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

The court affirmed the approval of a class action settlement and grant of attorneys' fees and service awards in a suit alleging that Symantec failed to disclose that consumers could use various free alternatives to re-download their Norton anti-virus software. The district court did not abuse its discretion by approving the settlement without knowing the final administrative costs or the final amount received by the class; in awarding the requested fees where the circumstances of this case justified a large award, and the reasonableness of the award was cross-checked against the lodestar method; in approving the terms of the settlement agreement providing that any minimal remaining funds would be distributed to the Electronic Frontier Foundation, as an appropriate cy pres recipient; and in awarding service awards to each of the named plaintiffs. View "Caligiuri v. Symantec Corp." on Justia Law

The court affirmed the denial of plaintiff's application for supplemental security income, concluding that substantial evidence supported the ALJ's decision. Substantial evidence supported the ALJ's conclusion that claimant did not meet or equal Listing 12.05C because he did not demonstrate the adaptive function limitations necessary to qualify; the ALJ adequately accounted for plaintiff's limitations in concentration persistence, or pace in the residual functional capacity; and the vocational expert's testimony constituted substantial evidence supporting the ALJ's finding at step five. View "Scott v. Berryhill" on Justia Law

The court affirmed the grant of a permanent injunction enjoining BC Cleaners from using Martinizing's trademarks, concluding that Martinizing failed to prove willful infringement by BC Cleaners. Because Martinizing failed to prove that it was entitled to monetary remedies against BC Cleaners, the individual defendants were likewise not liable for damages, an accounting for profits, and attorneys' fees. The court also concluded that the district court did not abuse its discretion in not granting injunctive relief against the individual defendants, because BC Cleaners had agreed to stop using the trademarks. Therefore, the court reversed as to these issues; affirmed the denial of a default judgment against Defendants Lundell and Carver; and remanded with directions to enter amended judgments. View "Martinizing International v. BC Cleaners" on Justia Law

The court vacated the dismissal of The Med's claim of alleged impairment of a hospital lien, concluding that the claim was not barred by the Rooker-Feldman doctrine. The court explained that to apply Rooker-Feldman in this case to a non-party who had an opportunity to intervene in state-court proceedings would echo the pre- Exxon Mobil Corp. v. Saudi Basic Indus. Corp. lower-court rulings that expanded the doctrine too far. Here, the Med did not seek to reverse the order of the Arkansas state court, and acknowledged that it could not seek a judgment directly against the proceeds of the personal injury settlement. The court also concluded that the district court erred by alternatively ruling that Arkansas law applied to the dispute between the parties. Rather, the court applied a choice-of-law analysis and concluded that Tennessee law applied in this case. View "Shelby County Health Care Corp. v. Southern Farm Bureau Casualty" on Justia Law

Creditor challenged the bankruptcy court's order confirming debtor's Chapter 13 plan. In this case, Creditor did not provide the panel with a transcript of the relevant bankruptcy proceedings, specifically the confirmation hearing. The panel concluded that, because the bankruptcy court stated her findings of fact and conclusions of law on the record and the panel has no transcript of the bankruptcy court's statements made during the portion of the hearing during which she did so, there was no basis upon which the panel could say that the bankruptcy court erred. Accordingly, the panel affirmed the bankruptcy court's decision. View "Situm v. Coppess" on Justia Law

Defendant pled guilty to accessing and possessing child pornography, possessing child obscenity, and violating the terms of his supervised release. The district court sentenced defendant to the statutory mandatory minimum for each offense and ran the sentences for the new conduct concurrently to each other, but consecutively to the revocation sentence. The court concluded that the district court did not ignore the mitigating factors; rather, the mitigating factors were a major focus at the sentencing hearing. In this case, the district court expressly addressed the essence of defendant's position, and did not fail to consider a relevant factor that should have received significant weight. The court also concluded that the district court did not abuse its discretion by making defendant's revocation sentence run consecutive to any other sentences. Accordingly, the court affirmed the judgment. View "United States v. Beyers" on Justia Law

Defendant appealed his conviction after pleading guilty to being a felon in possession of a firearm. The district court imposed a sentencing enhancement pursuant to the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1), based on defendant's two prior Arkansas residential burglary convictions. The court concluded that the Arkansas residential burglary convictions did not qualify as ACCA predicate felonies because Arkansas residential burglary categorically sweeps more broadly than generic burglary. Accordingly, the court vacated the sentence and remanded for resentencing. View "United States v. Sims" on Justia Law

Defendant appealed his conviction of one count of conspiracy to distribute heroin and one count of possessing heroin with the intent to distribute. Defendant admitted that he distributed heroin, but he argued that the government's decision to prosecute him violated his free exercise rights under the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb-1. Defendant alleged that he is a student of Esoteric and Mysticism studies who created a religious non-profit to distribute heroine to the sick, lost, blind, lame, deaf, and dead members of God's Kingdom. The district court assumed without deciding that defendant's practice of distributing heroin was an exercise of sincerely held religious beliefs and that the prosecution therefore substantially burdened his exercise of religion. The court explained that the government was not prosecuting defendant for engaging in a "circumscribed, sacramental use" of heroin, but for distributing heroin to others for non-religious uses. The court explained that it had no difficulty concluding that prosecuting defendant under the Controlled Substances Act (CSA), 21 U.S.C. 841(a)(1), would further a compelling governmental interest in mitigating the risk that heroin will be diverted to recreational users; the government has chosen the least restrictive means necessary to further that interest; and the court rejected defendant's argument that he was entitled to present his RFRA defense to the jury. Accordingly, the court affirmed the judgment. View "United States v. Anderson" on Justia Law

Defendant appealed from this 18 month prison sentence imposed after revoking his supervised release. The court concluded that the district court did not err when it properly analyzed the 18 U.S.C. 3553(a) factors; the sentence was substantively reasonable where the district court did not abuse its discretion in sentencing defendant, given his troubled history while on supervised release, as well as domestic assault; and thus the court affirmed the sentence. View "United States v. Ford" on Justia Law

Mark Moore and two others filed suit against the Arkansas Secretary of State, challenging certain Arkansas statutes that set the filing deadline for individuals who wish to appear on the general election ballot as independent candidates. Plaintiffs sought a declaratory judgment that the filing deadline is unnecessarily early and thus violates the First and Fourteenth Amendments, as well as 42 U.S.C. 1983. Plaintiffs sought to enjoin the Secretary from enforcing this deadline against Moore. The district court granted the Secretary's motion for summary judgment and denied Moore's motion for reconsideration. The court concluded that the district court correctly noted that the March 1 filing deadline for independent candidates imposes a burden "of some substance" on Moore's First and Fourteenth Amendment rights and that Arkansas has a compelling interest in timely certifying independent candidates for inclusion on the general election ballot. The court concluded, however, that the district court erred in determining that there was no genuine dispute of material fact whether the March 1 deadline is narrowly drawn to serve that compelling interest. In this case, there exists a genuine factual dispute whether the verification of independent candidate petitions would conflict with the processing of other signature petitions under the former May 1 deadline. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Moore v. Martin" on Justia Law