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

In this case, the United States Court of Appeals for the Eighth Circuit upheld the conviction of William Goodman for distribution of fentanyl resulting in death and unlawfully possessing a firearm as a felon. Goodman appealed his conviction on the grounds that the district court improperly admitted hearsay testimony from the deceased user’s girlfriend and wrongly instructed the jury regarding Goodman’s prior convictions.The court rejected Goodman's first argument, ruling that his co-conspirator's statements, relayed through the girlfriend's testimony, fell under the co-conspirator exclusion under Rule 801(d)(2)(E) of the Federal Rules of Evidence as they were made during and in furtherance of a conspiracy to distribute drugs. The court also dismissed Goodman's second argument, finding that the expanded list of uses for evidence of Goodman's prior convictions under Rule 404(b) did not prejudice the defendant and thus did not warrant a new trial. The court affirmed the district court's judgment. View "United States v. Goodman" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit examined an appeal by John Lee Ralston, who was charged with being a prohibited person in possession of a firearm after a search of his residence. The search was conducted under a warrant that was primarily issued based on criminal activity suspected of another person, Colton Varty, who was believed to be residing on the same piece of property but in a different residence. Ralston argued the warrant did not establish probable cause that evidence would be located inside his house.The district court had denied Ralston’s motion to suppress the evidence obtained from the search of his residence, ruling that even though the warrant lacked probable cause, the officers acted in good faith, relying on the Leon good-faith exception. On appeal, the Court of Appeals for the Eighth Circuit disagreed and reversed the district court's decision.The Court of Appeals held that the Leon good-faith exception did not apply in this case. The court found that the affidavit supporting the warrant was so lacking in evidence connecting Ralston and his residence to the suspected criminal activity of Varty that no reasonable officer would have relied upon a warrant that was issued based on it. The Court of Appeals concluded that without evidence that Varty had access to Ralston’s residence or facts pointing to a fair probability that Ralston’s residence contained stolen property or was being used to fence stolen property, the Leon good-faith exception could not apply. The Court of Appeals remanded the case to the district court with directions to vacate Ralston’s guilty plea and grant his motion to suppress. View "United States v. Ralston" on Justia Law

A car dealership, Broadway Ford Truck Sales, Inc., in St. Louis, Missouri, suffered a significant fire damage to its business premises and filed claims under its insurance policy provided by Depositors Insurance Company. However, disputes arose over the coverage and Broadway Ford sued Depositors for breach of contract and vexatious refusal to pay. The United States District Court for the Eastern District of Missouri granted summary judgment favoring Depositors.At the time of the fire, Broadway Ford had an insurance policy that covered loss or damage to its Building and Business Personal Property (Building/Property) and loss of Business Income and Extra Expenses (BI/EE) due to a suspension of operations. Broadway Ford and Depositors later entered into a Limited Settlement Agreement and Release of Disputed Property Damage Claims (LSA), in which Depositors agreed to pay a certain amount for the fire damage and Broadway Ford released Depositors from any claims related to the property damage. BI/EE claims were not included in this agreement and remained open.Broadway Ford’s complaint against Depositors alleged that Depositors breached the policy's implied covenant of good faith and fair dealing and that Depositors’ conduct amounted to vexatious refusal under Missouri law. The district court granted Depositors' motion for summary judgment, finding that Broadway Ford’s complaint was foreclosed by the LSA. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo.The appellate court affirmed the judgment of the district court. The court found that Broadway Ford had released its claims related to the Building/Property coverage in the LSA and could not pursue litigation for additional compensatory damages in the form of the “business income” it lost and the “extra expenses” it incurred due to Depositors’ alleged mishandling of its Building/Property coverage claim. View "Broadway Ford Truck Sales, Inc. v. Depositors Insurance Company" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit upheld a conviction against Richard Lee David Brown for possession with intent to distribute a controlled substance. Law enforcement found Brown in an apartment during the execution of a search warrant, along with drugs, drug paraphernalia, and a cell phone that Brown admitted was his. Brown appealed his conviction, alleging multiple pre-trial and trial-related errors. However, the court affirmed the conviction, rejecting Brown's claims that he was improperly denied a jury instruction regarding "mere presence," that the court erred in admitting evidence of his prior convictions, and that he received ineffective assistance of counsel, among other issues. The court held that the instructions given to the jury were adequate and that the evidence was sufficient to support the conviction. The court also found that Brown's claims of ineffective assistance were best left for a post-conviction relief proceeding, such as a motion under 28 U.S.C. § 2255. The court concluded that none of the alleged errors either individually or cumulatively warranted reversal of the conviction. View "United States v. Brown" on Justia Law

In this case heard by the United States Court of Appeals For the Eighth Circuit, the appellant, Tiano N. Trice, was appealing against a decision by the United States District Court for the Southern District of Iowa - Eastern. The dispute arose after Trice was arrested while on supervised release, leading to the revocation of his supervised release for domestic assault and child endangerment. Trice was sentenced to a 24-month imprisonment period, followed by 12 months of supervised release.In his appeal, Trice did not challenge the domestic assault violation but contested the child endangerment finding and the district court's factfinding and credibility determinations. The incident involved Trice and the mother of his children, Clareshanda Chamberlain, getting into a heated argument in the presence of their children, during which Trice lifted the bed Chamberlain was in and dropped it to the ground. The children, scared by the altercation, fled from the house or hid.The appellate court affirmed the district court's decision, stating that the district court's factual findings and credibility determinations were not erroneous. The court also rejected Trice's argument that hearing the assault, as opposed to actually seeing it, is insufficient to trigger child endangerment, stating that Iowa law does not make this distinction. The court concluded that Trice was aware his children were present during the assault on their mother, which constitutes child endangerment under Iowa law. Therefore, the district court did not err in finding that Trice committed child endangerment and did not abuse its discretion in revoking Trice's supervised release. The court affirmed the judgment of the lower court. View "United States v. Trice" on Justia Law

The United States Court of Appeals for the Eighth Circuit heard an appeal from Jacob Bermel, who had pleaded guilty to two child pornography offenses following the denial of his motion to suppress evidence that was found on a camera he had hidden in his daughter's bathroom. Bermel argued that the warrantless seizure and subsequent search of the camera and its memory card violated his Fourth Amendment rights. However, the district court found that the seizure was justified by exigent circumstances and that the search was lawful due to the daughter's consent.On appeal, Bermel made three arguments: (1) minor children cannot consent to a search of their parents' property, (2) even if minors can consent, his daughter lacked such authority, and (3) the district court erred in finding that his daughter had consented to the search of the camera and memory card.The Court of Appeals affirmed the district court's decision. It rejected Bermel's first argument, stating that there is no legal precedent for a per se rule that minors cannot consent to a search of their parents' property. The court also found that the daughter had apparent authority to consent to the search given her joint access and control over the camera and its memory card. Finally, the court determined that the daughter had indeed consented to the search of the camera and its memory card. The court noted that lack of verbal response did not negate consent and the scope of her consent reasonably extended to the camera's memory card. View "United States v. Bermel" on Justia Law

In this case before the United States Court of Appeals for the Eighth Circuit, the defendant, Bradley Ready, appealed his sentence following his guilty plea for possession with intent to distribute methamphetamine and possession of a firearm as an unlawful user of a controlled substance. The court affirmed the district court's decision.During a search of Ready's residence, law enforcement officers found drug paraphernalia, scales, a loaded hunting rifle, and three bags of methamphetamine. Ready was subsequently charged and pleaded guilty to both counts. At sentencing, the U.S. Probation Office recommended grouping the drug and gun counts together and applying a two-level enhancement due to the possession of a dangerous weapon. Ready objected to this enhancement, but the district court overruled this objection.On appeal, Ready argued that the district court erred in applying the enhancement for possession of a dangerous weapon and applied the wrong standard in determining his eligibility for safety valve relief. The appellate court found no error in the district court's conclusions.The appellate court held that the district court did not err in applying the enhancement for possession of a dangerous weapon, as it was not "clearly improbable" that the rifle found in Ready's bedroom was connected to the distribution of methamphetamine from his home. The court also held that the district court did not err in its application of the standard for determining Ready's eligibility for safety valve relief. Therefore, the district court's judgment was affirmed. View "United States v. Ready" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit heard an appeal by Armory Hospitality, LLC, an event venue in Minneapolis, Minnesota. Armory had an insurance policy with Philadelphia Indemnity Insurance Company and filed a claim to recover its business losses due to the closure of bars, restaurants, and performance venues for over a year by Minnesota’s Governor in response to the COVID-19 pandemic. The insurer denied the claim, leading to Armory suing. However, the district court dismissed Armory’s complaint, holding that the policy did not cover the losses, a decision which Armory appealed.The Court of Appeals affirmed the district court’s decision. The court interpreted the insurance policy under Minnesota law, which requires unambiguous policy language to be given its plain and ordinary meaning. Armory sought coverage under three clauses in its policy: the Building Coverage clause, the Business Income clause, and the Civil Authority clause. The first two clauses required “direct physical loss of or damage to” Armory’s property, which the court decided had not been met since the closure of the venue due to the pandemic did not satisfy the physicality requirement. The court disregarded Armory's argument that the "loss of" property included its inability to use its venue, citing previous precedent requiring physicality for both "loss of" and "damage to" property.As for the Civil Authority clause, the court found that Armory could not prove a causal link between the contamination of nearby properties (a hospital and a jail) by COVID-19 and the Governor’s orders to close venues. Hence, the court concluded that Armory could not recover under any of the clauses in its policy, and therefore affirmed the district court's dismissal of Armory's complaint. View "Armory Hospitality, LLC v. Philadelphia Indemnity Ins. Co." on Justia Law

In this case, the United States Court of Appeals For the Eighth Circuit examined claims by Colleen M. Johnson against her former employer, Midwest Division-RBH, LLC (Belton Regional Medical Center), her supervisor Patrick Avila, and her replacement Nicole Pasley. Johnson had been on medical leave for nine months due to heart-related issues when she informed Belton Regional that she could not give a return date. The next day, the company terminated her employment. Johnson sued under the Missouri Human Rights Act (MHRA), claiming age and disability discrimination, and also brought common law claims for emotional distress, defamation, and property damage. The district court dismissed the common law claims and granted summary judgment on the MHRA claims.On appeal, the Eighth Circuit affirmed the lower court's decision. The court rejected Johnson’s argument that her common law claims were not preempted by the MHRA, ruling that the MHRA provided the exclusive remedy for claims arising out of an employment relationship and that she had fraudulently joined the Missouri defendants to prevent removal. The court also found that Johnson could not establish a prima facie case of age or disability discrimination under the MHRA because she did not provide evidence that her age or disability was the “determinative influence” on her termination. Instead, the court concluded that Johnson was fired due to her refusal to provide a date when she would return from medical leave, not because of her age or disability. Finally, the court ruled that Johnson had waived her argument of constructive discharge by failing to provide meaningful legal analysis in her opposition to summary judgment. View "Johnson v. Midwest Division - RBH, LLC" on Justia Law

The United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of Darren J. Ackerman’s motion to suppress evidence of firearms discovered in his basement. The police had entered his home on the information that Ackerman had tried to choke his girlfriend, was possibly on drugs, and might be holding their infant daughter hostage. They found him at the bottom of the basement stairs, holding his daughter, and upon arresting and handcuffing him, they performed a protective sweep of the basement, during which they found firearms in a room adjoining the area of his arrest.Ackerman argued that the search was not a valid protective sweep as the rooms searched did not adjoin the place of his arrest. The court, however, determined that the arrest occurred at the bottom of the stairs, where Ackerman first submitted to the officers' authority. The court concluded that the room where the firearms were found immediately adjoined the area at the bottom of the stairs, and thus, the protective sweep complied with the Fourth Amendment.The court followed the "protective sweep" exception to the Fourth Amendment, which allows officers to conduct a quick and limited search of premises, incident to an arrest and conducted to protect the safety of police officers or others. The court used the two-prong test from the Supreme Court case Maryland v. Buie to determine the constitutionality of the protective sweep. The first prong allows officers to look in closets and other spaces immediately adjoining the place of arrest from where an attack could be launched, and the second prong allows officers to search areas where they believe a danger may be present based on articulable facts. View "United States v. Ackerman" on Justia Law