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

After Zetor filed suit against Ridgeway for trademark infringement, Ridgeway sought to enforce an arbitration clause in a prior settlement agreement between the parties. The Eighth Circuit affirmed the district court's motion denying Ridgeway's motion to compel arbitration, holding that Zetor's claims have no relation to the terms of the settlement agreement; Zetor's claims rest on independent trademark and copyright grounds, which have no relation to the terms of the agreement and in no way depend on its existence; and the plain language of the contract did not apply to wholly independent claims arising several years later. View "Zetor North America, Inc. v. Ridgeway Enterprises" on Justia Law

The Eighth Circuit affirmed the bribery conviction and ten-year prison sentence the district court ordered for a former state-court judge who admitted to trading a remittitur in a case for a campaign contribution and then had second thoughts about his guilty plea. The court held that defendant waived at least part of his appeal; rejected defendant's claim that there was no factual basis for finding him guilty because there was no nexus requirement between the bribe and federal money; and held that an upward variance did not reflect double-counting where defendant was not just a significant public official who took a bribe, but that he was a judge who took a bribe to decide a case a particular way. View "United States v. Maggio" on Justia Law

The Eighth Circuit held that MikLin did not violate the National Labor Relations Act (NLRA), 29 U.S.C. 158(a)(1) and (3), because the means used by the disciplined employees here were so disloyal as to exceed their right to engage in concerted activities protected by the NLRA, as construed in a controlling Supreme Court precedent, NLRB v. Local Union No. 1229, IBEW, 346 U.S. 464 (1953) ("Jefferson Standard"). In this case, the employees' attack was sharp, proceeding in a manner reasonably calculated to harm the company's reputation and reduce its income. The posters, press releases, and letter were an effective campaign to convince customers that eating Jimmy John's sandwiches might cause them to become sick. Therefore, the court declined to enforce the determination that MikLin violated the Act by disciplining and discharging those employees and by soliciting removal of the unprotected posters. The court enforced the remainder of the Order as so modified. View "MikLin Enterprises, Inc. v. NLRB" on Justia Law

The Eighth Circuit affirmed defendant's conviction for child pornography offenses. The court held that sufficient evidence supported the jury's verdict of guilt beyond a reasonable doubt; the district court did not err, much less plainly err, by admitting testimony regarding his use of adult pornography; and the district court did not clearly err by imposing a special assessment according to the Justice for Victims of Trafficking Act of 2015. View "United States v. Kelley" on Justia Law

The Eighth Circuit held that defendant's motion for the return of seized property was barred by the statute of limitations. Furthermore, defendant was not entitled to equitable tolling where the claim was inadequate on its face. In this case, a jury convicted defendant of a drug trafficking conspiracy and the district court entered judgment in 2006; this court affirmed on direct appeal in 2007; and the motion for return of the seized property was filed in 2016. The court also held that the district court did not err in declining to convene an evidentiary hearing. The court granted defendant's motion to notice his letter to counsel dated October 18, 2016. View "United States v. Mendez, Jr." on Justia Law

Plaintiff filed suit against Nebraska and others, alleging negligence, unlawful taking of property for public use under Nebraska law, and a deprivation of federal rights under 42 U.S.C. 1983, after his true name and picture mistakenly appeared on the Nebraska State Patrol's online sex offender registry. The Eighth Circuit held that even if plaintiff's pleading was sufficient to state a claim of negligence against defendants, his claim was barred by the two-year statute of limitations of the Nebraska State Tort Claims Act; plaintiff's claim of unlawful takings failed because he did not allege that any property was taken or damaged for public use; the district court properly dismissed under Rule 12(b)(1) the official-capacity claims and the claim against the State as they were pleaded; and the district court properly dismissed the section 1983 claims against the state employees in their individual capacities because a mistake or lack of due care by state employees in a particular circumstance did not establish invidious or irrational treatment that could violate the Equal Protection Clause. Accordingly, the court affirmed the judgment. View "Roe v. Nebraska" on Justia Law

The Eighth Circuit affirmed the denial of plaintiff's disability insurance benefits and supplemental security income. The court held that the ALJ clearly considered the Polaski factors in accessing plaintiff's subjective complaints and substantial evidence supported her determination that plaintiff's statements concerning her symptoms were not entirely credible. Furthermore, substantial evidence supported the ALJ's residual functioning capacity determination that plaintiff was able to perform medium work. View "Bryant v. Colvin" on Justia Law

The Eighth Circuit affirmed defendant's conviction and 30 year sentence for physically assaulting and raping his estranged wife. The court held that the district court did not abuse its discretion by admitting a social worker's expert testimony under FRE 702 without a Daubert hearing where her testimony rested on a reliable foundation and by refusing to exclude the testimony under Rule 403. The court also held that the district court did not abuse its discretion by admitting testimony regarding his prior tribal court convictions, prior bad acts, and the victim's statement. Finally, the court held that the district court did not err by applying a two level enhancement for obstruction of justice under USSG 3C1.1 and a two level vulnerable victim enhancement under USSG 3A1.1(b)(1). View "United States v. Johnson" on Justia Law

Plaintiff filed suit alleging that the union had violated the Missouri Human Rights Act (MHRA) by failing to accommodate his disability, by discriminating against him based on his disability, and by retaliating against him for reporting his disability and seeking accommodation. The district court determined that the claims were preempted under section 301(a) of the Labor Management Relations Act (LMRA) and section 9(a) of the National Labor Relations Act (NLRA), and that the statute of limitations had expired on those federal claims. The Eighth Circuit held that, because plaintiff's state-law claims were not completely preempted by section 301(a) of the LMRA or section 9(a) of the NLRA, the district court lacked removal jurisdiction over this case. Accordingly, the court vacated and remanded. View "Markham v. Wertin" on Justia Law

Minnesota state law grants a child attending a nonpublic school the right to a free appropriate education (FAPE), as well as the right to dispute the provisions of special education services in an impartial due process hearing. In this case, R.M.M. and her parents have a right, under both state and federal law, to an impartial due process hearing to dispute the provision of a FAPE by MPS. Accordingly, the court affirmed the district court's judgment. View "Special School District No. 1 v. R.M.M." on Justia Law