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

Police officers in Bella Vista, Arkansas, responded to a home shared by the Welters and Hutchins families after a suspected drug overdose, where they found pills, including fentanyl, in areas accessible to children. A week later, another overdose occurred at the same residence, resulting in a fatality while children were present. Months later, officers discovered traces of THC in the home’s trash, and a subsequent search revealed marijuana and drug paraphernalia throughout the house, including a still-smoking bong. During an interview, one parent admitted that adults regularly smoked marijuana in the home, though they tried to keep the children out of the room. Police notified the Arkansas Department of Human Services about possible child endangerment. Shortly after, Detective Wilson and other officers took the minor children for forensic interviews without a warrant, over the parents’ objections, and warned the parents they would be arrested if they interfered. The children were later returned to their parents.The United States District Court for the Western District of Arkansas granted summary judgment to Detective Wilson on the parents’ Fourth Amendment claims, finding she was entitled to qualified immunity. The court determined that the parents had not alleged a violation of their own Fourth Amendment rights and that the claims on behalf of the children did not overcome qualified immunity. The parents appealed, focusing solely on the Fourth Amendment claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The Eighth Circuit held that Detective Wilson was entitled to qualified immunity because, under the totality of the circumstances, a reasonable officer could have believed there was reasonable suspicion that the children were in danger. The court also declined to adopt a new standard requiring probable cause and exigent circumstances for such removals, noting that existing precedent did not clearly establish such a right. View "Welter v. Wilson" on Justia Law

Maurice Rose was convicted by a jury for attempting to kill a government witness in a federal drug and firearms case, intending to prevent the witness’s testimony against an associate. He was found guilty of two offenses: attempting to kill a person to prevent testimony in an official proceeding, and using a firearm during a crime of violence. Rose’s conviction resulted in a 330-month sentence, which was previously affirmed on direct appeal.After unsuccessful prior attempts at post-conviction relief, Rose sought permission to file a successive motion under 28 U.S.C. § 2255, relying on recent Supreme Court decisions—Sessions v. Dimaya and United States v. Davis—that changed the definition of “crime of violence” under 18 U.S.C. § 924(c). The United States Court of Appeals for the Eighth Circuit granted leave to file without addressing the merits. Rose then moved to vacate his firearm conviction, arguing that, under United States v. Taylor, witness tampering by attempted murder does not qualify as a “crime of violence.” The United States District Court for the Eastern District of Missouri denied the motion, finding that attempted killing remains a crime of violence, but issued a certificate of appealability due to the debatable nature of the issue.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed de novo whether Rose’s offense was a “crime of violence” under the elements clause of § 924(c). The court held that attempted murder, including attempted killing of a witness under § 1512(a)(1), categorically qualifies as a crime of violence because it requires the attempted use of physical force. The court distinguished this from the Supreme Court’s holding in Taylor, which addressed attempted Hobbs Act robbery. The Eighth Circuit affirmed the district court’s denial of Rose’s motion to vacate his conviction. View "Rose v. United States" on Justia Law

A Nebraska software company entered into a lease agreement with a financial technology firm for the use of proprietary software designed to facilitate electronic transactions. The agreement required the tech firm to pay substantial annual fees upon acceptance of the software, with installation dependent on the tech firm’s cooperation. The parties also entered a separate agreement for preinstallation services, which were paid in full. After initial delays and a temporary suspension due to the COVID-19 pandemic, the tech firm ultimately terminated the project, citing incompatibility of the software with its infrastructure.The software company filed suit in Nebraska state court, alleging breach of contract and breach of the implied covenant of good faith and fair dealing, seeking damages equal to the unpaid lease fees. The case was removed to the United States District Court for the District of Nebraska. The district court granted summary judgment for the tech firm, holding that a limitation-of-liability clause in the lease agreement barred the software company from recovering the damages sought. The court found that the clause limited recovery to fees actually paid, not fees owed, and that the clause was neither unconscionable nor rendered the contract meaningless. The court also determined that the Uniform Commercial Code did not apply, and even if it did, the contract did not fail of its essential purpose.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that, under Delaware law, the limitation-of-liability clause was enforceable as written, limiting damages to fees paid and barring recovery of unpaid fees. The court also found the clause was not unconscionable and that the contract did not fail of its essential purpose. The judgment in favor of the tech firm was affirmed. View "Baldwin Hacket and Meeks, Inc. v. Early Warning Services, LLC" on Justia Law

West Central Agri Services operates a grain handling facility in Missouri, where employees load grain into railcars by accessing the tops of the cars, which are about fifteen feet above the ground. Employees open and close lids on the railcars to facilitate grain transfer, and a Trackmobile moves the railcars into position. An OSHA inspector, investigating an unrelated explosion, discovered that employees frequently worked atop railcars without wearing fall protection personal protective equipment (PPE), despite the facility having a fall protection system in place on one track and safety training instructing use of such equipment. Supervisors were aware of the lack of PPE use, and employees were not disciplined for noncompliance.Following the investigation, the Secretary of Labor cited West Central for a willful and serious violation of 29 C.F.R. § 1910.132(d)(1)(i), which requires employers to ensure employees use appropriate PPE for identified hazards. After a three-day evidentiary hearing, an administrative law judge (ALJ) of the Occupational Safety and Health Review Commission upheld the citation and imposed a penalty of $122,878.80, finding that West Central recognized the fall hazard and failed to enforce PPE use. The Commission denied discretionary review of the ALJ’s decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the Federal Railroad Administration (FRA) has exercised statutory authority over the working conditions on top of railcars, specifically through its 1978 policy statement asserting jurisdiction over walking-working surfaces and employee protection around railcars. As a result, the FRA’s authority preempts OSHA’s jurisdiction under 29 U.S.C. § 653(b)(1). The court vacated the citation and reversed the ALJ’s order, concluding that OSHA cannot enforce its PPE regulation for employees working on top of railcars at this facility. View "MFA Enterprises, Inc. v. OSHRC" on Justia Law

A train conductor and other women working at a Nebraska railyard alleged that they were subjected to frequent sex-based harassment by coworkers and supervisors. The allegations included unwelcome sexual advances, derogatory comments about women’s abilities, sexually explicit jokes, persistent sexual graffiti in work areas, unsanitary restroom conditions intentionally created to harass women, and the display of sexually explicit images. The employer’s supervisors allegedly failed to address complaints, sometimes responding dismissively or with humor. The Equal Employment Opportunity Commission (EEOC) investigated these claims, found reasonable cause to believe that Title VII had been violated, and, after unsuccessful conciliation, filed suit on behalf of the named conductor and a group of similarly aggrieved women.The United States District Court for the District of Nebraska dismissed the EEOC’s claims on behalf of the group of women, holding that the EEOC failed to plead that the group suffered the same type of harassment as the named conductor and did not adequately specify the class size. The court later granted summary judgment to the employer on the individual claim, finding that the alleged harassment was not sufficiently severe or pervasive to constitute a hostile work environment under Title VII, and that conduct outside the statutory limitations period was not part of a continuing violation.The United States Court of Appeals for the Eighth Circuit reversed both the dismissal and the summary judgment. The appellate court held that the district court erred by imposing heightened pleading requirements not supported by law, and that the EEOC’s complaint plausibly alleged a hostile work environment for the group. The Eighth Circuit also found that there were genuine issues of material fact regarding the severity and pervasiveness of the harassment and whether pre- and post-limitations conduct formed a continuing violation. The case was remanded for further proceedings. View "EEOC v. BNSF Railway Company" on Justia Law

A fire occurred on September 27, 2018, at a multi-building apartment complex in Birmingham, Alabama, owned by Maxus Metropolitan, LLC. The fire destroyed one building and damaged others, including causing soot and water damage. Maxus was insured by Travelers Property Casualty Company of America under a policy covering physical loss or damage and lost business income. After the fire, Maxus and Travelers disagreed over the extent of coverage, particularly regarding remediation costs for microscopic soot and water damage. Maxus hired experts who found widespread soot contamination, prompting evacuation and remediation. Travelers disputed the necessity of remediation and delayed coverage decisions.Maxus sued Travelers in Missouri state court for breach of contract and vexatious refusal to pay, and Travelers removed the case to the United States District Court for the Western District of Missouri. At trial, the jury found for Maxus, awarding substantial damages, additional damages for vexatious refusal, and attorneys’ fees. The district court granted Maxus’s motions for attorneys’ fees and prejudgment interest, including fees for pre-suit work and paralegal support. Travelers moved for judgment as a matter of law and for a new trial, arguing issues with coverage, sufficiency of evidence, jury instructions, and calculation of damages and fees.The United States Court of Appeals for the Eighth Circuit reviewed the case. It affirmed the district court’s denial of Travelers’ motions for judgment as a matter of law and for a new trial, holding that microscopic soot can constitute “direct physical loss or damage” under Missouri law if it renders property uninhabitable, and that sufficient evidence supported the jury’s findings on coverage and vexatious refusal. The court also affirmed the attorneys’ fees award. However, it vacated the prejudgment interest award, finding the calculation method improper, and remanded for recalculation based on the dates payment was demanded from Travelers. View "Maxus Metropolitan, LLC v. Travelers Property Casualty Co." on Justia Law

Charles Sorensen, a retired airline pilot, engaged in a series of actions from 2016 to 2021 to evade federal income taxes for the years 2015 through 2019. His conduct included failing to file tax returns, submitting false returns, making fraudulent refund claims, concealing income and assets, and refusing to cooperate with the IRS. Sorensen used shell companies, such as LAWTAM and LAMP, to hide assets and income, transferred funds to avoid IRS levies, and ultimately converted assets into cryptocurrency to further shield them from collection. He also filed frivolous documents and lawsuits challenging the IRS’s authority. The total tax loss attributed to his actions was $1,861,722.A jury in the United States District Court for the District of Minnesota convicted Sorensen on seven counts, including filing false tax returns, tax evasion, failing to file tax returns, and making a false claim against the United States. The district court sentenced him to 41 months in prison. Sorensen appealed, arguing that the district court improperly admitted testimony from several witnesses who were not qualified as experts and erred in applying a sentencing enhancement for sophisticated means.The United States Court of Appeals for the Eighth Circuit reviewed the evidentiary rulings for abuse of discretion and the sentencing enhancement de novo. The appellate court held that the challenged witness testimony was properly admitted as lay testimony under Federal Rule of Evidence 701, as it was based on firsthand knowledge and personal experience, not specialized expertise. The court also found that the sophisticated means enhancement was appropriately applied, given Sorensen’s use of shell companies, cryptocurrency, and other complex methods to conceal his tax evasion. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Sorensen" on Justia Law

The plaintiff, a Nebraska resident, received Medicaid benefits administered by the Nebraska Department of Health and Human Services (NDHHS). In April 2024, she was sent a notice stating her Medicaid eligibility was ending due to income exceeding program standards. The notice informed her of her rights to request a conference or appeal and outlined the process for a fair hearing. She did not appeal the termination, and her coverage ended on May 1, 2024. Subsequently, she filed a federal lawsuit on behalf of herself and similarly situated individuals, alleging that the termination notices failed to meet due process requirements and seeking class certification, declaratory and injunctive relief, including reinstatement of benefits until proper notice was provided.The United States District Court for the District of Nebraska considered only her individual claims, as she did not challenge the court’s decision to exclude class claims on appeal. The district court denied her request for a temporary restraining order, finding she was unlikely to succeed because her claims sought retroactive relief barred by sovereign immunity and because the notices likely satisfied due process. The court then dismissed her complaint for lack of subject matter jurisdiction, concluding she had not alleged an ongoing violation of federal law and was not seeking prospective relief, as required to invoke the Ex parte Young exception to Eleventh Amendment immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s dismissal. The Eighth Circuit held that the plaintiff’s alleged due process violation was a discrete past event—the issuance of the notice and termination of benefits—not an ongoing violation. The court further held that the relief sought was retrospective, not prospective, and thus barred by the Eleventh Amendment. The court concluded that the Ex parte Young exception did not apply, and affirmed the dismissal. View "Filyaw v. Corsi" on Justia Law

A long-serving principal at a public middle school implemented an “inclusion project” that included a display of various flags, among them a Pride flag, using school funds. She informed staff that this project was part of her professional goals and later helped establish a Gay-Straight Alliance (GSA) student group. The inclusion of the Pride flag and her advocacy for LGBTQ+ students generated controversy among staff and community members, leading to complaints about her leadership style and claims that she was creating a divisive work environment. After an outside investigation substantiated concerns about her management, she was removed as principal and reassigned to a different administrative role.The United States District Court for the District of Minnesota granted summary judgment in favor of the school district and its officials on her federal claims, finding that her speech and actions were made pursuant to her official duties as principal and thus not protected by the First Amendment. The court also found insufficient evidence that any private speech or advocacy outside her official role was a motivating factor in the adverse employment actions. The district court dismissed her federal claims with prejudice and declined to exercise supplemental jurisdiction over her state law claims, dismissing them without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The appellate court held that the principal’s actions regarding the flag display and GSA were undertaken as part of her official duties and therefore constituted government speech, not protected by the First Amendment. The court also found no evidence that any private speech was a substantial or motivating factor in the employment decisions. The court further held that the district court did not abuse its discretion in declining supplemental jurisdiction over the state law claims. View "Thomas v. Marshall Public Schools" on Justia Law

Thomas Lamont Davis was investigated after selling methamphetamine to a confidential source on two occasions in March 2022. Law enforcement searched his residence in Des Moines, Iowa, and found firearms, large quantities of methamphetamine, cash, and drug paraphernalia. Davis was later involved in two separate high-speed chases while attempting to evade arrest, during which he possessed methamphetamine and cash. In one incident, Davis struggled with officers and bit one officer’s finger, causing injury that required stitches.The United States District Court for the Southern District of Iowa presided over Davis’s trial. Davis moved to exclude evidence of his prior Iowa felony convictions for drug and firearm offenses, but the district court denied the motion and admitted the convictions with a limiting instruction. A jury found Davis guilty on all counts, including drug distribution, possession with intent to distribute, and firearm offenses. At sentencing, the district court applied a two-level enhancement for maintaining a drug premises and a six-level enhancement for assaulting a law enforcement officer, resulting in a 360-month prison sentence.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Davis’s challenges to the admission of his prior convictions and the sentencing enhancements. The court held that the prior convictions were properly admitted for permissible purposes such as knowledge and intent, and the limiting instruction mitigated any risk of unfair prejudice. The court also found that the evidence supported the enhancements for maintaining a drug premises and for assaulting an officer, and that there was no impermissible double counting. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Davis" on Justia Law