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

Plaintiff filed suit against JLLA for, inter alia, failure to pay him a commission on a deal that closed shortly after his departure. The district court sua sponte granted summary judgment for plaintiff and held that JLLA had wrongfully withheld commission payments. The district court awarded plaintiff the amount of the commission as well as statutory penalties for late payment under Minn. Stat. 181.03, 181.13, and attorney's fees and costs. The court concluded that the district court erred in awarding commission, wages, and statutory late payment penalties where JLLA did not owe plaintiff a commission payment at the time of termination because commission payments were subject to at least two conditions precedent that had not yet been fulfilled, and even if JLLA did eventually owe plaintiff a commission, any such amount would not have been owed until after termination, and therefore, Minn. Stat. 181.03 and 181.13 do not apply. Accordingly, the court reversed the judgment on these issues. Given the court's reversal of the underlying award, the court also vacated the later order awarding costs and attorney's fees.View "Karlen v. Jones Lang LaSalle Americas, Inc." on Justia Law

The court reversed the district court's dismissal of plaintiff's claim for relief under the Religious Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb-1(a) to (c), and vacated the dismissal of plaintiffs' remaining claims. The court concluded that, in light of Burwell v. Hobby Lobby Stores, Inc., plaintiffs' complaint submitted a facially plausible claim for relief under the Act.View "O'Brien, Jr., et al. v. Dept. of HHS, et al." on Justia Law

Petitioner, convicted of charges related to the unauthorized interception of cable service and illegal currency structuring for which he is serving 70 months imprisonment, argued that his Sixth Amendment right to counsel was violated when his attorney left the courtroom, with the permission of the district court, to go to the bathroom during the government's direct examination of a co-conspirator. The parties agreed that petitioner's Sixth Amendment right to counsel was violated due to counsel's absence but disagree as to the degree of that error and whether harmless-error analysis can apply in light of Cronic v. United States. The court concluded that, although counsel's absence occurred at a "critical stage," the brevity of the absence - 3 minutes - distinguishes this case from the "complete denial of counsel" discussed in Cronic. The court agreed with the district court's reliance on Arizona v. Fulminante in concluding that counsel's brief absence constituted trial error and not a structured defect. Accordingly, the court affirmed the district court's ruling that the constitutional violation in this case was subject to harmless-error analysis. View "Sweeney v. United States" on Justia Law

The Bank filed suit against the Hanna Parties for breach of contract after the Hanna Parties failed to pay the balance due on a loan when it matured. The Hanna Parties counterclaimed, alleging fraud, breach of fiduciary duty, negligence, deceptive trade practices, and breach of contract by the Bank, and demanding reformation or rescission. The district court granted summary judgment in favor of the Bank as to the counterclaims. A jury concluded that the Hanna Parties did not breach the contract and the district court denied the Bank's post-verdict motions for judgment as a matter of law and for a new trial. Both parties appealed. The court concluded that the case was properly submitted to a jury, and the Bank is precluded from seeking a judgment as a matter of law, but that the jury's verdict was against the great weight of the evidence, so the court reversed and remanded for a new trial on the Bank's breach-of-contract claims. The court agreed with the district court that the Hanna Parties' counterclaims failed as a matter of law and affirmed the district court's grant of summary judgment for the Bank as to those claims.View "Bank of America v. JB Hanna, et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983, alleging that law enforcement officers used excessive force when they shot and killed her brother (Mahir S. Al-Hakim). The district court granted summary judgment to the City, its police chief, and Officers Ballard and Westrich. The court also granted summary judgment to the Kansas City Board of Police Commissioners and Officers McLaughlin. The court agreed with the district court that the officers' use of deadly force was objectively reasonable and therefore Al-Hakim's Fourth Amendment rights were not violated. The court rejected plaintiff's primary argument that the district court erred in disregarding video footage taken from a news helicopter. The court concluded that the district court viewed the video and concluded that it could not answer the issue of objective reasonableness from the perspective of an officer on the ground. Accordingly, the court affirmed the judgment of the district court.View "Aipperspach v. McInerney, et al." on Justia Law

G&K filed suit against Bill's for breach of contract and sought liquidated damages. Bill's counterclaimed, asserting common-law clams and a violation of the Arkansas Deceptive Trade Practices Act, Ark. Code 4-88-113. A jury found in favor of G&K on the common-law counterclaims but returned a verdict for Bill's on its deceptive trade practices counterclaim, awarding Bill's damages. The district court subsequently awarded G&K attorney's fees and denied Bill's motion for attorney's fees. The court concluded that the district court did not abuse its discretion in awarding $82,766.50 in attorney's fees to G&K where the district court expressly considered G&K's degree of success and reduced its requested award based on time devoted to unsuccessful causes of action; the district court did not abuse its discretion by implicitly finding that the hourly rates claimed by G&K's Little Rock-based attorneys were reasonable; the documentation was sufficient to support the district court's conclusion where the record includes invoices that detail the amount of time spent on this litigation and the activities on which that time was spent; although the district court did not expressly mention all eight of the Chrisco factors, the district court did address several and provided enough explanation for the court to conclude that there was no abuse of discretion. Accordingly, the court rejected Bill's challenge to the award of attorney's fees to G&K. In light of comments from the Arkansas courts and the absence of mandatory language in section 4-88-113(f), the court agreed with the district court that Bill's was not automatically entitled to an award of fees when it prevailed on a claim under the Deceptive Trade Practices Act. However, the court found little explanation for the district court's ruling and remanded for the district court to consider whether Bill's should be awarded a reasonable attorney's fee under section 4-88-113(f). The Act establishes an independent basis for awarding fees and does not restrict awards to a party that prevails in whatever larger litigation involves a claim under the Act. A party who prevails on a cause of action to recover actual damages under the Act is eligible for an award of attorney's fees, even when another party is the prevailing party in the overall action for purposes of Ark. Code Sec. 16-22-308.View "G&K Services Co., Inc. v. Bill's Super Foods, Inc." on Justia Law

Annex, Stuart Lind, and Tom Janas filed suit challenging HHS' contraceptive mandate under the Religioous Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb-1(a). Lind, a controlling shareholder of Annex, opposed insurance coverage of contraceptives for Annex's employees. The district court denied Annex and Lind's motion for a preliminary injunction respecting the contraceptive mandate's enforcement. The court concluded that Janas lacks standing to appeal because he did not join the preliminary injunction motion which forms the basis of the appeal; the mandate does not apply to Annex because Annex has fewer than fifty full-time employees and has no government-imposed obligation to offer health insurance of any kind; the only alleged injury is that independent third parties - private health insurance companies not involved in this case - are unable to sell Annex a health insurance plan that excludes healthcare inconsistent with Lind's religious relief; and, ultimately, it is unclear whether Annex's alleged injury is caused by the government defendants and redressable by the federal courts. Accordingly, the court vacated the district court's denial and remanded for the district court to conduct more fact-finding to determine whether subject matter jurisdiction exists. View "Annex Medical, Inc., et al. v. Sebelius, et al." on Justia Law

Appellants, two Minnesota-based, grassroots advocacy organizations and their leaders, filed suit claiming that a provision of the Minnesota Fair Campaign Practices Act (FCPA), Minn. Stat. 211B.01 et seq., inhibits appellants' ability to speak freely against school-funding ballot initiatives and, thereby, violates their First Amendment rights. The court rejected the county attorney's renewed challenge to standing; because the speech at issue occupies the core of the protection afforded by the First Amendment, the court applied strict scrutiny to legislation attempting to regulate it; the county attorneys failed to demonstrate that the interests advanced in support of section 211B.06 - preserving fair and honest elections and preventing fraud on the electorate - is narrowly tailored to meet a compelling government interest where the section is both overbroad and underinclusive and is not the least restrictive means of achieving any stated goal; and the attorney general is immune to suit. Accordingly, the court dismissed in part, reversed in part, and remanded for further proceedings.View "281 Care Committee, et al. v. Arneson, et al." on Justia Law

Defendant entered a conditional guilty plea to a charge of failing to register and update his sex offender registration, and subsequently appealed the denial of his motion to dismiss the indictment. Defendant argued that Congress lacked authority under Article I of the Constitution to impose the Sex Offender Registration and Notification Act's (SORNA), 42 U.S.C. 16911 et seq., registration requirement on him. The court concluded that Congress acted within its power in light of the Supreme Court's recent decisions in United States v. Comstock and United States v. Kebodeaux. The court's decision applies only to a sex offender who - at the time the registration requirement came into effect - was under federal parole supervision based on a conviction under federal law, and thus remained in a "special relationship with the federal government." The court rejected defendant's alternative contentions and affirmed the judgment.View "United States v. Coppock" on Justia Law

Defendant pled guilty to conspiracy to distribute marijuana and appealed the denial of his motion to suppress evidence. The court held that, assuming that the agents' warrantless entry into defendant's home was not justified by exigent circumstances, defendant's grant of consent to search was the product of free will sufficient to purge that taint of any Fourth Amendment violation occurring by virtue of the agents' entry. The court also held that the district court did not err in admitting defendant's statements to an agent. Accordingly, the court affirmed the judgment of the district court.View "United States v. Whisenton" on Justia Law