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

The Robbinses provide towing and wrecker services along the I-44 corridor in eastern Missouri. State Highway Patrol (MSHP) Troops C and I, pursuant to MSHP policy, used a “rotation list” of approved towing and wrecking companies to determine which company to call to the scene of a disabled vehicle if the vehicle owner had no preference. The Robbinses were on both lists until they were removed, reportedly because Robbins had been charged with shooting at a competitor’s truck in 1999. The Robbinses alleged the criminal charge resulted from a “sham investigation” and that their competitor used a friendship with an MSHP officer, with whom Robbins had had a confrontation, to harm the Robbinses’ business. A jury acquitted Robbins, but they were never reinstated to either list. In 2005, the Robbinses sued the MSHP. The state court determined the MSHP lacked statutory authority to create a rotation list. In 2010, the Robbinses sued officers in their individual capacities, alleging due process and equal protection violations and conspiracy to violate those rights under 42 U.S.C. 1983 and violations of the Sherman Act, 15 U.S.C. 1, 2, claiming that the officers conspired to deny them work and disparaged their business. The Eighth Circuit affirmed summary judgment in favor of the officers. View "Robbins v. Becker," on Justia Law

After graduating from the FAA Academy, Huynh became a trainee air traffic controller. Huynh, the only Asian American in his training class, reported problems with his instructors. He was assigned a different team. The new team reported that Huynh was performing poorly. Huynh was granted 42 additional training hours above the180 target hours. After he completed those hours, Huynh moved on to the second of 12 required certifications. He was again reported as performing poorly. Huynh's team provided many opportunities to improve, beyond the 180t hours. Superiors reported that Huynh did not have command of basic air traffic terminology and geography and was defensive when trainers noted mistakes. Huynh was the only member of his class suspended for poor performance on a skill check. Huynh applied for reassignment, but no other facilities offered to hire him. A review board concluded that Huynh had been given comprehensive training, but had failed to progress. A manager nonetheless continued Huynh's training. Huynh received additional instruction and several weeks to refresh his learning. Shortly after Huynh returned to training, he reported problems with his supervisors and classmates. He declined reassignment. Problems continued; Huynh was terminated. The court granted the FAA summary judgment. The Eighth Circuit affirmed, rejecting claims of racial discrimination under 42 U.S.C. 2000e and the Minnesota Human Rights Act, finding that the stated reasons for termination were not pretextual. View "Huynh v. Dep't of Transp." on Justia Law

R.W., a student, bought marijuana from Boykin, who delivered to campus. After a few months, Boykin and another dealer, Patterson, planned to rob R.W., whom Patterson did not know. Through the exchange of text messages, R.W. agreed to buy marijuana. Patterson and Boykin drove to campus. R.W. entered Boykin's car at his direction. R.W. then noticed Patterson, who pulled a gun and told R.W. that he had to "give up everything." R.W. had an iPhone, a "gar card," his dorm key, and $310 cash. After travelling a short distance from campus, they stopped. Patterson pointed the gun and told R.W. not to "try anything stupid" or he would "get shot." Boykin opened the door—because there was a child safety lock—and released R.W. R.W. called security. Police stopped Boykin and Patterson, seized a handgun from Boykin's car, and discovered R.W.'s gar card in the backseat. Boykin had $145, and Patterson had $40 and a .22 caliber round in his pocket. Boykin was convicted of kidnapping, 18 U.S.C. 1201, and conspiracy to distribute marijuana, 21 U.S.C. 841(a)(1), 841(b)(1)(D), and 846. The Eighth Circuit affirmed Boykin's kidnapping conviction, rejecting an argument that the indictment was missing an essential element, but reversed in part for insufficient evidence of a conspiracy to distribute marijuana. View "United States v. Boykin" on Justia Law

Mead, committed to Iowa's Civil Commitment Unit for Sex Offenders filed a 42 U.S.C. 1983 complaint alleging that defendants deprived him of "extensive dental care that he is unable to afford" and were "deliberately indifferent to [his] need for dental care." He alleged that he had many teeth pulled while in custody, was unable to chew food properly, suffered from acid reflux, and had become diabetic. The defendants moved for summary judgment arguing that Mead had sufficient funds to pay for a partial denture plate and failed to demonstrate a serious medical need because he had not requested and did not want a soft diet, had not lost weight, had complained of discomfort but not pain, had stated that he was satisfied with his medical care, and no dentist had concluded that Mead had a serious medical need for dentures. The defendants argued that they were entitled to qualified immunity, not personally responsible for Mead's alleged damages, and immune from money damages. The district court denied summary judgment, concluding that Mead had established genuine issues of material fact. The Eighth Circuit reversed, finding the defendants entitled to qualified immunity from damages on Mead's claim regarding the denial of partial dentures View "Mead v. Palmer" on Justia Law

After his car was hit by a car driven negligently by Sheffer, Behlmann was billed $89,884.79 for medical treatment. Behlmann settled with Sheffer for $50,000, the limit of Sheffer’s policy. Behlmann sued his insurer, Century, for underinsured motorist benefits. Century argued that Behlmann’s medical treatment cost less than $50,000 and resulted from pre-existing conditions. The jury found for Century. Behlmann unsuccessfully requested a new trial, challenging the admission of evidence on the value of his medical treatment and the strike of the only African-American venire person. The Eighth Circuit affirmed, noting Missouri law: “Parties may introduce evidence of the value of the medical treatment rendered to a party that was reasonable, necessary, and a proximate result of the negligence of any party.” Behlmann did not establish that Century’s reasons for the strike were pretextual. Juror 4 was a long-time autoworker; he failed to disclose he was an autoworker despite relevant questioning; and he failed to disclose involvement in prior litigation. View "Behlmann v. Century Sur. Co." on Justia Law

In April 2011, while its patent application was pending with the USPTO, U.S. Water Services, which “sell[s] water treatment and purification equipment, materials, and services,” especially “to ethanol process technologies,” sued its competitor, ChemTreat, for misappropriation of trade secrets. In October 2011, the USPTO issued the 244 patent covering a method to reduce the formation of insoluble scale deposits during the production of ethanol using enzyme, phytase, in its “pHytOUT® system.”Three days before U.S. Water and ChemTreat settled the misappropriation claim, ChemTreat filed counterclaims requesting declaratory judgments of noninfringement and invalidity of the 244 patent. The suit was filed before the Leahy-Smith America Invents Act, 125 Stat. 284, took effect, so the counterclaims independently did not establish appellate jurisdiction for the Federal Circuit. The district court granted ChemTreat summary judgment as to the noninfringement counterclaim and dismissed the invalidity counterclaim. The Eighth Circuit affirmed. Evaluating the “totality of [the] circumstances,” the district court did not err in finding the misappropriation action, together with U.S. Water’s statements to its customers and supplier, produced an objective, “reasonable apprehension of suit,” and did not err in concluding declaratory judgment subject matter jurisdiction existed. The decision did not constitute an advisory opinion. View "U.S. Water Servs., Inc. v. ChemTreat, Inc." on Justia Law

Milam applied for disability insurance benefits in 2011, identifying conditions of back pain, knee pain, hip pain, and osteoporosis and a 2009 disability onset date—the same day she was laid off. Milam had worked for 20 years, most recently as an administrative assistant. The ALJ noted his general suspicions about claimants who are "laid off—they work until the last day and then all of a sudden they're disabled," noting that after alleged onset date, Milam received unemployment benefits and looked for a new job. Milam testified that she can drive for only 20 minutes without back and hip pain, can sit for only 30 minutes continuously before needing to stand, can lift five to ten pounds, has limited ability to bend her back, and has difficulties rotating and squatting. She testified that she is in pain "24/7" and sleeps four to five hours per night. She submitted letters from three former coworkers stating that Milam was absent from work up to five days per month. The ALJ found that Milam was not disabled, but could perform sedentary work with restrictions. The Appeals Council denied her request for review. The district court and Eighth Circuit affirmed the denial as supported by substantial evidence. View "Milam v. Colvin" on Justia Law

Initially hired in 1987, Schaffhauser worked as a Plant Engineering Manager from 2007-2012. He received training on UPS’s anti-harassment, anti-discrimination, and ADA policies. The company prohibits unprofessional and discourteous actions, even if those actions do not constitute unlawful harassment. In 2012, Schaffhauser was at work chatting with Sharkey, Goodwin, and Williams (all African-Americans). Goodwin said, “I wish Rodney Barefield would take a swing at me and I would knock that motherf**r out.” Schaffhauser commented, “If he ever hit me, I would hit him back so hard it’d knock the black off him.” He admits making the comment, that it could be racist, and that it was a mistake, but claims he was just joking and did not intend it to be racist. In his report to human resources, Schaffhauser claimed that his medical condition was a “contributing factor in [his] poor choice of words.” Schaffhauser was demoted from manager to supervisor. Schaffhauser sued UPS, alleging reverse race discrimination and failure to accommodate a disability (he had received a steroid shot). The district court granted summary judgment to UPS. The Eighth Circuit affirmed. Schaffhauser did not request accommodation or inform UPS of the relevant details of his disability. UPS had a legitimate, nondiscriminatory reason for its action View "Schaffhauser v. United Parcel Serv., Inc." on Justia Law

Lumber, a tax-exempt insurance trust (26 U.S.C. 501(c)(9)), purchased life insurance issued by GAMHC. GAMHC converted from an insurer owned by policyholders to one owned by stockholders. In 2003, Lumber received a $1,474,442.30 liquidating distribution and a statement that the entire “initial distribution . . . will constitute long-term capital gain.” Lumber reported the gain on its return for fiscal year 2004 and paid capital gains tax of $200,686. Lumber received additional distributions of $285,647 and $213,567, which it reported as taxable capital gains on its 2006 and 2008 returns. The IRS had adopted the position that a policyholder’s proprietary interest in a mutual insurance company had a tax basis of zero. In 2008, the Claims Court rejected that position. Lumber sought refunds for 2004, 2006, and 2008. The IRS delayed a ruling until the Federal Circuit affirmed, then allowed Lumber’s claims for 2006 and 2008 and refunded $42,847 and $32,035, but denied Lumber’s claim for 2004, citing the three-year limitations period. The district court granted Lumber summary judgment, concluding that the mitigation provisions, I.R.C. 1311-1314, permitted correcting the erroneous recognition of gain. The Eighth Circuit reversed. Allowing taxpayers to reopen closed tax years based upon a favorable change in, or reinterpretation of, the laws would be inconsistent with the congressional intent in enacting the mitigation provisions to “preserve unimpaired the essential function of the statute of limitations.” View "Ill. Lumber & Material v. United States" on Justia Law

A.W., 10 months old, lived with his mother, Maxwell; his father, White; and half-siblings. A.W. was developing normally. On August 30, Maxwell took a walk with the other children, returning 10 minutes later. White met them at the door and stated that A.W. was choking and that he had found a cigarette filter in A.W.’s mouth. At the hospital, A.W. seized, breathed irregularly, had unequal pupils, and had extensor posturing, which can indicate injury at the deepest part of the brain. A doctor noticed bruising, estimated to be hours old, and believed that A.W. had been “shaken.” At a Fargo medical center, doctors found a brain hemorrhage and concluded that A.W. had shaken baby syndrome. His parents raised concerns about Maxwell’s eight-year old son, J.S., who may have played a role in the death of dogs who were thrown against a tree; knocked out another child’s teeth; threw rocks at children; and had previously injured A.W. A.W. survived and was placed into a therapeutic foster home for medically fragile children. A jury found White guilty of assault resulting in serious bodily injury in Indian country, 18 U.S.C. 113(a)(6), 1151, 1153(a). The court granted White’s motion for acquittal. The Eighth Circuit reversed. The government’s case favored guilt. There was evidence about J.S., but also evidence that a reasonable jury could find to be powerful evidence of White’s guilt and evidence that J.S. did not injure A.W. on August 30. View "United States v. White" on Justia Law