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

These consolidated appeals stem from a class action suit against Target after the retailer announced a security breach by third-party intruders that compromised the payment card data and personal information of millions of customers. Class member Leif Olson challenges the class certification for lack of adequate representation due to an alleged intraclass conflict; class member Jim Sciaroni challenges the district court’s approval of the settlement agreement; and both challenge the district court’s order requiring them to post a bond of $49,156 to cover the costs of this appeal. The court held that the district court abused its discretion by failing to rigorously analyze the propriety of certification, especially once new arguments challenging the adequacy of representation were raised after preliminary certification. Therefore, the court remanded for the district court to conduct and articulate a rigorous analysis of Federal Rule of Civil Procedure 23(a)'s certification prerequisites as applied to this case. The court also concluded that costs associated with delays in administering a class action settlement for the length of a class member’s appeal may not be included in an appeal bond under Federal Rule of Appellate Procedure 7. Therefore, the court reversed and remanded for the district court to reduce the Rule 7 bond to reflect only those costs that Appellees will recover should they succeed in any issues remaining on appeal following the district court’s reconsideration of class certification. View "Sciaroni v. Target Corp." on Justia Law

After defendant pled guilty to being a felon in possession of a firearm, he appealed the denial of his motion to suppress the firearm found in a rental car. The court concluded that defendant did not establish a reasonable expectation of privacy in the rental car and he has no standing to challenge the search. Accordingly, the court affirmed the judgment. View "United States v. Russell" on Justia Law

Defendant appealed his 121 month sentence and conviction for possessing child pornography. The court concluded that defendant's conditions of release, which he proposed, expressly authorized the warrantless searches of his computer's internet and email usage history; the search and seizure were reasonable; and the district court properly denied the motion to suppress. The court also concluded that the evidence was sufficient to support the jury's verdict and the district court properly denied the motion for judgment of acquittal. As to defendant's sentence, the court concluded that the district court did not err in applying an enhancement required by 18 U.S.C. 2252(b)(2) where his prior conviction for transporting obscene matters in violation of 18 U.S.C. 1462 is related to sexual assault and child pornography. Finally, the district court properly exercised its discretion in denying a downward departure, even in light of defendant's prostate cancer, where the district court had no unconstitutional motive and knew of its authority to grant a downward departure. Accordingly, the court affirmed the judgment. View "United States v. McCoy" on Justia Law

Hiland filed suit against National Union, alleging that National Union had a duty to defend and indemnify it in connection with a lawsuit arising from an explosion at its natural gas processing facility. The district court entered summary judgment for National Union. The court concluded that National Union did not have a duty to defend or indemnify Hiland because the allegations in the underlying complaint fell within the policy's pollution exclusion. The court also concluded that, because Hiland did not offer specific facts showing that it reported the pollution to National Union within twenty one days, the district court did not err by concluding that the exception to the exclusion did not apply. Accordingly, the court affirmed the judgment. View "Hiland Partners GP Holdings v. National Union Fire Insurance" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, against Regents and the University, seeking damages and injunctive relief after he was discharged based on sexual harassment allegations. The court concluded that because plaintiff did not sufficiently plead a pre-termination procedural due process violation, exhaustion of state remedies is required to proceed on his post-termination claim; plaintiff has not sufficiently alleged that proceeding with the Office of Conflict Resolution (OCR) hearing would have been futile; and thus plaintiff's section 1983 procedural due process claims were properly dismissed. Accordingly, the court affirmed the judgment. View "Raymond v. Board of Regents of the University of Minnesota" on Justia Law

ACI filed suit seeking a declaratory judgment that it amended and terminated a Licensing Agreement, thus ending ACI’s obligation to make royalty payments to Churchill. Churchill counterclaimed for breach of contract. The district court granted summary judgment for ACI. Although the court agreed with ACI and the district court that Amendment 4 of the Licensing Agreement did not have the effect of retroactively making Churchill a full party to the License Agreement, the court did not agree that either Amendment 4 or the receivership sale prevents Churchill from exercising the legal rights of a third-party beneficiary or assignee. The court also did not agree with ACI that the doctrine of merger prevents additional royalties from becoming due to Churchill. Therefore, the court concluded that ACI did not validly amend the Licensing Agreement to eliminate the post-termination royalties provision, and royalties are still due to Churchill for any sublicenses granted by ACI prior to July 21, 2014. Accordingly, the court reversed the entry of summary judgment for ACI on the issue of amendment of the Licensing Agreement, affirmed the entry of summary judgment in favor of ACI on the issue of termination, and remanded to the district court for further proceedings. View "ACI Worldwide Corp. v. Churchill Lane Associates, LLC" on Justia Law

Plaintiff filed suit against Chipotle, alleging claims under the Minnesota Human Rights Act (MHRA), Minn. State. 363A et seq., for reprisal, age discrimination, and sexual orientation discrimination. On appeal, plaintiff challenges the district court's grant of summary judgment on his reprisal claim. Chipotle claims that he was discharged due to declining work effort and performance. The court concluded that plaintiff failed to raise a genuine issue of material fact as to whether Chipotle’s stated reason for terminating his employment was pretextual. Therefore, the district court correctly determined that his reprisal claim under the MHRA fails as a matter of law and the court affirmed the judgment. View "Sieden v. Chipotle Mexican Grill, Inc." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against defendants for unlawful arrest and excessive force. The district court denied summary judgment on the basis of qualified immunity for Defendants Hansen, Dirkes, and Rybak. In this case, plaintiff was arrested for obstructing a police officer and resisting arrest. The court concluded that Officer Hansen had arguable probable cause to arrest plaintiff for obstructing a police officer. When plaintiff initially approached Hansen to ask about his son's arrest, Hansen ordered plaintiff to step back, but plaintiff disobeyed Hansen's unequivocal instructions to leave. Plaintiff lingered and refused to comply with Hansen's instructions. The court also concluded that Officer Dirkes is entitled to qualified immunity from plaintiff's unlawful arrest claim and excessive force claims where Dirkes did not violate a constitutional right by executing the takedown and by using the taser. Finally, the court concluded that the law was not clearly established that the use of an arm bar in this context constitutes excessive force, and thus Rybak is entitled to qualified immunity. Accordingly, the court reversed the district court’s decision denying Officer Hansen, Officer Dirkes, and Trooper Rybak qualified immunity and remanded for further proceedings. View "Ehlers v. Dirkes" on Justia Law

Debtors challenge the bankruptcy court's order and decision sustaining the trustee's objection to debtors' claimed homestead exemption. 11 U.S.C. 522(o) requires the bankruptcy court to determine the extent to which the improvements debtors made to their homestead increased the value of debtors' interest in their homestead. The panel concluded that the bankruptcy court failed to do so in this case, and the panel remanded for the bankruptcy court to make this determination. View "Crabtree v. McDermott" on Justia Law

Defendant appealed his 135 month sentence and restitution after pleading guilty to one count of possessing child pornography. Defendant possessed over 600 images and videos of child pornography, including depictions of child rape and bondage. Among these were 21 videos from the “Vicky series,” depicting her sexual abuse at the age of 10 and 11. The court concluded that the district court did not abuse its discretion in sentencing at the bottom of the guidelines range and by carefully considering the 18 U.S.C. 3553(a) factors. The court also concluded that the district court properly awarded restitution to Vicky based on future losses; the district court properly applied the Paroline v. United States factors in its proximate cause determination; and the district court did not abuse its discretion in awarding $3,500 in restitution. Accordingly, the court affirmed the judgment. View "United States v. Funke" on Justia Law