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

In this case, law enforcement in Little Rock, Arkansas, conducted a sting operation targeting illegal prostitution, which led to the arrest of A.B., a woman working for Deonte Womack. Initially, A.B. did not identify Womack, but after suffering physical abuse from him, she later cooperated with authorities. The FBI’s investigation revealed that Womack managed a prostitution ring involving at least twelve women, exerting control through violence, threats, and financial manipulation. Womack was arrested and charged with three counts of sex trafficking by force, fraud, or coercion, and one count of witness intimidation.The United States District Court for the Eastern District of Arkansas presided over Womack’s trial. The court allowed testimony from a woman, C.C., about uncharged conduct under Federal Rule of Evidence 404(b), with a limiting instruction to the jury. At the close of the government’s case, the district court granted Womack’s motion for judgment of acquittal on one sex trafficking count and the witness intimidation count, but denied it as to the remaining two sex trafficking counts. The court also denied Womack’s request for a lesser included offense jury instruction and sentenced him to 235 months’ imprisonment, applying a base offense level of 34 under the sentencing guidelines.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed four issues. The court held that the district court did not abuse its discretion in admitting C.C.’s testimony under Rule 404(b), nor in denying the lesser included offense instruction, and found sufficient evidence supported the convictions. However, the appellate court concluded that the district court erred in calculating the base offense level at sentencing, as Womack was not convicted under 18 U.S.C. § 1591(b)(1). The court affirmed the convictions but remanded the case for resentencing with the correct base offense level. View "United States v. Womack" on Justia Law

Aaron Cardinale was stopped by Omaha police officers after they observed him allegedly failing to signal a left turn at least 100 feet in advance, as required by Nebraska law. During the stop, a K-9 unit detected drugs in his vehicle, leading to his arrest and subsequent indictment for possession with intent to distribute methamphetamine. Cardinale moved to suppress the evidence, arguing the stop was not supported by reasonable suspicion.The United States District Court for the District of Nebraska denied Cardinale's motion to suppress. The court found that the officers had a reasonable belief that Cardinale violated the traffic signal law based on Officer Cleveland's testimony. The court reviewed video evidence and other exhibits but concluded that the evidence did not clearly show the officer's belief was unreasonable. Cardinale's motion to reconsider was also denied, with the court reiterating that the entire record supported the officer's reasonable suspicion.The United States Court of Appeals for the Eighth Circuit reviewed the case. Cardinale argued that the government did not present sufficient historical facts to justify the stop and that Officer Cleveland's testimony was too conclusory. The appellate court upheld the district court's decision, noting that the officer's testimony was credible and supported by the record. The court emphasized that reasonable suspicion does not require precise measurements or perfect knowledge, only that the officer's belief was reasonable under the circumstances. The court affirmed the district court's denial of Cardinale's motion to suppress evidence. View "United States v. Cardinale" on Justia Law

In May 2020, a fire started in the engine of a recreational power boat on the Lake of the Ozarks, causing an explosion that injured Lauren Wilken and killed Shawn Carroll. The Carroll family and Wilken sued the boat's designer, manufacturer, and seller (collectively "Brunswick") for defective design, failure to warn, negligence, and wrongful death. The jury returned a verdict in favor of Brunswick.The plaintiffs appealed, asserting four errors by the United States District Court for the Western District of Missouri. They claimed the district court erred in denying their Batson challenge, excluding evidence of other similar incidents, striking expert testimony, and not allowing them to introduce evidence of other explosions during closing arguments.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no clear error in the district court's denial of the Batson challenge, as Brunswick's reason for striking Juror No. 13 was deemed reasonable and based on accepted trial strategy. The court also upheld the exclusion of evidence related to the Schroeder explosion, as the plaintiffs failed to show that the conditions of the boats were sufficiently similar. The court found no abuse of discretion in the district court's decision to strike the expert's testimony about the Schroeder explosion as a sanction for violating its order. Lastly, the court determined that the district court's curative instruction to the jury regarding Brunswick's counsel's comment during closing arguments was sufficient to mitigate any potential prejudice.The Eighth Circuit affirmed the district court's judgment in favor of Brunswick. View "Carroll v. Brunswick Corporation" on Justia Law

John Baldwin sued Union Pacific Railroad Company under the Americans with Disabilities Act (ADA) and the Age Discrimination in Employment Act (ADEA), alleging he was unlawfully removed from his position following a fitness-for-duty evaluation. Baldwin, who had degenerative arthritis and underwent a double hip replacement, experienced a bursitis flare-up while working, leading to a fitness-for-duty evaluation. Despite being cleared by his orthopedic surgeon and a physical exam, Union Pacific's Chief Medical Officer imposed work restrictions based on Baldwin's exercise tolerance test results, which showed low aerobic capacity and mild hypertension. Baldwin was ultimately prevented from returning to his job.The United States District Court for the District of Nebraska denied both parties' summary judgment motions. Baldwin voluntarily dismissed his disparate impact and ADEA claims, proceeding to trial on the ADA claims for disparate treatment and failure to accommodate. The jury found that Union Pacific discriminated against Baldwin based on a perceived disability but concluded he posed a direct threat to himself. The district court entered judgment for Union Pacific and denied Baldwin’s motion for a new trial, which challenged the jury instructions.The United States Court of Appeals for the Eighth Circuit reviewed the case. Baldwin argued that the jury instructions misallocated the burden of proof and omitted essential elements of the direct threat defense. The court found that while the direct threat instruction was incomplete, it did not affect the trial's outcome. The business judgment instruction was deemed appropriate and did not mislead the jury. The court affirmed the district court's judgment, concluding that the instructions, taken as a whole, did not mislead the jury or affect Baldwin's substantial rights. View "Baldwin v. Union Pacific Railroad Co." on Justia Law

Lonnie Parker, a licensed medical practitioner, was found guilty by a jury of distributing oxycodone and promethazine HCl with codeine solution in a manner unauthorized by the Controlled Substances Act. The case began when an individual named N.C. was pulled over for reckless driving, found impaired, and later died in custody. The DEA suspected Parker of operating a "pill mill" and seized patient records from his clinic. An expert reviewed these records and found that Parker had prescribed controlled substances inappropriately.The United States District Court for the Western District of Arkansas sentenced Parker to 87 months’ imprisonment. Parker appealed, arguing that the evidence was insufficient to support his convictions, the jury instructions were improper, and the district court committed procedural error in sentencing. The district court had calculated Parker’s base offense level by including uncharged prescriptions as relevant conduct, resulting in a total offense level of 30 and an advisory sentencing guidelines range of 108 to 135 months. The court varied downwards to 87 months.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the evidence was sufficient to support Parker’s convictions, as the expert testimony provided enough basis for the jury to conclude that Parker prescribed controlled substances without a legitimate medical purpose. The court also found no plain error in the jury instructions, noting that the instructions as a whole clarified the requirements for criminal conduct. Finally, the court determined that any potential error in calculating the quantity of controlled substances for sentencing was harmless, as the district court stated it would have imposed the same sentence regardless. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Parker" on Justia Law

Shue Moua was convicted by a jury of possession with intent to distribute methamphetamine. The conviction stemmed from a traffic stop conducted by Deputy Nils Hansen, who observed Moua's erratic behavior at a gas station and suspected she was impaired. During the stop, Hansen noted several signs of impairment and discovered methamphetamine in Moua's vehicle during an inventory search after her arrest.Moua moved to suppress the evidence obtained from the search, arguing that the traffic stop was invalid and unreasonably prolonged. A magistrate judge recommended granting the motion, finding that Hansen lacked reasonable suspicion to initiate the stop. However, the United States District Court for the District of Minnesota overruled this recommendation, concluding that Hansen had reasonable suspicion based on Moua's impaired behavior and vehicle registration issues. The district court also found that the stop was not unreasonably extended. Moua was subsequently convicted and sentenced to 72 months' imprisonment.The United States Court of Appeals for the Eighth Circuit reviewed the case and upheld the district court's decision. The appellate court found that Deputy Hansen had reasonable suspicion to stop Moua's vehicle based on her erratic driving and the absence of visible registration tags. The court also determined that the stop was not unreasonably prolonged, as Hansen's suspicions evolved during the encounter, justifying further investigation. The court affirmed the district court's denial of Moua's motion to suppress and upheld her conviction and sentence. View "United States v. Moua" on Justia Law

James Trambly was employed by the University of Nebraska-Kearney as a help desk associate and later promoted to workstation support specialist. His job performance declined after the promotion, leading to a negative evaluation and further issues. In November 2018, Trambly accused a co-worker of interfering with his email, and in January 2019, he removed a hard drive from a university computer without authorization, violating university policy. He was terminated on February 8, 2019. Trambly filed a lawsuit alleging disability discrimination and retaliation under the Rehabilitation Act, the Nebraska Fair Employment Practices Act (NFEPA), and the Americans with Disabilities Act (ADA).The United States District Court for the District of Nebraska granted summary judgment in favor of the Board of Regents of the University of Nebraska, concluding that Trambly failed to present sufficient evidence to support his claims. The court also denied Trambly's motion to amend his complaint to include a claim under Title II of the ADA, ruling that employment-based discrimination claims could only arise under Title I.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that Trambly did not provide sufficient evidence to show that he suffered from an impairment that substantially limited his major life activities. The court also found that Trambly's retaliation claims were unsupported, as the alleged adverse actions were not materially adverse or causally linked to his protected conduct. Additionally, the court upheld the denial of leave to amend the complaint, agreeing that Title II of the ADA does not apply to employment-based discrimination claims. The judgment of the district court was affirmed. View "Trambly v. Board of Regents of the University of Nebraska" on Justia Law

Patricia Conway, a registered nurse, was terminated from Mercy Hospital St. Louis for refusing to comply with the hospital's COVID-19 vaccination policy, which required all employees to be vaccinated unless they obtained an approved medical or religious exemption. Conway requested a religious exemption, which was denied. She was subsequently terminated and filed a lawsuit alleging religious discrimination under Title VII of the Civil Rights Act of 1964.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of Mercy Hospital, finding that as a religious organization, the hospital was exempt under 42 U.S.C. § 2000e-1(a). Conway appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that Mercy Hospital qualifies as a "religious organization" under § 2000e-1(a) due to its structure, mission, and affiliation with the Roman Catholic Church. The court found that the hospital's religious identity and mission, supported by uncontroverted facts, met the criteria for the exemption.The court also rejected Conway's arguments that Mercy Hospital waived its exemption by complying with the CMS mandate and that it should be estopped from invoking the exemption due to its internal vaccine policy. The court concluded that compliance with federal regulations does not waive a statutory exemption and that the hospital's policy did not constitute a clear representation that would induce detrimental reliance.The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Mercy Hospital, upholding the exemption for religious organizations under Title VII. View "Conway v. Mercy Hospital St. Louis" on Justia Law

Officer Mason Roth shot and killed Bobby Jo Klum, who was walking through a residential neighborhood with a gun to his head, evading arrest, and ignoring officer commands to drop the weapon. Klum’s spouse and mother sued Officer Roth and the City of Davenport under 42 U.S.C. § 1983, alleging a violation of Klum’s Fourth Amendment right against unreasonable seizure. The district court granted qualified immunity to Officer Roth and concluded the City of Davenport was not liable under Monell v. Department of Social Services.The United States District Court for the Southern District of Iowa granted summary judgment to Officer Roth and the City of Davenport on all claims. The court concluded that Klum’s Fourth Amendment right against unreasonable seizure was not violated and that Klum did not possess a clearly established right against seizure by deadly force under the circumstances. Plaintiffs appealed the district court’s grant of summary judgment based on qualified immunity as to their excessive force claim against Officer Roth and the City of Davenport.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The court held that any right was not clearly established at the time, and therefore, Officer Roth was entitled to qualified immunity. The court found that the totality of the circumstances, including Klum’s non-compliance, evasion, and proximity to bystanders, justified the use of deadly force. The court also upheld the district court’s grant of summary judgment on the Monell claim, concluding that Plaintiffs failed to raise a genuine issue as to whether the City of Davenport had a policy that directly caused the use of deadly force. View "Klum v. City of Davenport" on Justia Law

A law firm, Sutter & Gillham PLLC, and its partners were involved in a contentious wrongful-death lawsuit in Arkansas, representing the family of a teenage boy who died from a gunshot wound. The family suspected foul play, while the boy's friends claimed it was suicide. The state court dismissed the case with prejudice, citing misconduct by the family and its attorneys. Although the firm had withdrawn from the case, it felt unfairly maligned by the court's order. One partner's attempt to intervene and seek recusal of the judge was denied, and no appeal was filed. The family successfully overturned the dismissal, and the case remains pending.The firm faced related litigation, including a state court lawsuit by the wrongful-death defendants against the firm and its partners for alleged misconduct. The firm also filed a federal lawsuit alleging constitutional violations by the wrongful-death defendants and their attorneys, claiming they conspired with the state trial judge. The United States District Court for the Eastern District of Arkansas dismissed the case under the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court concluded that the Rooker-Feldman doctrine did not apply because the federal lawsuit did not seek to overturn the state court judgment but rather targeted the actions of the defendants and their attorneys. The court emphasized that the doctrine only applies when a federal action is essentially an appeal of a state court decision. The Eighth Circuit vacated the district court's dismissal and remanded the case for further proceedings, allowing the plaintiffs to pursue their claims. View "Sutter & Gillham PLLC v. Henry" on Justia Law