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

This case is a class action involving commercial truck drivers who claimed they were not paid properly by Werner Enterprises, Inc., and Drivers Management, LLC. The drivers alleged that they were not adequately compensated for off-duty time spent on short rest breaks and time spent resting in their trucks’ sleeper-berths. The case has been appealed multiple times, with the court previously vacating a jury verdict in favor of the drivers because the district court improperly allowed the drivers to submit an expert report after the deadline. On remand, the district court entered judgment in favor of the defendants. The drivers appealed again, and the court vacated the judgment and remanded the case back to the district court to conduct an analysis regarding whether the expert report should be excluded as a discovery sanction and whether the district court should appoint an independent expert.On remand, the district court concluded that exclusion of the drivers’ expert report was the appropriate sanction for its late disclosure and that appointment of an independent expert was not appropriate. It then entered judgment in favor of the defendants. The drivers appealed this decision, asserting that the district court erred in its analysis. The defendants cross-appealed, asserting that the drivers’ notice of appeal was untimely, requiring dismissal of the appeal.The United States Court of Appeals for the Eighth Circuit rejected the defendants’ contention on cross-appeal and affirmed the judgment of the district court. The court found that the district court did not abuse its discretion in excluding the expert report and denying the drivers’ motion for a new trial. The court also found that the district court did not err in declining to appoint an expert and in entering judgment in favor of the defendants. View "Petrone v. Werner Enterprises, Inc." on Justia Law

The plaintiff, Chiya Lloyd, filed a complaint against FedLoan Servicing LLC, Equifax Information Services, LLC, Trans Union, LLC, and Experian Information Solutions, Inc., alleging violations of the Fair Credit Reporting Act (FCRA). The case centered around Lloyd's nine federal student loans serviced by FedLoan, which reported to Experian that Lloyd's payments for certain months were overdue. Lloyd disputed these delinquencies, and Experian requested further information from FedLoan. After several rounds of disputes and investigations, all delinquent marks were removed from Lloyd's credit report. However, Lloyd initiated a civil action against the defendants, alleging that FedLoan failed to properly investigate the accuracy of the information it reported to Experian, and Experian failed to follow its procedures to discover FedLoan’s mistakes.The district court granted summary judgment in favor of Experian, finding that Lloyd could not show Experian failed to follow reasonable procedures or conduct a reasonable reinvestigation. The court also granted summary judgment in favor of FedLoan, concluding that Lloyd did not present sufficient evidence of damage to support her claim.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court found that Experian had followed the steps set forth by the FCRA for conducting a reinvestigation, and Lloyd failed to show that Experian did not satisfy its statutory requirements. The court also found that Lloyd failed to present a cognizable claim against Experian. Regarding FedLoan, the court found that Lloyd failed to present evidence sufficient to allow a jury to find that FedLoan’s investigation was unreasonable. The court also found that Lloyd failed to provide sufficient evidence to raise a jury question that she sustained actual damages from FedLoan’s reporting. Therefore, her claim failed. View "Lloyd v. FedLoan Servicing" on Justia Law

Mani Panoam Deng was charged with being an unlawful drug user in possession of a firearm, a violation of 18 U.S.C. § 922(g)(3). Deng moved to dismiss the indictment, arguing that the statute violated the Second Amendment and was void for vagueness. He pleaded guilty unconditionally, but appealed, renewing his constitutional challenges and arguing that the court erred by deferring a complete decision on his motion to dismiss.The United States District Court for the Southern District of Iowa denied Deng's facial Second Amendment challenge and deferred ruling on his other claims, as they were tied to facts about his offense conduct that a jury needed to find. After Deng pleaded guilty, he appealed, renewing his constitutional challenges and arguing that the court erred by deferring a complete decision on his motion to dismiss.The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision. The court held that § 922(g)(3) is facially constitutional, citing a previous decision in United States v. Veasley. Deng's as-applied challenge was deemed waived due to his unconditional guilty plea. The court also rejected Deng's vagueness challenge, stating that a criminal statute is void for vagueness under the Fifth Amendment’s Due Process Clause only if it fails to give ordinary people fair notice of the conduct it punishes or is so standardless that it invites arbitrary enforcement. The court found that § 922(g)(3) was not vague as applied to Deng's conduct. Deng's argument that the district court erred by deferring a ruling on his vagueness and as-applied Second Amendment challenges was also dismissed as he had waived this claim by pleading guilty. View "United States v. Deng" on Justia Law

Reginald Austin was convicted of possession of a firearm by a prohibited person after law enforcement found a loaded handgun in his pants during a traffic stop. Austin moved to suppress the firearm, arguing that the officers unreasonably prolonged the traffic stop and lacked reasonable suspicion to conduct the pat-down searches. The district court denied his motion and sentenced him to a 51-month term of imprisonment. The court added two points to his criminal history score pursuant to U.S.S.G. § 4A1.1(e), based on his two prior qualifying convictions for crimes of violence. Austin appealed, challenging the denial of his motion to suppress, the government's comments during closing argument, and the court's application of § 4A1.1.The district court had denied Austin's motion to suppress the firearm, arguing that the traffic stop was not unreasonably prolonged and the officers had reasonable suspicion to conduct a protective pat-down. Austin represented himself at trial, and a jury convicted him of being a felon in possession of a firearm. At sentencing, the district court determined Austin’s advisory Sentencing Guidelines range was 51 to 63 months, based on a total offense level of 20 and criminal history category IV. The district court calculated a total of eight criminal history points arising from two Missouri Circuit Court cases. Austin now appeals.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that the traffic stop was not unreasonably prolonged and the officers had reasonable suspicion to conduct a protective pat-down. The court also found that the prosecutor's remarks during closing arguments were not improper and did not deprive Austin of a fair trial. Finally, the court held that the district court did not err in its application of the Sentencing Guidelines, rejecting Austin's argument that his prior convictions for crimes of violence occurred on the same occasion and therefore § 4A1.1(e) was inapplicable. View "United States v. Austin" on Justia Law

The case revolves around Erin Bulfin, who sued St. Louis County and several employees of St. Louis County Animal Care & Control (ACC) after her pet dog, Daisy, was euthanized at ACC. Bulfin's dog had bitten her daughter, requiring hospitalization. Following the incident, Bulfin's husband, Edward Nea, took Daisy to ACC. The details of the conversation between Nea and ACC employees are disputed, but it is undisputed that Nea signed a form authorizing the euthanasia of Daisy. The next day, Bulfin went to ACC to pick up Daisy for home quarantine and was informed that Daisy had been euthanized.The district court granted summary judgment to the individual defendants, concluding that Bulfin's Fourth Amendment rights were not violated because the defendants reasonably relied on the apparent consent of Bulfin's husband to euthanize Daisy. The court also granted summary judgment in favor of the County on Bulfin's federal municipal liability claims and declined to exercise supplemental jurisdiction over Bulfin's state law claims.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that when ACC accepted custody of Daisy, that was not a seizure because it is undisputed Bulfin approved of Daisy being quarantined in ACC custody after biting her daughter. The court also held that the individual defendants were entitled to qualified immunity unless the evidence established a violation of her Fourth Amendment rights that was clearly established at the time of the violation. The court concluded that no Fourth Amendment violation occurred and that the individual defendants are entitled to qualified immunity because there is no clearly established authority holding that government officials violate the Fourth Amendment by seizing and destroying an effect with the consent of a person who reasonably has actual or apparent authority. View "Bulfin v. Rainwater" on Justia Law

Michael Jones, a pretrial detainee, filed a lawsuit against the City of St. Louis and four city employees, alleging that they held him in custody for eight months after his criminal charges were dismissed and failed to inform him of his right to be released. Jones's lawsuit, filed under 42 U.S.C. § 1983, included claims under both state and federal law. The defendants moved to dismiss all fourteen counts of the lawsuit. The district court dismissed seven counts, leaving no federal due process claims against the individual defendants at issue on appeal. The defendants appealed the denial of their motion to dismiss the remaining counts, arguing that Jones failed to allege plausible constitutional violations and that they were entitled to qualified immunity from damage claims.The United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo, accepting the factual allegations in Jones's First Amended Complaint as true. The court found that Jones failed to allege specific facts of personal involvement in, or direct responsibility for, a deprivation of his constitutional rights by the individual defendants. The court also found that Jones's allegations that the defendants "should have known" that he was incarcerated despite his charges being dismissed failed to state a claim under either the Fourth Amendment or the Due Process Clause.The court reversed the denial of qualified immunity and directed that the remaining counts be dismissed with prejudice. The case was remanded for further proceedings consistent with the court's opinion. The court did not rule on the state law claims of false imprisonment, leaving that for the district court to resolve on remand. View "Jones v. City of St. Louis" on Justia Law

Corey Lamar Cullar pleaded guilty to maintaining a home for the purpose of distributing controlled substances. The district court imposed a sentence of 240 months in prison, the maximum under the Guidelines. The court calculated Cullar's base offense level at 22, added levels for possessing a dangerous weapon, maintaining a drug premises, having an aggravating role in the offense, and using a minor or obstructing justice. The court then increased his offense level to 32 due to his status as a career offender and declined to give him a reduction for accepting responsibility.Cullar appealed, challenging the court's Guidelines calculation and the substantive reasonableness of his sentence. He disputed the court's drug quantity finding, most of its sentencing enhancements, and its denial of a reduction for accepting responsibility. He also argued that the court did not sufficiently consider his mitigating circumstances, making his sentence substantively unreasonable.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that any error in the district court's drug quantity finding and sentencing enhancements did not affect Cullar's Guidelines range and was therefore harmless. The court also upheld the district court's denial of a reduction for accepting responsibility, finding that Cullar had obstructed justice after pleading guilty by leaking documents that identified a cooperator. Finally, the court found that the district court did not abuse its discretion in determining the substantive reasonableness of Cullar's sentence, as it had considered all relevant factors and had not given undue weight to any improper or irrelevant factors. View "United States v. Cullar" on Justia Law

Leroy Johnson, a supervisor at Westinghouse Air Brake Technologies Corporation (Wabtec), was terminated after failing to fully disclose his contact with a COVID-19 positive individual, violating the company's COVID-19 protocols and a Last Chance Agreement he had signed. Johnson, the only salaried black employee at the plant, sued Wabtec for wrongful termination under the Missouri Human Rights Act (MHRA), Title VII of the Civil Rights Act of 1965, and the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment in favor of Wabtec.The district court's decision was based on the conclusion that Johnson had not established a prima facie case of discrimination. Johnson had argued that he was treated less favorably than similarly situated white employees, but the court found that the employees he cited were not similarly situated as they were not terminated for misconduct. The court also found that Johnson's failure to fully disclose his potential COVID-19 exposure constituted a safety concern and misconduct, which was grounds for termination under the Last Chance Agreement.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that Johnson had not established a prima facie case of discrimination and that his termination was due to his misconduct, not his race or age. The court also noted that Johnson had waived his ADEA claim by failing to address its merits in his opening brief. View "Johnson v. Westinghouse Air Brake Technologies Corporation" on Justia Law

Gabriel Eduardo Lemoine and co-defendant Manuel Martinez were indicted on charges related to drug trafficking, including conspiracy to distribute methamphetamine and cocaine, distribution of methamphetamine, and possession with intent to distribute methamphetamine and cocaine. Lemoine and Martinez had moved to Minnesota together, rented apartments and storage units, and were implicated in drug trafficking activities by a confidential informant. Lemoine, however, testified that he was unaware of Martinez's illegal activities.The district court granted Lemoine's motion for acquittal on the conspiracy charge, finding insufficient evidence to prove Lemoine's awareness or involvement in drug trafficking. The court narrowly rejected Lemoine's motion for acquittal on the remaining aiding and abetting counts. The jury found Lemoine guilty on three of the four counts, acquitting him on one charge of aiding and abetting possession with intent to distribute methamphetamine. Lemoine renewed his motion for judgment of acquittal and moved for a new trial after the jury verdict. The district court granted his motion for judgment of acquittal, finding no direct evidence that Lemoine knowingly aided in drug trafficking, and conditionally granted a new trial if its order of acquittal was overturned on appeal.The United States Court of Appeals for the Eighth Circuit reversed the district court's judgment of acquittal, finding that the district court had impermissibly reweighed the evidence and given Lemoine's testimony more weight than the inferences and evidence supporting the jury's verdict. The court found sufficient evidence for a jury to find Lemoine had constructive possession of the drugs located in the storage units. However, the court affirmed the district court's grant of a new trial, finding that the district court did not clearly or manifestly abuse its discretion in finding that a miscarriage of justice may have occurred. The case was remanded for further proceedings. View "United States v. Lemoine" on Justia Law

The case involves two defendants, Raekwon Patton and Austin Mallory, who were found guilty of their roles in a drive-by shooting following an encounter with a rival gang member. The shooting occurred after the defendants and their gang members spotted Raysean Nelson, a rival gang member, in a parking lot and followed him. The defendants were charged with attempted murder in aid of racketeering and discharging a firearm during a crime of violence.The district court overruled multiple objections raised by the defendants. Patton argued that the jury instructions were missing and that the evidence presented by the government was excessive and portrayed him negatively. He also claimed that his decision to return fire was justified as the other side shot first. However, the court found that Patton had not attempted to retreat before using force, which was required by Iowa law. The court also rejected Patton's argument that the instructions set the bar too low on the racketeering element.Mallory challenged the verdict based on two evidentiary decisions and questioned whether the government established that he was a knowing accomplice. The court excluded a hearsay statement that Mallory hoped would prove he was not the driver during the shooting. The court also did not admit evidence showing Mallory's involvement in non-gang activities, considering it as inadmissible character evidence.The United States Court of Appeals for the Eighth Circuit affirmed the judgments of the district court, finding sufficient evidence for the jury to conclude that Mallory was guilty as an accomplice and rejecting Patton's arguments about the jury instructions and the evidence presented by the government. View "United States v. Mallory" on Justia Law