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

Plaintiff was insured under a group long-term disability policy the county obtained from Hartford. After Hartford denied plaintiff's claim for disability benefits, she filed suit in Minnesota state court for breach of contract. Hartford timely removed to federal court based on diversity jurisdiction. The district court then granted Hartford summary judgment. Under the plain meaning of the statute, the court concluded that plaintiff's suit was time-barred. The court also concluded that the legislative distinction between individual and group policies does not violate the principles of equal protection under the United States and Minnesota constitutions. Accordingly, the court affirmed the district court's conclusion that plaintiff's suit was untimely. View "Walker v. Hartford Life and Accident Ins." on Justia Law

Petitioners, the Owner-Operator Independent Drivers Association and one of its members, seek review of regulatory guidance issued by the FMCSA, which exempts from federal accident-reporting regulations certain accidents involving commercial motor vehicles known as attenuator trucks. The court dismissed the petition for lack of an Article III case or controversy because petitioners have failed to identify a concrete and particularized injury that would give them standing to proceed. View "OOIDA v. US Dep't of Transp." on Justia Law

Defendant plead guilty to one count of robbery and aiding and abetting robbery and one count of conspiracy to commit robbery, in violation of the Hobbs Act, 18 U.S.C. 1951. On appeal, defendant challenged his sentence of 57 months in prison. The court concluded that the district court did not err in declining to adjust defendant's offense level downward based on a mitigating role in the offense pursuant to USSG 3B1.2 because defendant did not meet his burden to show that he was substantially less culpable than either of his codefendants. The court also concluded that the district court did not impermissibly rely on facts in a presentence report because defendant did not make a clear and specific objection. Therefore, the district court did not plainly err in relying on those facts when determining defendant's sentence. Accordingly, the court affirmed the judgment. View "United States v. Waddell, Jr." on Justia Law

Defendant was convicted of laundering and conspiring to launder money, and making a false statement. Defendant had laundered drug proceeds received from his brother-in-law, Brandon Lusk, through his law firm, and then lied to an IRS agent about his financial arrangements with Lusk. When Lusk was investigated by authorities, defendant acted as his lawyer and advised him to hide the nature of their financial relationship. The court concluded that the district court acted well within its discretion to rule that a question implying that defendant had associated with a person later charged with criminal activity, even if improper, did not require a new trial. In this case, the question was half-finished and unanswered. Moreover, the other inculpatory evidence the jury heard was extensive. The court also concluded that the district court properly considered the fact that defendant put his own personal interests ahead of his clients, and that this factor was enough to justify the sentence imposed, even if it resulted in a sentence that was harsh in comparison to others involved in the drug trafficking operation. Finally, there is no indication that the district court punished defendant more harshly because he was a lawyer. Accordingly, the court affirmed the judgment. View "United States v. Boedigheimer" on Justia Law

Bruce A. Hauptman, an investment consultant, sought judicial review of the Commissioner's notices of determination permitting a levy to collect Hauptman’s unpaid income tax liabilities for tax years 1992 through 1996. The tax court upheld the IRS’s determinations. The court rejected Hauptman’s challenge to the tax court’s jurisdiction where Hauptman cites to no authority to support his claim that there are additional requirements before a tax court can exercise jurisdiction over supplemental notices. The court agreed with the tax court’s conclusion that the Office of Appeals did not abuse its discretion when it rejected Hauptman’s offer-in-compromise based on its well-supported findings that Hauptman had not complied with his income tax obligations, that he had not fully disclosed his financial circumstances during the collection due process proceedings, and that he had not prioritized payment of his tax liabilities. Accordingly, the court affirmed the judgment. View "Hauptman v. Commissioner" on Justia Law

Plaintiff, an Iowa prison inmate, filed suit under 42 U.S.C. 1983 against prison officials for deliberate indifference to his serious medical need. Plaintiff alleged that Director Baldwin and Dr. Deol were deliberately indifferent to his need for dentures, and sought declaratory and injunctive relief, as well as compensatory and punitive damages. The district court granted Director Baldwin and Dr. Deol's motion for summary judgment. For the purposes of this appeal, the court will assume that plaintiff suffered from an objectively serious medical need. However, the court concluded that plaintiff failed to establish that Director Baldwin and Dr. Deol deliberately disregarded his need for dentures. The undisputed facts show that the delay in providing plaintiff with dentures was caused by a turnover or shortage of dentists in the prison. The undisputed facts also show that over the time that plaintiff waited for dentures, the IDOC made efforts to secure additional dental staff. Finally, Dr. Deol and Director Baldwin neither created the shortage of dentists nor the general issues with recruitment and retention. Accordingly, the court affirmed the judgment. View "Cullor v. Baldwin" on Justia Law

After plaintiff attempted to unilaterally rescind his resignation and resume his teaching role, and the District refused to reinstate him, plaintiff filed suit for breach of his employment contract. The district court granted summary judgment for the District. The court rejected plaintiff's duress claim, concluding that no evidence supports the allegation that the District made an unlawful threat. Even if plaintiff could demonstrate that the District unlawfully threatened him, the threat was cured by applying the factors set forth in St. Louis Park Inv. Co. v. R.L. Johnson Inv. Co. In the absence of duress, plaintiff's resignation was valid when accepted. Plaintiff's attempted rescission of that resignation merely constitutes an offer and requires that the District provide its consent. In this case, the district did not provide consent, and plaintiff cannot unilaterally rescind his resignation. Finally, the court concluded that there is no evidence that the District made material misrepresentations to plaintiff. Accordingly, the court affirmed the judgment. View "Olmsted v. Saint Paul Pub. Sch." on Justia Law

Defendant was found guilty of 11 counts related to conspiracy and distribution of cocaine and heroin. On remand, the district court made the necessary findings and reduced the drug sentence by 12 months for a total sentence of 336 months' imprisonment. Defendant subsequently challenged the denial of his motion for a two-level sentence reduction pursuant to 18 U.S.C. 3582(c)(2) based on Amendment 782 to the Guidelines. The court concluded that the district court exercised its discretion and expressly considered the 18 U.S.C. 3553(a) factors, recounting the nature and seriousness of defendant's offense. In this case, the district court properly exercised its discretion in choosing to give more weight to the aggravating factors, such as defendant's criminal history, rather than his post-sentencing rehabilitative efforts. Accordingly, the court affirmed the judgment. View "United States v. Granados" on Justia Law

After MFA formed a campaign committee less than 30 days before the November 4, 2014, election and violated Missouri law section 130.011(8), MFA filed suit against the executive director of the Missouri Ethics Commission (MEC), in his official capacity, seeking to declare unconstitutional the 30-day formation deadline. The district court granted a temporary restraining order, but after the election, dismissed MFA’s suit as not ripe. The court concluded that MFA has Article III standing to challenge section 130.011(8) on First Amendment grounds where MFA’s self-censorship is objectively reasonable; although the 2014 election has passed, this case is not moot where MEC can at any time implement its policy and assess the fee for violation of the formation deadline in section 130.011(8) and, in the alternative, this action is not moot under the “capable of repetition yet evading review” exception to mootness; and MFA’s case is ripe for review where MFA asserts the harm of self-censorship, based on its compliance with section 130.011(8). Accordingly, the court reversed and remanded for further proceedings. View "Missourians for Fiscal Accountability v. Klahr" on Justia Law

Defendant plead guilty to possession of child pornography. The district court concluded that defendant's prior conviction under Iowa law for indecent contact with a child in 1982 qualified as a predicate offense under 18 U.S.C. 2252(b)(2), and sentenced defendant to 120 months’ imprisonment. Section 2252(b)(2) requires a mandatory minimum term of ten years’ imprisonment for any person who violates 2252(a)(4) and who has a prior conviction “under the laws of any State relating to aggravated sexual abuse, sexual abuse, or abusive sexual conduct involving a minor or ward.” The court concluded that defendant's argument that his prior conviction for indecent contact with a child does not satisfy the definitions of aggravated sexual abuse, sexual abuse, or abusive sexual contact found in a separate statutory chapter (Chapter 109A), is foreclosed by United States v. Sonnenberg. Accordingly, the court rejected defendant's remaining contentions and affirmed the judgment. View "United States v. Krebs" on Justia Law