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

The United States Court of Appeals for the Eighth Circuit affirmed a lower court's judgment in favor of a police officer who filed a lawsuit against the city of Omaha and the chief of police of the Omaha Police Department. Katherine Belcastro-Gonzalez had filed a complaint alleging sexual harassment by a coworker in 2010, and in 2017, she discovered that her complaint wasn't adequately investigated. She alleged that her subsequent applications for promotions were denied due to her complaints about sex discrimination. A jury found in favor of Belcastro-Gonzalez and awarded her $700,000 in damages. The lower court also awarded her attorney's fees.The city appealed, arguing first that the district court erred in denying its motion for summary judgment. The appeals court held that it could not review this decision after a trial on the merits. The city should have raised these issues in a post-trial motion for judgment as a matter of law. The city also argued that the district court erred in admitting evidence from proceedings before the Nebraska Employment Opportunity Commission. However, the appeals court found that the admission of this evidence was not an abuse of discretion. The city's last argument was against the size of the attorney’s fees award. The appeals court found that the lower court did not abuse its discretion in determining the amount of the fee, including fees incurred during the administrative proceedings. View "Belcastro-Gonzalez v. City of Omaha" on Justia Law

This case from the United States Court of Appeals for the Eighth Circuit involves a dispute between Midwest Medical Solutions, LLC and Exactech U.S., Inc. This is the second time the case has come before the court. The initial appeal by Midwest was regarding a summary judgment in favor of Exactech, which was based on the district court's interpretation of a non-compete clause in the parties' Sales Agreement. The Court of Appeals reversed the summary judgment, finding the clause unambiguous, and remanded the case for further proceedings.In the latest appeal, Exactech contends that the district court erred by denying its motion for leave to replead two counterclaims. Exactech had initially included these counterclaims in its pleadings but later removed them, believing they had been rendered moot by the district court's order interpreting the disputed contract language in Exactech's favor. Exactech attempted to reintroduce these counterclaims after the Court of Appeals reversed the summary judgment. The district court denied Exactech's motion to amend its pleadings, citing Exactech's lack of diligence in adhering to scheduling deadlines and the absence of changed circumstances that would justify its delay.The Court of Appeals affirmed the district court's decision. It found that the district court did not abuse its discretion in denying Exactech's motion to amend, as Exactech had failed to establish good cause for amending the scheduling order. The court noted that Exactech had voluntarily chosen not to replead these counterclaims in its amended pleadings, and that this decision could not be considered a changed circumstance. The court further noted that Exactech could have pleaded these counterclaims in the alternative, rather than omitting them entirely. View "Midwest Medical Solutions, LLC v. Exactech U.S., Inc." on Justia Law

In the case before the United States Court of Appeals for the Eighth Circuit, the defendant Nolan Ryan Morin, who had pleaded guilty to a false-statements charge, a class D felony, faced the revocation of his supervised release multiple times. After his initial violation of supervised release, he was sentenced to 12 months' imprisonment and 3 years of supervised release. After two more violations, his supervised release was revoked and he was sentenced to 18 months' and then 24 months' imprisonment, respectively.Morin appealed his most recent 24-month revocation term of imprisonment, arguing that the "all or part" clause in 18 U.S.C. § 3583(e)(3), which governs the revocation of supervised release, requires a sentencing court to credit previous revocation terms of imprisonment up to a maximum of the term of supervised release authorized by statute for the underlying offense. In Morin's case, he claimed that the total length of all revocation imprisonment he may serve based on his false-statements conviction was capped at 3 years, and as he had already served 30 months on his first two revocations, the district court was only authorized to impose a maximum of 6 months on the present revocation.The Eighth Circuit disagreed with Morin's interpretation. The court held that the "all or part" clause imposed a per-revocation limit and did not require the court to consider or aggregate prior revocation terms of imprisonment. Moreover, the court opined that the clause expanded the sentencing court's authority by removing the limitation that a prison term imposed could never be longer than the term of the revoked supervised release. Thus, the court affirmed the 24-month term of revocation imprisonment Morin received as it was authorized by statute. View "United States v. Morin" on Justia Law

In August 2020, Machele Goetz filed a Chapter 13 bankruptcy petition and plan. She owned a residence worth $130,000 and claimed a $15,000 homestead exemption under Missouri law. It was agreed that if the trustee liquidated the residence on the date of the petition, the estate would have received nothing net of the exemption, the lien, and the sale expenses. On April 5, 2022, the bankruptcy court granted Goetz’s motion to convert her case from Chapter 13 to Chapter 7. Between the Chapter 13 filing and the date of the conversion order, Goetz’s residence had increased in value by $75,000, and she had paid down a further $960.54 on the mortgage.Goetz moved for the bankruptcy court to compel the trustee to abandon the property, arguing that the residence was of “inconsequential value and benefit to the estate” under 11 U.S.C. § 554(b). The trustee resisted Goetz’s motion, asserting that the bankruptcy estate in a converted case includes post-petition, pre-conversion increase in equity. The bankruptcy court agreed with the trustee, and this decision was affirmed by the Bankruptcy Appellate Panel for the Eighth Circuit.On appeal to the United States Court of Appeals for the Eighth Circuit, the court held that the post-petition, pre-conversion increase in equity in Goetz’s residence is property of the converted Chapter 7 estate. The court reasoned that, under the plain text of 11 U.S.C. § 348(f)(1)(A) and § 541, the equity in Goetz’s residence was property of her converted estate because it was property of the estate that she owned on the date of her petition and which she retained at conversion. The court rejected Goetz's arguments that this result punishes the good-faith debtor who attempts a Chapter 13 plan, pays down their mortgage, and then converts to Chapter 7. Instead, the court held that the Code’s values are not monolithic and balance multiple, often competing interests. View "Goetz v. Weber" on Justia Law

The petitioner, Loing Yar, a native and citizen of South Sudan who entered the United States as a refugee, appealed an order of the Board of Immigration Appeals (BIA) that denied his claim under the Convention Against Torture for deferral of his removal to South Sudan. Yar was convicted of distributing methamphetamine in the United States, which is considered an aggravated felony, leading to the initiation of removal proceedings against him. Yar sought relief from removal, claiming he would be likely tortured if he was returned to South Sudan due to his membership in the minority Nuer tribe and his relationship to his father, an advocate for South Sudanese independence who died under suspicious circumstances.An immigration judge initially granted deferral of removal under the Convention Against Torture, but the BIA vacated this decision, concluding that the potential harm identified by the immigration judge did not rise to the level of torture, as defined by the law. The BIA further asserted that the likelihood of detention or imprisonment alone does not amount to torture, and the indeterminate "chance" of future upheaval or ethnic cleansing did not meet the legal standard of "more likely than not" under the regulations implementing the Convention.The United States Court of Appeals for the Eighth Circuit denied Yar's petition for review, affirming the BIA's decision. The court found no error in the BIA's legal conclusion that Yar failed to establish a likelihood of torture upon return to South Sudan. The court agreed with the BIA's interpretation of the Convention Against Torture, emphasizing that the definition of torture is a legal issue and whether a predicted factual outcome meets the definition of "torture" is a question of law. View "Yar v. Garland" on Justia Law

Thomas Springs was convicted by an Arkansas jury for the capital murder of his wife, Christina, and sentenced to death. The conviction and sentence were affirmed on direct review by the Arkansas Supreme Court. Later, Springs filed a federal habeas corpus petition under 28 U.S.C. § 2254, arguing, among other points, that his trial counsel was ineffective for failing to investigate and present his son Matthew’s testimony during the trial's penalty phase.The United States Court of Appeals for the Eighth Circuit upheld the district court's denial of Springs' § 2254 petition. The court noted that Springs needed to show both that his counsel’s representation fell below an objective standard of reasonableness and that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. However, the court found that even if Matthew had testified, Springs failed to demonstrate a reasonable probability that the outcome of the trial would have been different given the extensive evidence against him and the nature of his crime. The court also declined to expand the certificate of appealability to include Springs's challenge to his competency to stand trial and participate in the appellate process. Therefore, the court affirmed the district court's judgment and denied Springs’s request to expand the certificate of appealability. View "Springs v. Payne" on Justia Law

In this case, James Scott filed a civil rights lawsuit against the City of Sherwood, Sherwood City Attorney Stephen Cobb, and Sherwood City Code Enforcement Officer Sheila Reynolds. Scott owned property in Sherwood, Arkansas, which he used for storage and a repair business. After Sherwood annexed his property, Scott faced numerous complaints, citations, and prosecutions over the use of his property.Scott filed a lawsuit in state court, which was dismissed on grounds of sovereign immunity. Later, he filed a nearly identical lawsuit in federal court. The defendants moved for dismissal, arguing that the doctrine of res judicata, which prevents issues that have been judicially decided from being re-litigated, applied to Scott's claims. The district court granted the motion, and Scott appealed.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that under Arkansas law, all the elements for claim preclusion, a type of res judicata, were satisfied. The court noted that Scott's lawsuit in state court was fully contested in good faith and resulted in a dismissal with prejudice, which constituted a final judgment. The state court had jurisdiction over the matter, and Scott's state and federal lawsuits involved the same civil rights claims and parties.Scott argued that the Arkansas court did not have jurisdiction and that it did not enter a valid final judgment. The appellate court rejected these arguments, explaining that under Arkansas law, sovereign immunity is treated like an affirmative defense, not a matter of subject-matter jurisdiction. The court also noted that the proper course of action for Scott to remedy an erroneous decision would be an appeal or a post-judgment motion, not another lawsuit. View "Scott v. City of Sherwood, Arkansas" on Justia Law

The plaintiffs, Sandeep and Sarvani Thigulla, were lawful nonimmigrant workers seeking to become lawful permanent residents (LPRs) in the United States and had applied for approval of their Form I-485 applications with the U.S. Citizenship and Immigration Services (USCIS). When the Department of State decreased the number of applications it would adjudicate, the Thigullas sought a temporary restraining order against the Director of USCIS, compelling the prompt adjudication of their applications under the Administrative Procedure Act. The district court denied this order, and the Thigullas appealed.The United States Court of Appeals for the Eighth Circuit dismissed the case due to a lack of subject-matter jurisdiction. The court found that the decision to delay adjudicating the Thigullas' applications falls under the Attorney General’s discretionary authority as stated in 8 U.S.C. § 1255(a) and that this authority is protected from judicial review by 8 U.S.C. § 1252(a)(2)(B)(ii). The court rejected the plaintiffs' arguments that this interpretation went against congressional intent, citing clear textual evidence in the statute. The court concluded that it lacked the jurisdiction to review the decision to delay adjudication of the applications, even under the Administrative Procedure Act. Consequently, the court dismissed the case and remanded it to the district court for proceedings consistent with its opinion. View "Thigulla v. Jaddou" on Justia Law

The Mandan, Hidatsa and Arikara Nation (MHA), an Indian nation of three affiliated tribes, appealed the U.S. Department of the Interior's Bureau of Land Management (BLM) approval of eight applications for oil drilling by the Slawson Exploration Company, Inc. next to Lake Sakakawea, MHA's sole source of drinking water. MHA challenged the approvals under the Administrative Procedure Act, arguing that BLM's approval of the project was arbitrary and capricious due to an insufficient record and by precluding MHA from further developing the record about the threat the project posed to MHA's health and welfare.The United States Court of Appeals for the Eighth Circuit affirmed the district court's grant of summary judgment to BLM and Slawson, dismissing the case with prejudice. The court found that BLM had engaged in reasoned decision-making and had evaluated all relevant factors. It noted that the agency placed the responsibility on Slawson to comply with tribal law without impeding MHA's ability as a sovereign to enforce its laws. The court also found that BLM's decision not to evaluate tribal law did not impact tribal sovereignty. The court concluded that MHA's jurisdiction over Slawson's project was not a relevant factor to the approvals and therefore further development of the record was not required.Furthermore, the court found that MHA was not entitled to an evidentiary hearing as there was no dispute of material fact and MHA had adequate opportunities to submit evidence. Therefore, the court ruled that MHA had received all process required by the Constitution, laws, and agency regulation. View "Mandan, Hidatsa & Arikara Nation v. U.S. Dept. of the Interior" on Justia Law

In 2021, a warehouse developed by TriStar Companies, LLC but possessed by Amazon collapsed during a tornado, causing injuries and deaths. Several personal injury and wrongful death lawsuits were filed against TriStar, claiming negligence in the warehouse's construction. TriStar, insured by AXIS Surplus Insurance Company, sought coverage under their policy, but AXIS denied coverage and filed a complaint for a declaratory judgment that it had no duty to defend or indemnify TriStar for the resulting lawsuits. The district court granted AXIS's motion for summary judgment, ruling that the insurance policy did not cover the warehouse due to certain exclusions and limitations.Upon appeal, the United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision. The Court of Appeals applied Missouri law, giving the insurance policy terms "the meaning which would be attached by an ordinary person of average understanding if purchasing insurance." The court found that the policy's language was clear and unambiguous. It limited coverage to premises owned, rented, or occupied by TriStar per a schedule of locations on file with AXIS. As the warehouse's location was not listed in the schedule, and TriStar did not own, rent, or occupy the warehouse when the incident occurred, the court concluded that the policy did not cover the incident.The court rejected TriStar's interpretation of the schedule of locations, which would have resulted in coverage extending to an entire city, as untenable and against common sense. Therefore, AXIS had no duty to defend or indemnify TriStar for the lawsuits arising from the warehouse collapse. View "Axis Surplus Insurance Company v. TriStar Companies, LLC" on Justia Law