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

Nurse Dalton was terminated from her supervisory position at the ManorCare skilled nursing facility. Dalton alleged interference with her statutory rights under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601, and discrimination based on her Chronic Kidney Disease disability in violation of the Iowa Civil Rights Act, Iowa Code Ch. 216, and the Americans with Disabilities Act, 42 U.S.C. 12101. ManorCare claimed that nurses that Dalton supervised had complained about her job performance and that Dalton had received a Third/Final Written Warning for violating Major/Type B Work Rules, citing inappropriate negative comments about her work at the nurses’ station, where patients could overhear; failure to notify staff members she had cancelled a meeting; and taking an extended lunch break and failing to attend patient care conferences. There were also problems with attendance and late reports. Dalton understood that any further performance-related issue could result in termination. The district court dismissed all claims. The Eighth Circuit affirmed. Dalton’s termination was the end of an on-going, unrelated disciplinary process. View "Dalton v. Manor Care of West Des Moines, LLC" on Justia Law

The City of Little Rock issued Carrick three citations for violating municipal ordinances. In Arkansas, such citations, if contested, are initially tried to a judge and can be appealed to a jury in the state trial court, Ark. Code 16-96-112. Carrick contested the citations and was found guilty of two violations following the initial bench trial. The court imposed no punishment. Carrick then appealed to a jury, paying a $150 filing fee and a $15 "technology fee," both of which are non-refundable. After an initial mistrial, the case against Carrick was dismissed. Carrick sought a refund of the fees. The Arkansas Court of Appeals affirmed denial of a refund; the Arkansas Supreme Court denied review. Carrick filed suit under 42 U.S.C. 1983, alleging violations of the Arkansas Constitution, Arkansas statutes, and the Fifth, Sixth, and Fourteenth Amendments of the U.S. Constitution. The district court denied relief. The Eighth Circuit affirmed, rejecting an argument that the non-refundable fees served as impermissible barriers to the exercise of his Sixth Amendment right to a jury trial because Carrick had no Sixth Amendment right to a jury trial regarding his alleged ordinance violations. View "Carrick v. Beebe" on Justia Law

Debtor is a talented singer. Wilson agreed to help manage the Debtor’s career. The two entered into a series of agreements. Wilson claims to have spent significant funds to advance Debtor’s career, but did not identify any related debts in his own 2008 bankruptcy. Debtor filed a Chapter 7 petition in 2012. Wilson filed an adversary proceeding and appealed bankruptcy court rulings denying his requests for: a judgment of nondischargeability under 11 U.S.C. 523; a money judgment; enforcement of a money judgment against Debtor’s non-filing spouse or her company; and denial of the Debtor’s discharge under 11 U.S.C. 727. The Eighth Circuit Bankruptcy Appellate Panel affirmed, finding that Debtor owed no debt to Wilson. Two contracts between the Debtor and Wilson were void as unconscionable; Wilson had no claim for a lost investment in the Debtor or his career. Wilson had no cause of action under section 523 and there was no basis upon which to deny the Debtor’s discharge, View "Wilson v. Walker" on Justia Law

Debtor filed a voluntary chapter 11 petition. Debtor had a program under which independent contractor drivers could lease and acquire ownership of trucks. Trucks were financed or leased from creditors, including Daimler. At the time of filing, Daimler was the lessor of 14 trucks and held security interests in 99 others and in driver lease payments and other proceeds generated by the use of such trucks. Daimler sought sequestration to prevent unauthorized use of that money. The parties submitted an agreed order, providing that Daimler would sell 21 trucks and credit the net proceeds. Debtor would retain 80 trucks subject to Daimler’s security interest and would make adequate protection payments. The order was silent about Daimler’s security interest in proceeds from the use of the trucks. The bankruptcy court confirmed a plan. The debtor appealed with respect to application of excess adequate protection payments, claiming it overpaid for erosion in the value of the trucks and argued that the court erred when it supplemented the secured portion of Daimler’s claim with an award of $51,909.40 as proceeds from the use of Daimler’s trucks. The Eighth Circuit dismissed for lack of jurisdiction. The orders were interlocutory. The debtor now possesses no trucks; no meaningful relief could be granted. Debtor did not propose a plan that was denied, so it is not an aggrieved party, and does not have standing. View "O&S Trucking, Inc. v. Mercedes Benz Fin. Servs., USA" on Justia Law

Prisoners on death row filed suit, challenging Missouri's execution protocol as violating the federal Controlled Substances Act and the Food, Drug and Cosmetic Act, and based on Eighth Amendment due process, ex post facto, and other claims. The district court sealed certain documents or docket entries, making them inaccessible to the public. There was no indication in the record why the entries were sealed, nor any explanation of what types of documents were sealed. Publisher Larry Flynt filed motions to intervene in both cases, under Federal Rule 24(b), and moved to unseal the records and entries. No party opposed Flynt's motions to intervene. One case had already been dismissed. In his motions, Flynt stated he had an interest in the sealed records as a publisher and as an advocate against the death penalty. Flynt claimed a heightened interest because Franklin, who had confessed to shooting Flynt, was a Missouri death row inmate and a plaintiff in both cases. Franklin was executed in November 2013; on that same day the district court denied Flynt's motion to intervene in one case as moot, and in the other, stating that "generalized interest" does not justify intervention. The Eighth Circuit reversed; for reasons of judicial efficiency, Rule 24(b) intervention is often preferable to filing a separate action. View "Flynt v. Lombardi" on Justia Law

A Minnesota jury convicted Martin of first-degree murder, committed at age 17. Martin received a mandatory life sentence without possibility of release. The Minnesota Supreme Court affirmed and rejected a challenge to the jury’s composition under Batson. Martin filed a habeas petition under 28 U.S.C. 2254. While it was pending, the U.S. Supreme Court held that mandatory life sentences without parole for defendants who commit homicide before age 18 violate the Eighth Amendment. Martin argued that Miller applied retroactively to him. The district court denied the petition. The Eighth Circuit affirmed. Miller does not apply retroactively on collateral review. The Minnesota Supreme Court did not unreasonably determine that the trial court properly rejected Martin’s Batson challenge. View "Martin v. Symmes" on Justia Law

The Festus City Council terminated Draper from his position as City Administrator six months into a three-year employment contract, after the election of a council member who was critical of Draper’s performance. The city had refused to reschedule or continue the hearing regarding Draper’s job performance. Neither Draper nor his attorney was present. Several witnesses testified. The council concluded that Draper had manipulated the evaluation process to choose an engineering firm to complete a road project; that Draper had authorized heating system repairs and the purchase of new windows without competitive bidding, in violation of Festus policy; that Draper had sent a memorandum stating that the sick-leave-bonus program had been abolished when it had not been; and that Draper had requested reimbursement for a hotel room he had paid for with his Festus credit card. The district court entered summary judgment, rejecting claims of violations of procedural and substantive-due-process rights under 42 U.S.C. 1983, a section 1983 conspiracy claim, breach of contract, and violation of the Missouri Administrative Procedure Act, Mo. Rev. Stat. 536.010-536.160. The Eighth Circuit affirmed. The evidence supported the city’s decision to terminate Draper, so and that its decision was not arbitrary, capricious, or unreasonable. View "Draper v. City of Festus" on Justia Law

Cotton was attempting to enter an apartment complex in a violent area, "plagued with narcotic activity, robberies, [and] shootings." Police officers saw an individual throw keys off a balcony to Cotton and an unidentified male, waiting below. The property manager had instructed residents not to throw their keys to people. One officer was aware of that security provision. After the keys hit the ground, an officer yelled that Cotton and the unidentified male were not allowed to take the keys. The unidentified male grabbed the keys and walked quickly toward a door; as he was unlocking the door, the officer yelled "stop." The unidentified male finished unlocking the door, entered the complex, and pulled the door shut. Cotton did not move during this interaction. An officer approached Cotton, who appeared nervous and, according to the officer, reached for his waistband. Believing Cotton was reaching for a weapon, an officer grabbed Cotton's arms and handcuffed him. During a pat-down, a pistol was found in Cotton's waistband. Cotton was charged with being a felon in possession of a firearm. The district court denied a motion to suppress. The Eighth Circuit affirmed: the officers conducted a constitutionally permissible seizure. View "United States v. Cotton" on Justia Law

Williamson pleaded guilty to participating in a counterfeiting conspiracy, 18 U.S.C. 513(a) and 371, for printing counterfeit checks, purportedly drawn on local businesses, and cashing the checks using stolen social security numbers. Months later, she pleaded guilty to a different counterfeiting conspiracy violation involving counterfeit checks, and to a mail fraud, 18 U.S.C. 1341, for falsely reporting that her car had been stolen and collecting insurance proceeds. The district court imposed consecutive 10- month sentences for each of the three offenses. The Eighth Circuit affirmed, rejecting arguments that the court committed procedural error in imposing consecutive sentences, and that the sentence was substantively unreasonable. Although the court considered mitigating factors, Williamson’s steady employment and return to school; her minor child; her minimal criminal history; and the substantial influence of a relative, the court determined that her quick return to fraud after being arrested and her central role in the counterfeiting conspiracies outweighed these mitigating factors. View "United States v.Williamson" on Justia Law

In 2001, Woodall was convicted of in Missouri for having sexual relations with his 15-year-old stepsister. He was required to register as a sex offender. In November 2012, Woodall moved to Iowa but did not notify Missouri authorities or register in Iowa, as required by the Sex Offender Registration and Notification Act, 42 U.S.C. 16901. Woodall pleaded guilty, 18 U.S.C. 2250(a). A presentence report found that Woodall "consumed marijuana once every other month" and described himself as a "social drinker, consuming one or two beers each month." Woodall had been terminated from a sex offender treatment program in 2007, during a previous incarceration, when he got into a fight and attempted to commit suicide in 2014, leaving a note that was potentially threatening to U.S. Marshals. Woodall was diagnosed with major depressive disorder and potential adult attention deficit disorder. The district court sentenced Woodall to 10 months, the bottom of the Guidelines range, and imposed five years of supervised release with conditions prohibiting use of alcohol; entering bars, or other establishments whose primary source of income is derived from the sale of alcohol; and contact with children without the prior written consent. The Eighth Circuit vacated the condition relating to alcohol. View "United States v. Woodall" on Justia Law