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

Defendant appealed his conviction for violating 18 U.S.C. 39A(a), which imposes criminal liability on anyone who "knowingly aims the beam of a laser pointer at an aircraft in the special aircraft jurisdiction of the United States, or at the flight path of such an aircraft." Relying on plain text and common usage, the court concluded that section 39A(a)'s requirement that the laser beam be knowingly aimed does not require an offender to intend the beam to strike the aircraft or flight path in question. Because the district court correctly interpreted the statute, it did not err in excluding defendant's expert's irrelevant testimony and rejecting defendant's inapposite proposed instructions. Accordingly, the court affirmed the judgment of the district court. View "United States v. Smith" on Justia Law

Claimant appealed the the magistrate judge's order directing forfeiture of $48,100 seized pursuant to a traffic stop. Claimant contended that the evidence did not support the magistrate judge's conclusion that the currency was substantially connected to an intended drug transaction. The court concluded that the government failed to carry its burden to prove it more likely than not that claimant intended to use the seized currency in a planned drug transaction. Accordingly, the court reversed the order and remanded with directions to dismiss the action. View "United States v. Nelson" on Justia Law

Plaintiff filed a qui tam suit under the False Claims Act, 31 U.S.C. 3729-3733, alleging that KCP&L fraudulently induced the GSA to install an all-electric heating-and-cooling system at the Richard Bolling Federal Building. The court concluded that the district court did not grossly abuse its discretion or make pretrial proceedings fundamentally unfair to relator. On the merits, the court concluded that the district court properly dismissed the building life cycle cost analysis and false-rate claims as publicly disclosed, and correctly granted summary judgment on the gratuities claim. Accordingly, the court affirmed the judgment of the district court. View "United States ex rel. Kraxberger v. Kansas City Power & Light Co." on Justia Law

Plaintiff filed suit alleging that, during his incarceration as a pretrial detainee, he received constitutionally deficient medical care and that medical officials used excessive force against him while responding to his medical emergency. The court affirmed the grant of summary judgment to Dr. Johnson's motion for summary judgment where plaintiff failed to show that the doctor acted with deliberate indifference; affirmed the grant of summary judgment to Nurse Smith where plaintiff has not identified any evidence that the nurse ever refused or failed to treat him; affirmed the grant of Nurse Anderson's and Nurse Washburn's motions for summary judgment on plaintiff's excessive-force claim; and concluded that, in this case, a nurse's act of hitting plaintiff's nose was a de minimus use of force that was not actionable under the Due Process Clause. Accordingly, the court affirmed the judgment of the district court. View "Tucker v. Holladay, et al." on Justia Law

FFCC filed suit against Lonza, alleging breach of contract and promissory estoppel claims. The court concluded that the district court properly granted summary judgment to Lonza on the contract claim because the parties did not reach a meeting of the minds as to all terms and, therefore, there was no contract formed; the district court properly granted summary judgment on the promissory estoppel claim where nothing in the Letter of Intent or in the parties' conduct suggested that Lonza made a firm promise to purchase 1000 metric tons of Diethoxymethane in 2009; the court dismissed as moot FFCC's claim that the district court abused its discretion in denying FFCC's motion for a jury trial; dismissed FFCC's appeal as it pertains to the unsealing of the record for lack of appellate jurisdiction; and affirmed the district court's grant of attorney's fees. View "FutureFuel Chemical Co. v. Lonza" on Justia Law

Defendant appealed his sentence after pleading guilty to drug offenses pursuant to a written plea agreement. The court concluded that, given defendant's criminal history, the district court did not abuse its discretion by imposing a below-guidelines sentence of 176 months. Further, the disparity between defendant's and his codefendant's sentence was not unwarranted given that the codefendant was not a career offender and did not face a mandatory minimum sentence. Accordingly, the court affirmed the judgment of the district court. View "United States v. Edison" on Justia Law

Defendant appealed his 18-month sentence imposed after he violated his conditions of supervised release. A district court may rely on a defendant's actual conduct rather than the offense to which he pled guilty in classifying his supervised release violation under the sentencing guidelines. The court concluded that the sentence imposed by the district court was substantively reasonable where the district court treated defendant's Arizona conviction as a "Grade B" violation because his actual conduct constituted an offense punishable by a term of imprisonment exceeding one year. The district court did not abuse its discretion in sentencing defendant at the top of his guidelines range for violating the conditions of his supervised release. Accordingly, the court affirmed the judgment of the district court. View "United States v. Ceballos-Santa Cruz" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 suit against the County and the sheriff after he was terminated as deputy sheriff. The court concluded, under the Pickering/Connick balancing test, that at least some of plaintiff's campaign speech does not merit First Amendment protection; that even if plaintiff's speech was fully protected by the Constitution, the sheriff could have reasonably believed that the speech would be at least potentially damaging and disruptive of the discipline and harmony of and among coworkers in the sheriff's office and detrimental to the close working relationships and personal loyalties necessary for an effective and trusted local policing operation; considering North Dakota law and well-established federal and state jurisprudence, the sheriff could have logically and rationally believed that his decision to terminate plaintiff was well within his duties as a public official; and that the sheriff was entitled to qualified immunity to shield him from any liability. Accordingly, the court reversed the district court's denial of the sheriff's motion for summary judgment. View "Nord v. Walsh County, et al." on Justia Law

Polar Tank discharged a maintenance technician for failing to safely complete repair of an overhead crane. The Union grieved the discharge and the grievance was submitted to arbitration. The arbitrator partially upheld the grievance, reducing the technician's discipline to a thirty-day unpaid suspension. Polar Tank sued to vacate the arbitration award and the Union counterclaimed to enforce it. The court affirmed the district court's grant of summary judgment enforcing the award where the award at issue drew its essence from the collective bargaining agreement (CBA). The arbitrator considered the technician's poor performance and concluded that it constituted negligence but not the type of insubordination for which Article 29 mandated discharge; the court rejected Polar Tank's claim that the arbitrator was wrong to disregard the Standards of Conduct; and the arbitrator did not err in disregarding the Management Rights clause. View "PSC Custom, LP v. United Steel, etc." on Justia Law

Plaintiff and her husband brought a products liability action against the Little Giant Ladder's manufacturer after she suffered injuries while using the ladder. The district court excluded plaintiff's expert testimony and concluded that there was insufficient evidence to prove the various theories of products liability. On appeal, plaintiff challenged the district court's grant of summary judgment to the manufacturer. The court concluded that the district court did not abuse its discretion in excluding evidence of the compression tests on the grounds the tests were not conducted under conditions substantially similar to those surrounding the accident. Furthermore, because plaintiff had no admissible expert testimony to support her theories of product liability, the court concluded that the district court did not err in granting the manufacturer's motion for summary judgment. Accordingly, the court affirmed the judgment of the district court. View "Loomis, et al. v. Wing Enterprises, Inc." on Justia Law