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

Defendant appealed his revocation of supervised release, arguing that the district court violated his due process right to confront witnesses when it admitted hearsay evidence - a police report - at the revocation hearing without engaging in the analysis required by United States v. Bell and later decisions. The court affirmed the judgment of the district court, concluding that the Bell issue was not properly preserved in the district court. View "United States v. Simms" on Justia Law

Defendants Conway, Robinson, and Randolph appealed their conviction for various drug and weapons offenses. The court concluded that the evidence was sufficient to convict defendants of the offenses; the district court did not abuse its discretion in determining that the evidence failed to support the giving of a buyer-seller instruction; and the district court did not abuse its discretion in refusing to give a multiple conspiracies preliminary instruction. Accordingly, the court affirmed the judgment of the district court. View "United States v. Conway" on Justia Law

Plaintiff filed suit against his employer, alleging race discrimination and retaliation. The court concluded that plaintiff was unable to show a prima facie case of discrimination because he failed to show circumstances which would give rise to an inference of discrimination. Plaintiff also failed to show direct or inferential evidence his employer engaged in retaliation. Accordingly, the court affirmed the district court's grant of summary judgment. View "Young v. Builders Steel Co." on Justia Law

Defendant appealed his sentence for conspiracy to distribute more than fifty grams of cocaine base and his concurrent sentence for managing a home for the purpose of distributing cocaine base. There was sufficient evidence to find that defendant engaged in a conspiracy involving in excess of 280 grams and any error was not plain; because the district court properly applied the separate U.S.S.G. 4B1.1 enhancement to find an offense level of 37, no plain error occurred because even without the application U.S.S.G. 2D1.1(b)(12), defendant's offense level would have been the same; and the district court did not abuse its discretion and the sentence was reasonable. View "United States v. Goodrich" on Justia Law

Defendants Martinus and Maurice appealed their sentences after pleading guilty to conspiracy to commit wire fraud. The court concluded that Martinus's eighty-five month sentence was substantively reasonable where the district court considered the appropriate factors in varying from the guidelines and adequately explained its sentence. Because the district court would have sentenced Maurice to the same sentence even without the government's breach of the plea agreement, the court could not say that the breach of the plea agreement required reversal under the plain error standard; the district court sufficiently explained the defendant-specific facts relevant to sentencing Maurice and the district court did not plainly err in sentencing Maurice to the same term of imprisonment as Martinus; and Maurice's sentence was substantively reasonable. View "United States v. Sayles" on Justia Law

Defendant appealed his conviction and sentence for being a felon in possession of a firearm. The court concluded that the evidence was sufficient to convict defendant where a recorded interview supported the imminently reasonable inference that the gun defendant owned and wanted out of the residence was the same gun found by police shortly after his arrest. The court held that a violation of Minnesota Statute 609.487, subd. 3, fleeing an officer in a motor vehicle, presented a serious potential risk of physical injury to another and is therefore a violent felony under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e). The court rejected defendant's claim that the ACCA's residual clause is void for vagueness. Accordingly, the court affirmed the judgment of the district court. View "United States v. Pate" on Justia Law

Petitioner appealed the district court's denial of her 28 U.S.C. 2255 motion, alleging ineffective assistance of counsel. Because petitioner failed to show prejudice, the court declined to address whether her attorney's performance was deficient. The only prejudice petitioner identified was admission of her grand jury testimony at trial. The court concluded, however, that the grand jury testimony was cumulative of other trial evidence and there was no reasonable probability that the result of the proceeding would have been different had she not testified before the grand jury. Assuming that petitioner's attorney advised her to reject the plea, she cannot prove that counsel's performance was deficient. Any advice that petitioner hold the government to its burden at trial was not constitutionally unreasonable. Further, nothing in the record indicated that petitioner wanted to accept the plea offer and would have acknowledged her guilt even if properly advised about the risks of trial. Accordingly, the court affirmed the judgment of the district court. View "Hyles v. United States" on Justia Law

Plaintiff, guardian ad litem for minor H.T.P., appealed the district court's adverse grant of summary judgment in this products liability case. Plaintiff alleged that Enfamil, an infant formula, was defective or unreasonably dangerous due to C.sak contamination. On appeal, plaintiff argued that the district court abused its discretion in refusing to allow its experts' testimony under Rule 702. The court concluded that the district court abused its discretion in excluding plaintiff's experts where the methodology employed by the experts was scientifically valid, could properly be applied to the facts of the case and was therefore reliable enough to assist the trier of fact. With the expert testimony proposed, plaintiff has created an issue of fact for a jury on the issue of the specific cause of H.T.P.'s C. sak infection and plaintiff was entitled to attempt to prove his claim for products liability under Minnesota law. Accordingly, the court reversed the orders of the district court excluding the testimony of plaintiff's experts, and granting summary judgment and costs in favor of Mead, and remanded for further proceedings. View "Johnson v. Mead Johnson & Co." on Justia Law

Swift County filed suit against Fannie Mae, Freddie Mac, and FHFA, alleging that the federal agencies violated state law by failing to pay taxes on the transfers of deeds to real property. The court affirmed the district court's grant of the federal agencies' motion to dismiss because the Exemption Statutes, 12 U.S.C. 1723a(c)(2) and 12 U.S.C. 1452(e), established an exemption from all state taxation. The court concluded that the Exemption Statutes are a valid exercise of Congress's power under the Commerce Clause and the federal agencies are federal instrumentalities, not privately-held corporations. View "Vadnais, et al. v. Federal National Mortgage, et al." on Justia Law

Plaintiff filed suit against her employer, CBE, under 42 U.S.C. 1981, alleging claims of race discrimination, hostile work environment, retaliation, and constructive discharge. The district court granted summary judgment in favor of CBE. The court concluded that, even considering the otherwise time-barred acts that were similar to the acts that occurred within the limitations period, plaintiff failed to set forth sufficient evidence to survive summary judgment on her hostile work environment claim. The twelve incidents of alleged harassment that occurred after March 1, 2007, as well as the similar acts that occurred before then, taken together are not sufficiently severe or pervasive to show that plaintiff's work environment was objectively offensive. Having affirmed the district court's decision on the hostile work environment claim, the court need not further address plaintiff's constructive discharge claim. Accordingly, the court affirmed the judgment of the district court. View "Clay v. Credit Bureau Enterprises, Inc." on Justia Law