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

During a night of civil unrest in Des Moines, Iowa, police and Polk County deputies arrested 14 individuals. The arrestees claimed their Fourth Amendment rights were violated and sued 53 defendants under 42 U.S.C. § 1983. The district court issued a comprehensive opinion with around 800 rulings on various motions for summary judgment and qualified immunity, leading to multiple appeals.The United States District Court for the Southern District of Iowa denied qualified immunity to several officers and granted summary judgment to some plaintiffs. The Des Moines defendants appealed these decisions, arguing they had probable cause to arrest anyone in the vicinity of the protests for misdemeanors such as participation in a riot, unlawful assembly, and failure to disperse. The district court found that the officers lacked probable cause or arguable probable cause for these arrests, as they did not provide specific evidence linking the plaintiffs to violent behavior or failure to disperse.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decisions de novo. The court affirmed the denial of qualified immunity to Officers Herman, Holtan, and McCarthy on Klingenberg's unlawful arrest claim, and dismissed Officer Lawler's appeal for lack of jurisdiction. The court also dismissed appeals from Captain Hardy and other officers regarding Lard's and DeBrossard's unlawful arrest claims and Lard's excessive force claim. The court affirmed the grant of summary judgment to the Patton group on their unlawful arrest claims and denied qualified immunity to the Des Moines defendants on the plaintiffs' malicious prosecution claims. Additionally, the court affirmed the grant of summary judgment to the plaintiffs on their phone seizure claims against Officer Youngblut and denied him qualified immunity.The court reversed the district court's denial of qualified immunity to Deputy Smith on Timberlake's unlawful arrest claim, finding no clearly established duty for Smith to ensure the lawfulness of the arrest before taking custody. Finally, the court affirmed the grant of qualified immunity to Officer Holtan and Deputy Callahan on Dunn's and Fugate's unlawful arrest claims, concluding they had arguable probable cause under Iowa's failure to disperse statute. The case was remanded for further proceedings consistent with these rulings. View "Dunn v. Does" on Justia Law

Farnsworth Coleman, the sole member of Coleman Consulting, LLC (CC), entered into a written Confidentiality Agreement with Domtar A.W. LLC (Domtar A.W.) in November 2016 to provide consulting services for a pulp mill in Ashdown, Arkansas. CC was compensated for its services and expenses at an agreed hourly rate. CC later claimed that an oral agreement was made with Domtar A.W. for additional compensation based on a percentage of increased profits from CC's recommendations, which Domtar A.W. denied. CC filed a lawsuit for breach of contract and unjust enrichment after Domtar A.W. terminated the consulting services in May 2017.The United States District Court for the Western District of Arkansas granted summary judgment in favor of Domtar A.W., concluding that the Arkansas statute of frauds barred CC's breach of contract claim because the alleged oral agreement could not be performed within one year. The court also found that CC failed to prove its unjust enrichment claim, as CC had been fully compensated for its services under the written agreement. CC's motion for reconsideration, based on newly discovered evidence, was denied.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court agreed that the oral agreement was subject to the statute of frauds and could not be performed within one year. The court also found that the part performance and detrimental reliance exceptions to the statute of frauds did not apply. Additionally, the court upheld the dismissal of the unjust enrichment claim, noting that CC had been paid for its services and could not use unjust enrichment to enforce an unenforceable oral contract. The denial of the motion for reconsideration was also affirmed, as CC failed to demonstrate due diligence in obtaining the new evidence. View "Coleman Consulting, LLC v. Domtar Corporation" on Justia Law

Anthony Fisher, while burglarizing a home, encountered the homeowner and shot him multiple times. Fisher, a felon at the time, was charged by the federal government with unlawful possession of ammunition under 18 U.S.C. § 922(g)(1). The jury found Fisher guilty. On appeal, Fisher argued that he lacked knowledge of his prohibited status when he possessed the ammunition, relying on the Supreme Court's decision in Rehaif v. United States.The United States District Court for the Northern District of Iowa oversaw the trial. Fisher contended that he did not know he was a felon when he possessed the ammunition. The jury, however, found sufficient evidence to convict him. Fisher was sentenced to 120 months in prison, the statutory maximum, despite the Sentencing Guidelines suggesting a longer term.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court examined whether the evidence supported the jury's finding that Fisher knew of his felon status when he possessed the ammunition. The court noted that Fisher had pleaded guilty to an Iowa felony in 2020, signed documents acknowledging his felony status, and had a probation agreement that explicitly stated his crime was a felony. Additionally, Fisher's probation officer testified that his felony status affected his employment opportunities. The court concluded that a reasonable jury could find that Fisher knew he was a felon based on this evidence.The Eighth Circuit affirmed the district court's judgment, holding that the evidence sufficiently supported the jury's finding that Fisher knew of his prohibited status when he possessed the ammunition. View "United States v. Fisher" on Justia Law

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

Marcus Millsap was convicted by a jury of conspiracy to violate the Racketeer Influenced and Corrupt Organizations Act (RICO), aiding and abetting attempted murder in aid of racketeering, and conspiracy to distribute and possess with intent to distribute 500 grams or more of methamphetamine. Millsap was involved with the New Aryan Empire, a white-supremacist organization engaged in drug trafficking. He assisted the organization's president, Wesley Gullett, in drug operations and attempted to retaliate against Bruce Hurley, a police informant, by offering money to have him killed. Gullett attempted to kill Hurley but failed, and Hurley was later murdered by an unknown perpetrator.The United States District Court for the Eastern District of Arkansas sentenced Millsap to life imprisonment. Millsap appealed, arguing that his indictment should have been dismissed due to a violation of the Interstate Agreement on Detainers Act, and that the district court made several errors regarding evidentiary issues and juror intimidation. He also challenged his sentence if the convictions were upheld.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the Interstate Agreement on Detainers Act did not apply because Millsap was transferred to federal custody via a writ of habeas corpus ad prosequendum before a detainer was lodged. The court also held that there was no sufficient showing of juror intimidation to justify a mistrial. The court found the evidence sufficient to support Millsap's convictions on all counts, including his association with the drug-trafficking enterprise and his involvement in the attempted murder of Hurley.The court also ruled that the district court did not err in admitting co-conspirator statements and other evidence, and that any potential errors were harmless. The court upheld the district court's application of sentencing enhancements and the calculation of Millsap's criminal history points. Consequently, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Millsap" on Justia Law

TD Ameritrade offers brokerage services to retail investors, allowing them to trade stocks through its online platform. The company routes customer orders to trading venues for execution. Roderick Ford, representing a group of investors, alleged that TD Ameritrade's order-routing practices violated the company's duty of best execution by prioritizing venues that paid the company the most money rather than those providing the best outcomes for customers. Ford claimed this violated § 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, and that CEO Frederic J. Tomczyk was jointly liable under § 20(a) of the Act.A magistrate judge initially recommended denying Ford's motion for class certification due to the predominance of individual questions of economic loss. However, the district court certified a class, believing Ford's expert's algorithm could address these issues. The Eighth Circuit reversed this decision, stating individual inquiries were still necessary. Ford then proposed a new class definition and moved again for certification under Rule 23(b)(3), (b)(2), and (c)(4). The district court certified the class under Rule 23(b)(3) and alternatively under Rule 23(b)(2) and (c)(4).The United States Court of Appeals for the Eighth Circuit reviewed the district court's certification order for abuse of discretion. The court found that Ford's new theory of economic loss, based on commissions paid, did not align with the previous definition of economic loss and still required individualized inquiries. Consequently, the court held that the district court abused its discretion in certifying the class under Rule 23(b)(3). The court also found that the alternative certifications under Rule 23(b)(2) and (c)(4) were improper due to the predominance of individual issues and the lack of cohesiveness among class members. The Eighth Circuit reversed the district court's order and remanded for further proceedings. View "Ford v. TD Ameritrade Holding Corp." on Justia Law

Darris Lamar Mull pleaded guilty to four counts of being a felon in possession of firearms, violating 18 U.S.C. § 922(g)(1). The presentence investigation report (PSR) assessed a base offense level of 20 due to the involvement of a semiautomatic firearm capable of accepting a large capacity magazine. Mull objected, arguing that his co-defendant was responsible for that firearm. The district court overruled the objection and sentenced Mull to 135 months’ imprisonment. Mull appealed, challenging the application of the sentencing enhancement and arguing that 18 U.S.C. § 922(g)(1) violated his Second Amendment rights.The United States District Court for the Western District of Missouri initially reviewed the case. Mull objected to the PSR's findings, particularly the base offense level enhancement under U.S.S.G. § 2K2.1(a)(4)(B). The district court found that Mull's offense involved a semiautomatic firearm with a large capacity magazine and overruled his objection. The court adopted the PSR's factual content and calculations, sentencing Mull to 135 months based on the 18 U.S.C. § 3553(a) factors.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not err in applying the § 2K2.1(a)(4)(B) enhancement. It found that Mull and his co-defendant engaged in jointly undertaken criminal activity, making Mull accountable for the co-defendant's possession and use of the firearm. The court also rejected Mull's Second Amendment challenge, citing Eighth Circuit precedent that upheld the constitutionality of 18 U.S.C. § 922(g)(1). The Eighth Circuit affirmed the district court's judgment, maintaining Mull's 135-month sentence. View "United States v. Mull" on Justia Law

JES Farms Partnership sold crops through Indigo Ag's digital platform. In 2021, JES initiated arbitration against Indigo, alleging breach of a marketplace seller agreement and trade rule violations. Indigo counterclaimed, alleging JES breached the agreement and its addenda. JES then sought a federal court's declaratory judgment that Indigo’s counterclaims were not arbitrable and that some addenda were invalid. Indigo moved to compel arbitration based on the agreement's arbitration clause.The United States District Court for the District of South Dakota partially denied Indigo's motion. The court agreed that Indigo’s counterclaims were arbitrable but ruled that the enforceability of the addenda was not arbitrable under the marketplace seller agreement. The court found the arbitration clause "narrow" and concluded that disputes about the addenda's enforceability did not relate to crop transactions. Indigo appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court determined that the arbitration clause in the marketplace seller agreement was broad, covering "any dispute" related to the agreement or transactions under it. The court found that the enforceability of the addenda was indeed a dispute "relating to crop transactions" and thus fell within the scope of the arbitration clause. Consequently, the Eighth Circuit reversed the district court's decision and directed it to grant Indigo’s motion to compel arbitration and address the case's status pending arbitration. View "JES Farms Partnership v. Indigo Ag Inc." on Justia Law

Erica Barrett and other employees of O’Reilly Automotive, Inc. alleged that the company’s 401(k) plan managers breached their fiduciary duty by imposing high recordkeeping expenses and inflated expense ratios on the plan, resulting in less money for the participants. They claimed that these high costs were due to either incompetence or laziness on the part of the plan managers.The United States District Court for the Western District of Missouri dismissed the complaint. The court found that the plaintiffs failed to provide meaningful benchmarks to support their claim that the plan’s fees were excessive. Specifically, the court noted that the plaintiffs did not adequately compare the costs of O’Reilly’s plan with those of similar plans offering the same services.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court affirmed the district court’s decision, agreeing that the plaintiffs did not provide meaningful benchmarks to show that the plan’s fees were excessive. The court emphasized that the plaintiffs’ comparisons were flawed because they did not account for the different services included in the fees of the comparator plans. Additionally, the court found that aggregate data from the Investment Company Institute was insufficient to establish a plausible claim of mismanagement. The court also dismissed the failure-to-monitor claim against O’Reilly and its board of directors, as it was derivative of the primary claim. Finally, the court held that the district court did not abuse its discretion in dismissing the complaint with prejudice, as the plaintiffs did not formally request leave to amend their complaint. View "Barrett v. O'Reilly Automotive, Inc." on Justia Law

In 2011, Shawn Scherer was convicted of possessing a firearm as a felon and sentenced to 120 months’ imprisonment followed by three years of supervised release. Shortly after beginning his supervised release, he tested positive for methamphetamine and absconded, leading to the revocation of his supervised release in June 2020. He was sentenced to 10 months’ imprisonment and three more years of supervised release. Scherer violated the conditions of his second supervised-release term, resulting in another revocation in April 2021 and a sentence of 14 months’ imprisonment and 24 months of supervised release. During his third term, he again violated conditions, leading to state charges and federal revocation proceedings.The United States District Court for the District of North Dakota revoked Scherer’s supervised release multiple times due to repeated violations, including drug use and absconding from reentry centers. At his latest revocation hearing, Scherer admitted to the violations. The government requested a sentence within the Guidelines’ range of 8 to 14 months, while Scherer’s counsel highlighted his positive activities while incarcerated. The district court, however, noted Scherer’s consistent non-compliance with supervised release conditions and sentenced him to 36 months’ imprisonment with no supervised release.The United States Court of Appeals for the Eighth Circuit reviewed the case. Scherer argued that the district court abused its discretion by limiting his counsel’s argument and that his sentence was substantively unreasonable. The Eighth Circuit held that any error in limiting counsel’s argument was harmless, as the mitigating factors were already presented through other means. The court also found the 36-month sentence substantively reasonable, given Scherer’s repeated violations and failure to comply with supervised release conditions. Therefore, the Eighth Circuit affirmed the district court’s decision. View "United States v. Scherer" on Justia Law