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

Charles Sorensen, a retired airline pilot, engaged in a series of actions from 2016 to 2021 to evade federal income taxes for the years 2015 through 2019. His conduct included failing to file tax returns, submitting false returns, making fraudulent refund claims, concealing income and assets, and refusing to cooperate with the IRS. Sorensen used shell companies, such as LAWTAM and LAMP, to hide assets and income, transferred funds to avoid IRS levies, and ultimately converted assets into cryptocurrency to further shield them from collection. He also filed frivolous documents and lawsuits challenging the IRS’s authority. The total tax loss attributed to his actions was $1,861,722.A jury in the United States District Court for the District of Minnesota convicted Sorensen on seven counts, including filing false tax returns, tax evasion, failing to file tax returns, and making a false claim against the United States. The district court sentenced him to 41 months in prison. Sorensen appealed, arguing that the district court improperly admitted testimony from several witnesses who were not qualified as experts and erred in applying a sentencing enhancement for sophisticated means.The United States Court of Appeals for the Eighth Circuit reviewed the evidentiary rulings for abuse of discretion and the sentencing enhancement de novo. The appellate court held that the challenged witness testimony was properly admitted as lay testimony under Federal Rule of Evidence 701, as it was based on firsthand knowledge and personal experience, not specialized expertise. The court also found that the sophisticated means enhancement was appropriately applied, given Sorensen’s use of shell companies, cryptocurrency, and other complex methods to conceal his tax evasion. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Sorensen" on Justia Law

The plaintiff, a Nebraska resident, received Medicaid benefits administered by the Nebraska Department of Health and Human Services (NDHHS). In April 2024, she was sent a notice stating her Medicaid eligibility was ending due to income exceeding program standards. The notice informed her of her rights to request a conference or appeal and outlined the process for a fair hearing. She did not appeal the termination, and her coverage ended on May 1, 2024. Subsequently, she filed a federal lawsuit on behalf of herself and similarly situated individuals, alleging that the termination notices failed to meet due process requirements and seeking class certification, declaratory and injunctive relief, including reinstatement of benefits until proper notice was provided.The United States District Court for the District of Nebraska considered only her individual claims, as she did not challenge the court’s decision to exclude class claims on appeal. The district court denied her request for a temporary restraining order, finding she was unlikely to succeed because her claims sought retroactive relief barred by sovereign immunity and because the notices likely satisfied due process. The court then dismissed her complaint for lack of subject matter jurisdiction, concluding she had not alleged an ongoing violation of federal law and was not seeking prospective relief, as required to invoke the Ex parte Young exception to Eleventh Amendment immunity.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s dismissal. The Eighth Circuit held that the plaintiff’s alleged due process violation was a discrete past event—the issuance of the notice and termination of benefits—not an ongoing violation. The court further held that the relief sought was retrospective, not prospective, and thus barred by the Eleventh Amendment. The court concluded that the Ex parte Young exception did not apply, and affirmed the dismissal. View "Filyaw v. Corsi" on Justia Law

A long-serving principal at a public middle school implemented an “inclusion project” that included a display of various flags, among them a Pride flag, using school funds. She informed staff that this project was part of her professional goals and later helped establish a Gay-Straight Alliance (GSA) student group. The inclusion of the Pride flag and her advocacy for LGBTQ+ students generated controversy among staff and community members, leading to complaints about her leadership style and claims that she was creating a divisive work environment. After an outside investigation substantiated concerns about her management, she was removed as principal and reassigned to a different administrative role.The United States District Court for the District of Minnesota granted summary judgment in favor of the school district and its officials on her federal claims, finding that her speech and actions were made pursuant to her official duties as principal and thus not protected by the First Amendment. The court also found insufficient evidence that any private speech or advocacy outside her official role was a motivating factor in the adverse employment actions. The district court dismissed her federal claims with prejudice and declined to exercise supplemental jurisdiction over her state law claims, dismissing them without prejudice.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The appellate court held that the principal’s actions regarding the flag display and GSA were undertaken as part of her official duties and therefore constituted government speech, not protected by the First Amendment. The court also found no evidence that any private speech was a substantial or motivating factor in the employment decisions. The court further held that the district court did not abuse its discretion in declining supplemental jurisdiction over the state law claims. View "Thomas v. Marshall Public Schools" on Justia Law

Thomas Lamont Davis was investigated after selling methamphetamine to a confidential source on two occasions in March 2022. Law enforcement searched his residence in Des Moines, Iowa, and found firearms, large quantities of methamphetamine, cash, and drug paraphernalia. Davis was later involved in two separate high-speed chases while attempting to evade arrest, during which he possessed methamphetamine and cash. In one incident, Davis struggled with officers and bit one officer’s finger, causing injury that required stitches.The United States District Court for the Southern District of Iowa presided over Davis’s trial. Davis moved to exclude evidence of his prior Iowa felony convictions for drug and firearm offenses, but the district court denied the motion and admitted the convictions with a limiting instruction. A jury found Davis guilty on all counts, including drug distribution, possession with intent to distribute, and firearm offenses. At sentencing, the district court applied a two-level enhancement for maintaining a drug premises and a six-level enhancement for assaulting a law enforcement officer, resulting in a 360-month prison sentence.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Davis’s challenges to the admission of his prior convictions and the sentencing enhancements. The court held that the prior convictions were properly admitted for permissible purposes such as knowledge and intent, and the limiting instruction mitigated any risk of unfair prejudice. The court also found that the evidence supported the enhancements for maintaining a drug premises and for assaulting an officer, and that there was no impermissible double counting. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Davis" on Justia Law

A certified nurse midwife in Nebraska sought to provide home birth services but was prevented from doing so by state law. The Nebraska Certified Nurse Midwifery Practice Act requires midwives to work under a supervising physician through a practice agreement and prohibits them from attending home births outside authorized medical facilities. The midwife alleged that these restrictions forced her to turn away women seeking home births and sued state officials, claiming the law violated her constitutional rights and the rights of her prospective patients.The United States District Court for the District of Nebraska dismissed the midwife’s claims. The court found that she failed to state a claim for violation of her own rights under the Due Process Clause and lacked standing to assert claims on behalf of her prospective patients. The district court concluded that the statutory requirements were rationally related to legitimate state interests in health and safety and that the midwife did not have a sufficiently close relationship with prospective patients nor could she show that those patients were hindered from bringing their own suits.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the Nebraska law regulating midwifery is subject to rational basis review and that the legislature could rationally believe the restrictions serve legitimate interests in public health and safety. The court also held that the midwife lacked third-party standing to assert the rights of prospective patients because she did not have a close relationship with them and they were not hindered from bringing their own claims. The Eighth Circuit affirmed the district court’s judgment, upholding the dismissal of all claims. View "Swanson v. Hilgers" on Justia Law

The Securities and Exchange Commission (SEC) initiated a civil enforcement action against several individuals, alleging they orchestrated profitable “pump-and-dump” schemes to artificially inflate stock prices and then sell shares at a profit, harming investors. The SEC ultimately obtained final judgments and recovered over $11 million in sanctions. Under the Dodd-Frank Act, the SEC is required to pay whistleblower awards to individuals who voluntarily provide original information leading to successful enforcement actions. After posting a Notice of Covered Action, five claimants submitted applications for whistleblower awards related to this enforcement action.The SEC’s Claims Review Staff awarded 30 percent of the monetary sanctions to Daniel Fisher, a former executive at a company central to the investigation, finding that Fisher provided new, helpful information that substantially advanced the investigation. The staff denied the other applications, including those from Lee Michael Pederson, John Amster, and Robert Heath, concluding that their information was either duplicative, based on publicly available sources, or not used by enforcement staff. Pederson and Fisher were found not to have acted jointly as whistleblowers, and Amster and Heath’s information was not relied upon in the investigation. The SEC affirmed these determinations in its final order.The United States Court of Appeals for the Eighth Circuit reviewed the SEC’s final order, applying a deferential standard to the agency’s factual findings and reviewing legal conclusions de novo. The court held that substantial evidence supported the SEC’s determinations: Pederson and Fisher did not act jointly, Pederson’s individual tips were not original or helpful, and Amster and Heath’s information did not lead to the enforcement action. The court also rejected Pederson’s due process and procedural arguments and denied his motion to compel. The petitions for review were denied, and the SEC’s order was affirmed. View "Pederson v. U.S. Securities Exch. Comm." on Justia Law

Marcus D. Evans, an inmate at the Varner Supermax Unit in Arkansas, was placed in full restraints to attend a prison program. After returning to his cell, officers removed his hand restraints but refused to remove his leg restraints, despite his repeated requests. Evans remained in leg restraints for approximately 15 hours, during which he experienced pain, had difficulty sleeping, and was forced to cut off his clothing to shower. Medical records indicated he reported significant pain but showed no serious physical injury. Evans alleged that the officers’ refusal to remove the restraints was intentional and stemmed from prior altercations and threats.Evans filed suit in the United States District Court for the Eastern District of Arkansas, asserting an excessive force claim under 42 U.S.C. § 1983 against the officers. The officers moved for summary judgment, arguing qualified immunity. A magistrate judge recommended granting summary judgment, finding that while a jury could find a constitutional violation, the right was not clearly established. The district court declined to adopt this recommendation, holding that existing precedent clearly established that prolonged restraints without penological justification could constitute excessive force, and denied qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo. The court held that the officers’ refusal to remove the leg restraints constituted a use of force, and that Evans’s pain and discomfort, even absent serious injury, were sufficient to support an excessive force claim. The court further found that existing case law clearly established that subjecting an inmate to prolonged restraints without penological justification could violate the Eighth Amendment. Therefore, the Eighth Circuit affirmed the district court’s denial of qualified immunity to the officers. View "Evans v. Smith" on Justia Law

A waste hauling company operating in Kansas City brought suit against a mobile waste compaction business and its franchisor. The waste hauler owns containers that are leased to customers, who sometimes contract separately with the compaction company to compress waste inside those containers. The hauler alleged that the compaction company’s activities damaged its containers and interfered with its business relationships. The hauler sought various forms of relief, including damages, injunctive and declaratory relief, and nominal damages, but ultimately disavowed any claim for actual monetary damages, citing a lack of evidence to support such damages.The United States District Court for the Western District of Missouri denied the hauler’s request for a temporary restraining order, finding no irreparable harm. During discovery, the hauler admitted it could not identify or quantify any actual damages and stipulated it was not seeking damages outside Kansas City. The district court granted the compaction company’s motion to strike the hauler’s jury demand, holding that the hauler had not presented evidence of compensatory damages, that nominal damages were unavailable under Missouri law for the claims asserted, and that the remaining claims were equitable in nature. After a bench trial, the district court entered judgment for the compaction company and its franchisor, finding the hauler failed to prove essential elements of its claims, including actual damages and direct benefit conferred for unjust enrichment.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed. The court held that the hauler was not entitled to a jury trial under the Seventh Amendment because it failed to present evidence of compensatory damages and nominal damages were not available for its claims under Missouri law. The court also affirmed judgment for the compaction company on the trespass to chattels and unjust enrichment claims, finding the hauler failed to prove dispossession, damages, or a direct benefit conferred. View "Allied Services v. Smash My Trash, LLC" on Justia Law

The defendant was charged with multiple counts after sexually abusing a female relative over a period of years, beginning when she was eight years old and continuing until she turned eighteen. He produced nude photographs and videos of the victim, including recordings of sexual assaults. Following his arrest, he was indicted on eight counts. He entered a plea agreement, pleading guilty to two counts of sexual exploitation of a child in exchange for the government’s dismissal of the remaining counts and a recommendation of a 25-year sentence. The agreement also allowed the defendant to recommend a 20-year sentence.The United States District Court for the District of North Dakota accepted the plea but ultimately sentenced the defendant to 45 years’ imprisonment, which was within the applicable Guidelines range of 30 to 60 years. At sentencing, the government advocated for a 25-year sentence, using language such as “restrict its recommendation to 25 years” and “ask the court to impose no less than 25 years.” The defendant did not object to the government’s phrasing at the time. The district court considered the relevant statutory factors, including the nature and seriousness of the offense, the need for just punishment, and the protection of the community, before imposing the sentence.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the government breached the plea agreement and whether the sentence was substantively unreasonable. Applying plain error review, the court held that the government’s statements did not breach the plea agreement, as they were consistent with its obligation to recommend a 25-year sentence. The court also found that the district court did not abuse its discretion in imposing a 45-year sentence, as it properly considered all relevant factors. The Eighth Circuit affirmed the sentence. View "United States v. Johnson" on Justia Law

A police sergeant in Dermott, Arkansas, was terminated from his position after being charged with tampering with physical evidence and abuse of office. The charges stemmed from an incident in which the sergeant received a bag of quarters, believed to be stolen, from another officer following a robbery investigation. The sergeant’s documentation of the evidence was inconsistent, and the quarters were not turned in to the department. During a subsequent investigation, the sergeant admitted he may have used the quarters for personal purposes. Although the charges were later dismissed, the sergeant maintained that his termination was solely due to the criminal charges. He also previously reported another officer’s excessive use of force, which he claimed was a motivating factor in his firing.The United States District Court for the Eastern District of Arkansas granted summary judgment and judgment on the pleadings in favor of the defendants, including the police chief, the officer involved, and the city. The court found that the sergeant failed to establish a genuine dispute of material fact regarding whether his termination was motivated by his protected speech, as the firing occurred long after his report and the criminal charges provided an obvious alternative explanation. The court also determined that the sergeant was not seized under the Fourth Amendment, negating his malicious prosecution claim, and that he lacked a property interest in his employment under Arkansas law, defeating his due process claims. The court exercised supplemental jurisdiction over the state law claims and found them lacking on the merits, including claims under the Arkansas Whistle-Blower Act, malicious prosecution, abuse of process, and defamation.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that the sergeant failed to present sufficient evidence to support his federal constitutional claims or his state law claims, and that the district court did not abuse its discretion in retaining and resolving the state law claims. View "Brown v. City of Dermott Arkansas" on Justia Law