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

The Eighth Circuit affirmed the district court's grant of summary judgment as to plaintiff's excessive force claim against Deputy Sheriff Daniel Hallock. The court held that, based on the circumstances Hallock confronted upon arriving at the 101 Bar & Grill, his use of the arm-bar technique fell short of the level of force required to constitute a constitutional violation. In this case, Hallock was dispatched to that location in response to a report that a man had threatened to stab several patrons with a knife. Although plaintiff neither visibly possessed a weapon nor attempted to resist arrest prior to the takedown, a variety of factors suggested that the amount of force Hallock employed was reasonable under the circumstances. View "Vester v. Hallock" on Justia Law

The Eighth Circuit found no violation of Fed. R. Civ. P. 11 or abuse of the judicial process in this consolidated appeal involving parties in a putative action. The court held that counsel did not violate Rule 41 in stipulating to the dismissal of the action and counsel had at least a colorable legal argument that the district court’s approval was not needed under Rule 23(e) to voluntarily dismiss the claims of the putative class. Therefore, the district court abused its discretion in finding that counsel acted with an improper purpose under Rule 11 and abused the judicial process by stipulating to the dismissal of the federal action for the purpose of seeking a more favorable forum and avoiding an adverse decision. Consequently, the district court also abused its discretion in imposing sanctions upon plaintiffs' counsel for the purported violation. The court reversed the district court's orders and remanded for further proceedings. View "Castleberry v. USAA" on Justia Law

Plaintiff filed suit against defendants for constitutional violations resulting from an encounter between Officer Wilson and Johnson. The Eighth Circuit affirmed the district court's denial of defendants' motion to dismiss based on qualified immunity. The court held that plaintiff sufficiently alleged that he was seized; that there was a violation of a constitutional right; and, at the time of the incident in this case, that the law was sufficiently clear to inform a reasonable officer that it was unlawful to use deadly force against nonviolent, suspected misdemeanants who were not fleeing or resisting arrest, posed little or no threat to the officer or public, did not receive verbal commands to stop, and whose only action was to stop walking when a police car blocked their path. Therefore, a reasonable officer in Officer Wilson's position would not have shot his gun and the district court correctly denied qualified immunity to Officer Wilson. Furthermore, the district court did not err by denying Chief Jackson qualified immunity and the court did not have jurisdiction to review the City's liability. The court dismissed the rest of the appeal for lack of jurisdiction. View "Johnson v. City of Ferguson" on Justia Law

Stratasys shareholders filed a securities fraud action claiming several company promotional statements were knowingly false. The Eighth Circuit affirmed the district court's determination that these statements were mere puffery and that the shareholders failed to sufficiently plead that Stratasys knew its statements were false when made. In this case, the statements the shareholders claim were materially misleading were so vague and such obvious hyperbole that no reasonable investor would rely upon them. Therefore, without tying the timing of the knowledge to the allegedly misleading statements, the shareholders did not plead facts sufficient to support a strong inference of scienter. View "Macomb County Employees Retirement System v. Stratasys Ltd." on Justia Law

None of the exceptions to Fed. R. Crim. P. 41 expressly allow a magistrate judge in one jurisdiction to authorize the search of a computer in a different jurisdiction. The Eighth Circuit reversed the district court's grant of defendants' motions to suppress evidence obtained through a warrant authorizing a search of their respective computers through the use of a Network Investigative Technique (NIT). Defendants were separately indicted for accessing child pornography. The court held that the execution of the NIT in this case required a warrant and the NIT warrant exceeded the magistrate judge's jurisdiction. The NIT warrant was void ab initio, rising to the level of a constitutional infirmity. However, because there was no reckless disregard for the truth and law enforcement did not demonstrate bad faith, the Leon exception applied in this case. View "United States v. Horton" on Justia Law

Plaintiff filed suit against her former employer, alleging claims of discrimination and retaliation leading to wrongful termination. The Eighth Circuit rejected plaintiff's claim that the district court failed to consider her status as a pro se litigant; sovereign immunity barred plaintiff's claims under the Americans with Disabilities Act, the Age Discrimination in Employment Act; and 42 U.S.C. 1981 and 83; assuming that plaintiff met her burden of establishing a prima facie case of race and gender discrimination under Title VII, the university has offered a legitimate, nondiscriminatory reason for terminating her (failure to report for work and the need to fill her position); and plaintiff's claim of discrimination was rejected. Accordingly, the court affirmed the judgment of the district court. View "Bunch v. University of AR Board of Trustees" on Justia Law

The Eighth Circuit vacated defendant's 84 month sentence after he pleaded guilty to being a felon in possession of a firearm. The court held that defendant's prior conviction for third degree riot does not qualify as a crime of violence under the force clause of USSG 4B1.2(a), because the statute encompasses crimes against property. The court remanded for the district court to consider the government's alternate argument that third degree riot may qualify as a crime of violence under the residual clause. View "United States v. McMillan" on Justia Law

The Eighth Circuit affirmed the district court's decision upholding National Union's denial of benefits. The court held that National Union did not abuse its discretion in denying plaintiff's claims for accidental death and spousal benefits, because National Union's interpretation of the policy was not unreasonable. In this case, the policy gave National Union full discretionary authority to interpret its terms. View "Donaldson v. National Union Fire Insurance Co." on Justia Law

ACE filed suit against LifeTime Funds' investment adviser, PMC, for breach of its section 36(b) fiduciary duty to the LifeTime Funds under the Investment Company Act (ICA) of 1940, 15 U.S.C. 80a-35(b). ACE based its excessiveness-of-adviser-fees challenge on all or part of the adviser fees paid to PMC by the funds in which the LifeTime Funds invest, fees which indirectly reduced the net asset values of the LifeTime Funds. The Eighth Circuit affirmed the district court's entry of judgment for PMC based on lack of statutory standing, holding that ACE cannot sue on behalf of a fund in which it lacks an interest. In this case, each mutual fund was a separate unregistered investment company and ACE had no security interest in the underlying funds. Therefore, the cross appeal and the motion to dismiss the cross appeal were moot or denied as moot. View "American Chemicals & Equipment Inc. 401(K) Retirement Plan v. Principal Management Corp." on Justia Law

Plaintiff filed suit against the school district, alleging that the district and others violated his due process rights by declining to renew his coaching contract solely on the basis of parental complaints. The Eighth Circuit affirmed the district court's grant of defendants' motion for judgment on the pleadings and dismissed the due process claims. The court held that the 2013 amendment to Minnesota Statue 122A.33 did not grant plaintiff a property interest in the renewal of his coaching contract. View "McGuire v. Independent School District No. 833" on Justia Law