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

An 11-year-old child, L.D., was placed in foster care with Trina Mae Johnson. Over a period of fifteen months, Johnson inflicted severe abuse on L.D., including physical torture, starvation, denial of medical care, and psychological torment. The abuse resulted in significant weight loss, untreated injuries, and lasting trauma. Johnson concealed the abuse, enlisted others in her household to participate, and intimidated L.D. into silence. The abuse came to light when Johnson brought L.D. to a youth shelter, prompting an investigation by child services and the FBI.Johnson and several co-defendants were indicted on charges of child torture, child neglect, child endangerment, and assaulting a minor with a dangerous weapon in both federal and Minnesota state law violations. Some co-defendants pleaded guilty, while Johnson’s sister went to trial. Johnson was unable to accept a plea agreement because it was contingent on both sisters pleading guilty. She ultimately pleaded guilty without an agreement. The United States District Court for the District of Minnesota sentenced Johnson to 216 months in prison, after considering the relevant sentencing factors and victim impact statements. The sentence was below the government’s recommendation but above the prior plea offer.On appeal to the United States Court of Appeals for the Eighth Circuit, Johnson argued that the district court judge’s direct, sympathetic comments to L.D. at sentencing demonstrated judicial bias and violated her due process right to an impartial tribunal. The Eighth Circuit applied plain error review, noting Johnson did not object to the judge’s comments at sentencing or seek recusal. The court held that the judge’s empathetic remarks to the victim did not display deep-seated favoritism or antagonism that would make fair judgment impossible. Finding no plain error or due process violation, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Johnson" on Justia Law

Thomas Sanderson, a registered sex offender in Missouri, challenged a statutory provision requiring all registered sex offenders to post a sign at their residence on Halloween stating, “No candy or treats at this residence.” Sanderson had a history of elaborate Halloween displays, but after his 2006 conviction and imprisonment, he was informed by police that he was “grandfathered in” and could continue participating in Halloween festivities. This changed in 2022 when Hazelwood police arrested and convicted him for violating the statute, specifically the sign mandate. Sanderson then brought a facial challenge under the First Amendment, arguing that the mandate compelled speech.The United States District Court for the Eastern District of Missouri first granted a preliminary injunction, finding Sanderson was likely to succeed on the merits. After a bench trial, the court found that the sign mandate was unconstitutional compelled speech under the First Amendment and issued a permanent injunction barring enforcement of the mandate statewide. The State appealed, contesting both the constitutional ruling and certain evidentiary decisions made during the trial.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error, applying heightened scrutiny to facts relevant to the First Amendment claim. The appellate court held that the sign mandate compelled speech and thus required strict scrutiny. While the State’s interest in protecting children on Halloween was compelling, the court found the sign mandate was not narrowly tailored to achieve that interest. The evidence failed to show the signs provided any additional protection beyond existing restrictions, and no justification was presented for their necessity. The Eighth Circuit affirmed the district court’s holding that the sign mandate facially violates the First Amendment, vacated the injunction due to recent Supreme Court precedent, and remanded for reconsideration of the scope of injunctive relief. View "Sanderson v. Hanaway" on Justia Law

The dispute arose from a tragic incident on January 14, 2022, when Marquise Webb and Richie Aaron, Jr. boarded an Amtrak train in Illinois. Although unrelated, both transferred to Amtrak’s River Runner train in Missouri, where Webb fatally shot Aaron without apparent motive during a scheduled stop. Amtrak prohibits firearms onboard, but does not routinely conduct passenger security screenings. After the shooting, Amtrak crew initially dismissed reports of gunfire as fireworks, and medical aid was rendered to Aaron at the next station, but he was pronounced dead shortly thereafter.Following these events, Breayonna Aaron, representing herself, her deceased husband, and their children, filed suit in the United States District Court for the Western District of Missouri against Amtrak for negligence, negligent hiring/training/supervision, and wrongful death, seeking substantial compensatory and punitive damages. Amtrak moved for judgment as a matter of law, but the court submitted the case to a jury, which found Amtrak liable and awarded both compensatory and punitive damages. After trial, Amtrak renewed its motion for judgment as a matter of law or, alternatively, sought a new trial or reduction in punitive damages. The district court denied Amtrak’s motions, but reduced the punitive damages award as constitutionally excessive.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of Amtrak’s motion for judgment as a matter of law de novo. It held that the plaintiffs failed to provide legally sufficient evidence of a duty or causation under any negligence theory presented, as Missouri law requires foreseeability of criminal acts for a duty to exist, and but-for causation for wrongful death. The appellate court reversed the district court’s denial of Amtrak’s motion for judgment as a matter of law and directed the entry of judgment for Amtrak, finding no basis for liability on the claims asserted. View "Aaron v. National Railroad Passenger Corporation" on Justia Law

Jonathan Russell Wright was convicted by a jury in 2012 for possession with intent to distribute cocaine base, a federal offense, and sentenced to life imprisonment under the Controlled Substances Act. The life sentence was imposed due to three prior convictions under Arkansas law for cocaine-related offenses, which triggered a mandatory minimum enhancement. Years later, Congress enacted the First Step Act, which reduced mandatory minimum penalties for certain drug offenses but did not apply retroactively. Wright sought a sentence reduction in 2024, arguing that changes in law, including the First Step Act and recent case law, created a gross disparity between his sentence and what he would receive today. He claimed his prior Arkansas convictions should no longer qualify as predicate offenses for enhancement.The United States District Court for the Eastern District of Arkansas-Central granted Wright’s motion in part, reducing his sentence to 420 months and imposing ten years of supervised release. The court acknowledged the disparity created by the First Step Act as an “extraordinary and compelling reason” for reduction but rejected Wright’s argument that his prior Arkansas convictions could not serve as predicate offenses, citing prior decisions. Wright appealed, arguing for a lower sentence and challenging the district court’s treatment of his prior convictions and its weighing of sentencing factors.The United States Court of Appeals for the Eighth Circuit reviewed the case, first addressing whether President Biden’s commutation of Wright’s sentence to 330 months mooted the appeal. The Eighth Circuit held that the commutation did not moot the case, as courts retain authority over judicial sentences. On the merits, the court found that Wright’s Arkansas convictions no longer qualify as predicate offenses under federal law and that the district court abused its discretion by failing to consider this legal development. The Eighth Circuit vacated Wright’s sentence and remanded for resentencing consistent with its ruling. View "United States v. Wright" on Justia Law

The plaintiffs owned and operated a hotel that had a record of serious structural and safety problems, including a window and a stone falling from the building, and repeated failures to correct code violations. After a fire occurred without activation of the sprinkler system, a follow-up inspection revealed that several fire code violations remained unaddressed, along with new violations. Based on these findings, the city’s building administrator ordered the hotel to be closed immediately, citing imminent safety risks. The owners sought to appeal and demanded hearings, but the city cited the COVID-19 pandemic as a reason for delay and directed them to other appellate avenues. The closure order was lifted once the most urgent hazards were remedied, and the owners eventually fixed all violations.The United States District Court for the District of Minnesota granted summary judgment to the city and the building administrator, finding no violations of procedural due process or the Fifth Amendment, and that qualified immunity protected the administrator in his individual capacity. The plaintiffs appealed, challenging the procedural due process provided for the closure, the application of qualified immunity, and asserting that the closure constituted a regulatory taking.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The court held that, even assuming a protected property interest existed, the risk of erroneous deprivation was low due to specific regulations and the availability of prompt post-deprivation remedies. The court also found that swift action in the face of public safety threats justified summary administrative action without additional pre-deprivation process. Regarding qualified immunity, the court determined that no clearly established law prohibited the administrator’s conduct. Finally, the court held that the temporary closure was a lawful exercise of police power and did not amount to a compensable regulatory taking. View "reVamped LLC v. City of Pipestone" on Justia Law

Ronald B. Panting, an independent contractor serving as a Designated Pilot Examiner (DPE) for the FAA, was conducting a pilot certification checkride for Michael Trubilla in a plane rented from the LeMay Aero Club, a government-affiliated organization. Both men died when the plane crashed during the checkride. Five days prior to the accident, Ronald signed a covenant not to sue the government for injuries sustained while participating in Aero Club activities, applicable to himself and his estate. His spouse, Lynne D. Panting, sued the United States under the Federal Tort Claims Act, alleging negligent maintenance of the aircraft.The United States District Court for the District of Nebraska denied the government’s motion for summary judgment, ruling the covenant not to sue was void as against public policy under Nebraska law. The court did not address Lynne’s alternative argument that the covenant did not apply to Ronald’s activities as a DPE on the day of the crash. Following a bench trial, the district court found the government negligent and entered judgment for Lynne, awarding damages. The government appealed, challenging the district court’s decision regarding the covenant’s validity.The United States Court of Appeals for the Eighth Circuit held that it had jurisdiction to review the denial of summary judgment because the enforceability of the covenant was a purely legal issue. Applying Nebraska law, the appellate court determined the covenant was neither clearly repugnant to public policy nor the product of disparate bargaining power, and that the Aero Club did not provide a public or essential service. The Eighth Circuit reversed the district court’s judgment and remanded for consideration of whether the covenant covered Ronald’s activities as a DPE, and for further proceedings as appropriate. View "Panting v. United States" on Justia Law

An undercover law enforcement operation targeted individuals seeking to purchase sex from minors through an online platform known for prostitution ads. An agent created a fake profile of a 45-year-old woman but, upon contact, informed the defendant that "she" was actually 13 years old. Despite multiple text exchanges in which the defendant expressed reluctance to engage with someone underage, he continued the conversation, eventually requesting photos, discussing sexual acts, and arranging a meeting while being repeatedly reminded of the minor’s age. At the meeting site, agents seized his phone, which he attempted to wipe, erasing relevant evidence.The United States District Court for the Northern District of Iowa conducted a trial in which a jury convicted the defendant of attempted sex trafficking of a child and destruction of evidence. The court sentenced him to concurrent terms of 292 months and 240 months’ imprisonment. The defendant appealed, challenging the admission of lay-opinion testimony by the undercover agent regarding the perceived maturity of the fictitious minor’s responses, the denial of his request to contact a juror based on alleged outside influence, and the refusal to grant a downward sentencing variance on grounds of purported sentencing manipulation.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The appellate court held that the agent’s lay-opinion testimony was appropriately admitted under Federal Rule of Evidence 701, as it was based on personal knowledge and aided the jury’s understanding. The court found no abuse of discretion in denying juror contact, as the defendant’s claims were speculative and unsupported by evidence of outside influence. Finally, the court rejected the sentencing manipulation claim, determining that law enforcement had a legitimate goal in targeting those seeking sex with very young minors and that the agent’s actions were not solely intended to enhance the sentence. The judgment was affirmed. View "United States v. Johnson" on Justia Law

Yuri Chachanko and an accomplice committed a series of armed robberies in South Dakota and Montana, leading to federal charges in both states. He was first prosecuted in Montana, where he received a 219-month sentence for Hobbs Act violations and firearm use. After completing that sentence, he faced prosecution in South Dakota, where he pleaded guilty to another firearm offense and was sentenced to 300 months, to be served consecutively after the Montana sentence. Years later, after legislative changes under the First Step Act, Chachanko sought a reduction of his South Dakota sentence, arguing that it was unusually long and that his medical conditions warranted relief.The United States District Court for the District of South Dakota considered his motion. The court focused on whether Chachanko had served at least 10 years of the South Dakota sentence, as required for a reduction based on an unusually long sentence under the Sentencing Guidelines. It found that, although Chachanko had spent 17 years in custody overall, he had only just begun serving the South Dakota sentence, as the sentences were consecutive. The court also found that his medical conditions were adequately managed and did not meet the standard for extraordinary and compelling reasons, and that no combination of circumstances justified relief.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the phrase “the term of imprisonment” in the relevant statute and guidelines refers specifically to the sentence imposed by the court reviewing the motion—here, the South Dakota sentence—and not to an aggregate of multiple sentences. As Chachanko had not served 10 years of the South Dakota sentence, he was ineligible for relief on that basis. The court also found no abuse of discretion in denying relief based on medical or other circumstances. View "United States v. Chachanko" on Justia Law

A man was charged with several federal offenses, including being a felon in possession of a firearm, transporting a minor with intent to engage in prostitution, and possession of child pornography. The charges arose after he met a 16-year-old runaway through Craigslist, transported her across state lines, and engaged in a sexual relationship with her. Law enforcement discovered him with the minor, searched his residence, and found child sexual abuse material and multiple firearms. The defendant admitted to knowing the minor’s age and her mental health issues.He ultimately pled guilty to the firearm charge and one transportation count, with the remaining charges dismissed as part of a plea agreement. At sentencing in the United States District Court for the Southern District of Iowa, he received 292 months for transportation of a minor and 180 months for the firearm offense, to run concurrently. Thirteen days later, he moved to withdraw his guilty plea on the transportation count, arguing that he only learned at sentencing that the minor was missing and that this constituted exculpatory evidence the prosecution should have disclosed. The district court denied his motion, stating it lacked authority to consider post-sentencing withdrawal of a guilty plea except by direct appeal or collateral attack, and found that the minor’s unavailability was not exculpatory since public records of her status were available before the plea.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial under the abuse of discretion standard and affirmed. The appellate court held that Federal Rule of Criminal Procedure 11(e) barred post-sentencing withdrawal of a guilty plea except by direct appeal or collateral attack, and that no Brady violation occurred because the information about the minor’s status was publicly available. The court also declined to review the firearm sentence under the concurrent sentence doctrine, as any ruling would not affect the defendant’s time to be served. The judgment was affirmed. View "United States v. Adkins" on Justia Law

A railroad company headquartered in Nebraska provides track safety services known as “flagging,” often using its own employees. A third-party company, RailPros, also supplies flagging workers for outside projects that require access to the railroad’s property. A labor union, which represents some employees of the railroad but not RailPros workers, requested that a federal agency determine whether RailPros flagging workers should be considered covered employees under federal railroad retirement and unemployment statutes. The union argued that the railroad’s use of RailPros workers displaced union members and undermined the benefits system. The agency began an investigation, requested information from the railroad, and ultimately scheduled a hearing to decide the employment status of the RailPros workers. The agency also designated the union as a party to the hearing, which would give it access to confidential business information.The railroad objected to the union’s party status, arguing that it would result in disclosure of sensitive information to an adversarial party. After the agency declined to remove the union as a party or to sufficiently protect the railroad’s confidential information, the railroad filed a lawsuit in the United States District Court for the District of Nebraska. The railroad sought judicial review of the agency’s order under the Administrative Procedure Act (APA), alleging the order was unlawful and would cause irreparable harm. The district court dismissed the complaint for lack of subject matter jurisdiction, concluding that exclusive judicial review lay in the courts of appeals under the statutory schemes governing railroad retirement and unemployment benefits.The United States Court of Appeals for the Eighth Circuit reversed, holding that the agency’s order granting the union party status was a final agency action under the APA and not subject to exclusive review in the courts of appeals under the relevant statutes. The court ruled that the district court had subject matter jurisdiction to review the agency’s order immediately under the APA and remanded the case for further proceedings. View "Union Pacific Railroad Co. v. RRRB" on Justia Law