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

Plaintiff filed suit against his former employer, Medtronic, alleging that the company improperly denied his claim for benefits under a long-term disability plan governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. The court held that the district court did not abuse its discretion by admitting Medtronic's supplemental evidence for the limited purpose of determining the proper standard of review. The Plan provided Medtronic with complete and total discretionary authority to interpret and administer its provisions and this language is sufficient to trigger a deferential abuse-of-discretion standard of review and plaintiff failed to establish a procedural irregularity that would alter this standard or weigh in the court's consideration under it. Under this standard, the court agreed with the district court that Medtronic did not abuse its discretion in denying plaintiff's claim for "any occupation" long-term disability benefits. Accordingly, the court affirmed the judgment of the district court. View "Waldoch v. Medtronic, Inc." on Justia Law

Defendant appealed his conviction and sentence for assault with a dangerous weapon and assault resulting in serious bodily injury. The court concluded that there was sufficient evidence to show that defendant used a dangerous weapon; although defendant presented evidence in support of his self-defense theory, a jury could reasonably have rejected his testimony and concluded beyond a reasonable doubt, based on the other evidence, that he did not act in self defense; and therefore, the district court did not err by denying defendant's motion for judgment of acquittal. The district court did not abuse its discretion in refusing to give the defense of property jury instruction; the trial court did not abuse its discretion in refusing to give the lesser offense instruction; and the court found no error in the district court's instruction to the jury on the issue of self defense. The district court did not err in denying defendant's motion to suppress his boots and a saliva sample where, even if the affidavits do not set forth probable cause, the court found the good faith exception to the warrant requirement applicable based on the totality of the circumstances. The district court did not abuse its discretion in denying the continuance motion; did not abuse its discretion in determining that the testimony of Danette Serr was relevant and not so cumulative of other testimony or so prejudicial such that it necessitated exclusion; and the court rejected defendant's arguments regarding the use of leading questions. Accordingly, the court affirmed the judgment of the district court. View "United States v. Farlee" on Justia Law

Windstream filed suit against defendant and other retirees who challenged company authority to modify retiree benefits unilaterally. The court concluded that there was no evidence indicating that Windstream was required to obtain retiree consent. The court also concluded that the benefits were not permanently vested. Accordingly, the court affirmed the judgment in favor of Windstream. View "Windstream Corporation,., et al. v. Lee, et al." on Justia Law

Defendant Gutierrez pleaded guilty to one count of conspiracy to distribute methamphetamine and Defendant Perez-Sanchez was convicted of one count of conspiracy to distribute and five counts of distribution or possession with intent to distribute. The court concluded that there was sufficient evidence for the district court to conclude that a witness for the prosecution was an expert in reviewing Spanish-language audio recordings of controlled drug transactions involving Perez-Sanchez and preparing written transcripts of the dialogue in English; the district court did not err in permitting the jury to read the transcripts that the expert prepared where it was for the jury to decide whether the government met its burden to show that the transcripts were reliable enough to weigh against Perez-Sanchez; the evidence was sufficient to convict Perez-Sanchez; and the district court did not err in applying an organizer, leader, manager, or supervisor enhancement under U.S.S.G. 3B1.1(c) to Gutierrez's sentence where Gutierrez oversaw distribution by Perez-Sanchez, supplied the drugs, directed Perez-Sanchez to customers; and controlled the proceeds of the transaction. Accordingly, the court affirmed the judgment of the district court. View "United States v. Gutierrez" on Justia Law

Debtor served as the trustee of a consolidated case (NWFX). As a result of debtor's fraud, the NWFX court entered judgment against debtor in favor of the bankruptcy estate for $199,979.26 plus interest. After debtor filed his own petition for Chapter 11 bankruptcy relief, plaintiff filed a complaint to determine the dischargeability of the debt underlying the judgment. On plaintiff's motion for summary judgment under 11 U.S.C. 523(a)(4), the bankruptcy court concluded that the debt was nondischargeable and entered a judgment to that effect. Reviewing the matter de novo, the panel determined that there was no genuine issue of material fact and that plaintiff was entitled to judgment as a matter of law. The panel rejected debtor's arguments that it was unclear whether plaintiff complied with Arkansas law for reviving the judgment. Accordingly, the panel affirmed the judgment of the bankruptcy court. View "Shaffer v. Bird, II" on Justia Law

Defendant appealed his sentence after pleading guilty to possession with intent to distribute 50 grams or more of actual methamphetamine. In this case, the oral pronouncement was sufficiently ambiguous that the court was permitted to look to the entire sentencing pronouncement. Looking at the oral pronouncement, the hearing record as a whole, and the written record, it remained unclear as to whether the district court committed procedural error. Accordingly, the court remanded for additional proceedings. View "United States v. Thomas" on Justia Law

Plaintiff filed suit against his former employer, Annett, alleging that the company acted in bad faith when it failed to provide medical care and refused to pay him healing-period benefits. Annett counter-claimed for fraud. The court concluded that the district court correctly ruled that plaintiff was required to exhaust his claim with the commissioner; under Iowa law, Annett had a reasonable basis to believe that it could request plaintiff to undergo an examination by the company's chosen physician and plaintiff's refusal to submit to the examination made the propriety of the company's denial of healing-period benefits at least fairly debatable; therefore, the district court properly granted summary judgment for Annett on plaintiff's bad-faith failure to pay benefits claim; and, under either Iowa law or federal law, Annett was judicially estopped from proceeding against plaintiff because Annett had admitted liability in plaintiff's alternate care petition. Accordingly, the court affirmed the judgment of the district court. Annett's motion to strike portions of plaintiff's supplemental appendix was denied as moot. View "Spencer v. Annett Holdings, Inc." on Justia Law

Defendant appealed his sentence after pleading guilty to possession of child pornography. The court concluded that the district court did not err in applying a five-level upward adjustment for distribution in expectation of a "thing of value" pursuant to U.S.S.G. 2G2.2(b)(3)(B) where defendant used a file sharing program to view the pornography. The government presented sufficient evidence of defendant's knowledge of distribution and the district court did not err in determining that defendant's evidence of ignorance was not concrete. Accordingly, the court affirmed the judgment of the district court. View "United States v. Lynch" on Justia Law

Defendant appealed his sentence for revocation of supervised release. In this instance, the district court's earlier statement about counting on getting 36 months' incarceration for future violations did not display a deep-seated antagonism that would make fair judgment impossible where the district court gave a warning and recognized it was subject to change. The district court took great lengths to recite defendant's history, his performance on supervised release, and his attitude throughout the case. The court concluded that the district court acted reasonably, determining that defendant's behavior justified a 36-month sentence consecutive to his state sentence. Accordingly, the court affirmed the judgment of the district court. View "United States v. Martin" on Justia Law

Plaintiff, trustee for the heirs and next of kin of Erik Kirk Kolski, filed suit against the City and police officers, alleging that defendants violated Kolski's constitutional rights when the officers used deadly force against Kolski during a response to a domestic disturbance with a weapon. The court affirmed the district court's grant of summary judgment on the basis of qualified immunity to Officers Glirbas and Cudd where the use of deadly force was constitutionally permissible because Kolski made threats and possessed a firearm. The court also affirmed the district court's grant of summary judgment to Officers Glirbas and Cudd on the state-law claims on the basis of official immunity where plaintiff identified no evidence showing that the officers intentionally committed an act that they had reason to believe was prohibited and, instead, the evidence demonstrated that they acted reasonably in response to a significant threat of death or physical injury. View "Smith v. City of Brooklyn Park, et al." on Justia Law