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

Defendant appealed the denial of his motion to suppress after pleading guilty to distributing and possessing with intent to distribute a controlled substance, and to aiding and abetting that offense. A state trooper pulled over behind defendant's broken-down car and initially approached him to offer assistance. The court concluded that a reasonable person in defendant's position would have understood that a state trooper had legitimate reasons to monitor the situation without seizing the motorist; once defendant identified himself as the driver and admitted that he did not have a driver's license, the trooper had probable cause to issue defendant a citation for a traffic violation and was thus entitled to detain defendant; the trooper had reasonable, articulable suspicion sufficient to justify an investigatory stop, including a dog sniff, where, among other things, defendant was unable to identify his passengers and knew one of them only as "Homie," and the trooper was unable to match the name and date of birth that defendant provided to the law enforcement database; once this reasonable suspicion was developed, the trooper did not effect an unreasonable seizure by detaining defendant until another officer arrived with the drug-detection dog; and because defendant's hour-long detention before the dog-sniff was due to the remote location, not any lack of diligence or unnecessary delay by law enforcement, the court concluded that it was reasonable under the circumstances. The district court did not violate defendant's rights under the Fifth and Sixth Amendments by considering records of the drug-detection dog's field performance in camera without disclosing the records to him where evidence of the dog's training and certification was sufficient to establish the dog's reliability and thereby demonstrate probable cause. Accordingly, the court affirmed the judgment of the district court. View "United States v. Salgado" on Justia Law

Plaintiff appealed the denial of his application for disability insurance benefits and supplemental security income (SSI) benefits. The court concluded that the ALJ did not err in concluding that plaintiff did not have a severe impairment that met the criteria of listing 12.04 (Affective Disorders); substantial evidence supported the ALJ's conclusion that plaintiff did not meet all the criteria for the listed impairment; the ALJ's determination of plaintiff's residual functional capacity (RFC) was supported by substantial evidence, and the ALJ did not err in declining to give a nurse practitioner's assessment controlling weight; and the hypothetical posed by the ALJ to the vocational expert was not defective. Accordingly, the court affirmed the denial of benefits. View "Blackburn v. Colvin" on Justia Law

Petitioner, convicted of first degree murder and sentenced to life imprisonment, appealed the district court's denial of his petition for habeas relief. Assuming without deciding that Cuyler v. Sullivan applied to conflict of interest not arising out of multiple representation, the court held that petitioner failed to demonstrate that he was entitled to relief where trial counsel's conflict of interest did not adversely affect his performance. Petitioner also failed to demonstrate that appellate counsel was ineffective by failing to press arguments outside the scope of remand. Accordingly, the court affirmed the judgment of the district court. View "Williams v. Ludwick" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of Encompass in this insurance coverage dispute. Plaintiff's home was damaged from a broken drain pipe in the basement shower stall and she sought to recover repair costs for the damage. The court concluded that Encompass failed to satisfy its burden of proving the applicability of the policy's exclusion and the district court erred when it determined as a matter of law that the water damage resulted from seepage. Further, the district court erred when it determined the "seepage or leakage" exclusion for mold remediation barred all of plaintiff's claims. Accordingly, the court reversed and remanded for further proceedings. View "Syfco v. Encompass Indemnity Co." on Justia Law

Plaintiffs challenged the constitutionality of Minnesota's Family Child Care Providers Representation Act, Minn. Stat. 179A.06 and 179A.52. Plaintiffs, operators of child-care businesses in their homes, argued that the exclusive representation and the fair share fee provisions of the Act violate their First Amendment rights. The court dissolved the injunction pending appeal and affirmed the district court's dismissal because plaintiffs' claims are unripe for review where an election is not currently scheduled, no organization is trying to obtain certification through a card check program, no organization has filed a petition for an election, and plaintiffs have not shown any significant practical harm from awaiting a petition. View "Parrish, et al. v. Governor Mark Dayton, et al." on Justia Law

Debtor filed for Chapter 7 bankruptcy and his former business associate, David Heide, challenged certain debts debtor owed to Heide as nondischargeable. The court reversed the BAP and reinstated the bankruptcy court's judgment that the debt was non dischargeable under 11 U.S.C. 523(a)(2)(A) because debtor obtained and lost more than $300,000 in loans by false representation. View "Heide v. Juve" on Justia Law

Defendant appealed his sentence after pleading guilty to conspiracy to distribute methamphetamine. The court concluded that the Government did not breach the plea agreement by introducing additional evidence to establish defendant's role under U.S.S.G. 3B1.1(a) because the plea agreement contained no provision limiting the scope of relevant conduct or defining defendant's role in the offense and because the Government unequivocally stood by its stipulation to a base offense level of 36. Accordingly, the court affirmed the district court's judgment. View "United States v. Noriega" on Justia Law

Plaintiff and her kids filed a wrongful death action in state court against R.J. Reynolds and others after her husband died from throat cancer. Defendants removed to federal court, arguing that both of the nonmanufacturers had been fraudulently joined. The district court then granted defendants' motion to dismiss because the family's claims were barred by res judicata. The court concluded that the district court did not err in finding fraudulent joinder, denying plaintiff's motion for remand, and then dismissing the nonmanufacturers from the case. The court also concluded that the "one recovery" rule of Missouri Revised Statutes 537.080 barred recovery against defendants in plaintiff's earlier suit for a wrongful death caused by the same conduct. Therefore, the district court was correct in dismissing the claims against the manufacturing defendants under the more demanding of the dismissal standards. As a result of the prior judgment, the husband no longer had a viable claim against the cigarette manufacturers at the time of his death, and his family is barred from bringing such a claim now. Accordingly, the court affirmed the judgment of the district court. View "Thompson, et al. v. R. J. Reynolds Tobacco Co., et al." on Justia Law

Defendant conditionally plead guilty to possessing marijuana with intent to distribute and appealed the denial of his motion to suppress evidence found during a warrant search of his apartment. The court concluded that the exclusionary rule did not apply to preclude use of the evidence in the search warrant application where the officers reasonably relied on binding circuit precedent in conducting a dog sniff outside the door of the apartment at issue. Therefore, the warrant was valid and defendant's motion to suppress was properly denied. Accordingly, the court affirmed the judgment of the district court. View "United States v. Davis" on Justia Law

Petitioner, a native of Mexico, petitioned for review of the BIA's denial of his motion to reopen and challenged the BIA's refusal to open his case sua sponte. The court concluded that it had no jurisdiction to review the Board's June 2013 order denying the April 2013 motion to reopen where petitioner's contentions regarding the Board's evaluation of new factual information presented no question of law. Further, the court lacked jurisdiction to review the Board's refusal to reopen a case sua sponte because there is no meaningful standard against which to judge the agency's exercise of discretion and the determination is committed to agency discretion by law. Accordingly, the court dismissed the petition for review. View "Barajas-Salinas v. Holder, Jr." on Justia Law