the same sentence based on the 18 U.S.C. § 3553(a) factors, considering Phillips's reoffending on parole and possession of a large quantity of fentanyl.However, the Eighth Circuit vacated the federal-benefits ban, finding it was a plain error to apply it to Phillips, as the ban only applies to drug distributors, not gun possessors. The court held that the district court's application of the ban was clearly incorrect and affected Phillips's substantial rights. The court affirmed the 120-month prison sentence but vacated the federal-benefits ban. View "United States v. Phillips" on Justia Law