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

Petitioner, a native of Ethiopia and a former government official, petitioned for review of the BIA's denial of his application of asylum, withholding of removal, and protection under the Convention Against Torture (CAT). When petitioner attempted to narrow his social group, the Eighth Circuit held that it lacked jurisdiction to consider such arguments not clearly made before the agency. The court also held that petitioner did not experience past persecution on account of his political opinion, and his fear of future persecution was not objectively reasonable. Consequently, petitioner failed to meet the higher burden of proof required for withholding of removal. Therefore, the court denied the petition for review. View "Baltti v. Sessions" on Justia Law

The Eighth Circuit affirmed the district court's revocation of defendant's supervision and 24 month sentence. In this case, the district court did not clearly err in its factual determination that defendant committed an Iowa crime in the parking lot of a hotel by pointing a gun at another thereby violating the terms of his supervised release. View "United States v. Cotton" on Justia Law

The Eighth Circuit affirmed the denial of habeas relief, holding that petitioner's criminal conspiracy conviction did not violate his constitutional right to due process because the evidence was sufficient to support the conviction. In this case, the evidence supported the finding that petitioner and his friend participated in committing the murder and attempting to conceal it. View "Howard v. Braun" on Justia Law

Plaintiff, an African American farmer, filed suit against the USDA and others, alleging racial discrimination, retaliation, and conspiracy regarding his loan applications, servicing requests, and the application of administrative offsets to collect on a defaulted loan. The district court dismissed the complaint with prejudice. The Eighth Circuit reversed the district court's conclusions that plaintiff's Equal Credit Opportunity Act (ECOA), 15 U.S.C. 1691 et seq., claims were barred by res judicata and collateral estoppel because the Office of the Assistant Secretary for Civil Rights could not bar subsequent federal litigation; the individual defendants have not demonstrated that plaintiff failed to state an ECOA claim against them where the complaint included sufficient allegations from which one could plausibly infer that the individual defendants qualified as creditors under the ECOA; the district court erred in dismissing plaintiff's Bivens claims against the individual defendants in their individual capacities because his constitutional claims were not barred by a comprehensive remedial scheme; and plaintiff failed to state a claim for conspiracy against the individual defendants. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Johnson v. Perdue" on Justia Law

The Eighth Circuit affirmed MetLife's denial of long term disability (LTD) benefits to plaintiff under a group insurance plan sponsored by her former employer pursuant to the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that plaintiff presented no evidence of factors tending to demonstrate a consequential conflict of interest, or other indicia of biased decision making; the district court did not err by using an abuse of discretion standard of review; and MetLife did not abuse its discretion by denying LTD benefits to plaintiff where it properly considered all medical records, APS reports, comments, and other information submitted by plaintiff and her physicians. View "Cooper v. Metropolitan Life Insurance Co." on Justia Law

The Eighth Circuit affirmed the district court's order approving a class action settlement and awarding attorneys' fees. Plaintiffs filed suit against Blue Buffalo, alleging that the pet food company broke its "True Blue Promise" that its products contained no chicken or poultry by-product meals. The court held that, in light of the Van Horn factors, the settlement was fair, reasonable, and adequate; it was not an abuse of discretion to find that a settlement providing such benefits was fair to all class members, including those who may have had additional state-law claims; and the attorneys' fees and costs were reasonable. View "Keil v. Lopez" on Justia Law

The Eighth Circuit affirmed the district court's denial of qualified immunity and dismissal of the City's appeal for lack of jurisdiction in an action alleging violation of plaintiff's civil rights after she was arrested for possession of methamphetamine. The court held that Officer Cotton violated no constitutional right by arresting plaintiff and was entitled to qualified immunity for the arrest; Officer Delezene was not entitled to qualified immunity because plaintiff's allegations were based on disputed material facts and thus summary judgment was not appropriate in this case; and the court lacked jurisdiction to hear the City's appeal. View "Manning v. Cotton" on Justia Law

Plaintiffs Combs and Williams, on behalf of themselves individually and others similarly situated, filed a race discrimination suit against several entities with the District. Plaintiffs alleged that defendants engaged in a pattern and practice of racial discrimination that interfered with the ability of African American men to patronize bar and restaurant establishments in the District. The district court granted summary judgment to all defendants. The Eighth Circuit held that Combs was not judicially estopped from certain claims because they had not been listed as assets in his bankruptcy petition, and thus the district court abused its discretion by applying judicial estoppel to claims involving Defendants Mosaic and Tango. On the merits, there was insufficient evidence to support a rabbit scheme at Maker's Mark and LiveBlock. Furthermore, summary judgment was properly granted to Defendant First Response because plaintiffs failed to establish that First Response employed the security guards who escorted Combs out of the LiveBlock. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Combs v. The Cordish Companies, Inc." on Justia Law

Alex Lindholm's parents filed suit against BMW after Alex died when a jack supplied by his car's manufacturer fell and killed him. Alex and his father used the jack to raise the car off the ground so that they could make repairs, the jack fell on Alex when he was lying underneath the car. The Eighth Circuit held, under South Dakota law, that Alex's misuse of the jack was not foreseeable as a matter of law, given the warnings that accompanied the jack about lying under the vehicle. Therefore, BMW was entitled to summary judgment as to the strict liability claim. In regard to the negligence and negligent-design claims, Alex's misuse of the jack also constituted contributory negligence, which barred plaintiffs from recovering. The court affirmed summary judgment as to these claims. Finally, the court affirmed the grant of summary judgment on the implied-warranties claim and the wrongful-death claim. View "Lindholm v. BMW of North America, LLC" on Justia Law

The Eighth Circuit reversed defendant's sentence of 150 months in prison after he pleaded guilty to bank robbery. The court held that the district court incorrectly applied the two-level enhancement under USSG 3B1.4, for use of a minor in the commission of the offense, because the evidence failed to demonstrate that defendant affirmatively acted to involve a minor in the robbery. View "United States v. Fisher" on Justia Law