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

The Eighth Circuit affirmed the district court's denial of defendant's motion to withdraw his guilty plea to two counts of aggravated sexual abuse. The court held that the district court did not violate Federal Rule of Criminal Procedure 11(b)(1)(I), because no mandatory minimum penalty applied in this case. Even if Rule 11 required the district court to advise defendant that he was not eligible for probation, a departure from Rule 11 requirements was harmless error because it did not affect his substantial rights. In this case, an attorney advised defendant before he entered his guilty plea that probation was not an option, and defendant sought to withdraw his plea long before he learned he was not eligible for probation so he could not show that the district court's failure to advise that probation was unavailable caused his decision to plead guilty. View "United States v. Ladue" on Justia Law

Plaintiff filed suit against correctional officers and medical staff under 42 U.S.C. 1983, after he spent three and a half hours on a restraint board. The district court dismissed all claims except an Eighth Amendment excessive force claim against Lieutenant Jeff Gutzmer, who authorized use of the restraint board. The Eighth Circuit held that the district court erred as a matter of law when it denied qualified immunity to Gutzmer. The court held that Gutzmer was entitled to qualified immunity if the totality of the circumstances justified use of the restraint board even if Gutzmer erred in believing plaintiff was self-injurious when placed on the board. In this case, plaintiff violated rules for obtaining medical assistance, falsely claimed a medical emergency, and seriously disrupted ACU operations; discipline was warranted after nurses reported that plaintiff had contrived a medical emergency and could safely be placed on the restraint board; and employing the restraint in accordance with the safety precautions required by prison policy was needed to preserve internal order and discipline and to maintain institutional security. View "Jackson v. Gutzmer" on Justia Law

Plaintiffs filed suit against BNSF, alleging retaliation claims under the Federal Railroad Safety Act, 49 U.S.C. 20109(a)(1)(C). The Eighth Circuit affirmed the district court's dismissal of certain claims for failure to exhaust administrative remedies and conclusion that claims that were properly exhausted failed on the merits. The court held that the district court properly concluded that claims asserting additional adverse actions were unrelated to the claims in plaintiffs' OSHA complaint and unexhausted, and plaintiffs failed to exhaust their claims asserting retaliation for alleged protected activity in their statements to a claims representative. In regard to properly exhausted claims, the court held that, assuming that providing information about an injury caused by the carrier's negligence could give rise to liability, plaintiffs first alleged protected activity -- handwritten statements to the trainmaster -- fell short of satisfying section 20109(a)(1). Furthermore, plaintiffs' testimony at the investigative hearing could not have contributed to earlier adverse actions, and plaintiffs failed to prove that the discipline imposed by the company for rule violations was made with retaliatory motive. View "Foster v. BNSF Railway Co." on Justia Law

The Bankruptcy Appellate Panel affirmed the bankruptcy court's order granting defendants' motion to dismiss plaintiffs' complaint. The panel held that the bankruptcy court was correct in concluding it had "arising in" jurisdiction; the bankruptcy court had, at minimum, "related to" jurisdiction; and plaintiffs have consented to the authority of the bankruptcy court. The panel also held that the bankruptcy court had continuing jurisdiction notwithstanding the closing of the case; plaintiffs' complaint was barred by res judicata; and the bankruptcy court did not err in finding the shareholders standing rule prevented plaintiffs from asserting the claims. View "Sears v. Sears" on Justia Law

The Eighth Circuit affirmed defendant's conviction and sentence for possession with intent to distribute methamphetamine. The court held that the district court did not err in denying defendant's motion for a judgment of acquittal because the evidence presented at trial was sufficient to support his conviction. Furthermore, the district court did not abuse its discretion in denying defendant's motion for a new trial because the newly discovered evidence was not material to the issues involved and would not have produced an acquittal at a new trial. View "United States v. Shumaker" on Justia Law

After plaintiff was arrested and charged with hindering, obstructing, resisting, or otherwise interfering with Kansas City police officers in violation of Kansas City Ordinance 50-44(a), he filed suit against the arresting officers and police officials for various claims. The Eighth Circuit affirmed the district court's grant of summary judgment for defendants, holding that summary judgment on the malicious prosecution claim was proper where the officers had probable cause to arrest plaintiff; plaintiff's fabrication of evidence claim failed where any misleading impression the incident report may leave as to the order of events demonstrated at most negligence; and because plaintiff's 42 U.S.C. 1983 claim of fabrication of evidence was properly dismissed, the civil conspiracy claim based on the alleged fabrication also failed. View "Riddle v. Riepe" on Justia Law

The Eighth Circuit affirmed Defendants Springer and Makohoniuk's convictions for bank fraud. The court held that there was sufficient evidence to demonstrate that defendants intended to cause a financial loss and that their scheme subjected the financial institutions to a risk of loss; the jury instructions did not put defendants at risk of being convicted of bank fraud based on trivial irrelevancies where the "materiality" qualification obviates any fear that the instructions could allow the jury to convict defendants for harmless misrepresentations; the jury had ample evidence to find materiality; the indictment fully and fairly apprised defendants of the charges they must meet at trial; submission of an aiding and abetting instruction was not error; the government did not violate Federal Rule of Evidence 404(b) by admitting evidence of the underlying scheme; the jury had sufficient evidence to conclude that the HUD-1s were false; the district court did not err by sua sponte severing Makohoniuk's trial from Springer's; and Makohoniuk knowingly waived his right to testify at trial. View "United States v. Springer" on Justia Law

The Eighth Circuit affirmed defendant's 180 month sentence after he pleaded guilty to conspiracy to distribute methamphetamine. The court held that the district court did not abuse its discretion by discussing two paragraphs in the presentence report; the district court did not clearly err in weighing the relevant factors when it imposed the sentence; the court rejected defendant's argument that his sentence created an unwarranted disparity among similarly situated defendants; and the district court appropriately weighed the 18 U.S.C. 3553(a) factors. View "United States v. Lisenbery" on Justia Law

Bank of America filed suit against the Hanna Parties for breach of contract after they failed to pay a loan. The jury found that the Hanna Parties did not breach the contract and the district court entered judgment for them. On remand, the Hanna Parties advanced defenses of fraudulent inducement and fraudulent failure to disclose. The Eighth Circuit affirmed the district court's grant of the Bank's motion for summary judgment on those defenses because JB Hanna could not have reasonably relied on the Bank's allegedly fraudulent representations. In this case, the district court correctly rejected the defenses of fraudulent inducement and fraudulent failure to disclose as a matter of law. Furthermore, because there was insufficient evidence to support the fraud defenses, the setoff defense also failed. View "Bank of America v. JB Hanna, LLC" on Justia Law

Plaintiff filed suit against the government under the Federal Tort Claims Act and the Constitution, seeking compensation for harms arising from his alleged wrongful removal to Mexico. The Eighth Circuit affirmed the district court's conclusion that it lacked subject matter jurisdiction over the action and dismissal of the complaint. The court held that 8 U.S.C. 1252(g) precludes the exercise of jurisdiction because plaintiff challenged the execution of a removal order. View "Lopez Silva v. United States" on Justia Law