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

A former employee of a Defense Commissary Agency store at Offutt Air Force Base alleged that he was denied reasonable accommodations for his disabilities, harassed, and discriminated against based on his race and gender. The employee’s father initially raised concerns with management about the employee’s need for support and mentioned a disability, but neither the employee nor his father specified the nature of the disability at that time. The employee later complained about work assignments, leave requests, and comments from supervisors, believing these actions were motivated by discriminatory animus. After resigning, he sought to engage in the reasonable accommodation process, submitting a form that listed several diagnoses, but it was later revealed that his father, not a medical professional, had completed the relevant sections.The United States District Court for the District of Nebraska granted summary judgment to the Secretary of Defense on all claims. The court found that the employee failed to provide sufficient evidence of a disability or to show that he had requested or been denied a reasonable accommodation. The court also determined that there was no evidence connecting alleged harassment to the employee’s race or gender, nor was there evidence of conduct severe or pervasive enough to constitute a hostile work environment.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 employee did not produce sufficient evidence to establish that he was disabled within the meaning of the Rehabilitation Act, nor did he make a facial showing necessary for a failure-to-accommodate claim. Additionally, the court concluded that the conduct alleged did not meet the threshold for a hostile work environment under Title VII, as it was not sufficiently severe or pervasive. The judgment in favor of the Secretary of Defense was affirmed. View "Yelder v. Hegseth" on Justia Law

Anthony Schmitt, a Christian volunteer, taught a program called “The Quest for Authentic Manhood” at the Minnesota Correctional Facility from 2012 until 2020, when all religious programming was suspended due to the COVID-19 pandemic. The Quest program, which is based on biblical teachings about manhood, was popular among inmates and had been offered voluntarily. In 2023, after religious programming resumed, the Minnesota Department of Corrections (MDOC) decided to discontinue Quest, citing concerns that its content conflicted with the department’s diversity, equity, and inclusivity values. The MDOC specifically objected to the program’s biblical perspective on masculinity, its treatment of sexual orientation, and its portrayal of gender roles.Schmitt filed suit in the United States District Court for the District of Minnesota, alleging that the MDOC’s decision violated his First Amendment rights to free speech and free exercise of religion, and constituted a denominational preference in violation of the Establishment Clause. He sought a preliminary injunction to reinstate the Quest program. The district court denied the motion, applying the standard from Turner v. Safley, and found that the MDOC’s decision was rationally related to legitimate penological interests, was neutral, and did not violate Schmitt’s constitutional rights.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the preliminary injunction. The court held that, even assuming the Turner standard applied, the MDOC’s action was not neutral because it targeted Schmitt’s religious viewpoint. The court found that Schmitt was likely to succeed on the merits of his First Amendment claims and that the other factors for a preliminary injunction also favored him. The Eighth Circuit reversed the district court’s denial of the preliminary injunction and remanded with instructions to reinstate the Quest program pending further proceedings. View "Schmitt v. Rebertus" on Justia Law

Robert Gafford, a rural mail carrier for the United States Postal Service in Scott County, Missouri, was observed by residents Karen and Doug Ressel to be failing to deliver their mail over several months in 2021 and 2022. Despite road construction initially being suspected as the cause, the problem persisted after construction ended. The Ressels reported the issue to postal supervisors, who repeatedly instructed Gafford to deliver the mail, but he claimed the mailbox location was unsafe. Both a supervisor and a union representative inspected the mailbox and found it safe. The Ressels used the USPS “Informed Delivery” service and an Apple AirTag to track their mail, ultimately discovering that undelivered mail was ending up at Gafford’s residence. A postal inspector then conducted a controlled test with a tracking device, which led to the discovery of the Ressels’ mail in Gafford’s personal vehicle.A grand jury indicted Gafford for delay and embezzlement of mail under 18 U.S.C. §§ 1703(a) and 1709. At trial in the United States District Court for the Eastern District of Missouri, a jury found Gafford guilty on both counts. The district court sentenced him to fourteen months’ imprisonment on each count, to run concurrently.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Gafford’s challenges to the sufficiency of the evidence, the admission of testimony regarding the AirTag device, and the length of his sentence. The appellate court held that there was sufficient evidence for both convictions, finding that a reasonable jury could infer Gafford’s intent to convert the mail for his own use and that he unlawfully detained the mail. The court also found no abuse of discretion in admitting the AirTag testimony and determined that sentencing challenges were moot due to Gafford’s release. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Gafford" on Justia Law

After being stopped by police in Council Bluffs, Iowa, for running a red light, George Kitchen was approached by officers who detected a strong odor of marijuana coming from his vehicle. When informed that his vehicle would be searched, Kitchen initially agreed but then fled the scene, leading officers on a high-speed chase. During the pursuit, law enforcement observed packages being thrown from the vehicle, which were later recovered and found to contain significant quantities of methamphetamine and cocaine. Kitchen and his passenger were apprehended after police used stop sticks to disable the vehicle. A search of Kitchen and his car uncovered cash, drug paraphernalia, and cell phones with evidence of drug transactions.The United States District Court for the Southern District of Iowa denied Kitchen’s motion to suppress the evidence, finding that the initial stop was justified by the observed traffic violation and that the odor of marijuana provided probable cause to extend the stop and search the vehicle. After a jury trial, Kitchen was convicted on both counts of drug possession with intent to distribute and sentenced to 260 months in prison.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the suppression motion for clear error regarding factual findings and de novo for legal conclusions. The appellate court held that the traffic stop was supported by probable cause and that the district court’s credibility determinations regarding the officer’s testimony were not clearly erroneous. The court also upheld the admission of co-conspirator hearsay and other bad act evidence, finding no abuse of discretion and determining that any potential error was harmless given the weight of the evidence. The Eighth Circuit affirmed Kitchen’s convictions. View "United States v. Kitchen" on Justia Law

Investigators in Iowa and Minnesota identified an individual as a customer of methamphetamine distributors and, during a search of his home, found a loaded handgun, methamphetamine, and drug paraphernalia. The individual admitted to purchasing and distributing significant quantities of methamphetamine and to buying the firearm. He was charged with conspiracy to distribute methamphetamine and being a prohibited person in possession of a firearm. He pleaded guilty to the drug conspiracy charge, and the government agreed to dismiss the firearm charge. The parties stipulated that a two-level sentencing enhancement for possession of a dangerous weapon applied.The United States District Court for the Southern District of Iowa adopted the presentence report’s calculation, which included the firearm enhancement, and denied the defendant’s request for safety-valve relief from the mandatory minimum sentence. The court found that the defendant could not prove by a preponderance of the evidence that he did not possess a firearm in connection with the drug offense, citing the proximity of the gun to the drugs and the lack of an alternative explanation for possessing the firearm. The court sentenced the defendant to the mandatory minimum of 120 months after considering mitigating factors and granting a downward variance.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s interpretation of the safety-valve statute de novo and its factual findings for clear error. The appellate court held that the district court did not clearly err in finding the defendant ineligible for safety-valve relief under 18 U.S.C. § 3553(f)(2) and USSG § 5C1.2(a)(2), because the defendant failed to prove that he did not possess a firearm in connection with the drug offense. The judgment of the district court was affirmed. View "United States v. Boyd" on Justia Law

A Missouri consumer incurred a medical debt that was later assigned to a debt collection agency. Several years after the initial collection letter, the consumer sent a fax to the agency disputing the debt and requesting no further contact. In response, the agency mailed a letter verifying the debt and indicating that collection efforts would resume. The consumer then filed suit, alleging that the agency violated the Fair Debt Collection Practices Act (FDCPA) by communicating after being asked not to.The United States District Court for the Western District of Missouri reviewed cross-motions for summary judgment based on stipulated facts. The court found that the consumer had suffered a concrete injury because the unwanted letter intruded upon her seclusion and privacy. It granted summary judgment for the consumer, awarded statutory damages and attorneys’ fees, and denied the agency’s motion for reconsideration.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s standing determination de novo. The appellate court held that the consumer lacked Article III standing because she did not suffer a concrete injury. The court reasoned that the agency’s letter was a required response under the Fair Credit Reporting Act (FCRA) after the consumer disputed the debt in connection with her credit report, and that a single, invited letter verifying a debt does not amount to an intrusion upon seclusion or a highly offensive act. The Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss the complaint. View "Denmon v. Kansas Counselors, Inc." on Justia Law

A firefighter in Forrest City, Arkansas, was terminated after posting a provocative anti-abortion image on his personal Facebook page. The image, intended to express his pro-life views, was interpreted by some as racially insensitive, particularly because it included the caption “I can’t breathe!”—a phrase associated with protests following George Floyd’s death. After complaints from a retired fire supervisor and others, the firefighter deleted the post. However, the mayor placed him on administrative leave and, following a brief investigation, fired him, citing the public outcry and concerns about the city’s ability to provide public services. The firefighter, who had served over four years without prior incident, learned of his termination through a press release.The firefighter filed suit in the United States District Court for the Eastern District of Arkansas, alleging First Amendment retaliation against the mayor in both his individual and official capacities, and against the city for an alleged unwritten policy allowing officials to censor employee speech. The district court granted summary judgment for the defendants, holding that the mayor was entitled to qualified immunity and that there was no evidence of an unwritten policy justifying the official-capacity and policy-based claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the firefighter’s Facebook post addressed a matter of public concern and was made as a private citizen. The court found insufficient evidence of actual or reasonably predicted disruption to the fire department’s operations to justify summary judgment for the defendants. The court reversed the district court’s grant of summary judgment on the First Amendment retaliation claims against the mayor and the city, affirmed the dismissal of the unbridled-discretion claim, and remanded for further proceedings. View "Melton v. City of Forrest City, Arkansas" on Justia Law

A debtor filed for Chapter 7 bankruptcy and sought to discharge student loan debts owed to both the Department of Education and a private lender, the Bank of North Dakota. The debtor, a 50-year-old woman with degrees in physics, education, communication, and mechanical engineering, had a history of mental health challenges and an unconventional work history, including periods of unemployment and underemployment. She consistently sought employment in her fields of study but often had to accept lower-paying or unrelated jobs. At the time of the proceedings, she was employed as an engineer earning $78,000 annually, with modest assets, minimal retirement savings, and reasonable living expenses.The United States Bankruptcy Court for the Northern District of Iowa held a trial and a supplemental evidentiary hearing. The court found that the debtor’s federal student loan debt was not dischargeable, but the private student loan debt owed to the Bank of North Dakota was dischargeable under 11 U.S.C. § 523(a)(8), concluding that repayment of the Bank’s loan would impose an undue hardship. The court based its decision on the debtor’s financial resources, reasonable expenses, lack of significant assets, ongoing mental health needs, and the inflexibility of the Bank’s repayment terms. The Bank of North Dakota appealed the dischargeability determination.The United States Bankruptcy Appellate Panel for the Eighth Circuit reviewed the bankruptcy court’s legal conclusions de novo and its factual findings for clear error. The panel affirmed the bankruptcy court’s decision, holding that the debtor met her burden of proving undue hardship under the totality-of-the-circumstances test. The panel agreed that the Bank’s student loan was dischargeable, while the Department of Education loan was not, and found no error in the bankruptcy court’s analysis or application of the law. View "Duncanson v. Bank of North Dakota" on Justia Law

Twelve days before filing for bankruptcy, the debtors purchased a new property in New Hampton, Iowa, but did not list this property in their bankruptcy schedules. Instead, they listed their Waucoma property, consisting of three contiguous parcels totaling just under 30 acres, as their residence and claimed it as fully exempt under Iowa’s homestead laws. No objections were filed to this exemption. The debtors later sold two of the three Waucoma parcels, retaining only a vacant lot (Parcel A). After their bankruptcy discharge, a creditor, AgVantage, sought to execute a pre-petition judgment lien against Parcel A, ultimately acquiring it at a sheriff’s sale.The United States Bankruptcy Court for the Northern District of Iowa denied the debtors’ motion to avoid AgVantage’s judicial lien, finding that the debtors had abandoned the Waucoma property as their homestead by purchasing and using the New Hampton property. The court also dismissed the debtors’ adversary complaint seeking contempt sanctions against AgVantage for violating the discharge injunction, concluding that AgVantage held a valid lien and was enforcing in rem rights, not collecting a discharged debt. The bankruptcy court further denied the debtors’ motion to amend the judgment.On appeal, the United States Bankruptcy Appellate Panel for the Eighth Circuit found that the bankruptcy court’s factual findings regarding the debtors’ homestead status on the petition date were not supported by the record. The panel held that the debtors’ exemption claim was presumptively valid and that AgVantage had not met its burden to rebut this presumption. The panel also determined that the bankruptcy court erred in granting a motion to dismiss the adversary proceeding without affording the debtors the procedural presumptions required at that stage. The panel reversed the bankruptcy court’s decision and remanded for further proceedings, including an evidentiary hearing. View "Jencks v. AgVantage FS" on Justia Law

Sammie Smith, Jr. and Elizabeth Smith filed for Chapter 13 bankruptcy three times within approximately two and a half years. Their first case was voluntarily dismissed. In their second case, they changed attorneys multiple times, filed several amended plans, and ultimately had their case dismissed for failure to make plan payments. Shortly after, they filed a third Chapter 13 case, again changing attorneys and submitting multiple amended plans and schedules. The Smiths also filed objections to creditor claims and requested several continuances. They failed to appear at a scheduled hearing on one of their objections, leading the bankruptcy court to issue an order to show cause regarding dismissal for failure to appear.The United States Bankruptcy Court for the Eastern District of Arkansas dismissed the Smiths’ third bankruptcy case, citing unreasonable delay prejudicial to creditors under 11 U.S.C. § 1307. The court also barred the Smiths from filing another bankruptcy case in any jurisdiction for one year. The Smiths appealed, arguing they were denied due process and a fair hearing, particularly objecting to the lack of notice regarding the possibility of a refiling bar.The United States Bankruptcy Appellate Panel for the Eighth Circuit reviewed the case. It held that the bankruptcy court did not abuse its discretion in dismissing the Smiths’ case, as the record supported dismissal for unreasonable delay and failure to appear. However, the appellate panel found that imposing a one-year bar on refiling without prior notice or an opportunity for the Smiths to be heard on that sanction was an abuse of discretion and violated due process. The panel affirmed the dismissal of the bankruptcy case but reversed and vacated the one-year refiling bar. View "Smith v. Gooding" on Justia Law