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

The EEOC and Adam Breaux, a terminated employee of PFI, appealed the district court's adverse grant of summary judgment in favor of PFI. Breaux asserted that PFI discriminated against him based on his right shoulder injury and the district court erred in granting summary judgment on this claim. The court concluded that the year-long period that PFI accommodated Breaux's injury negated causation; and the casual, somewhat ambiguous conversation that took place in August 2009, does not establish a causal connection between Breaux's termination and his disability. Even if a prima facie case was established, because PFI has advanced a legitimate nondiscriminatory reason for terminating Breaux - poor performance - the burden shifted back to the EEOC and Breaux to show that PFI's proffered reason is pretext for intentional discrimination. In this case, the EEOC and Breaux failed to show pretext. Therefore, the district court correctly granted summary judgment on the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), discrimination claim. Further, the district court properly granted summary judgment on the ADA failure-to-accommodate claim where Breaux failed to prove that he requested an accommodation. Because the district court properly dismissed the discrimination and retaliation claims, the court affirmed its dismissal of the successor liability claim. Accordingly, the court affirmed the judgment of the district court.View "EEOC v. Product Fabricators, Inc., et al." on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of Prairie Ethanol on his claim of disability discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12201 et seq. Assuming, without deciding, that plaintiff established a prima facie case of disability discrimination, Prairie Ethanol has offered a legitimate, non-discriminatory justification for terminating his employment - plaintiff's overly aggressive style of operating the plant, which resulted in the plant machinery swinging on three occasions and nearly losing the plant on one of those three occasions. Prairie Ethanol's performance-related concern constituted a legitimate, non-discriminatory justification for discharging plaintiff. Accordingly, the court affirmed the district court's judgment. View "Cody v. Prairie Ethanol, LLC" on Justia Law

Plaintiff filed suit against defendant, individually and in his official capacity as a circuit judge, alleging violations of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., the Rehabilitation Act, 29 U.S.C. 701 et seq., and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq, as well as statutory violations. Plaintiff contended that defendant unlawfully discriminated against him on the basis of a disability, his back injury, by terminating him and by failing to accommodate his disability, and retaliated against him for requesting an accommodation. The court concluded that no genuine issue of material fact exists for trial regarding whether defendant discriminated against plaintiff on the basis of his disability; the record demonstrated that defendant accommodated all of plaintiff's known limitations during the period of his employment at issue; and defendant did not violate the ADA and the Rehabilitation Act by retaliating against him for requesting accommodation for his disability where plaintiff failed to establish a genuine issue for trial regarding a causal connection; and plaintiff failed to make a submissible case of interference with his FMLA rights. Accordingly, the court affirmed the judgment of the district court.View "Withers v. Johnson, et al." on Justia Law

Defendant, a police officer, was found guilty of willfully depriving another person of the right to be free from the use of unreasonable force and knowingly falsifying a police report with the intent to obstruct justice. The government appealed defendant's sentence of 20 months' imprisonment and defendant cross-appealed. The court concluded that the district court, while finding that defendant's conduct was egregious, imposed a substantively unreasonable sentence in this case where the district court varied downward from the bottom of the Guidelines range by 115 months; the district court's justification for the variance failed to support the degree of the variance in this case; and, therefore, the court vacated and remanded for resentencing. The court denied defendant's cross-appeal where the district court did not err in applying a two-level enhancement for physical restraint nor did the district court err in denying a downward departure for victim provocation.View "United States v. Dautovic" on Justia Law

Defendant appealed his sentence after being convicted of two counts of bank robbery. The district court sentenced defendant to life imprisonment because he previously had been convicted of two serious violent felonies. The court concluded that defendant's argument, that Alleyne v. United States and the Sixth Amendment require that a jury must find the fact of his prior convictions because it increased the maximum penalty to which he was exposed, was foreclosed by precedent. Further, defendant's argument, that the affirmative defense of 18 U.S.C. 3559(c)(3), and its placement of a burden of persuasion on defendant to show that a prior bank robbery conviction is nonqualifying, contravenes the Fifth and Sixth Amendments, was also foreclosed by precedent. Accordingly, the court affirmed the judgment of the district court.View "United States v. Roberts" on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against a law enforcement officer for violating her Fourth Amendments rights and for battery and false imprisonment under Minnesota law. The district court denied defendant's motion for summary judgment based on qualified and official immunity. The court concluded that the officer's arrest of plaintiff and frisking her did not violate plaintiff's clearly established Fourth Amendment rights. The officer reasonably believed that plaintiff was at least moderately intoxicated, and the law at the time of plaintiff's arrest was not so clear that a reasonable officer would have known that he lacked probable cause to arrest a moderately intoxicated individual in lieu of leaving her alone on a public roadway at night. Further, the officer was entitled to official immunity on plaintiff's state-law battery and false imprisonment claims where a reasonable officer would not have known that arresting and frisking plaintiff would have violated her constitutional rights and the officer provided uncontroverted testimony that it was standard practice to transport intoxicated individuals to detox facilities. Accordingly, the court reversed and remanded.View "Meehan v. Thompson" on Justia Law

Sentis filed suit against Shell, alleging contract and fraud claims, and violations of Missouri franchise laws as well as the Petroleum Marketing Practices Act, 15 U.S.C. 2801 et seq. The court agreed with the district court's conclusion that Sentis' failure to preserve evidence caused sufficient prejudice to defendants to serve as sanctionable spoliation. Dismissal with prejudice was the appropriate sanction given plaintiffs' cumulative pattern of conduct in this matter and given the nature of the missing evidence and its role in Sentis' and Shell's cases. The court affirmed the judgment.View "Sentis Group, et al. v. Shell Oil Co., et al." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the two officers who stripped searched him, alleging that the officers violated his rights under the Fourth Amendment. The court affirmed the district court's grant of summary judgment to the officers based on qualified immunity where the strip search did not violate clearly established law at the time where a reasonable officer had a solid basis to believe that strip searching an arrestee was constitutional if there was reasonable suspicion that the detainee possessed contraband. In this case, plaintiff had recently admitted to smoking a bowl of marijuana so there was probable cause to believe that he had committed a controlled substance offense. View "Jacobson v. McCormick, et al." on Justia Law

Plaintiff filed suit against Wyeth, alleging that she developed breast cancer after using Wyeth's's hormone therapy medication, Prempro. The Judicial Panel on Multidistrict Litigation transferred the case to the the Eastern District of Arkansas as part of the ongoing In re Prempro Products Liability Litigation. After the district court subsequently dismissed plaintiff's case for failure to respond to discovery orders, her attorney filed a Rule 60(b)(1) motion to set aside the dismissal. Plaintiff's attorney had failed to register for the Case Management/Electronic Case Files (CM-ECF) system and, consequently, did not receive electronic notices of the filings in plaintiff's case. The court affirmed the district court's denial of the Rule 60(b)(1) motion because the district court did not abuse its discretion where, on more than one occasion, the district court instructed all attorneys to register for the CM-ECF system and warned that those who did not would not receive electronic filing notices or hard copies of orders.View "Freeman v. Wyeth, et al." on Justia Law

This case arose when an investment advisor committed fraud by opening a doing-business-as ("d/b/a") bank account using the name of his employer when he did not have the employer's authority to do so. The employer's insurance company subsequently filed suit against the bank, alleging that the bank negligently failed to inquire into whether the former advisor had authority to open the d/b/a account. The court affirmed the district court's dismissal of the suit because the bank owed no recognized duty to the employer.View "National Union Fire Ins. Co. v. Hometown Bank, N.A., et al." on Justia Law