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

The Eighth Circuit affirmed defendant's concurrent sentences based on drug and felony related convictions, holding that the district court did not err, much less plainly err, in declining to reduce defendant's offense level for acceptance of responsibility under USSG 3E1.1. In this case, defendant never accepted responsibility for his criminal conduct and did not attempt to plead guilty. The court also held that the district court committed no procedural error where it expressly considered the 18 U.S.C. 3553(a) factors and their applicability to defendant's case. Furthermore, the district court did not abuse its discretion by imposing an upward variance, and the sentence was substantively reasonable. View "United States v. Kirlin" on Justia Law

The Eighth Circuit affirmed defendant's sentence of 152 months in prison, holding that the district court correctly determined that 18 U.S.C. 3582(c)(2) and USSG 1B1.10 forbid the court to reduce defendant's sentence below the amended guideline range. The court also held that an undischarged term of imprisonment thus did not factor into a court's determination of an amended guideline range in a section 3582(c)(2) proceeding, and it did not justify fixing a term of imprisonment that was less than the amended range. View "United States v. White" on Justia Law

Defendant, a corporal in the Arkansas Game and Fish Commission (AGFC), appealed the denial of his motion to dismiss claims related to the search of a residence. The district court determined that defendant was not entitled to qualified immunity because a reasonable officer would have known that a warrant should not have issued based on the information he provided to the issuing court. The Eighth Circuit reversed, holding that it was not entirely unreasonable for defendant to believe that his affidavit established sufficient indicia of probable cause for the search and seizure of the items listed in the warrant. In this case, the affidavit provided probable cause to seize a deer, based on an anonymous tip and a recorded jailhouse call. Furthermore, the items described in the warrant were relevant to the criminal offense under investigation, as they directly related to the existence, capture, and maintaining of a pet deer. View "Kiesling v. Spurlock" on Justia Law

The Eighth Circuit affirmed the denial of plaintiff's social security disability benefits, holding that substantial evidence supported the ALJ's decision to deny benefits. The court held that substantial evidence supported the ALJ's decision to assign little weight to the opinion of plaintiff's treating psychiatrist based on internal inconsistency and conflict with other evidence on the record; the ALJ did not err by assigning insufficient weight to the opinions of plaintiff's caseworker and Mental Health Paraprofessional (MHPP); and the ALJ's residual functioning capacity determination, as well as the other evidence in the record, reflected the limitations of plaintiff's ability to follow instructions, socialize, and maintain concentration. View "Chesser v. Berryhill" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the employer on plaintiff's claim of retaliatory discharge in violation of the Minnesota Whistleblower Act (MWA). The court held that there was no genuine issue for trial because no rational trier of fact could conclude on this record that plaintiff's protected activity was causally connected to his termination. Therefore, the district court thus did not err in concluding that plaintiff failed to satisfy his initial burden of establishing a causal connection between his protected activity and his termination sufficient to establish a prima facie case of retaliation under the MWA. Even assuming that plaintiff had established a prima facie case of retaliation, he has not shown that Plant Engineering's stated reason for terminating his employment—unsatisfactory job performance—was pretext for retaliation. View "Mervine v. Plant Engineering Services" on Justia Law

Plaintiff filed suit against the City and three police officers, alleging that they beat him while he was handcuffed. A jury found for the officers. The Eighth Circuit affirmed and held that the district court did not clearly err by denying plaintiff's Batson challenge where the officers offered a race-neutral rationale that the district court found credible; the district court did not abuse its discretion by admitting hospital records that were cumulative and harmless; the district court did not err by excluding evidence of racist emails sent and received by an officer given the minimal probative value of the officer's bias and the potential unfair prejudice to the other defendant officers who were not associated with the emails; and the district court did not abuse its discretion by refusing to sanction the officers with an adverse inference instruction for spoliation of evidence. View "Davis v. White" on Justia Law

This case arose out of an accident that killed three people and injured others. Family members of the deceased and the driver filed suit against Toyota alleging various claims. The jury found that the driver was 40 percent at fault and Toyota was 60 percent at fault for the collision. The Eighth Circuit held that the district court did not abuse its discretion by admitting evidence of a limited number of substantially similar incidents; the district court did not abuse its broad discretion by allowing plaintiff's expert's opinion under FRE 702; the district court did not err by denying Toyota's motion for judgment as a matter of law where plaintiffs presented sufficient evidence from which a jury could find that the 1996 Camry contained a design defect; the district court erred in awarding prejudgment interest and vacated the award of prejudgment interest to Plaintiff Trice; and Trice's award should not be reduced by the amount that Plaintiff Devyn previously recovered from the driver and the driver's insurers. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Adams v. Toyota Motor Corp." on Justia Law

Father, a citizen of Israel, petitioned for return of the child under the Hague Convention on the Civil Aspects of International Child Abduction, as implemented by the International Child Abduction Remedies Act (ICARA), 22 U.S.C. 9001-9011. The Eighth Circuit held that the district court did not err in finding that the child's habitual residence was the United States, and thus the retention of the child was not wrongful within the meaning of the Convention. Accordingly, the court affirmed the judgment of the district court. View "Cohen v. Cohen" on Justia Law

A court generally acts within its discretion when it imposes an amended sentence that is in proportion to the initial sentence. In this case, defendant was originally sentenced at the top of his advisory guidelines range. After defendant moved for a sentencing reduction, the district court sentenced defendant at the top of the amended range. The Eighth Circuit affirmed defendant's sentence, holding that the district court permissibly limited defendant's sentence reduction by considering his criminal history and the danger that he would pose to the community. View "United States v. Banderas" on Justia Law

Plaintiff filed suit against multiple defendants under 42 U.S.C. 1983, alleging claims of excessive force, illegal arrest, and illegal search, as well as tort claims under Arkansas law. The Eighth Circuit affirmed the denial of summary judgment to the defendants who took part in the incident, holding that the district court did not err in holding that Defendant Wolfe violated plaintiff's Fourth Amendment right to be free from excessive force because her use of force was objectively unreasonable as a matter of law. In this case, plaintiff was stopped and questioned while he was at a car wash and he did not commit any crimes. Furthermore, defendant was not resisting arrest, and was not acting aggressively towards Defendant Clark or threatening Clark's safety. Finally, plaintiff's right to be free from such excessive force was clearly established at the time. Therefore, defendants were not entitled to summary judgment based on qualified immunity. View "Perry v. Wolfe" on Justia Law