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

Plaintiffs filed suit against Green Tree to prevent it from foreclosing on plaintiffs' home. Plaintiffs alleged that Green Tree lacked authority to foreclose. The district court granted Green Tree's motion to dismiss based on plaintiffs' lack of standing to challenge the assignment between creditors and concluded that plaintiffs' notice claim failed to state a plausible claim for relief under Ashcroft v. Iqbal. The court concluded that plaintiffs' invalid assignment claim is nearly identical to the claim in Quale v. Aurora Loan Services, LLC, where the court determined the homeowners did not have standing to raise such a claim because they “were not injured by the assignment” and any harm to the homeowners was not fairly traceable to the allegedly invalid assignment. The court also rejected plaintiffs' contention that the district court erred in dismissing their amended complaint where plaintiffs failed to state a facially plausible claim for relief. Accordingly, the court affirmed the judgment. View "Brown v. Green Tree Servicing LLC" on Justia Law

Plaintiff, who suffers from Ehlers-Danlos Syndrome, filed suit against the Department after it denied him "shelter needy" benefits, raising claims under 42 U.S.C. 1983; the Americans with Disabilities Act (ADA), 12 U.S.C. 12101 et seq.; and the Rehabilitation Act (RA), 29 U.S.C. 701 et seq. The court concluded that the appeal was timely, rejecting the district court's conclusion that plaintiff did not timely file notice and proof of service; concluded that the Rooker-Feldman doctrine is inapplicable to judicial review of executive action, including determinations made by a state administrative agency; and disagreed with the district court’s conclusion that section 256.045 of the Minnesota statutes prevented the court from exercising supplemental jurisdiction over the appeal from a state agency’s decision. In interpreting Minn. Stat. 256.045, subd. 7, the court concluded that subdivision 7 lays out one permissible route through which an aggrieved party may appeal from the Commissioner’s order and thus prevent it from becoming final, but it does not strip the federal court of its authority to hear the same appeal through the exercise of supplemental jurisdiction. Because the district court improperly concluded that it lacked jurisdiction based solely on the state statute, the district court failed to determine whether it should exercise supplemental jurisdiction under 28 U.S.C. 1367 or whether any abstention doctrine applied. Therefore, the court vacated the decision dismissing the supplemental state-law claim and remanded for further consideration. Because the state agency’s decision was not final, the district court erred by finding that plaintiff’s ADA and RA claims were precluded. Finally, the court agreed with the district court that plaintiff's allegations failed to state a due process or equal protection claim. Because plaintiff’s equal protection claim is predicated on the same allegations as his ADA and RA claims, the district court did not err by dismissing the section 1983 claim. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings. View "Wong v. Minnesota DHS" on Justia Law

Silgan and the Union challenge an arbitration award. The district court granted summary judgment in favor of Silgan and the Union appealed. The court concluded that the question of validity and formation is not within the scope of the arbitration agreement. Because the arbitrator lacked authority to decide this issue, the district court did not err in vacating the award. Furthermore, the district court erred in granting summary judgment to Silgan and rescinding Article 36 where the mistake has resulted solely from the negligence or inattention of the party seeking relief, and the other party is without fault. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Silgan Containers Corp. v. Sheet Metal Workers Int'l" on Justia Law

Defendant appealed his 108 month sentence after pleading guilty to one count of being a felon in possession of a firearm. The court concluded that the district court did not commit procedural error by imposing a two-level enhancement for obstruction of justice under USSG 3C1.1 for attempting to suborn testimony where the language of section 3C1.1 and the language of the relevant examples all contemplate attempt as sufficient. The court also concluded that defendant's sentence is not substantively unreasonable where the district court considered all of the 18 U.S.C. 3553(a) factors, and noted defendant's difficult life and criminal history. Accordingly, the court affirmed the judgment. View "United States v. Edwards" on Justia Law

Defendant pled guilty to possession of a firearm by a prohibited person and then challenged the warrantless search of his residence. The court concluded that the officers acted in their community caretaking function when they entered the residence where the officers received a call from a concerned member of the community regarding the safety of another community member (defendant's ex-girlfriend). On the scene, the officers learned further details indicating serious concern for the safety of defendant's ex-girlfriend and establishing multiple reasons why she would be at defendant’s residence and held against her will or in danger. The court also concluded that the officers reasonably believed an emergency situation existed that required their immediate attention in the form of entering defendant’s residence to search for the ex-girlfriend. Furthermore, the scope of the encounter was carefully tailored to satisfy the purpose. The firearm at issue was lying on the bed in the bedroom where the ex-girlfriend was located and it was partially covered by a bed sheet. Therefore, the firearm is admissible under the plain view doctrine. Accordingly, the court affirmed the district court's denial of defendant's motion to suppress. View "United States v. Smith" on Justia Law

Defendant pled guilty to being a felon in possession of a firearm and the district court sentenced him under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), based on his three prior violent felony convictions. The court concluded that defendant's prior conviction for felony domestic assault is a violent felony under the force clause. Accordingly, the court affirmed the judgment. View "United States v. Schaffer" on Justia Law

Plaintiff filed suit against LP, alleging claims for fraudulent misrepresentation, unfair or deceptive practices, and breach of warranty against LP for the purported defectiveness of its TrimBoard product. The district court granted summary judgment to LP. In order for plaintiff to prevail on his fraudulent-misrepresentation claim under Iowa law, he must prove eight elements. At issue is the sixth element - justifiable reliance. In this case, plaintiff's builder's affidavit is insufficient to create a genuine issue of material fact as to whether the builder - a third party - received a communication from LP that he subsequently communicated to plaintiff and upon which plaintiff relied. Therefore, the district court did not err in rejecting defendant's fraudulent-misrepresentation claim. Likewise, plaintiff's unfair or deceptive practices claims fail. The court also concluded that the district court did not err in enforcing the terms of LP's limited warranty where the mere fact that the limited warranty does not compensate plaintiff for the entirety of his damages does not mean it has failed of its essential purpose, and where the limited warranty is neither procedurally nor substantively unconscionable. Accordingly, the court affirmed the district court's judgment. View "Brown v. Louisiana-Pacific Corp." on Justia Law

Defendant appealed his 188 month sentence after pleading guilty to conspiracy to distribute methamphetamine. The court concluded that the district court did not err by applying a role enhancement under USSG 3B1.1(b) where the record demonstrates that the conspiracy involved five participants and defendant directed the actions of two coconspirators by instructing them to deposit drug proceeds and by instructing one of them to send photos of drug packages. The court also concluded that the district court did not clearly err by attributing to defendant 4.5 kilograms of actual methamphetamine. Finally, the government did not breach defendant's cooperation agreement by offering testimony regarding his proffer statements to support its drug quantity calculation. Accordingly, the court affirmed the sentence. View "United States v. Gonzalez Alcalde" on Justia Law

Defendant pleaded guilty to conspiracy to distribute cocaine and to distribution of cocaine. Defendant moved to withdraw his guilty plea after a presentence report recommended an enhanced advisory guidelines sentence range based on a pending murder charge in state court. Under circuit precedent, misapprehension about the applicable guidelines calculation is not a fair and just reason to withdraw a plea, even if the confusion stemmed from erroneous legal advice. The court concluded that defendant is not entitled to withdraw his plea because the district court explained to him the statutory range of punishments for both counts of the indictment, and the district court further advised defendants that it would order preparation of a presentence report and advised him how the district court would calculate a sentencing range. Because no record was developed on a Sixth Amendment claim in the district court, any claim of ineffective assistance of counsel should be raised in a motion under 28 U.S.C. 2255. The court also concluded that defendant failed to identify a plain error warranting relief in regard to his claim that the district court, by applying the cross reference to USSG 2A1.1 and sentencing him based on the increased advisory guideline range, violated his Sixth Amendment right to trial by jury. Even if the premise of an unreasonable sentence were satisfied, defendant’s interpretation of the Sixth Amendment is not clearly correct under current law. Accordingly, the court affirmed the judgment. View "United States v. Briggs" on Justia Law

St. Jude filed suit against Jose B. de Castro and Biosense, alleging state law claims of breach of contract and tortious interference. The court concluded that the district court correctly concluded that the Minnesota choice-of-law provision in St. Jude's employment agreement with de Castro is valid because the parties acted in good faith and without the intent to evade the law; the district court correctly concluded that St. Jude's term-of-years employment agreement with de Castro is valid and enforceable under Minnesota law and that Biosense was liable for tortuously interfering with that agreement; the district court correctly concluded that St. Jude could recover damages for lost profits based on Biosense's tortious interference; and the district court correctly determined that there was sufficient evidence from which a reasonable jury could conclude that Biosense caused St. Jude to lose profits. Accordingly, the court affirmed the judgment. View "St. Jude Medical S.C., Inc. v. Biosense Webster, Inc." on Justia Law