U.S. Court of Appeals for the Eighth Circuit - Justia Case Law Summaries

United HealthCare Services, Inc. v. AmerisourceBergen Corporation

2026-07-31T07:30:59-08:00

The dispute centers on allegations by a Minnesota-based health insurer that several related pharmaceutical companies carried out an unlawful scheme involving the distribution and sale of repackaged and adulterated oncology drugs. The scheme allegedly involved breaking sterile seals on medication vials, pooling overfill amounts—which were not intended for patient use—and creating pre-filled syringes that were then sold to healthcare providers. These syringes were ultimately administered to cancer patients, including many insured under programs operated by the plaintiff. The defendants did not themselves submit claims for reimbursement, but the plaintiff asserts it paid for treatments using these adulterated drugs, unaware of their compromised quality. Prior to this lawsuit, the scheme was the subject of other civil actions and federal investigations, including qui tam actions and a federal criminal prosecution. The defendants disclosed these investigations in annual reports filed with the Securities and Exchange Commission and the events received media attention beginning in 2012. In 2017, a related company pleaded guilty to federal charges, admitting to the repackaging scheme, and paid significant fines and settlements. The plaintiff filed suit in 2023, asserting claims for common-law fraud, unjust enrichment, and violations of several Minnesota consumer protection statutes. The United States District Court for the District of Minnesota dismissed the complaint, finding the claims were barred by the applicable six-year statute of limitations, and that the plaintiff had failed to sufficiently plead fraudulent concealment to toll the limitations period. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. It concluded that publicly available disclosures and the plaintiff’s own allegations established that the plaintiff should have discovered its causes of action no later than 2016. Because the plaintiff did not file suit until 2023, its claims were untimely. The court affirmed the district court’s judgment, holding that all claims were barred by the statute of limitations. View "United HealthCare Services, Inc. v. AmerisourceBergen Corporation" on Justia Law

United States v. Ketcher

2026-07-31T07:30:56-08:00

Shelly Ketcher was employed as a bookkeeper for South Delta Aviation (SDA) and also managed the personal affairs of the owner, D.R. Over a five-year period, she embezzled about $2.7 million from SDA and D.R. by forging more than a thousand checks, making them payable to herself, family, and friends. Ketcher concealed her extensive criminal history of prior fraud and embezzlement convictions when she was hired. The embezzlement was discovered after D.R. found he was delinquent on property taxes and confronted Ketcher, who attempted to cover up her actions with forged documents. The United States District Court for the Western District of Arkansas handled Ketcher’s guilty plea to one count of money laundering and one count of filing a false federal income tax return. The Presentence Investigation Report calculated an advisory guidelines range of 92 to 115 months. At sentencing, after hearing victim impact statements and arguments from both sides, the court imposed an upward variance, sentencing Ketcher to a total of 156 months in prison—120 months for money laundering and a consecutive 36 months for the tax offense. The court cited the egregiousness of the offense and Ketcher’s repeated similar crimes as aggravating factors, outweighing her mitigating circumstances. On appeal to the United States Court of Appeals for the Eighth Circuit, Ketcher argued that her sentence was substantively unreasonable, asserting that the district court gave insufficient weight to mitigating factors, imposed a harsher sentence than similarly situated defendants, and was motivated by personal animosity. The Eighth Circuit held that the district court did not abuse its discretion in imposing the upward variance, found the court’s reasoning and weighing of factors appropriate, and affirmed the judgment. View "United States v. Ketcher" on Justia Law

King v. Texas Insurance Company

2026-07-30T07:31:06-08:00

Empirical Prime, LLC defaulted on a loan issued by Enterprise Bank, violating the loan agreement by obtaining additional loans from other banks. Officers of Empirical allegedly submitted inaccurate financial statements and manipulated documents to secure these loans, as well as commingled and misappropriated funds. After the default, Enterprise Bank sought the appointment of a receiver, resulting in Brent King being appointed as receiver for Empirical. King, acting as receiver, sent letters to Texas Insurance Company (TIC) asserting that Empirical was owed coverage under a Directors and Officers Liability Policy, citing losses from the officers’ alleged misconduct. The case was initiated in Missouri state court by King, alleging breach of contract and vexatious refusal to pay under Missouri law. TIC removed the action to the United States District Court for the Western District of Missouri and moved to dismiss, arguing King lacked standing and that his claims failed to meet the policy’s requirements for coverage. The district court found that King had standing but concluded he failed to sufficiently allege either a “Claim” or a “Loss” as defined by the policy, because his letters to TIC were not demands against Empirical and there was no allegation of a legal obligation to pay resulting from a claim. The court granted TIC’s motion to dismiss and denied King’s motions to alter the judgment and to file an amended complaint, finding amendment would be futile. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The court held that King’s complaint did not plausibly allege a “Claim” or “Loss” triggering coverage under the policy, and that the district court did not err in denying leave to amend because the proposed amendments would not cure these deficiencies. Thus, the dismissal and denial of leave to amend were upheld. View "King v. Texas Insurance Company" on Justia Law

Hibbert v. MC Realty Group, LLC

2026-07-30T07:31:05-08:00

The plaintiff, a lead engineer employed by JanCo FS3, LLC (doing business as Velociti Services), worked at UMB Bank's Technology Operations Center in Kansas City and later at the 1010 Grand Building. He had a permanent disabled parking placard due to an ankle replacement, which affected his mobility. After his building assignment changed, he requested to park in a handicap spot at 1010 Grand, rather than his assigned spot at the Tech Center. Velociti requested updated medical documentation to support his accommodation request, but the plaintiff only provided his handicap placard renewal paperwork, which did not explain his disability or limitations. Despite repeated requests and deadline extensions from Velociti, he did not submit the required medical certification. He continued to park in the unassigned garage, received disciplinary warnings, and was ultimately fired for insubordination. The United States District Court for the Western District of Missouri granted summary judgment in favor of the defendants, finding that the plaintiff failed to provide sufficient medical documentation to support his accommodation request and did not demonstrate that the defendants’ actions were motivated by discriminatory animus. The court held that the employer’s enforcement of its parking policy and subsequent termination of the plaintiff for insubordination constituted legitimate, non-discriminatory reasons for the adverse action. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The Eighth Circuit affirmed the district court’s decision, holding that any breakdown in the interactive process was due to the plaintiff’s failure to provide necessary medical information, not the employer’s refusal to accommodate. The court also held that the plaintiff did not present direct or indirect evidence of disability discrimination or retaliation, and that the employer’s stated reason for termination was not pretextual. The judgment for the defendants was affirmed. View "Hibbert v. MC Realty Group, LLC" on Justia Law

Rolfsrud v. Continental Resources, Inc.

2026-07-30T07:31:05-08:00

The dispute centers on mineral rights to a property in McKenzie County, North Dakota. In 1938, the county acquired the property from Ellen Stole through foreclosure. In 1948, the county leased mineral rights—the “County Lease”—to Thomas Dorough, granting extraction rights in exchange for royalties. Hans Stole, Ellen’s son, redeemed the property in 1951, terminating the county’s ownership, and in 1954 ratified the County Lease as it pertained to his interest. There has been continuous mineral production since 1957. The Rolfsruds acquired the property in 2002 and entered new leases in 2007 and 2019—the latter (“Rolfsrud Lease”) granting higher royalties and naming Davis Exploration as lessee. Continental Resources operated under both leases, ultimately paying royalties at the lower County Lease rate. The Rolfsruds, joined by Davis Exploration, sued Continental and Petro-Hunt, asserting the Rolfsrud Lease controlled the property and raising several claims, including breach, quiet title, and declaratory relief. The United States District Court for the District of North Dakota granted summary judgment to the defendants. The court relied on Ulrich v. Amerada Petroleum Corporation and Holbeck v. Hull from the North Dakota Supreme Court, finding the County Lease had priority. The court determined the Rolfsrud Lease was a “top lease” and quieted title in favor of Petro-Hunt’s interest under the County Lease. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. It held the County Lease became voidable—not void—upon redemption, and Hans’s ratification was valid as to the property he owned. The court further held continuous production under the County Lease sustained its force, despite no Pugh clause or lack of production on the specific property. The Eighth Circuit affirmed the district court’s judgment, holding the County Lease controls the subject property and the Rolfsrud Lease is a top lease. View "Rolfsrud v. Continental Resources, Inc." on Justia Law

Wells Fargo Bank N.A. v. Ameritas Life Insurance Corp.

2026-07-30T07:31:03-08:00

A senior citizen, Jerry Freid, became the insured under a $4 million life insurance policy in 2008, with the policy owned by a trust naming his daughter as beneficiary. The transaction was orchestrated by Michael Binday, whose business solicited seniors to take out life insurance policies for third-party investors through premium financing schemes. These arrangements typically ensured that neither the insured nor their estate bore financial risk, and the policies were ultimately acquired by investors after a contestability period. In Freid’s case, all premiums were financed and the trust sold the policy to an investor after two years. Evidence established that Freid lacked both the means and legitimate reason to seek such a large policy, and that the representations made in the policy application regarding his finances and intent were false. After Freid’s death in 2020, Ameritas Life Insurance Corp., successor to the original issuer, refused to pay policy benefits to Vida Longevity Fund, which had purchased the policy and was represented by Wells Fargo as securities intermediary. Wells Fargo sued in the United States District Court for the District of Nebraska, alleging breach of contract and bad faith. The district court granted summary judgment for Ameritas, finding New Jersey law applied and that the policy was void as a stranger-originated life insurance (STOLI) policy, contrary to state law. The court concluded that because the policy was void ab initio, Ameritas owed no benefits. The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. It affirmed the district court’s decision, holding that New Jersey law governed the policy under Nebraska’s choice of law rules, and that the policy was void under New Jersey law as a STOLI transaction. The court determined that no genuine dispute of material fact existed and that summary judgment for Ameritas was proper. View "Wells Fargo Bank N.A. v. Ameritas Life Insurance Corp." on Justia Law

Iowans for Alternatives v. Mosiman

2026-07-30T07:31:02-08:00

In 2024, Iowa enacted legislation (HF 2677) prohibiting the manufacture and sale of electronic nicotine delivery systems (ENDS) that had not received marketing authorization from the United States Food and Drug Administration (FDA). The law required manufacturers to certify their compliance with federal premarket approval requirements or demonstrate that their products were pending FDA review. Several manufacturers, retailers, and consumers challenged the law, contending it was preempted by federal law, specifically the Family Smoking Prevention and Tobacco Control Act, and that it violated constitutional equal protection guarantees. The United States District Court for the Southern District of Iowa granted a preliminary injunction, halting enforcement of the law. The district court found that at least one plaintiff had standing, was likely to succeed on the merits of the preemption claim, and was not required to post a security bond. It dismissed claims against the Iowa Department of Revenue based on Eleventh Amendment immunity but allowed the case to proceed against the Director in her official capacity. The Department voluntarily stayed enforcement while the litigation continued. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s order. The Eighth Circuit held that at least one retailer plaintiff had Article III standing, as they plausibly alleged injury from the credible threat of enforcement. However, the appellate court concluded the plaintiffs were not likely to succeed on the merits of their preemption claim. The court determined that HF 2677 was not preempted by federal law, as it fell within the scope of the Tobacco Control Act’s savings clause, which permits state requirements relating to the sale and distribution of tobacco products. The Eighth Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Iowans for Alternatives v. Mosiman" on Justia Law

United States v. Owl

2026-07-30T07:31:01-08:00

The case concerns a defendant who was originally charged with felony murder and arson after a fatal fire in a cabin in Mandaree, North Dakota, which resulted in the death of one individual. The incident occurred after a bonfire gathering attended by the defendant, his wife, and two others. There was evidence of a dispute between the defendant and his wife, who hid in a vehicle to avoid him. The cabin burned down shortly thereafter. Forensic evidence linked gasoline to the fire, and reports included statements from the defendant’s wife that he had accused her of infidelity and intended to harm her. After an initial mistrial due to an evidentiary dispute, the defendant pleaded guilty to voluntary manslaughter as part of a plea agreement; the more severe charges were dismissed. Following the guilty plea, the United States District Court for the District of North Dakota conducted sentencing. The court declined to grant a two-level reduction for acceptance of responsibility under the sentencing guidelines, finding that the defendant had not genuinely accepted responsibility, as evidenced by his statements to the probation office denying involvement in the offense. The court adopted the advisory guideline range but determined it was inadequate, and imposed an upward variance to the statutory maximum sentence of fifteen years. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the sentence. The appellate court held that the district court did not clearly err in denying the reduction for acceptance of responsibility, nor did it abuse its discretion in considering reliable evidence outside the guilty plea for sentencing purposes. The Eighth Circuit further found no plain error or constitutional violation by the district court in basing the upward variance on facts not admitted in the plea, nor was the sentence substantively unreasonable. The judgment of the district court was affirmed. View "United States v. Owl" on Justia Law

Rennenger v. Aquawood, LLC

2026-07-30T07:31:01-08:00

Five individuals obtained over $1.8 million in workplace sexual harassment judgments against various related business entities and individuals. When these judgments went unpaid, they brought a civil suit under the Racketeer Influenced and Corrupt Organizations Act (RICO) against fifteen defendants, alleging a scheme to evade collection of the judgments. The plaintiffs claimed that the defendants orchestrated fraudulent asset transfers and used a sham consignment scheme involving false customs forms to prevent the plaintiffs from seizing assets to satisfy their judgments. Previously, the United States District Court for the Southern District of Iowa dismissed the plaintiffs’ RICO claims based on predicate acts of bankruptcy crimes, money laundering, and obstruction of justice, as well as their claim for declaratory relief regarding alter ego liability. However, the court allowed the RICO claims predicated on wire fraud related to the consignment scheme to proceed. After discovery, the defendants moved for summary judgment. The district court granted summary judgment for the defendants, holding that the plaintiffs failed to show proximate causation between the alleged wire fraud and their inability to collect on their judgments, and that they were not entitled to adverse inference sanctions for alleged discovery misconduct. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The Eighth Circuit held that the plaintiffs failed to establish that the consignment scheme was a but-for cause of their injury, as they did not show that any assets subject to seizure belonged to the judgment debtors. The court further concluded that claims based on other predicate offenses failed due to insufficient evidence and lack of particularity. The appellate court also found no error in the district court’s refusal to draw adverse inferences or to allow amendment of the complaints at this stage. The court affirmed summary judgment for all defendants on all claims. View "Rennenger v. Aquawood, LLC" on Justia Law

United States v. Dominquez

2026-07-30T07:30:59-08:00

Victor Dominquez was indicted on multiple charges, including aggravated sexual abuse of a minor in Indian country. The indictment specifically alleged that, between March 2006 and March 2012, Dominquez knowingly engaged in acts involving the penetration of the genital opening of a child under twelve years old, with an intent to arouse or gratify sexual desire. At trial, the minor victim, M.D., testified that Dominquez, while bathing her as a child, used his fingers to clean her vagina, describing sensations and experiences that the jury found credible and sufficient for conviction. Following the jury’s guilty verdict on all counts, the United States District Court for the District of South Dakota granted Dominquez’s motion for judgment of acquittal on the aggravated sexual abuse charge. The district court reasoned that, even when viewing the evidence in the light most favorable to the government, M.D.’s testimony was too ambiguous and nonspecific to prove beyond a reasonable doubt that Dominquez penetrated her genital opening, as required by statute. The court noted that clarifying questions might have elicited more explicit testimony but concluded it could not sustain a conviction based on suspicion or possibility. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s order de novo. The appellate court held that a rational jury could infer that M.D. used the ordinary anatomical meaning of “vagina” in her testimony, and that Dominquez’s actions described by M.D. necessarily involved penetration of the vaginal orifice. The court concluded that the evidence was sufficiently specific to support the verdict. Accordingly, the Eighth Circuit reversed the district court’s order granting judgment of acquittal, reinstating the jury’s finding of guilt. View "United States v. Dominquez" on Justia Law

Fayetteville Public Library v. Murray

2026-07-30T07:30:58-08:00

Arkansas enacted Act 372 in 2023, which criminalizes furnishing materials deemed “harmful to minors” and requires public libraries to adopt written policies for curating their collections and responding to challenges about appropriateness. Plaintiffs, including libraries, bookstores, and patrons, filed suit against Arkansas officials, alleging that these provisions violated the First Amendment due to overbreadth and the Fourteenth Amendment due to vagueness, before the act took effect. The United States District Court for the Western District of Arkansas granted summary judgment for the plaintiffs. The court permanently enjoined enforcement of both challenged sections, finding them unconstitutional as overbroad and void for vagueness, and awarded nearly $450,000 in attorney fees and costs. Defendants, including prosecuting attorneys and the Attorney General, appealed. The United States Court of Appeals for the Eighth Circuit reviewed the appeal de novo. The court found that the librarian and bookstore plaintiffs had standing to challenge the criminal provision, but patrons lacked standing regarding the library policy requirement, as no concrete injury was shown. The court determined the challenges to the criminal provision were ripe. On the merits, the court held that the criminal section was not unconstitutionally overbroad, as plaintiffs failed to provide evidence of substantial unconstitutional applications among third parties, and the record did not establish a lopsided ratio of impermissible to permissible applications. The court also held the provision was not void for vagueness because its language was commonly understood and included scienter requirements. Ultimately, the court reversed the district court’s judgment, vacated its permanent injunction, and vacated the award of attorney fees and costs. View "Fayetteville Public Library v. Murray" on Justia Law

Weems Industries, Inc. v. Teknor Apex Company

2026-07-30T07:30:57-08:00

Two companies manufacture and market water hoses. One company, after registering a trademark for the color chartreuse as applied to the body of its hoses, sued its competitor, claiming trademark infringement under the Lanham Act and related Iowa common law. The competitor responded by arguing that the chartreuse color was a functional feature, not eligible for trademark protection, and requested that the trademark registration be canceled and the claims dismissed. The United States District Court for the Northern District of Iowa held a bench trial and found in favor of the defendant. The court concluded that the chartreuse color served a functional purpose by making the hoses more visible and thus safer, which is a utilitarian advantage. The court also found that the color had not acquired the distinctiveness required for trademark protection, but determined that either ground was sufficient for cancellation. The district court canceled the trademark registration, dismissed all claims, and awarded the defendant more than three million dollars in attorneys’ fees, finding the case “exceptional” due to the plaintiff’s lack of candor before the USPTO, trial conduct, and continued misapplication of the functionality standard. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual finding of functionality for clear error and its award of attorneys' fees for abuse of discretion. The appellate court affirmed the district court’s determination that the chartreuse color was functional and thus unregistrable as a trademark. It also upheld the attorneys’ fees award, finding no abuse of discretion in the lower court’s assessment of the plaintiff’s conduct and the exceptional nature of the case. View "Weems Industries, Inc. v. Teknor Apex Company" on Justia Law

Knight v. Cambria Company, LLC

2026-07-28T07:01:10-08:00

Anthony Knight was employed by Cambria Company, LLC as a process engineering technician, primarily assisting with production line functionality. In late 2022, Knight’s father passed away, leading Knight to struggle with depression. He subsequently requested and was granted leave under the Family and Medical Leave Act (FMLA) from February to April 2023. In mid-March 2023, while Knight was on FMLA leave, Cambria terminated his employment, citing elimination of his position due to a reduction in force. Cambria stated that Knight was selected for termination because of his shorter period of employment compared to other employees, and his job responsibilities were shifted to other departments without hiring a replacement. Knight filed suit in the United States District Court for the District of Minnesota, alleging that Cambria discriminated against him and interfered with his FMLA entitlements. During discovery, Cambria asserted that the decision to terminate Knight was based solely on seniority and the need to reduce headcount due to production slowdowns. The district court granted summary judgment in favor of Cambria, finding that Knight had not produced sufficient evidence of discriminatory intent or pretext, and that Cambria provided legitimate, nondiscriminatory reasons for his termination. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The Eighth Circuit held that Knight failed to raise a genuine dispute as to whether Cambria’s stated reasons for termination were pretextual or connected to his FMLA leave. The court found that Cambria’s reduction in force and reliance on seniority were legitimate reasons, and Knight’s evidence did not show intentional discrimination or unlawful interference with FMLA rights. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "Knight v. Cambria Company, LLC" on Justia Law

United States v. Bogan

2026-07-28T07:01:09-08:00

The defendant, after joining a gang at age 14, participated in a drive-by shooting in Iowa that resulted in the death of a bystander. He was convicted by a state jury of first-degree murder, but the conviction was reversed on appeal. He subsequently pleaded guilty to voluntary manslaughter and related charges and was sentenced to up to 25 years in state prison. Following his release in 2014, he was convicted of being a felon in possession of a firearm and later, after further criminal activity including high-speed chases and renewed gang involvement, conspired to distribute cocaine and participated in a shooting incident in 2020. Surveillance footage captured him firing a weapon, and he was later charged federally with RICO conspiracy and felon-in-possession offenses. The United States District Court for the Southern District of Iowa denied the defendant’s pretrial motions to dismiss the indictment. He had argued that the inclusion of his juvenile conduct in the RICO charge violated the Juvenile Delinquency Act (JDA), and challenged the constitutionality of the felon-in-possession statute under New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022). The district court rejected both arguments, and the defendant entered a conditional guilty plea, preserving his right to appeal the denial of his motions. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s rulings de novo. It held that post-majority ratification of a conspiracy allows pre-majority conduct to be considered as part of a federal RICO prosecution, making the JDA inapplicable in this context. The court also held that circuit precedent foreclosed the defendant’s Bruen-based challenge to the felon-in-possession statute. The Eighth Circuit affirmed the district court’s denial of the motions to dismiss. View "United States v. Bogan" on Justia Law

Goforth v. Transform Holdco, LLC

2026-07-28T07:01:08-08:00

Matthew Goforth, through MG Management Co., LLC, entered a dealer agreement with Sears Authorized Home Stores that included a broad non-compete provision, extending restrictions to his spouse, Malinda Goforth. After Matt decided not to renew the agreement, Sears suspected the Goforths would open a competing business and initiated arbitration, seeking to enforce the non-compete. The Goforths opposed enforcement, asserting the provision was unreasonable. The arbitrator initially denied emergency injunctive relief but later, upon learning that Matt and Malinda were opening Goforth Home & Lawn, granted interim relief enforcing the non-compete and added Malinda and her company as parties. A final arbitration award enforced the non-compete, but an appellate arbitrator later held the provision unenforceable while affirming attorneys’ fees to Sears. Subsequently, the Goforths initiated a second arbitration alleging antitrust violations, but the arbitrator determined their antitrust claims were compulsory counterclaims that should have been brought in the first arbitration. Following Sears’s bankruptcy, the Goforths brought an action in the United States District Court for the Western District of Missouri against Sears’s owners, Transform Holdco, LLC and affiliates, asserting the same antitrust claims. Transform moved for summary judgment, arguing the claims were compulsory counterclaims barred by their failure to raise them in the initial arbitration. The district court agreed, holding the claims accrued upon Sears’s initiation of the first arbitration and were thus subject to compulsory counterclaim rules. The court granted summary judgment for Transform and did not address alternative grounds or the Goforths’ partial summary judgment motion. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the Goforths’ antitrust claims accrued when Sears initiated the first arbitration, making them compulsory counterclaims under Federal Rule of Civil Procedure 13. The court also held that Malinda and her company were bound by the agreement’s arbitration provision. View "Goforth v. Transform Holdco, LLC" on Justia Law

United States v. Longie

2026-07-28T07:01:07-08:00

In this case, the defendant had previously pleaded guilty in Minnesota state court to a serious sexual offense, which required him to register as a sex offender under both state law and the federal Sex Offender Registration and Notification Act (SORNA). After his release in 2022, he indicated in Minnesota that he would reside at a local shelter, but was homeless when the shelter had no space for him. He expressed interest in moving to another state for employment, and was advised that he must provide specific information and obtain approval before relocating. He registered as living in Moorhead, Minnesota at the end of June 2022, but soon after left the state without proper authorization, spent time in North Dakota, and eventually resided in South Dakota with his mother without registering in either state. For over 600 days, he failed to comply with SORNA’s registration requirements. The United States District Court for the District of South Dakota presided over his criminal trial after he was discovered living in South Dakota. The defendant sought to introduce an affirmative defense based on “uncontrollable circumstances” under 18 U.S.C. § 2250(c), claiming that threats and harassment prevented him from registering. The district court excluded some testimony from the defendant and his mother concerning alleged threats and mistreatment, and refused to instruct the jury on the uncontrollable circumstances defense, concluding there was insufficient evidence to support it. The jury convicted the defendant, who was then sentenced to 45 months’ imprisonment. The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that there was no abuse of discretion in excluding the testimony and that, even when viewed favorably to the defendant, the evidence did not establish the statutory elements of the uncontrollable circumstances defense. Therefore, the district court’s refusal to instruct the jury on this defense was proper. View "United States v. Longie" on Justia Law

United States v. Striplin

2026-07-28T07:01:06-08:00

Benjamin Striplin was apprehended after leading police on a high-speed chase that ended with his arrest. During a search of his vehicle, officers found a loaded pistol and a makeshift device used for smoking methamphetamine. Striplin admitted to regularly using methamphetamine and to owning the firearm at the time of his arrest. Based on these admissions, a grand jury charged him with possessing a firearm as an unlawful user of a controlled substance, in violation of federal law. Before trial, Striplin moved to dismiss the indictment, arguing that the statute under which he was charged violated the Second Amendment and was unconstitutionally vague, both on its face and as applied to him. A magistrate judge recommended denial of the motion, reasoning that historical firearm regulations supported restrictions on possession by certain categories of persons, and concluded that vagueness challenges could not be resolved until trial. The United States District Court for the Western District of Missouri adopted these recommendations, denied the motion to dismiss, and later found Striplin guilty at a bench trial based on stipulated facts. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to dismiss. The appellate court rejected Striplin’s vagueness challenge, finding the statute clear as applied to someone who admitted to regular drug use contemporaneous with firearm possession. However, regarding the Second Amendment claim, the Eighth Circuit noted that recent case law requires a fact-specific analysis to determine whether the application of the statute aligns with historical firearm regulation traditions. Because the district court did not conduct this analysis, the appellate court reversed the district court’s judgment and remanded the case for further proceedings consistent with current legal standards. View "United States v. Striplin" on Justia Law

Jones v. City of St. Louis, Missouri

2026-07-27T07:01:12-08:00

Four pretrial detainees housed at a St. Louis correctional facility brought claims under 42 U.S.C. § 1983 against several correctional officers, alleging excessive use of force in violation of their Fourteenth Amendment due process rights. The detainees asserted that officers acted unreasonably by deploying mace against them during several incidents. They also sued the City of St. Louis under § 1983, raising Monell claims for excessive force and unlawful conditions of confinement related to the use of mace and deprivation of water. Additionally, two detainees brought claims under the Americans with Disabilities Act (ADA) against the City for failure to accommodate their medical conditions. The United States District Court for the Eastern District of Missouri denied summary judgment on all claims, rejecting the officers’ and City’s assertion of qualified immunity. The defendants appealed, challenging the denial of qualified immunity and seeking review of the Monell and ADA claims. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of summary judgment de novo and determined that the district court did not conduct a proper individualized qualified immunity analysis for each officer. The appellate court conducted its own individualized analysis, affirming the denial of qualified immunity for some claims—specifically, for certain uses of mace against restrained and non-resisting detainees by Lieutenant Fowlkes, and against Lieutenant Richard for excessive force. The court reversed the denial of qualified immunity as to other officers and incidents where the use of force was found reasonable or where the officers lacked personal involvement. The court dismissed the City’s appeal of the Monell and ADA claims for lack of jurisdiction, as those claims were not inextricably intertwined with the qualified immunity analysis. The disposition was to affirm in part, reverse in part, remand for further proceedings, and dismiss in part. View "Jones v. City of St. Louis, Missouri" on Justia Law

Joseph v. Thomas-Grace Const. Inc.

2026-07-24T07:31:09-08:00

Becky Joseph was employed as a Lead Installer by a Minnesota-based construction company. After being hired, she worked on projects in Nevada and experienced conflicts with several supervisors. Joseph frequently complained to management about being disrespected and not having her opinions valued, and at one point threatened to resign, but later withdrew her resignation. She was involved in a minor workplace accident and had an incident with hotel staff during a company-provided stay. After further complaints about her supervisors, Joseph alleged that the men at the company were treated as more valuable than women and referenced discrimination. The company investigated her complaints but found no substantiating evidence. Joseph was then offered a transfer to another jobsite, which she declined, choosing instead to resign. Joseph subsequently filed suit in the United States District Court for the Western District of Michigan, alleging sex discrimination and retaliation in violation of Title VII of the Civil Rights Act and Michigan’s Elliott-Larsen Civil Rights Act. The case was transferred to the District of Minnesota, where the district court granted summary judgment for the employer. The district court found that Joseph’s complaints did not mention sex discrimination until after the events in question, that there was no evidence linking the employer’s actions to discriminatory animus, and that her claims were not supported by any documentary evidence. The court also determined that Joseph’s complaints did not amount to protected activity under the retaliation statutes. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed. The court held that Joseph failed to provide direct evidence or sufficient facts to support a prima facie case of discrimination or retaliation. The court determined the employer had legitimate, non-discriminatory reasons for its actions and that Joseph had not shown those reasons were pretextual. The judgment of the district court was affirmed. View "Joseph v. Thomas-Grace Const. Inc." on Justia Law

Audette v. Lake of the Woods County

2026-07-24T07:31:08-08:00

Robert and Jennifer Audette purchased a lakefront property in Minnesota and constructed a 12-foot-wide concrete ramp from their home to the lake’s ordinary high-water mark without first obtaining approval from Lake of the Woods County. County officials had previously advised them about permissible improvements, including limitations on new concrete and the importance of staying within existing fill, but the Audettes exceeded these instructions. Subsequent inspections revealed substantial wetland impacts, and the County issued restoration orders and identified violations of both zoning ordinances and a state-funded shoreline stabilization project. After the ramp was constructed, the Audettes sought an after-the-fact conditional use permit, citing the need for handicap accessibility for Jennifer Audette, who has multiple sclerosis. The Lake of the Woods County Planning Commission recommended approval with conditions, but the Lake of the Woods County Board denied the permit, emphasizing environmental concerns, procedural violations, and the availability of less impactful alternatives. The Audettes then applied for approval under the Wetland Conservation Act, which was also denied by the County and, upon appeal, by the Minnesota Board of Water and Soil Resources. The Minnesota Department of Natural Resources later cited the Audettes for failure to comply with restoration orders. The Audettes filed suit in the United States District Court for the District of Minnesota, alleging discrimination under Title II of the Americans with Disabilities Act due to denial of their permit application. The district court granted summary judgment for the County, finding the Audettes had not timely requested an accommodation and had violated County instructions. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment de novo and affirmed. The Eighth Circuit held that the County did not violate ADA accommodation duties, as the Audettes never sought a reasonable accommodation at the appropriate time and provided no evidence of intentional discrimination. View "Audette v. Lake of the Woods County" on Justia Law

RMS v. Commerce Bank

2026-07-23T07:31:02-08:00

A technology company developed a healthcare revenue management software platform and, in 2014, licensed a white-labeled version to a bank. The bank branded this software as its own and used it to provide services to its customers. The licensing agreement gave the bank access to confidential software and data, while prohibiting reverse engineering, copying, or creating derivative works. In 2018, the bank began developing its own software that performed similar functions. The technology company later noticed a decline in users of its platform and suspected the bank had breached the contract by reverse engineering and copying its software. The company then sought a preliminary injunction to stop the bank from using its new platform and from misusing the information gained through the contract. The United States District Court for the Western District of Missouri reviewed the request for a preliminary injunction. The district court found that the technology company failed to show that it would suffer irreparable harm absent injunctive relief, ruling that any potential financial losses could be compensated with money damages and that claims of reputational harm were too speculative. The court also determined that the contract’s clause permitting injunctive relief was not, by itself, sufficient to require an injunction. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that the district court did not clearly err in finding the alleged harms compensable with money damages or too speculative, nor did it abuse its discretion by giving limited weight to the contract’s injunctive relief provision. The court emphasized that failure to demonstrate likely irreparable harm is, by itself, a sufficient ground to deny a preliminary injunction. Accordingly, the denial of the preliminary injunction was affirmed. View "RMS v. Commerce Bank" on Justia Law

United States v. Berry

2026-07-23T07:31:01-08:00

Authorities began investigating after receiving a Suspicious Activity Report concerning the defendant’s large-scale firearm purchases. Between 2018 and 2024, he acquired over 180 firearms from licensed dealers in Arkansas, and thirteen of those weapons were later found at crime scenes. A search of his home and vehicle uncovered more than 100 firearms, price tags totaling over $30,000, and evidence suggesting auction sales, including checks indicating proceeds of nearly $54,000 from a gun auction. The defendant was indicted on allegations of unlicensed dealing, but ultimately pled guilty to making a false statement in acquiring a firearm by denying marijuana use. The United States District Court for the Western District of Arkansas accepted the plea, adopted the Presentence Investigation Report, and calculated a Sentencing Guidelines range of 57 to 71 months’ imprisonment. The court imposed a below-Guidelines sentence of 48 months’ imprisonment and three years of supervised release. The defendant appealed, arguing that the court relied on clearly erroneous facts by treating him as a commercial firearms dealer rather than a hobbyist, and that it gave improper weight to this finding, resulting in a procedurally and substantively unreasonable sentence. The United States Court of Appeals for the Eighth Circuit reviewed the case for both procedural error and substantive reasonableness. It determined that the district court had not made any clearly erroneous factual findings, noting that the evidence supported the conclusion that the defendant was engaged in the business of dealing firearms. The appellate court also found that the district court did not abuse its discretion in weighing sentencing factors, particularly given the below-Guidelines sentence. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Berry" on Justia Law

La Belle Dairy, LLC v. Sharpe Holdings, Inc.

2026-07-23T07:31:00-08:00

A dairy operator in Northeast Missouri leased thousands of acres of adjacent forage land from a landowner to grow feed for its cattle and manage waste under regulatory requirements. The lease included provisions for renewal at a market rental rate and an agreement for the eventual sale of the leased and surrounding acreage to the dairy, with fair market value to be established by appraisal if necessary. The dairy alleged that the landowner breached the lease by unilaterally raising rent, demanding an unfavorable addendum, and refusing to complete the agreed land sales, while the landowner asserted that the dairy breached by not signing the addendum and threatened eviction. The United States District Court for the Eastern District of Missouri granted the dairy’s request for injunctive relief, enjoining the landowner from evicting or otherwise interfering with the dairy’s possession of the leased land. The landowner appealed, arguing lack of adequate notice and opportunity to be heard, as well as contesting the enforceability of the lease and the propriety of the injunction. The United States Court of Appeals for the Eighth Circuit first determined it had jurisdiction, treating the lower court order as a preliminary injunction rather than a temporary restraining order, based on its duration and effect. The appellate court held that the landowner waived or forfeited its due process objections by not raising them below. On the merits, the court found the dairy had a fair chance of prevailing on its contract claims, including the enforceability of the land-sale provision and compliance with notice requirements. The court further concluded that the dairy faced irreparable harm due to threatened loss of unique land, that the balance of harms favored the dairy, and that the public interest did not weigh against the injunction. The Eighth Circuit affirmed the district court’s issuance of the preliminary injunction. View "La Belle Dairy, LLC v. Sharpe Holdings, Inc." on Justia Law

Elsharkawy v. Chisago Lakes Board of Education

2026-07-21T07:01:32-08:00

A high school student with multiple health and learning disabilities attended public school in the Chisago Lakes School District. He was provided with an individualized education plan (IEP) and various accommodations, including homebound instruction at times. Despite efforts by the school and his mother to address attendance, behavioral, and peer issues, the student experienced ongoing absenteeism, disciplinary incidents, and some incidents of bullying. The school responded to reported bullying by disciplining offenders and adjusting supervision. The student’s mother raised concerns about the school’s implementation of his IEP and its disciplinary practices. In the months leading up to his death by suicide, the student’s academic and social situation fluctuated, but there was no indication that the school was aware of a suicide risk. The United States District Court for the District of Minnesota granted summary judgment to the school district and individual defendants on the mother’s claims under the Rehabilitation Act, the Americans with Disabilities Act (ADA), and Minnesota’s wrongful death statute. The court found that there was no genuine dispute of material fact regarding whether the district was deliberately indifferent to the student’s disability or failed to address bullying or IEP requirements. The court also concluded that the school district did not owe a special duty to prevent the student’s suicide because it was not reasonably foreseeable under the circumstances. The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eighth Circuit held that the record did not support a finding of deliberate indifference under the Rehabilitation Act or the ADA. It also held that, under Minnesota law, the facts did not establish that the school district or its employees could have reasonably foreseen the student’s suicide or owed a heightened duty to prevent it. Accordingly, summary judgment in favor of the defendants was affirmed. View "Elsharkawy v. Chisago Lakes Board of Education" on Justia Law

United States v. Wako

2026-07-20T07:31:01-08:00

Police officers in Sioux Falls, South Dakota, attempted to stop a vehicle reported as stolen. The driver, later identified as Boru Wako, Jr., fled on foot after officers approached the parked vehicle. Upon searching the vehicle, officers discovered a handgun in the driver’s side door and a machete on the seat. DNA testing linked Wako to the firearm. He was indicted for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1) and for illegal receipt of a firearm by a person under indictment under 18 U.S.C. § 922(n). The United States District Court for the District of South Dakota denied Wako’s pretrial motions to dismiss both counts. For the § 922(g)(1) count, the court found that a previous guilty verdict for eluding police qualified Wako as a felon, making him subject to the statute. For the § 922(n) count, the court rejected Wako’s facial constitutional challenge but held his as-applied challenge in abeyance pending factual development at trial. After the jury found Wako guilty on both counts, the district court sentenced him to 84 months in prison, following an upward departure and variance. On appeal, the United States Court of Appeals for the Eighth Circuit held that the district court did not err in denying Wako’s challenge to the § 922(g)(1) count, reaffirming that Supreme Court precedent did not require individualized analysis for each felony under that statute. However, the appellate court found the district court erred by failing to revisit and resolve Wako’s as-applied challenge to § 922(n) after trial. The Eighth Circuit therefore reversed the denial of the motion to dismiss the § 922(n) count as applied to Wako and remanded the case for further proceedings, directing the district court to make the necessary factual findings. View "United States v. Wako" on Justia Law

United States v. Reis

2026-07-20T07:30:59-08:00

Michael Reis was involved in two separate criminal incidents. In the first, he sold a counterfeit oxycodone pill containing fentanyl to Paris Hunt, who later discovered her four-year-old son unresponsive after the child apparently ingested part of the pill. The child died from fentanyl toxicity. In the second incident, a fifteen-year-old girl identified as MV1 reported that Reis trafficked her for sex. Law enforcement found evidence linking Reis to commercial sex advertisements involving MV1, communications showing he arranged for her to engage in sex acts for money, and Reis’s own admission that he suspected MV1 was a minor and had profited from her prostitution. The United States District Court for the District of Nebraska presided over both cases. Reis was convicted by a jury of conspiracy to distribute fentanyl resulting in death and pleaded guilty to sex trafficking of a minor. The district court consolidated the cases for sentencing, applied enhancements for targeting a vulnerable victim, and found Reis had not accepted responsibility for the combined offenses. It imposed concurrent life sentences. On appeal to the United States Court of Appeals for the Eighth Circuit, Reis challenged the sufficiency of the evidence supporting his drug conspiracy conviction, the calculation of the sentencing guidelines (including the denial of an acceptance-of-responsibility reduction and the vulnerable victim enhancement), and the substantive reasonableness of his life sentences. The Eighth Circuit held that sufficient evidence supported the jury’s finding that the fentanyl distributed by Reis was the but-for or independently sufficient cause of the child’s death. The court also found no clear error in the district court’s application of the sentencing guidelines, including its denial of a reduction for acceptance of responsibility and its application of the vulnerable victim enhancement. The Eighth Circuit concluded that the life sentences were reasonable and affirmed the district court’s judgments. View "United States v. Reis" on Justia Law

G.T. v. Liberty Mutual Fire Insurance Company

2026-07-17T07:01:10-08:00

After enduring physical and sexual abuse while in the care of James and Susan McLaurie as a young child, the plaintiff obtained a $150 million judgment against both individuals in Missouri state court. Seeking to collect on this judgment, the plaintiff subsequently filed a new action in state court against the McLauries and their homeowner’s insurer, Liberty Mutual, asserting equitable garnishment claims against all three and additional claims, including bad faith and breach of contract, against Liberty Mutual. Liberty Mutual removed the action to the United States District Court for the Eastern District of Missouri, invoking diversity jurisdiction. At the time of removal, James McLaurie had not yet been served but later entered an appearance. The plaintiff moved to remand, arguing a lack of complete diversity, and James McLaurie joined this motion, expressly refusing to consent to removal. The district court disagreed that diversity was lacking but found that the absence of consent from all defendants rendered removal procedurally defective under the requirement of unanimity in 28 U.S.C. § 1446(b)(2)(A). The court granted remand on this procedural ground. On appeal, the United States Court of Appeals for the Eighth Circuit examined whether it had jurisdiction to review the district court’s remand order. The appellate court held that, under 28 U.S.C. § 1447(d), remand orders based on procedural defects—such as a lack of unanimity among defendants—are not reviewable, so long as the district court’s basis was at least “colorably” procedural. The court determined that the district court’s characterization of its order as resting on a procedural defect was colorable. Accordingly, the Eighth Circuit dismissed the appeal for lack of jurisdiction. View "G.T. v. Liberty Mutual Fire Insurance Company" on Justia Law

United States v. Denby

2026-07-17T07:01:09-08:00

After receiving reports that Tyler Denby threatened several individuals in Alliance, Nebraska, law enforcement located him sitting in his vehicle. Upon observing a marijuana pipe in his pocket, officers searched Denby and his vehicle, finding various electronic devices, children’s items, and a collection of girls’ underwear. This discovery led investigators to obtain a warrant to search Denby’s SD cards, which contained child pornography. Denby subsequently confessed to possessing and transporting child pornography across state lines. The United States District Court for the District of Nebraska presided over Denby’s trial. Denby moved to suppress the evidence from his vehicle and his confessions, but the court denied the motion. He also sought to reopen the suppression hearing based on new evidence, which was denied as untimely and futile by a magistrate judge. Denby filed motions in limine to exclude certain evidence, which the court granted in part and denied in part. A jury convicted Denby of transporting and possessing prepubescent child pornography, and the district court sentenced him to 262 months’ imprisonment. On appeal, the United States Court of Appeals for the Eighth Circuit addressed Denby’s claims regarding his competency, the suppression motion, evidentiary rulings, and the reasonableness of his sentence. The court held that the district court did not abuse its discretion by not ordering a competency evaluation or by admitting certain evidence, including the girls’ underwear, for non-propensity purposes under Rule 404(b)(2). The appellate court found no error in denying suppression or reopening the hearing and concluded that the sentence was substantively reasonable. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Denby" on Justia Law

United States v. Mendez

2026-07-15T07:01:19-08:00

In August 2020, Joshua Brooks, accompanied by several friends, went to confront a family in Fargo, North Dakota, believing they had stolen from him. One member of the group, Jesse Burnett, fired a gun at the family, resulting in the death of a man. The investigation into the shooting stalled until 2022, when Andeus Smith, involved in a separate federal firearms case, provided information that reopened the case and led to Brooks’s arrest on state murder charges. Brooks agreed to cooperate with federal and state law enforcement, providing details that led to Burnett’s arrest. Both Brooks and Burnett were subsequently held at the Cass County Jail, where Shaquiel Mendez was also incarcerated. Mendez, who interacted with both Brooks and Burnett, facilitated the sharing of discovery materials within the jail. After receiving these materials, Brooks was confronted and assaulted by another inmate, Daniel Cisse, while Mendez and others acted as lookouts. Following these events, Mendez was indicted in the United States District Court for the District of North Dakota on one count of conspiracy to tamper with a witness, in violation of 18 U.S.C. § 1512(k). A jury found Mendez guilty. On appeal to the United States Court of Appeals for the Eighth Circuit, Mendez argued that the government had not provided sufficient evidence to establish the necessary federal nexus for conviction under the statute. The Eighth Circuit reviewed whether the government proved it was reasonably likely that Brooks would communicate with federal law enforcement officers regarding a federal offense, as required by § 1512(a)(2)(C), referencing the Supreme Court’s decision in Fowler v. United States. The court found that, given Brooks’s previous cooperation with federal authorities and the ongoing nature of the investigation, it was reasonably likely such communication would occur. Thus, the court affirmed Mendez’s conviction, concluding that the government had met its burden to establish the required federal nexus. View "United States v. Mendez" on Justia Law

United States v. Redmon

2026-07-14T07:31:01-08:00

The defendant pleaded guilty in 2016 to conspiring to distribute and possess with intent to distribute cocaine base and was sentenced to 292 months in prison, followed by eight years of supervised release. In January 2025, the President granted him executive clemency, resulting in his early release from prison in July 2025, at which point he began supervised release. The district court modified his supervised release conditions to require up to 120 days at a residential reentry center. Within two weeks of his release, he was terminated from the reentry center for violating rules and was later found to have violated another condition by traveling more than fifty miles from his residence without notifying his probation officer. He declined a modification offer, leading the Probation Office to initiate revocation proceedings. The United States District Court for the Western District of Missouri held a revocation hearing, found two Grade C violations, revoked his supervised release, and sentenced him to 14 months in prison, at the top of the recommended guidelines range, with additional supervised release to follow. The court reimposed the same employment and potential community service conditions as before. The defendant appealed, arguing that his revocation sentence improperly considered retributive factors barred by the Supreme Court’s decision in Esteras v. United States, and that the community service condition impermissibly authorized more than 400 hours without justification, contrary to circuit precedent. The United States Court of Appeals for the Eighth Circuit held that the district court did not violate Esteras because it did not rely on forbidden retributive considerations under 18 U.S.C. § 3553(a)(2)(A) in imposing the revocation sentence. The appellate court affirmed the sentence of imprisonment and revocation. However, it remanded the case for the district court to consider whether to modify the community service condition in light of policy guidance that generally limits such service to 400 hours and to provide an explanation for its decision. View "United States v. Redmon" on Justia Law

United States v. Baxter

2026-07-13T07:31:37-08:00

In this case, a man was involved in a fight between rival gangs in downtown Des Moines, Iowa. Law enforcement broke up the fight, but it resumed later, leading to a chase. During the pursuit, a bystander informed officers that the man had a gun. When confronted, he fled but was quickly apprehended. Officers found a loaded pistol and marijuana on him, and subsequent testing confirmed drug use. He was indicted for possessing a firearm as an unlawful drug user under federal law. Previously, the United States District Court for the Southern District of Iowa denied his motion to dismiss the indictment, in which he argued that the statute violated his Second Amendment rights and was unconstitutionally vague. He entered a conditional guilty plea, preserving his right to appeal. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s ruling on the vagueness issue but found the record insufficient to resolve the as-applied Second Amendment challenge, remanding for further proceedings. On remand, the district court held a bench trial on stipulated facts, found him guilty, conducted an evidentiary hearing, and again denied his motion to dismiss, concluding that the statute did not violate the Second Amendment as applied to him. The United States Court of Appeals for the Eighth Circuit reviewed the denial of the motion to dismiss de novo and affirmed. The court held that the government bears the burden of showing, by a preponderance of the evidence, that the application of the statute is consistent with this nation’s historical tradition of firearm regulation. The court concluded that the man’s conduct—chronic drug use, gang involvement, and aggressive behavior while armed—was sufficiently analogous to conduct historically prohibited under Founding-era “going armed to terrorize” laws. Thus, the statute was constitutional as applied to him, and the district court’s denial of the motion to dismiss was affirmed. View "United States v. Baxter" on Justia Law

Iron Workers STL Pension Fund v. Barnhart Crane & Rigging Co.

2026-07-13T07:31:36-08:00

Several local iron workers unions and their associated trust fund boards sued a Tennessee-based company, alleging that the company failed to make required contributions for work performed by its employees within the unions’ territorial jurisdiction. The plaintiffs claimed the company was obligated to make these contributions under collective bargaining agreements with the unions, and they sought to recover the amounts they alleged were owed, including interest and damages. The United States District Court for the Eastern District of Missouri handled the case. During discovery, the defendant company moved to exclude the testimony of the plaintiffs’ witness, Bradley Soderstrom, arguing he was an undisclosed expert and his damages calculations were speculative. The district court agreed, excluding Soderstrom’s expert opinions and associated audit reports because the plaintiffs had not disclosed him as an expert and his calculations relied on unsupported assumptions. The district court granted summary judgment in favor of the company on one claim after finding the company was not a party to the relevant agreement, and on the remaining claims due to lack of admissible evidence of damages. The court also awarded attorneys’ fees to the company but did not set an amount. Plaintiffs appealed, challenging the exclusion of Soderstrom’s testimony, the grant of summary judgment, and the award of attorneys’ fees. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s exclusion of Soderstrom’s testimony, noting that plaintiffs failed to contest the finding that his damages model was speculative. The appellate court also affirmed summary judgment for the company because plaintiffs had no admissible evidence of damages without Soderstrom’s expert analysis. The court dismissed the appeal regarding attorneys’ fees, finding it was not ripe since the district court had not yet determined the fee amount. View "Iron Workers STL Pension Fund v. Barnhart Crane & Rigging Co." on Justia Law

Lackie v. Noe

2026-07-13T07:31:35-08:00

Jackie Lackie owned property adjacent to Greers Ferry Lake, a federally managed lake in Arkansas. In January 2022, park rangers discovered sixty-nine trees had been cut down on government land between Lackie’s property and the lake. The Army Corps of Engineers identified Lackie as responsible, filed a notice of trespass, and sent Lackie a letter offering to settle the violation if he paid for the tree damage. The letter also indicated the Corps was recommending revocation of his shoreline use permit for a boat dock. Enclosed was a settlement agreement stating the parties intended to settle “all known disputes” regarding the public lands. Lackie signed the agreement and paid the requested sum, but the Corps subsequently revoked his shoreline use permit. Lackie challenged the revocation in the United States District Court for the Eastern District of Arkansas, seeking judicial review under the Administrative Procedure Act. He argued the Corps’s action breached the settlement agreement, which he contended had resolved all disputes, including the permit issue. The district court affirmed the Corps’s decision, reasoning that the letter accompanying the settlement made clear that the permit revocation was not resolved by the agreement, so the Corps did not violate the agreement by revoking the permit. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The court held that under the applicable federal common law, guided by Arkansas law, the unambiguous language of the settlement agreement encompassed “all known disputes,” including the dispute over Lackie’s permit. The Eighth Circuit concluded that the Corps’s revocation of Lackie’s permit contravened the settlement agreement and constituted unlawful agency action. The court reversed the district court’s judgment, remanding with instructions to set aside the Corps’s permit revocation. View "Lackie v. Noe" on Justia Law

United States v. Drayton

2026-07-13T07:31:35-08:00

On February 23, 2023, Cedar Rapids police, acting on information from a confidential informant, surveilled Robert Lee Drayton, Jr., who was suspected of packaging and distributing methamphetamine. Officers observed Drayton engage in several brief encounters consistent with drug transactions throughout the day. They conducted an initial traffic stop, discovering a firearm, MDMA pills, and methamphetamine, but did not detain Drayton. Later, after observing what appeared to be a delivery of a bag to Drayton’s vehicle, police initiated a second traffic stop after observing Drayton’s car hit the fog line multiple times and change lanes without signaling. During this stop, a canine unit alerted to the presence of drugs, leading to the discovery of a duffel bag containing several kilograms of methamphetamine and another firearm. Drayton was arrested, and subsequent searches of his home and cellphones yielded additional drugs, firearms, cash, and evidence of drug transactions. Drayton moved to suppress the evidence from the second stop, his stationhouse statements, the search of his home, and drug tests, arguing the stop lacked probable cause or reasonable suspicion and was unlawfully prolonged for the canine sniff. The United States Magistrate Judge for the Northern District of Iowa conducted an evidentiary hearing and recommended denial of the motion, finding the officers credible and concluding the stop and subsequent searches were constitutional. The United States District Court for the Northern District of Iowa adopted the recommendation, and Drayton entered a conditional guilty plea. The United States Court of Appeals for the Eighth Circuit affirmed. The court held that the second traffic stop was supported by reasonable suspicion based on Drayton’s observed driving and collective law enforcement knowledge of his suspected drug activity. The canine sniff did not unlawfully prolong the stop, and there was probable cause for the vehicle search. All challenged evidence was lawfully seized, and Drayton’s constitutional rights were not violated. View "United States v. Drayton" on Justia Law

United States v. Caster

2026-07-10T07:01:08-08:00

The defendant was charged with conspiracy to possess with intent to distribute and distribute 500 grams or more of methamphetamine, a violation of federal law. He entered into a written plea agreement, in which he acknowledged understanding the nature and elements of the charge, agreed he was guilty, and specifically waived his right to appeal except for limited circumstances. During the plea colloquy, the district court confirmed the defendant’s understanding of the plea and the appeal waiver, and reviewed the drug quantity at issue. The defendant and his counsel reserved the right to object to specific drug amounts attributable to him, but agreed there was a sufficient factual basis for the essential elements of the crime, including responsibility for at least 500 grams of methamphetamine. After entering his plea, and nearly a year later, the defendant moved to withdraw his guilty plea in the United States District Court for the District of North Dakota. He claimed that the court failed to establish an adequate factual basis for the drug quantity element, that he did not understand the nature of his offense, and that his plea was not voluntary. The district court denied the motion, finding that the record established an adequate factual basis for the drug quantity, that the defendant was aware of the nature of the offense, and that the plea was knowing and voluntary. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the defendant’s plea and appeal waiver were entered knowingly and voluntarily, and whether enforcing the waiver would result in a miscarriage of justice. The court held that the record showed the defendant understood the charge, including the drug quantity element, and knowingly and voluntarily entered his plea and waiver. The court found no grounds for applying the miscarriage-of-justice exception. As a result, the Eighth Circuit enforced the appeal waiver and dismissed the appeal. View "United States v. Caster" on Justia Law

United States v. Loggins

2026-07-10T07:01:07-08:00

Two individuals were convicted of armed robberies and related firearms offenses in separate incidents, resulting in lengthy prison sentences due to mandatory minimums under 18 U.S.C. § 924(c). Years after their sentencing, Congress passed the First Step Act of 2018, which reduced mandatory penalties for repeat § 924(c) violations, but did not make these changes retroactive. Both individuals argued that, had they been sentenced under the amended law, their sentences would be significantly shorter. They sought sentence reductions under the compassionate release statute, 18 U.S.C. § 3582(c)(1)(A), asserting that the disparity created by the nonretroactive change constituted “extraordinary and compelling reasons” for release. The United States District Court for the Northern District of Iowa and the United States District Court for the Southern District of Iowa both rejected these arguments, relying on the Eighth Circuit’s prior decision in United States v. Crandall, which held that nonretroactive sentencing changes do not qualify as extraordinary and compelling reasons for compassionate release. Although the United States Sentencing Commission subsequently amended its policy statement to allow consideration of nonretroactive legal changes in some circumstances, the district courts concluded that Crandall remained controlling law in the Eighth Circuit and that the Commission’s policy statement was inconsistent with the statute. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district courts’ decisions. The Eighth Circuit held that, in light of the Supreme Court’s recent decision in Rutherford v. United States, nonretroactive sentencing amendments—standing alone or in combination with other insufficient factors—cannot constitute “extraordinary and compelling reasons” to reduce a sentence under § 3582(c)(1)(A), even if the Sentencing Commission’s policy statement suggests otherwise. The court affirmed the orders denying compassionate release. View "United States v. Loggins" on Justia Law

Lower Brule Sioux Tribe v. U.S. Dept. of Interior

2026-07-09T07:01:15-08:00

The plaintiff, a federally recognized Indian tribe, entered into self-determination contracts with the federal government under the Tribally Controlled Schools Act (TCSA), receiving funds to operate tribal schools. From 2012 to 2019, the tribe used some of these funds for non-school tribal operations, resulting in unearned revenue deficits. After conducting annual audits as required, the Bureau of Indian Affairs (BIA) found, in reports covering fiscal years 2016, 2017, and 2018, that the tribe owed millions in disallowed costs. The government began recouping these sums by offsetting other federal payments to the tribe. Although each report notified the tribe of its right to administratively appeal the findings, the tribe did not file any timely administrative or judicial appeals regarding these determinations. The United States District Court for the District of South Dakota dismissed the tribe’s initial complaint as untimely, finding the claims barred by the one-year limitations period set by the Indian Self-Determination and Education Assistance Act (ISDEAA) and the Contract Disputes Act (CDA). The district court allowed the tribe to amend its complaint to assert an overcollection claim concerning the FY 2017 debt. The government moved for summary judgment on this claim, which the district court granted, concluding the tribe had not presented evidence or legal authority to support its position and that the claim was foreclosed by statutory finality rules. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s dismissal and grant of summary judgment. The Eighth Circuit held that the tribe’s failure to exhaust its administrative remedies and timely pursue judicial review deprived the courts of subject matter jurisdiction over its claims. The court also held that the government’s collection actions were lawful, since the BIA’s determinations became final and binding when not timely appealed, and rejected the tribe’s arguments regarding overcollection and technical assistance. View "Lower Brule Sioux Tribe v. U.S. Dept. of Interior" on Justia Law

United States v. Dat

2026-07-09T07:01:11-08:00

Police, acting on a tip that drugs and firearms were present and sold at a particular Omaha residence, began an investigation. They corroborated the tip by conducting a lawful search of the home’s trash, finding marijuana residue, a ziplock bag piece, and unfired bullets. This led to a search warrant, and a SWAT team later found drugs, firearms, and related paraphernalia in the home, which was occupied by Baling N. Dat, Dilang N. Dat, Jany Jock, and others. The police also discovered incriminating text messages, images, and search histories on the defendants’ phones, showing ongoing illegal possession and transfer of firearms. Each defendant was charged under various federal firearm and drug statutes. The United States District Court for the District of Nebraska denied Baling’s motions to suppress evidence from the search and for severance of his trial. The jury convicted Baling of drug and firearm offenses, Dilang of being a felon in possession, and Jock of unlawfully supplying a firearm to a felon. The district court sentenced each to prison and denied Dilang’s and Jock’s motions for acquittal. The district court also admitted summary phone evidence and gang-related testimony over defendants’ objections. The United States Court of Appeals for the Eighth Circuit reviewed the convictions and sentences. It held that the search warrant was supported by probable cause, the district court did not abuse its discretion in denying severance, and the summary phone evidence was properly admitted. The court found that the admission of co-conspirator statements and gang-related evidence was not erroneous or, where not properly objected to, did not amount to plain error. The evidence was sufficient to support the convictions. The sentences, including upward variances, were not substantively unreasonable, and the district court adequately explained its decisions. The Court of Appeals affirmed the judgments and sentences in all respects. View "United States v. Dat" on Justia Law

Murphy v. Continental Resources, Inc.

2026-07-08T07:31:06-08:00

The case concerns disputes between two groups of North Dakota surface landowners and an oil and gas company with rights to drill on their land. After the company gave statutory notice and commenced drilling, the landowners and the company were unable to reach an agreement on compensation for damages to the land, as required by North Dakota’s Oil and Gas Production Damage Compensation Act. Both sets of landowners, represented by the same law firm, filed separate lawsuits in federal court seeking compensation for damages. The cases involved substantial litigation over discovery, scheduling, expert witnesses, and attorneys’ fees, with mediation attempts failing. Eventually, the parties reached stipulated judgments settling the claims for monetary amounts. After settlement, the landowners sought attorneys’ fees under North Dakota law, submitting discounted requests and supporting invoices. The company objected, arguing that the requests were excessive given the simplicity of the dispute and raising concerns such as alleged excessive billing, duplicative work, and poor documentation. The company also requested an in-person hearing on the fee motions, which was denied. The United States District Court for the District of North Dakota applied the lodestar method to determine reasonable attorneys’ fees, starting with the actual fees incurred, then reducing the amounts based on factors such as poor documentation and litigation conduct. The court awarded the landowners more than they requested, after finding the hourly rates and the time expended reasonable, but applying a 10% reduction for documentation issues and delays. The court also denied the company’s motion for oral argument. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed. The court held that the district court did not abuse its discretion in its fee award calculations, its consideration of relevant factors, or in denying an oral argument. The court found that the district court’s approach and reductions were consistent with precedent and North Dakota law. View "Murphy v. Continental Resources, Inc." on Justia Law

United States v. Zephier

2026-07-07T07:01:24-08:00

The case centers on Ellery Zephier, Sr., who was charged with two counts of assault with a dangerous weapon, assault resulting in serious bodily injury, and kidnapping, all arising from conduct toward his ex-girlfriend, Kristy Selwyn, over several days in July 2024. The evidence included testimony from the victim, medical personnel verifying her injuries, and law enforcement officers who corroborated aspects of her account, including finding blood and bloodstained clothing at the scene. The government also presented evidence under Federal Rule of Evidence 404(b) regarding a 2023 incident in which Zephier allegedly assaulted and kidnapped another former girlfriend, Angelique Drapeau. The United States District Court for the District of South Dakota, presided over by Chief Judge Roberto A. Lange, conducted the trial. The district court excluded evidence relating to a 2022 incident with another woman, A.K., but ultimately admitted evidence of the 2023 incident with Drapeau, offering a limiting instruction to the jury. The court also restricted the defense’s cross-examination of Drapeau to prevent introduction of prejudicial and speculative testimony regarding A.K.’s death. The jury acquitted Zephier of assault with a dangerous weapon but convicted him of kidnapping and assault resulting in serious bodily injury. On appeal, Zephier challenged the district court’s admission of the 404(b) evidence, the limits placed on his cross-examination of Drapeau, and the sufficiency of the evidence for both convictions. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the Rule 404(b) evidence was properly admitted, the limitation on cross-examination did not violate the Sixth Amendment, and that sufficient evidence supported both the kidnapping and assault convictions. Thus, the convictions and sentences were upheld. View "United States v. Zephier" on Justia Law

Wilbur-Ellis Company v. Gompert

2026-07-07T07:01:21-08:00

Four former employees of an agricultural products and services company resigned and soon after began working for a competitor. The company alleged that these employees breached their duty of loyalty, misappropriated trade secrets in violation of federal and state law, and tortiously interfered with its business relationships. The employees were paid by both companies for a two-week period during the transition. In total, at least eleven employees moved from the plaintiff company to the competitor during the same period. After the company filed suit in the United States District Court for the District of Nebraska, several discovery disputes arose. The magistrate judge and the district court denied the company’s attempts to obtain discovery from the competitor before seeking discovery from the employees and found the company’s identification of trade secrets to be overly broad and nonspecific. The company’s subsequent motion to compel discovery from the employees was denied on procedural grounds for failing to follow court-ordered procedures, and the district court affirmed this decision. The company also unsuccessfully requested a stay of summary judgment, which the district court denied as untimely. On summary judgment, the district court dismissed most of the company’s claims, finding insufficient evidence to support the trade secrets, tortious interference, and most duty of loyalty claims, but allowed a limited claim regarding dual employment during the two-week period to proceed. The parties later stipulated to dismiss this remaining claim without prejudice. The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s orders in full. The appellate court held that the district court did not abuse its discretion in its discovery rulings or in denying a stay. It further held that summary judgment was properly granted for the employees on all claims due to the company’s failure to identify specific trade secrets, provide admissible evidence of breach, or substantiate tortious interference. View "Wilbur-Ellis Company v. Gompert" on Justia Law

Carnes v. Blehm

2026-07-07T07:01:21-08:00

The case centers on Keith Carnes, who was convicted of first-degree murder and armed criminal action for the killing of Larry White in Kansas City, Missouri, in 2005. The prosecution relied primarily on eyewitness testimony from Lorianne Morrow and Wendy Lockett, which conflicted with physical evidence. Carnes was sentenced to life in prison and served eighteen years. In 2022, the Supreme Court of Missouri granted Carnes habeas relief, finding the state had violated Brady v. Maryland by failing to disclose material evidence, and Carnes was released. The state dismissed the charges. Carnes subsequently filed a civil rights lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Western District of Missouri. He alleged that certain detectives and a prosecutor had violated his constitutional rights through the fabrication of evidence, suppression of exculpatory evidence, and a reckless investigation. He also brought claims for malicious prosecution and unlawful pretrial detention. The district court granted summary judgment for most defendants but denied summary judgment for Detectives Robert Blehm and Avery Williamson on the reckless investigation claim, and for Blehm on the suppression of evidence claim. Prosecutor Amy McGowan’s motion for summary judgment on qualified immunity, prosecutorial immunity, and official immunity was also denied. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment. The court held that a reasonable factfinder could determine the detectives acted recklessly by relying on witness testimony that contradicted physical evidence and by failing to pursue alternative suspects, thus violating Carnes’s right to fair criminal proceedings. It further held that Prosecutor McGowan was not entitled to absolute immunity or qualified immunity where a genuine dispute existed about whether she coerced a witness and suppressed evidence before probable cause. The court affirmed the district court’s denial of summary judgment. View "Carnes v. Blehm" on Justia Law

Miller-Fields v. Londregan

2026-07-07T07:01:19-08:00

Minnesota State Troopers stopped Ricky Cobb, II during the early morning hours for driving without headlights. Shortly after the stop, Trooper Seide learned Cobb was wanted for a felony violation of a protective order. Seide, along with Trooper Londregan and another officer, received instructions from the Ramsey County Sheriff’s Office to arrest Cobb. When the troopers attempted to take Cobb into custody, he refused to exit his vehicle and shifted his car into drive, causing the vehicle to move forward with one trooper partially inside. In response, Trooper Londregan shot Cobb, who then drove a short distance before his car was stopped by the troopers. Cobb was removed from the vehicle and died at the scene. The United States District Court for the District of Minnesota reviewed the case after Nyra Miller-Fields, representing Cobb’s estate, brought a lawsuit under 42 U.S.C. § 1983. The suit alleged that the troopers’ actions constituted an unreasonable seizure and excessive force in violation of the Fourth and Fourteenth Amendments. The district court considered body and dash camera evidence and granted the troopers’ motion to dismiss on the basis of qualified immunity, concluding that the troopers’ conduct did not violate clearly established constitutional rights. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The court held that the troopers had reasonable suspicion to extend the stop and probable cause for Cobb’s arrest based on the protective order violation. It further held that the use of deadly force by Trooper Londregan did not violate a clearly established constitutional right in the specific context of this case, given the immediate risk to officer safety. The Eighth Circuit concluded that the troopers were entitled to qualified immunity and affirmed the dismissal of the claims. View "Miller-Fields v. Londregan" on Justia Law

Compeer Financial, ACA v. Corp. Amer. Lending, Inc.

2026-07-06T07:30:57-08:00

Compeer, a group of federally chartered farm credit associations, entered into a master participation agreement with Corporate America Lending, Inc. (CAL), under which Compeer paid CAL $58 million in exchange for the right to receive all payments due on a set of agricultural loans CAL had originated to Famoso Hills Ranch in California. Under the agreement, CAL was to promptly remit any payments or proceeds received on these loans to Compeer. When Famoso refinanced its loans and paid off the balance to CAL, CAL failed to notify Compeer or transfer the payoff proceeds as required and instead concealed receipt of the funds and withheld them as a negotiation tactic, eventually claiming a right to offset based on alleged damages suffered. Arbitration proceedings commenced, resulting in an award in favor of Compeer, finding it was unconditionally entitled to the payoff proceeds and that CAL had no legal basis to withhold them. The arbitration panel found for Compeer on its claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and unjust enrichment. Compeer moved in the United States District Court for the District of Minnesota to confirm the award and appoint a receiver to secure the funds. The district court confirmed the arbitration award, finding it final and enforceable, and appointed a receiver due to CAL’s repeated noncompliance and attempts to dissipate the funds. CAL appealed, arguing the award was nonfinal, violated public policy, and the receivership was improper due to a forum-selection clause and lack of necessity. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The court held that the arbitration award was final and confirmable, the public policy exception to vacatur under the Federal Arbitration Act did not require setting aside the award given the alternative equitable bases for Compeer’s recovery, and the district court acted within its discretion in appointing a receiver due to CAL’s conduct and the inadequacy of alternative remedies. View "Compeer Financial, ACA v. Corp. Amer. Lending, Inc." on Justia Law

McInnis v. Bolin

2026-07-02T07:30:58-08:00

Jquan Leearthur McInnis, then a juvenile, shot and killed Gustav Christianson and an infant, J.R., by firing seven shots into a car in downtown Minneapolis. Evidence gathered by investigators included statements made by McInnis to associates and forensic evidence showing the sequence of shots. After being apprehended and advised of his Miranda rights, McInnis initially denied involvement but eventually confessed to the shootings after invoking his right to remain silent. He maintained that he did not intend to kill Christianson and was unaware of the infant’s presence. The case was tried in a Minnesota state court, where McInnis moved to suppress his confession, arguing it was obtained after he had invoked his Fifth Amendment rights. The trial court denied the motion, concluding that McInnis had not unequivocally invoked his right to remain silent. The trial proceeded on stipulated evidence, including the confession, and McInnis was convicted of two counts of first-degree murder and sentenced to two consecutive life terms with the possibility of parole. On appeal, the Minnesota Supreme Court agreed that the confession should have been suppressed but determined that its admission was harmless beyond a reasonable doubt, given the other overwhelming evidence of guilt. McInnis then sought a writ of habeas corpus from the United States District Court for the District of Minnesota, arguing that the Minnesota Supreme Court unreasonably applied federal law on harmless error. The district court denied relief but granted a certificate of appealability on the harmless error issue. On appeal, the United States Court of Appeals for the Eighth Circuit held that McInnis failed to show that the Minnesota Supreme Court’s harmless error determination was contrary to or an unreasonable application of clearly established federal law. The Eighth Circuit affirmed the district court’s denial of the habeas petition. View "McInnis v. Bolin" on Justia Law

United States v. I-44 Truck Cntr & Wrecker Svc

2026-07-01T07:31:07-08:00

The defendant operated a trucking and towing business with a facility in Rolla, Missouri, where the Occupational Safety and Health Administration (OSHA) conducted inspections and issued two citations for safety violations in June and October 2017. The first citation imposed a penalty of $5,541 and the second a penalty of $65,184 for failure to abate a prior violation. The defendant did not respond or pay either penalty, causing both citations to become final orders. After the penalties remained unpaid for more than 180 days, OSHA referred the debts to the Department of Treasury, which then referred them to private collection agencies and ultimately to the Department of Justice. Two demand letters were sent to the defendant in March 2022 seeking payment. In January 2023, the government filed suit under the Debt Collection Improvement Act (DCIA) to collect the debts, which had accrued to $124,567.78. The United States District Court for the Eastern District of Missouri denied the defendant’s motion to dismiss, reasoning that the statute of limitations found in 28 U.S.C. § 2462 did not apply to collection actions under the DCIA. The court struck the defendant’s notice defense and granted summary judgment to the government. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to dismiss de novo. The appellate court held that § 2462’s five-year statute of limitations does apply to government actions seeking to collect civil penalties, even when proceeding under the DCIA. Because the penalties were punitive in nature and the government’s collection action was filed more than five years after the penalties became final orders, the action was time-barred. The Eighth Circuit reversed the district court’s judgment and remanded with instructions to dismiss the government’s collection action. View "United States v. I-44 Truck Cntr & Wrecker Svc" on Justia Law

Novartis Pharmaceuticals Corp. v. Hanaway

2026-07-01T07:31:06-08:00

A pharmaceutical manufacturer participating in the federal 340B Drug Pricing Program challenged a Missouri law that prohibits manufacturers from restricting the delivery of discounted 340B drugs to contract pharmacies associated with covered entities. The manufacturer argued that its policy of limiting deliveries to only one contract pharmacy conflicted with Missouri’s statute, which requires delivery to all contract pharmacies designated by covered entities. The manufacturer sought declaratory and injunctive relief, claiming the Missouri statute violated the dormant Commerce Clause and was preempted by federal law. The United States District Court for the Western District of Missouri granted a motion to dismiss the manufacturer’s preemption claims, finding Missouri’s statute did not conflict with federal patent or drug exclusivity laws or the 340B Program, and that Eighth Circuit precedent foreclosed the field preemption argument. The court denied the motion to dismiss the dormant Commerce Clause claim, but ultimately denied the manufacturer’s motion for a preliminary injunction, concluding the manufacturer was unlikely to succeed on the merits of its claims, had not shown irreparable harm, and that the balance of equities and public interest weighed against preliminary relief. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of preliminary injunction under the abuse of discretion standard. The appellate court affirmed the district court’s decision, holding that the Missouri statute regulates only in-state delivery of 340B drugs and does not impermissibly control extraterritorial commerce, discriminate against interstate commerce, or impose excessive burdens in relation to local benefits. The court also found the manufacturer’s preemption claims foreclosed by Eighth Circuit precedent and concluded the statute is neither field nor conflict preempted. The district court’s denial of preliminary injunctive relief was affirmed. View "Novartis Pharmaceuticals Corp. v. Hanaway" on Justia Law

Osorio-Calderon v. Sandstone

2026-06-30T11:01:22-08:00

Jose Osorio-Calderon, a federal inmate sentenced for coercion and enticement of a minor, participated in recidivism reduction programs while incarcerated and earned significant time credits under the First Step Act (FSA). These credits advanced his projected release date and made him eligible for prerelease custody starting July 3, 2024. Osorio-Calderon initially sought placement in New York, but the United States Probation Office found his sister’s residence unsuitable. The Bureau of Prisons (BOP) then explored options in Puerto Rico but determined, due to local ordinances and proximity to schools and daycare centers, that residential reentry center placement was not feasible. Despite eligibility, Osorio-Calderon remains incarcerated after exhausting administrative remedies. The United States District Court for the District of Minnesota reviewed Osorio-Calderon's habeas petition, which sought to compel the BOP to transfer him to prerelease custody based on his earned time credits. A magistrate judge recommended granting the petition, reasoning that the FSA’s language required the transfer. However, the district court rejected that recommendation and dismissed the petition, holding that, despite the FSA’s mandatory language, it lacked jurisdiction to review BOP’s placement decisions due to statutory preclusion in 18 U.S.C. § 3621(b). The United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. It held that, although the FSA directs the BOP to transfer eligible prisoners to prerelease custody, Congress preserved the BOP’s broad discretion under § 3621(b) and expressly barred judicial review of placement decisions. The court affirmed the district court’s dismissal, concluding that Osorio-Calderon's petition sought relief that is not reviewable by any court, regardless of the FSA’s mandatory language. View "Osorio-Calderon v. Sandstone" on Justia Law

United States v. Crump

2026-06-30T07:01:12-08:00

The case involved an individual who served as general manager at a Minnesota-based telemarketing company engaged in a nationwide scheme to defraud individuals by misrepresenting magazine subscription renewals. The operation used deceptive scripts to induce customers to purchase new subscriptions under the guise of reducing costs or renewing existing ones. The defendant was responsible for overseeing day-to-day operations, managing lead lists, and coordinating with other telemarketing entities. Evidence included email exchanges, consumer complaints, and state investigations indicating awareness and active participation in the fraudulent scheme. Previously, the United States District Court for the District of Minnesota heard the case. The defendant was charged with conspiracy to commit mail fraud and wire fraud, among others, and challenged the sufficiency of evidence, jury instructions, and alleged discovery violations. The district court denied the defendant’s motions for acquittal and a new trial, finding sufficient evidence of participation in the fraud, rejecting arguments about script truthfulness, and concluding that any government discovery failures did not prejudice the defense. The United States Court of Appeals for the Eighth Circuit reviewed the conviction. The court applied de novo review to sufficiency of evidence claims and found that a rational jury could have convicted the defendant based on the evidence presented. The court held the district court’s jury instructions were consistent with precedent regarding materiality in fraud cases and found no abuse of discretion. Regarding discovery, the Eighth Circuit determined there was no violation of Rule 16 or Brady concerning emails, as they were not in the government’s possession or control and the defendant could have accessed them independently. The court also agreed that the undisclosed digital evidence was not material under Brady. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Crump" on Justia Law

United States v. Pineda

2026-06-30T07:01:12-08:00

Law enforcement arranged three controlled purchases of methamphetamine from Saul Pineda at his residence in Shakopee, Minnesota, between September and October 2022. Each transaction involved Pineda and a confidential informant. Following these buys, a search of Pineda’s property uncovered drug paraphernalia, a methamphetamine conversion lab, and approximately 31 pounds of methamphetamine buried in the yard. Pineda was indicted on multiple counts related to possession and distribution of methamphetamine. At trial, Pineda testified that he engaged in the drug sales because he was acting under threats to his life and the lives of his family members, originating from an alleged kidnapping and coercion by armed men in Mexico who later directed his actions in Minnesota. The United States District Court for the District of Minnesota heard the case. After Pineda’s testimony, the court considered whether to instruct the jury on the defense of duress. The district court declined to provide the instruction, finding that Pineda’s evidence did not establish an immediate, specific threat related to the charged offenses or the absence of reasonable legal alternatives, such as contacting law enforcement during the periods he was unmonitored. The jury subsequently found Pineda guilty on all counts. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the district court erred by not instructing the jury on duress. Applying de novo review to the sufficiency of the evidence for an affirmative defense, the appellate court held that Pineda’s evidence did not meet the requirements for a duress instruction, as the threats were not immediate or connected to the charged conduct and reasonable legal alternatives existed. The Eighth Circuit affirmed the district court’s refusal to instruct on duress and upheld Pineda’s convictions. View "United States v. Pineda" on Justia Law

Flowers v. Caremark PCS Health, LLC

2026-06-29T07:01:20-08:00

Kevin Flowers, a participant in an employee benefits plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), receives prescription drug benefits administered by Caremark, a pharmacy benefits manager. Flowers alleges that Caremark unjustly enriches itself by limiting maintenance prescription coverage to either CVS retail pharmacies or Caremark’s mail-order delivery service. He claims this violates Arkansas statutes requiring PBMs not to mandate home delivery and to provide reasonably adequate and accessible pharmacy networks, leading him and similarly situated individuals to pay out of pocket at local pharmacies. Reviewing the case, the United States District Court for the Western District of Arkansas granted Caremark’s motion to dismiss. The court determined that Flowers failed to plausibly plead a violation of the Mail Order Provision because Caremark did not require prescriptions to be filled solely through home delivery. Regarding the Network Adequacy Provision, the district court found that ERISA preempted the Arkansas requirements, particularly those imposing geographic coverage standards for pharmacy networks. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The court affirmed the district court’s ruling, holding that Flowers did not plausibly allege a violation of the Mail Order Provision. The court also concluded that the geographic coverage requirements imposed by Arkansas regulations under the Network Adequacy Provision are preempted by ERISA, as they force PBMs to tailor their networks in ways that interfere with nationally uniform plan administration and constitute an impermissible connection with ERISA plans. The court expressly left open whether the Network Adequacy Provision, without its implementing regulations, would also be preempted. The court affirmed the district court’s dismissal of Flowers’s claims. View "Flowers v. Caremark PCS Health, LLC" on Justia Law

Fraase v. Advantage Credit Bureau

2026-06-25T07:31:01-08:00

Austin Stuart Fraase applied for a full-time maintenance technician position with Fargo Parks District. During the hiring process, Fargo Parks ordered a background check from Advantage Credit Bureau, which incorrectly reported that Austin had a speeding conviction. In reality, the ticket belonged to his twin brother, Aaron Stuart Fraase. The criminal search section of the report listed the conviction, though the motor vehicle section showed a clean record. Fargo Parks’ human resources staff discussed the report with Austin and his supervisor, ultimately concluding that the ticket likely belonged to his brother. Austin was reassured that it would not affect his interview or hiring, and he accepted and began the job as scheduled. Advantage sent Austin notices of his right to dispute the report, but he chose instead to file suit under the Fair Credit Reporting Act. The United States District Court for the District of North Dakota granted summary judgment to Advantage. The court concluded that Advantage had used reasonable procedures by searching the official North Dakota Courts website with Austin’s identifying information and reporting the results, and that Austin suffered no damages as he was hired without delay or loss. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The Eighth Circuit held that Advantage’s reliance on the official court website as a reputable source was reasonable under the Fair Credit Reporting Act. The court found no evidence of systemic problems with the website or that Advantage failed to follow its own procedures. Thus, Advantage was not liable for the inaccurate report. The court did not address whether Austin suffered actual damages, as it found no violation of the statute. The district court's grant of summary judgment was affirmed. View "Fraase v. Advantage Credit Bureau" on Justia Law

T&T Management, Inc. v. Choice Hotels Int'l

2026-06-25T07:31:00-08:00

T&T Management, Inc. operated a Country Inn & Suites hotel in Port Orange, Florida, under a 15-year license agreement that restricted the franchisor and others from operating hotels using the Country Inn & Suites marks within a defined area. In 2016, Radisson acquired the Country brand, and in 2022, Choice Hotels International purchased the brand from Radisson, assuming all obligations under the license agreement. Prior to acquiring the Country brand, Choice had licensed Sunshine Fund Port Orange, LLC to operate a WoodSpring Suites hotel within the protected area. T&T argued that this violated its license agreement, which it claimed protected it from all competing branded hotels operated or licensed by Choice in the area, and that the agreement’s definition of “Marks” included the WoodSpring mark. T&T initially brought suit in Florida, but after procedural rulings, the case was transferred to the United States District Court for the District of Minnesota. After amending its complaint multiple times—including to reflect its sale of the Country-branded hotel—T&T alleged breach of contract, breach of the implied covenant of good faith and fair dealing, and tortious interference. The district court dismissed the third amended complaint for failure to state a claim and denied further leave to amend, finding no good cause for additional amendments. Before the United States Court of Appeals for the Eighth Circuit, T&T contended that the district court erred in interpreting the contract, dismissing its claims, and denying further amendment. The Eighth Circuit held that, under Florida law, the agreement unambiguously permitted Choice to license non-Country-branded hotels, such as WoodSpring Suites, within the protected area. It affirmed the dismissal of T&T’s breach of contract and good faith claims, and also found the tortious interference claims insufficient because T&T failed to allege a breach or a non-speculative business expectancy. The appellate court also upheld the denial of further leave to amend due to lack of diligence. The judgment of the district court was affirmed. View "T&T Management, Inc. v. Choice Hotels Int'l" on Justia Law

Nare v. Omaha Discovery Trust

2026-06-24T07:31:16-08:00

The plaintiffs, a Black family residing in Nebraska, visited the Kiewit Luminarium, an institution operated by Omaha Discovery Trust. They paid the full admission price for entry in February 2024. The Luminarium had a policy granting free admission to registered members of federally recognized Native American tribes and their household members. After learning of this policy, the plaintiffs sought a refund for their tickets, which was denied. They then filed suit, alleging that the policy constituted unlawful racial discrimination in violation of federal civil rights statutes and the Nebraska Consumer Protection Act. The United States District Court for the District of Nebraska reviewed the complaint after the defendant moved to dismiss. The district court granted the motion to dismiss on all claims. It reasoned that the Luminarium’s policy distinguished based on tribal membership, which is a political classification rather than a racial one. As a result, the court concluded the plaintiffs failed to state a claim for race discrimination under the relevant federal statutes and that their Nebraska Consumer Protection Act claim failed for the same reason. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The Eighth Circuit affirmed the district court’s judgment. The appellate court held that membership in a federally recognized tribe is a political classification, not a racial one, relying on Supreme Court and circuit precedent. The court determined the plaintiffs did not plead facts showing they were discriminated against because of their race. Because their claims under 42 U.S.C. §§ 2000a, 2000a-2, 1981, and 1982, as well as under the Nebraska Consumer Protection Act, all depended on a showing of racial discrimination, the Eighth Circuit affirmed dismissal of all claims. View "Nare v. Omaha Discovery Trust" on Justia Law

Euphoric, LLC v. 4128 Broadway, LLC

2026-06-24T07:31:15-08:00

A business entity, through its principal, attempted to lease a commercial property in Kansas City, Missouri, from the property owner’s company. Both parties signed a lease document; however, the space for the “Commencement Date” was left blank. After negotiations soured—particularly following concerns from neighboring business owners about the potential use and branding of the property—the landlord refused to provide the tenant with keys or possession. The tenant did not provide a requested business plan and, shortly thereafter, the landlord leased the property to a different tenant. The would-be tenant had already paid a security deposit and incurred expenses in anticipation of opening its business. The tenant company filed suit in the United States District Court for the Western District of Missouri, raising claims including breach of contract and racial discrimination. Several months later, after the property was re-leased, the tenant moved for a preliminary injunction and temporary restraining order to compel the landlord to grant possession. At the hearing, the tenant conceded its request for injunctive relief was based solely on the breach of contract claim. The district court denied both the motion for a preliminary injunction and a motion for reconsideration, finding the lease failed to satisfy Missouri’s statute of frauds because the commencement date—an essential term—was not included in the writing, and further finding the tenant failed to show irreparable harm. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s denial of both motions. The Eighth Circuit held that, under Missouri law, a lease for longer than one year must include all essential terms, including the commencement date, in a signed writing, and that parol evidence cannot supply missing essential terms. Because the lease lacked the commencement date, the tenant failed to show a likelihood of success on the merits, and failed to demonstrate irreparable harm. The court also found no abuse of discretion in denying reconsideration. View "Euphoric, LLC v. 4128 Broadway, LLC" on Justia Law

Dobbins v. Rollins

2026-06-24T07:31:12-08:00

Sara Dobbins worked for the U.S. Department of Agriculture (USDA) and experienced mental health issues related to domestic abuse, leading to accommodations at work such as flexible schedules and telework. After her supervisor retired, the USDA allowed her to continue with adjusted scheduling, but with new requirements. When Charles Parr became her supervisor in 2021, he restricted these accommodations due to her frequent unapproved absences and tardiness. Over four months, Dobbins accumulated over thirty “absent without leave” infractions. The USDA suspended her, and later terminated her employment. Dobbins filed an EEOC complaint alleging sex and disability discrimination, hostile work environment, failure to accommodate, and retaliation. The EEOC found no actionable harassment or discrimination. The United States District Court for the Western District of Missouri granted summary judgment in favor of the USDA, finding that Dobbins did not provide sufficient evidence of discrimination or harassment, and failed to exhaust administrative remedies for her failure to accommodate claim. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment order de novo. The appellate court agreed that Dobbins did not present direct or indirect evidence that her suspension or termination were motivated by discrimination based on sex or disability. The court found that her absences, not her disabilities, were the basis for the adverse actions, and that her comparator evidence was insufficient as the other employee was not similarly situated. The court further held that Dobbins’s hostile work environment claim failed because the conduct described was not sufficiently severe or pervasive, nor clearly linked to her disability. Additionally, her failure to accommodate claim was barred for failure to exhaust administrative remedies, and her sex discrimination and retaliation claims were waived because she did not contest them at summary judgment. The court affirmed the district court’s judgment. View "Dobbins v. Rollins" on Justia Law

Close v. City of Bellevue Iowa

2026-06-24T07:31:11-08:00

Angela Prichard endured months of harassment and stalking from her ex-husband, Christopher, including threats, vandalism, and surveillance. Despite multiple reports to police and both temporary and permanent restraining orders—each of which mandated Christopher’s arrest for violations—law enforcement officers did not take significant protective action. After a period away from her home, Angela returned despite warnings from the Chief of Police. A week later, Christopher fatally shot her. He was subsequently convicted of her murder. Angela’s family, including her sons, then sued the City of Bellevue and three police officers, alleging that the failure to protect Angela violated federal constitutional rights and Iowa law. The United States District Court for the Northern District of Iowa dismissed the complaint, determining that neither federal nor Iowa law created a duty for law enforcement to protect Angela from private violence under these circumstances. The court also denied the family’s post-judgment motion to amend their complaint, finding it was untimely and would have been futile because the proposed amendments did not present sufficient factual matter to plausibly state a claim. Reviewing the case, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The Eighth Circuit held that substantive due process under the United States Constitution does not impose an affirmative duty on the government to protect individuals from private violence, consistent with the Supreme Court’s decision in DeShaney v. Winnebago County Department of Social Services. The court also concluded that Iowa’s no-contact order statute does not create a private right of action against law enforcement for failing to enforce such orders. The court further rejected the family’s other state law claims, including those brought under the Iowa Slayer Statute and for intentional infliction of emotional distress, finding the facts alleged did not support those causes of action. The court found no abuse of discretion in denying leave to amend the complaint. View "Close v. City of Bellevue Iowa" on Justia Law

Bedford v. MO Dept of Social Services, Family Support Div.

2026-06-24T07:31:10-08:00

Several individuals who were non-custodial parents and owed more than $2,500 in child support had their driver’s licenses suspended by the Missouri Department of Social Services, Family Support Division (FSD), under a statutory scheme that, until 2023, did not require consideration of an individual’s ability to pay before suspending a license. The plaintiffs’ suspensions occurred in 2017 and 2018. Two plaintiffs’ suspensions were later stayed, and a third’s license was fully restored. They argued that the suspension policy violated their constitutional rights under the Fourteenth Amendment and the fundamental right to travel, seeking declaratory and injunctive relief and reinstatement of their licenses. The United States District Court for the Eastern District of Missouri first denied a preliminary injunction as moot and then partially dismissed the complaint. It rejected dismissal based on the Rooker-Feldman doctrine and Younger abstention, finding that plaintiffs’ claims were independent and no ongoing state proceeding existed. The court allowed only the procedural due process claim to proceed, dismissing other constitutional claims and claims against the governor. Later, the district court dismissed the case sua sponte for lack of subject matter jurisdiction, concluding that the plaintiffs lacked standing because their suspensions were stayed or lifted. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. It held that the plaintiffs lacked standing for declaratory relief because they did not allege ongoing or immediate injury, and their alleged harms were too speculative or unsupported. Any relief regarding Missouri’s prior statutory scheme was moot due to legislative amendments that now require consideration of ability to pay. The court affirmed the district court’s dismissal of the complaint for lack of subject matter jurisdiction and dismissed the appeal regarding the preliminary injunction as moot. View "Bedford v. MO Dept of Social Services, Family Support Div." on Justia Law

Wilansky v. Morton County, North Dakota

2026-06-24T07:31:09-08:00

During protests opposing the Dakota Access Pipeline in November 2016, Sophia Wilansky was severely injured when police fired an aerial warning munition that struck her arm. Earlier that night, officers had ordered Wilansky and another protester to disperse from a barricade on a closed bridge, warning that they would use less-lethal munitions if the order was ignored. When Wilansky and the other protester did not comply, officers fired various less-lethal munitions. After Wilansky began retreating, she was struck by the aerial munition, causing permanent injury to her left hand and forearm. Following the incident, Wilansky filed two lawsuits in the United States District Court for the District of North Dakota. She alleged, under 42 U.S.C. § 1983, that county and state officers used excessive force in violation of the Fourth and Fourteenth Amendments and that Morton County maintained unconstitutional policies or customs. During the litigation, the district court struck certain new allegations and defendants from one complaint and ordered Wilansky to file an amended complaint. Wilansky then filed a second lawsuit with additional allegations against the stricken defendants. The district court ultimately dismissed both cases with prejudice. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgments. The court held that Wilansky did not sufficiently plead that the officers’ actions amounted to a clearly established Fourth Amendment seizure, nor did her allegations meet the “shocks the conscience” standard required for a Fourteenth Amendment claim. The court further held that she failed to establish a pattern of unconstitutional conduct by Morton County as of the date of her injury. Finally, the Eighth Circuit concluded that the district court did not abuse its discretion in dismissing the claims with prejudice. View "Wilansky v. Morton County, North Dakota" on Justia Law

United States v. Lindsey

2026-06-17T07:30:59-08:00

A member of a drug-trafficking organization suspected his nephew of orchestrating a robbery at a stash house, resulting in the loss of millions in cocaine and cash. Believing it was an inside job, the organization’s leader arranged for a third party to have the nephew killed. The third party recruited the defendant and paid him $15,000 to carry out the murder. The defendant lured the victim to St. Louis, Missouri, where he shot him in a park and documented the act with a photograph. Investigators later recovered this photograph from a cell phone. The defendant was indicted for conspiracy to commit murder for hire and murder for hire. The United States District Court for the Eastern District of Missouri handled the trial. Before trial, the Government requested that the defendant be placed in leg restraints due to his violent criminal history and the severity of the charges. Defense counsel initially opposed the restraints, but later expressed indifference and did not seek additional findings from the court. The court ordered leg restraints, taking steps to conceal them from the jury. The jury convicted the defendant on both counts, and the court sentenced him to two concurrent life sentences. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the district court erred by ordering restraints without making adequate findings. The appellate court held that the district court did not abuse its discretion because it justified the restraints based on the defendant’s specific criminal history and pending charges. The court also found no evidence that the jury was aware of the restraints or prejudiced by them. The appellate court rejected the defendant’s arguments under Deck v. Missouri, ruling that the district court had adequate justification for its decision. The judgment of the district court was affirmed. View "United States v. Lindsey" on Justia Law

United States v. Bruhn

2026-06-17T07:30:58-08:00

Steven Bruhn was initially charged with conspiracy to distribute and possess with intent to distribute controlled substances. After cooperating with the government and showing improvement during his time in rehabilitation, the district court deferred acceptance of his plea to support further rehabilitation. Eventually, the court sentenced him to time served and imposed five years of supervised release, warning him to avoid drug-related activities due to his history of substance abuse. Approximately a year into his supervised release, the government petitioned for revocation, alleging that Bruhn had relapsed into drug use and had been terminated from a treatment program. The magistrate judge first detained Bruhn, but later allowed his release to the North Dakota Adult and Teen Challenge rehabilitation program under strict conditions. After only two days, Bruhn was expelled from Teen Challenge for nonparticipation, and he failed to surrender to authorities as required. At the final revocation hearing, the United States District Court for the District of North Dakota found that Bruhn had not engaged with the rehabilitation opportunities provided and sentenced him to 20 months’ imprisonment, an upward variance from the calculated Guidelines range of 5 to 11 months. Bruhn appealed to the United States Court of Appeals for the Eighth Circuit, arguing that the district court imposed the sentence based on speculation and unsupported inferences, particularly regarding his intentions at Teen Challenge. The Eighth Circuit found no plain error, holding that the district court’s findings were supported by the record, including the unobjected-to violation report and statements from Bruhn’s probation officer. The appellate court affirmed that the district court adequately considered the relevant sentencing factors and provided sufficient justification for the upward variance. Therefore, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Bruhn" on Justia Law

Klimek v. CentraCare Health System

2026-06-15T07:30:59-08:00

A registered nurse developed a serious medical condition, Complex Regional Pain Syndrome, after a workplace injury while working for her employer. This condition caused chronic pain and other debilitating symptoms. In 2016, after her doctor advised that vaccines could aggravate her condition, her employer granted her a permanent medical exemption from certain vaccines. In 2021, she began working 100% remotely in a non-patient-facing role. Later that year, the employer instituted a mandatory COVID-19 vaccination policy, with exemptions available for medical reasons. She applied for a medical exemption, providing supporting documentation from her health providers, but her request was denied without explanation. Despite further communication and clarification of her remote work status, her employer maintained its denial and placed her on unpaid leave for noncompliance. The United States District Court for the District of Minnesota granted summary judgment for the employer. The district court concluded that compliance with the COVID-19 vaccination policy was an essential job function and that the requested exemption was not related to her disability. The court also found the employer had made a good faith effort to assist her in seeking an accommodation. The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that there were genuine issues of material fact regarding whether the nurse was a qualified individual under the ADA, whether she suffered an adverse employment action because of her disability, and whether the employer failed to engage in the interactive process or provide a reasonable accommodation. The court clarified that exemptions from vaccination requirements are accommodations, not essential job functions, and that the employer did not meet its burden to show undue hardship in allowing her to continue remote work. The court remanded the case for further proceedings. View "Klimek v. CentraCare Health System" on Justia Law

Rhodes v. Fulton Thermal Corp.

2026-06-12T07:31:03-08:00

An employee at a food processing plant was severely injured during a scheduled inspection of a boiler used to heat cooking oil. The boiler, manufactured and periodically inspected by a third-party company, exploded while the employee and his supervisor were checking its safety devices. The explosion caused significant burns to both men. The boiler had been manufactured twenty-one years earlier, and had undergone both regular quarterly and annual inspections by the manufacturer, with no issues reported. An inspection of the accident scene took place within weeks, but the injured employee was not notified or present for that inspection. After the accident, the injured employee filed a lawsuit in the United States District Court for the Western District of Arkansas, alleging that the manufacturer was liable under theories of strict products liability and negligence, claiming defects in design, manufacturing, and marketing, and inadequate inspections. During litigation, the plaintiff’s expert suggested that a leak in the boiler’s coils likely caused the explosion but admitted an inability to identify a specific defect or rule out numerous other possible causes. The district court granted summary judgment for the manufacturer, finding no evidence of a defect, breach of duty, or proximate causation. The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that the plaintiff failed to present substantial evidence to show either that the boiler was defective or that the manufacturer’s inspections were negligent in a way that proximately caused the injuries. The court emphasized that conjecture and speculation were insufficient to survive summary judgment, and that the plaintiff’s evidence did not exclude other possible causes or establish the manufacturer’s liability. View "Rhodes v. Fulton Thermal Corp." on Justia Law

Headley v. Ognenovski

2026-06-10T07:01:08-08:00

While incarcerated at a Missouri correctional center, Corey Coffelt exhibited significant mental health challenges, including diagnoses of substance-induced mood disorder with psychosis and a history of suicide attempts. Despite being prescribed psychiatric medications, Coffelt’s medication administration was inconsistent in the weeks preceding his death. On February 4, 2022, Coffelt was placed in administrative segregation, partly for safety concerns. Although his mental health conditions were noted, a nurse practitioner determined suicide watch was not necessary. Two days later, Coffelt died by suicide in his segregation cell. The corrections officers on duty were responsible for conducting visual checks per facility policy, but Coffelt was found deceased approximately an hour after he was last seen alive. In the United States District Court for the Eastern District of Missouri, Coffelt’s parents brought state wrongful death and federal civil rights claims against several corrections officers. The officers moved to dismiss, asserting official immunity on the state claim and qualified immunity on the federal deliberate indifference claim. The district court denied the motions, finding that the complaint plausibly alleged a ministerial duty under facility policy for the wrongful death claim and sufficient facts for the § 1983 deliberate indifference claim, allowing both to proceed. The United States Court of Appeals for the Eighth Circuit reviewed the denial of immunity de novo. It held that the cell check policy required some officer discretion and was not a purely ministerial duty; therefore, official immunity barred the state wrongful death claim. Regarding the § 1983 claim, the court concluded that the complaint did not sufficiently allege the officers had actual knowledge of a substantial suicide risk or acted with deliberate indifference. The Eighth Circuit reversed the district court’s denial of both official and qualified immunity and remanded the case for further proceedings. View "Headley v. Ognenovski" on Justia Law

Lockhart v. Siloam Springs, Arkansas

2026-06-10T07:01:06-08:00

In the early morning hours of March 11, 2019, a police officer in Siloam Springs, Arkansas, stopped Christopher Lockhart, a licensed bail bondsman and private investigator, after observing Lockhart’s vehicle touch the centerline while driving below the speed limit. During the stop, the officer noted Lockhart’s slow and slurred speech, bloodshot and glassy eyes, droopy eyelids, and apparent confusion. Lockhart performed poorly on field sobriety tests and admitted to recent use of prescription pain medication. Although a subsequent blood test showed no alcohol, and a Drug Recognition Expert concluded Lockhart was not impaired but rather had medical issues, the officer arrested him for driving while intoxicated (“DWI”) and related offenses. The charges were later dismissed, and Lockhart was found not guilty on the DWI charge after no evidence was presented at trial. Lockhart filed suit in the United States District Court for the Western District of Arkansas against the City of Siloam Springs and several employees, asserting constitutional and state law claims, including false arrest and malicious prosecution. The district court granted summary judgment on most claims but allowed the false arrest claim against the officer and the malicious prosecution claim against the city to proceed. On a previous appeal, the United States Court of Appeals for the Eighth Circuit upheld the denial of summary judgment for the malicious prosecution claim but reversed as to the Fourth Amendment claim, remanding for further consideration of whether probable cause supported the arrest. In the current appeal, the United States Court of Appeals for the Eighth Circuit held that Officer Ware was entitled to qualified immunity on the false arrest claim because, under the undisputed facts, he had probable cause to arrest Lockhart for DWI. The court reversed the denial of summary judgment for the officer, remanded for entry of judgment in his favor, and dismissed the city’s appeal on the malicious prosecution claim, declining to revisit its prior decision. View "Lockhart v. Siloam Springs, Arkansas" on Justia Law

United States v. Evans

2026-06-09T08:31:58-08:00

A 15-year-old girl, E.R., stayed overnight at her friend G.T.’s home, where G.T.'s uncle, Rayford Evans, also lived. The morning after the sleepover, E.R. saw a cell phone through a bathroom transom window while she was bathing, which was quickly withdrawn. She believed Evans had tried to record her and reported this to G.T., who, with E.R., informed G.T.'s father, Ancel Teal. Teal coordinated with E.R.'s parents, one of whom was a sheriff’s deputy. Law enforcement was notified, and Officer Smith from the Doniphan Police Department responded. He confronted Evans at the home, requested Evans’s phones, and ultimately seized one phone after Evans initially objected but then acquiesced. Evans then consented in writing to a search of the phone, which led to the discovery of videos of E.R. nude in the bathroom. In the United States District Court for the Eastern District of Missouri, Evans was charged with attempted sexual exploitation of a minor. He moved to suppress the evidence from the warrantless seizure and search of his cell phone, arguing his consent was involuntary and that neither exigent circumstances nor the inevitable discovery doctrine applied. The district court denied the motion, found Evans guilty after a bench trial, and sentenced him to 252 months’ imprisonment. Evans renewed his suppression motion and sought a new trial, both of which were denied. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that exigent circumstances justified the warrantless seizure of Evans’s phone because there was a reasonable belief Evans could imminently destroy evidence, and probable cause existed. The subsequent written consent to search the phone was voluntary. The court also held that sufficient evidence supported the conviction for attempted sexual exploitation of a minor. The judgment was affirmed. View "United States v. Evans" on Justia Law

Vaughn Boyd v. Deadwood Tobacco Co.

2026-06-08T07:31:04-08:00

Two businesses and their principals were involved in the sale of a cigar company. The sale was governed by a written agreement which expressly reserved three registered trademarks for the sellers, and did not mention other closely related marks. After the sale, the buyers’ company launched new cigar products and marketing campaigns referencing the history and reputation of the reserved marks and associated product lines. The sellers objected, claiming infringement of their reserved trademark interests and associated goodwill. When attempts to resolve the dispute failed, the sellers filed a federal trademark infringement lawsuit. The first lawsuit was brought in the United States District Court for the Southern District of Florida. That court did not address the merits of the trademark claims. Instead, it found that the claims arose out of the sales agreement, which contained a forum selection clause requiring venue in state court in Lawrence County, South Dakota. On that basis, the Florida district court dismissed the case on forum non conveniens grounds. Subsequently, the buyers initiated a related contract lawsuit in South Dakota state court. The sellers then filed the present lawsuit in the United States District Court for the District of South Dakota, asserting only federal Lanham Act claims and omitting the sales agreement from their initial filings. The United States Court of Appeals for the Eighth Circuit held that the federal trademark claims arose out of the sales agreement, because resolving them would require analyzing the parties’ contractual allocation of trademark rights and goodwill. The court further held that the forum selection clause in the agreement was valid, mandatory, and enforceable under South Dakota law and federal law, and that it required litigation to proceed in state court in Lawrence County, South Dakota. The Eighth Circuit also concluded that state courts have concurrent jurisdiction over federal Lanham Act claims. Accordingly, the Eighth Circuit affirmed the district court’s dismissal. View "Vaughn Boyd v. Deadwood Tobacco Co." on Justia Law

Tiah v. Blanche

2026-06-08T07:30:59-08:00

A lawful permanent resident from Liberia was charged with removability after being convicted twice in North Dakota for violating protection orders that prohibited him from contacting his wife, Rose Tiah. These orders were issued following incidents in which he engaged in disorderly conduct and was alleged to have threatened or harassed his wife. The protection orders in question were not included in the administrative record, but related police reports, charging documents, and the petitioner’s own admissions demonstrated that the orders arose from domestic violence-related circumstances and that he had willfully violated them by being present near, or contacting, his wife. The Immigration Judge found the petitioner removable under 8 U.S.C. § 1227(a)(2)(E)(ii), relying on his convictions, the evidentiary record, and his admissions. The judge also denied his application for cancellation of removal and other requested relief. The Board of Immigration Appeals dismissed the petitioner’s appeal, agreeing that the record was sufficient to establish removability even though the actual protection orders were not submitted. The Board concluded that the convictions and supporting documents demonstrated that the violated orders were issued to protect against threats or acts of domestic violence. The United States Court of Appeals for the Eighth Circuit reviewed the case and held that the government is not required to submit the actual protection orders to establish removability under 8 U.S.C. § 1227(a)(2)(E)(ii) if the record otherwise clearly and convincingly establishes that the statutory requirements are met. The court found that the evidence—including state statutes, docket reports, charging documents, police reports, and the petitioner’s admissions—was sufficient to show that the protection orders were issued for the purpose of preventing domestic violence and that the petitioner violated their no-contact provisions. The petition for review was denied. View "Tiah v. Blanche" on Justia Law

United States v. Debevec

2026-06-02T07:31:00-08:00

An undercover law enforcement officer created a profile on an adult-only dating app, portraying an 18-year-old woman named “Zoee,” but quickly disclosed to Jayden Debevec that she was actually 15 years old. Over the course of about a day, Debevec initiated contact, repeatedly acknowledged Zoee’s stated age, and escalated the conversation to explicit sexual topics. He arranged an in-person meeting, sent sexually explicit messages, and was arrested upon arrival at the agreed location. Evidence from his phone confirmed the communications, and he admitted to initiating the sexual conversation. The government also introduced evidence of his prior online searches for terms associated with sexualized depictions of minors and a separate, sexually explicit conversation with an adult woman. The United States District Court for the District of South Dakota denied Debevec’s motion for a judgment of acquittal before the verdict. The jury found him guilty of attempted enticement of a minor using the internet, and the court sentenced him to 120 months in prison with supervised release. Debevec appealed, challenging the sufficiency of the evidence in light of his entrapment defense and objecting to the admission of prior acts evidence under Federal Rule of Evidence 404(b). The United States Court of Appeals for the Eighth Circuit reviewed the denial of the judgment of acquittal de novo and found sufficient evidence to support the jury’s rejection of the entrapment defense, concluding that Debevec was neither induced by the government nor lacked a predisposition to commit the offense. The appellate court also held that the district court did not abuse its discretion in admitting the Amazon search history and found any error in admitting the WhatsApp conversation to be harmless. The Eighth Circuit affirmed the judgment. View "United States v. Debevec" on Justia Law

United States v. Simpson

2026-06-02T07:30:59-08:00

Kansas City police received an anonymous tip indicating that an individual with a prior felony conviction was in possession of a firearm. Detectives discovered that both the individual and his wife had outstanding arrest warrants. The following day, officers observed the couple leaving an apartment, initiated a traffic stop, and arrested both occupants. A firearm was found inside a purse on the passenger-side floor. The individual was charged with being a felon in possession of a firearm. Prior to trial in the United States District Court for the Western District of Missouri, the defendant moved to exclude any reference to the anonymous tip, arguing it was inadmissible hearsay and violated his rights under the Confrontation Clause. The government contended that the tip was being offered to explain the officers’ conduct during the stop, not for the truth of its contents. The district court denied the motion and allowed testimony about the tip. The defendant renewed his objections and moved for a mistrial, but the district court again denied these requests. The jury found the defendant guilty. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether admission of the anonymous tip violated the defendant’s Confrontation Clause rights and whether any such error was harmless. The court held that the tip was testimonial hearsay and its admission was erroneous because the propriety of the police investigation was not at issue, and its relevance was limited to proving the truth of the matter asserted. The court further found that the error was not harmless, given the tip’s prejudicial effect on the only disputed element at trial—possession of the firearm. Consequently, the Eighth Circuit vacated the conviction and remanded the case for further proceedings. View "United States v. Simpson" on Justia Law

Bonham v. Bisignano

2026-06-02T07:30:58-08:00

The appellant, a military veteran, developed significant neck and back issues following his service, which worsened in May 2012. Medical imaging revealed cervical spondylosis with a herniated disk, leading to spinal fusion surgery in October 2012. He continued to suffer pain and functional limitations, including weakness in his left arm, and received limited disability benefits from the Department of Veterans Affairs. In 2021, he applied for Social Security disability benefits, claiming a disability onset date in 2012 and eligibility through the end of 2016. His application was denied by an Administrative Law Judge (ALJ) after a hearing, where both the appellant and a vocational expert testified. The ALJ found that, despite severe impairments, the appellant retained the residual functional capacity to perform light work, including his past relevant work as generally performed and other jobs available in the national economy. The ALJ discounted the only medical opinion addressing his functional ability—a 2016 evaluation by a physician’s associate—because it was inconsistent with other medical records. The Social Security Appeals Council denied review. The United States District Court for the Western District of Missouri affirmed the ALJ’s decision, holding that the ALJ’s findings were supported by substantial evidence. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the ALJ’s decision was supported by substantial evidence and free from legal error. The court held that the ALJ properly based the residual functional capacity determination on all relevant medical evidence, not just specific functional medical opinions. The court found that the ALJ thoroughly considered the record, including conflicting medical findings, and was not required to obtain additional functional evidence. The judgment of the district court, affirming the denial of disability benefits, was affirmed. View "Bonham v. Bisignano" on Justia Law

United States v. Franklin

2026-06-01T07:01:26-08:00

From 2011 to 2019, four individuals—Roy Franklin Jr., Ladele Smith, Gary Toombs, and David Duncan IV—participated in a drug-trafficking conspiracy in Kansas City, Missouri. They operated from a house rented by Toombs, storing firearms and distributing various drugs, including heroin, cocaine, oxycodone, and marijuana. The group, known as "246," also produced music that referenced drugs and violence. In September 2019, Franklin and Smith carried out a drive-by shooting in response to a perceived threat against Duncan. Law enforcement gathered evidence through social media, surveillance, controlled buys, and wiretaps. Searches uncovered significant quantities of drugs, firearms, and cash, and financial records revealed lavish spending inconsistent with reported income. The United States District Court for the Western District of Missouri denied motions to suppress social media and wiretap evidence, and admitted evidence regarding the group’s music and affiliations. The court declined to give requested jury instructions on entrapment and buyer-seller relationships. After a three-week trial, a jury convicted all four defendants of various drug, firearm, and money-laundering offenses. The district court imposed sentences ranging from 151 to 420 months. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the convictions and sentences. The court held that the search warrants and wiretap authorizations were supported by probable cause and particularity, and that the necessity requirement for wiretaps was met. The court found no error in the admission of rap lyrics and evidence of gang affiliation, and ruled that statements made by conspirators were admissible under the co-conspirator exception to hearsay. The court concluded that the evidence was sufficient to support all convictions and that the upward variances in sentencing were not substantively unreasonable. The judgments of conviction and sentences were affirmed. View "United States v. Franklin" on Justia Law

Kleinsteuber v. Metropolitan Life Ins. Co.

2026-05-29T07:31:24-08:00

After the death of Dana Kleinsteuber, her husband, Charles Kleinsteuber, sought accidental death and dismemberment (AD&D) benefits under an ERISA-governed insurance plan administered and insured by Metropolitan Life Insurance Company (MetLife). Dana Kleinsteuber, who suffered from end-stage renal disease (ESRD) due to a long history of an eating disorder, was using home dialysis as treatment. On the day of her death, she apparently failed to properly close her chest port after a dialysis session, resulting in severe blood loss and subsequent cardiac arrest. Emergency responders stopped the bleeding, but she died shortly after. MetLife initially denied the claim on the basis that Dana’s death resulted from natural causes related to her ESRD, and that an exclusion in the plan applied for losses caused or contributed to by illness or its treatment. Following an extensive administrative appeal submitted by Mr. Kleinsteuber, which included evidence from Dana’s doctor and other records, MetLife reconsidered and acknowledged the death was accidental. However, it maintained the exclusion applied because the death was caused or contributed to by the treatment for her ESRD. After Mr. Kleinsteuber exhausted his administrative remedies, he filed suit in the United States District Court for the District of Minnesota. The district court granted summary judgment for MetLife, finding the exclusion applicable. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that MetLife provided a full and fair review and that its conflict of interest deserved little weight. The court interpreted the plan exclusion de novo, finding that the ordinary meaning of “caused or contributed to” included Dana’s death under these circumstances. Applying an abuse-of-discretion standard to MetLife’s ultimate decision, the court found substantial evidence supported the denial. As a result, the Eighth Circuit affirmed the district court’s judgment, upholding MetLife’s denial of benefits. View "Kleinsteuber v. Metropolitan Life Ins. Co." on Justia Law

Lopez-Vasquez v. Bondi

2026-05-29T07:31:23-08:00

Elisa Lopez-Vasquez, a native and citizen of Guatemala, entered the United States illegally in 2004 and lived in Carthage, Missouri for about twenty years. She is the mother of six children who are U.S. citizens and married a Guatemalan citizen in 2021. In August 2024, the Department of Homeland Security charged her with being present in the United States without admission or parole. Lopez-Vasquez conceded removability and sought cancellation of removal, citing hardship to her children, and also requested voluntary departure. The Immigration Judge in Kansas City, Missouri, denied both requests. The judge found Lopez-Vasquez ineligible for cancellation of removal due to a prior Missouri conviction for a crime of child abuse and concluded she had not proven that her removal would cause her children “exceptional and extremely unusual hardship.” The judge also denied voluntary departure for lack of valid travel documents. Lopez-Vasquez appealed to the Board of Immigration Appeals, which affirmed the denial based on insufficient hardship and the absence of travel documents for voluntary departure. The Board also denied her motion to remand for consideration of new hardship evidence, finding the evidence neither material nor previously unavailable. Lopez-Vasquez then petitioned the United States Court of Appeals for the Eighth Circuit for review, arguing violations of due process and misapplication of the legal standards. The Eighth Circuit held that because cancellation of removal is a discretionary form of relief, Lopez-Vasquez had no constitutionally protected liberty interest in it, so her due process claims failed. The court further found that substantial evidence supported the Board’s hardship determination, and that the Board did not abuse its discretion in denying the motion to remand. The court dismissed as moot her voluntary departure claim, as she had already been removed to Guatemala, and ultimately denied her petition for review. View "Lopez-Vasquez v. Bondi" on Justia Law

United States v. Marr

2026-05-28T07:02:00-08:00

Michelle Lee Marr was charged after the death of her boyfriend, Jesse Gilpin, who was found unresponsive and later died from injuries. After Marr called 911, medical personnel observed bruises on Gilpin concealed with makeup. Marr made conflicting statements about who applied the makeup. Law enforcement conducted three interviews with Marr at her home or her mother’s home, during which she voluntarily provided her cell phone and, days later, signed a written consent for a search of the device. At trial, the government introduced her statements from the interviews and photographic evidence from her phone depicting Gilpin’s injuries. The United States District Court for the District of Nebraska denied Marr’s motions to suppress her statements and the cell phone evidence, finding she was not in custody during the interviews and consented voluntarily to the phone search. The court also admitted limited evidence under Federal Rule of Evidence 404(b) of prior violent acts Marr had committed against Gilpin, concluding that the probative value was not substantially outweighed by prejudice. Marr was convicted by a jury of second-degree murder and tampering with documents or proceedings and sentenced to 300 months for murder and 240 months for tampering, to be served concurrently. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings and judgment. The court held that Marr was not “in custody” for Miranda purposes during any interview, so warnings were not required; her consent to the phone search was knowing and voluntary; and the admission of prior violent acts was not an abuse of discretion. The court determined that sufficient evidence supported both convictions and that the sentence imposed was substantively reasonable. The judgment of the district court was affirmed. View "United States v. Marr" on Justia Law

Christianson v. McLean County

2026-05-28T07:01:59-08:00

While detained at the McLean County Detention Center, Dirk Alan Christianson developed a severe leg infection that ultimately resulted in the amputation of his leg above the knee. During his incarceration, Christianson sought medical attention several times and was treated both within and outside the jail, including being evaluated by a jail nurse and a family nurse practitioner. After displaying symptoms such as fever and pain, Christianson was transported to an outside clinic where he was evaluated, tested, and given instructions for follow-up. His condition deteriorated over the next several days, leading to hospitalization, a diagnosis of necrotizing fasciitis, and amputation. Christianson brought suit in the United States District Court for the District of North Dakota against McLean County, jail officials, medical staff, and the outside clinic, asserting claims under 42 U.S.C. § 1983 for deliberate indifference to serious medical needs, Monell municipal liability, and state law medical malpractice. The district court dismissed the Monell and medical malpractice claims, granted summary judgment to all defendants on the deliberate indifference claims, and denied Christianson’s motion to amend his complaint to identify and add John Doe defendants. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The appellate court held that Christianson failed to allege facts sufficient to support municipal liability under Monell, as the complaint did not set forth a specific policy or widespread custom causing constitutional harm. The court also determined that the evidence did not support claims of deliberate indifference by the sheriff, jail nurse, or family nurse practitioner, finding no facts showing that these individuals knew of and disregarded a serious medical need. Additionally, the court ruled that Christianson’s motion to amend was untimely and properly denied, and that dismissal of the John Doe defendants was appropriate. Finally, the court affirmed dismissal of the state law medical malpractice claim, concluding that the required expert affidavit was not timely served. View "Christianson v. McLean County" on Justia Law

General Electric Company v. Boilermaker-Blacksmith National Pension Trust

2026-05-26T07:31:01-08:00

General Electric Company (GE) was assessed withdrawal liability by the Boilermaker-Blacksmith National Pension Trust (the Fund) under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), which amended the Employee Retirement Income Security Act (ERISA). The Fund claimed that GE partially withdrew from the plan based on a 70% decline in contribution base units (CBUs) and the closure of a manufacturing facility in Chattanooga, resulting in liability assessments totaling over $227 million. GE disputed these assessments, arguing that it qualified for the “building and construction industry” (BCI) exception, which exempts certain employers from withdrawal liability if substantially all their covered employees perform work in the building and construction industry. An arbitrator considered the dispute and found in favor of GE, concluding that it met the requirements for the BCI exception. Both parties sought review in the United States District Court for the Western District of Missouri, which affirmed the arbitrator’s decision. The district court determined that the statutory language was ambiguous regarding how to count employees for the purpose of the BCI exemption and adopted GE’s cumulative headcount method rather than the Fund’s preferred monthly headcount method. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s legal conclusions de novo and examined the ambiguity in the statutory language. The Court held that, of the two methods presented, the cumulative headcount approach advanced by GE was more consistent with the purpose and legislative intent of the statute, which was designed to accommodate the fluctuating nature of employment in the building and construction industry. The Court affirmed the district court’s judgment, holding that GE qualified for the building and construction industry exemption and was not liable for withdrawal assessments. View "General Electric Company v. Boilermaker-Blacksmith National Pension Trust" on Justia Law

Roberts v. Thompson

2026-05-20T07:31:02-08:00

Black Hawk County, Iowa, charges jail inmates daily fees and a booking fee. Rather than pursuing the standard civil reimbursement process, which includes judicial review, the County requires inmates to sign confessions of judgment upon release, acknowledging the debt and agreeing to payment terms. Inmates’ money is seized and applied toward the debt, and the confession allows the County to file for judgment without further judicial review. Leticia Roberts and Calvin Sayers, former inmates who signed these confessions under coercive circumstances, allege that the County’s process deprived them of an opportunity to challenge the jail fees and violated their Fourteenth Amendment due process rights. Roberts made payments out of fear of further enforcement, while Sayers made one payment and had money seized by jail officials. The United States District Court for the Northern District of Iowa dismissed Roberts and Sayers’s claims for lack of standing and failure to state a claim. The district court reasoned that their injury was not traceable to the confession of judgment policy because they would owe jail fees regardless, and any payments were voluntary. The court also denied their motion for a preliminary injunction and leave to amend the complaint. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The Eighth Circuit held that Roberts and Sayers had standing to seek damages and injunctive or declaratory relief, as they plausibly alleged injuries traceable to the County’s policy and a real threat of recurring harm. The appellate court found reasonable inferences that the confessions of judgment were coercive and not voluntary, and that the County’s actions deprived Roberts and Sayers of property without constitutionally adequate process. The Eighth Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "Roberts v. Thompson" on Justia Law

United States v. Cooper

2026-05-19T07:31:02-08:00

On November 18, 2022, a confrontation took place in downtown Waterloo, Iowa, involving members of two rival gangs. Quintorey Kemp, associated with the "Only the Brothers" gang, had previously displayed a firearm at a barbershop during an encounter with members of the "All About Action" gang, including Andrew Spates and Keivon Anderson. Laindrell Cooper, also affiliated with "All About Action," arrived at the scene dressed in all black and wearing a mask, having been dropped off nearby. Surveillance footage captured Cooper approaching the barbershop, walking past waiting vehicles, and ultimately pursuing Kemp, firing multiple shots at him as Kemp fled. Cooper was charged in the United States District Court for the Northern District of Iowa with possession of a firearm by a prohibited person and possession of ammunition by a felon. He pleaded guilty to the ammunition charge. During sentencing, the district court applied the attempted murder cross-reference in the Sentencing Guidelines, concluding by a preponderance of the evidence that Cooper had attempted to murder Kemp. The district court rejected Cooper's arguments that he acted in self-defense or imperfect self-defense, finding no credible evidence that Cooper reasonably believed he or others were in imminent danger, and instead determined Cooper was the aggressor. The United States Court of Appeals for the Eighth Circuit reviewed Cooper’s appeal. The court held that Cooper’s constitutional challenge to 18 U.S.C. § 922(g)(1) was foreclosed by binding Eighth Circuit precedent. The court further held that the district court did not clearly err in its factual findings regarding Cooper's intent and the lack of justification for self-defense or imperfect self-defense, and properly applied the cross-reference for attempted murder in sentencing. The Eighth Circuit affirmed the judgment of the district court. View "United States v. Cooper" on Justia Law

United States v. Thunder

2026-05-19T07:31:01-08:00

On September 15, 2022, a woman named Nyvelle Quick Bear was fatally shot while inside Justin Bradford’s house. Initially, Bradford told authorities the shooting was accidental and involved a .22 caliber revolver. However, forensic evidence showed that Quick Bear was killed by a .45 caliber bullet fired from outside the house. Surveillance footage and witness testimony identified Clayton Fire Thunder as the person who approached Bradford’s house with a gun after having been drinking heavily. Testimony and forensic evidence indicated that Fire Thunder fired the shot that killed Quick Bear. Fire Thunder later denied possessing a gun during two separate interviews with law enforcement. Fire Thunder was indicted in the United States District Court for the District of South Dakota on charges of involuntary manslaughter and making false statements to federal law enforcement. At trial, the jury found him guilty on all counts. The district court determined the offense levels for the convictions, applied a three-level enhancement for substantial interference with the administration of justice regarding the false statement convictions, and grouped the offenses under the Sentencing Guidelines. Ultimately, the court imposed a total sentence of 96 months, which included upward variance to the statutory maximums. On appeal to the United States Court of Appeals for the Eighth Circuit, Fire Thunder challenged the sentencing enhancement, the substantive reasonableness of his sentence, and the sufficiency of the evidence. The Eighth Circuit held that any error in applying the enhancement was harmless because it did not affect the Guideline range or the sentence imposed. The court also found no abuse of discretion in the upward variance and statutory maximum sentence, concluding that the district court reasonably considered aggravating factors. Finally, the appellate court held that sufficient evidence supported each conviction. The judgment of the district court was affirmed. View "United States v. Thunder" on Justia Law

United States v. Sando

2026-05-19T07:31:01-08:00

On January 9, 2022, Sam Sando was involved in two significant events. Early that morning, he had a domestic dispute with Asatu Abalo, during which he allegedly threatened her with a firearm and warned her that there would be gunfire the next day. Later that evening, Sando and his cousin arranged to meet Andrew Meyer, who had earlier tried to sell Sando fake marijuana. When Meyer and two companions arrived at the meeting point, Sando and his cousin approached the vehicle with guns drawn and fired at them, resulting in the death of one occupant. Both Sando and his cousin fled but were arrested a week later. Although Sando was acquitted of first-degree murder in state court, he was subsequently prosecuted in federal court on charges related to attempted robbery, drug trafficking, and firearm use. At the United States District Court for the Southern District of Iowa, the government dismissed one count before trial, and a jury found Sando guilty on three remaining counts: attempted interference with commerce by robbery, attempted possession with intent to distribute a controlled substance, and carrying a firearm during and in relation to a drug trafficking crime. Sando challenged several of the district court’s evidentiary decisions, including the exclusion of Abalo’s state court deposition, the exclusion of a portion of another witness’s prior testimony, limitations on impeachment of a government witness, and the admission of evidence related to the domestic dispute. The United States Court of Appeals for the Eighth Circuit reviewed each of Sando’s claims for abuse of discretion. The court held that the district court did not abuse its discretion in excluding the deposition and prior testimony, limiting impeachment, or admitting evidence of the domestic dispute, either because the evidence was inadmissible under the rules or any error was harmless. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Sando" on Justia Law

Young v. Keyes

2026-05-19T07:31:00-08:00

A police officer in Williston, North Dakota, stopped a driver after observing an illegal turn late at night on New Year’s Eve. Noticing signs of alcohol intoxication, the officer conducted field-sobriety tests. During a subsequent interaction, the driver became argumentative and declined to answer whether he would agree to an additional alcohol screening. At that point, according to the complaint, the officers forcefully grabbed the driver without warning, commanded him to put his hands behind his back, and—assisted by a second officer—took him to the ground and handcuffed him. The driver alleges he suffered physical injuries and emotional harm as a result and sued both officers for using excessive force in violation of his Fourth Amendment rights. The United States District Court for the District of North Dakota granted the officers’ motion to dismiss, holding that their use of force was de minimis and, in the alternative, that it was objectively reasonable. The district court relied on dash-camera and body-camera footage, finding the videos consistent with the pleadings. Reviewing the case on appeal, the United States Court of Appeals for the Eighth Circuit applied a de novo standard to the motion to dismiss. The appellate court found that the video evidence did not conclusively contradict the plaintiff’s allegations regarding the severity of force or the absence of resistance. The court further held that, under clearly established law, force is least justified against nonviolent misdemeanants who do not actively resist arrest or pose a threat. Since the complaint alleged facts that, if true, would constitute a violation of clearly established rights, and the video evidence did not refute those allegations, the Eighth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Young v. Keyes" on Justia Law

Kendall v. Zoltek Corporation

2026-05-18T07:31:30-08:00

Angela Kendall was employed as a production operator by a manufacturing company that required physical tasks such as standing for up to 12 hours, lifting, bending, and reaching. In 2021, after suffering from back pain and being diagnosed with muscle spasms and potential sciatica, Kendall received a temporary workplace accommodation allowing her to sit occasionally during her shifts. Over time, her medical restrictions increased, including limitations on standing, bending, lifting, and other physical activities. After exhausting her leave and with no foreseeable return to unrestricted work, her employment was terminated. Kendall filed discrimination charges, alleging her employer failed to accommodate her disability and retaliated in violation of the Americans with Disabilities Act (ADA), and discriminated based on sex in violation of Title VII. The United States District Court for the Eastern District of Missouri granted summary judgment to the employer on all claims, finding that Kendall was not qualified for her position because she could not perform its essential functions, even with reasonable accommodation, and that there was no evidence of adverse employment action based on retaliation or sex. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that standing for extended periods, lifting, bending, and other physical tasks were essential functions of the production operator position, as evidenced by the job description and employer’s expectations. Kendall’s medical restrictions prevented her from performing these essential duties, and allowing her to sit as needed was not a reasonable permanent accommodation. The court also found that Kendall failed to establish a prima facie case of sex discrimination because she was not qualified for her position at the time of termination. Accordingly, the Eighth Circuit affirmed the district court’s judgment in favor of the employer. View "Kendall v. Zoltek Corporation" on Justia Law

Brake Plus NWA, Inc. v. Department of Transportation

2026-05-18T07:31:29-08:00

Two companies that distribute aftermarket electronic modules, which cause vehicles’ center high mounted stop lamps to pulse briefly before remaining bright, faced scrutiny from a federal safety agency. The National Highway Traffic Safety Administration (NHTSA) investigated whether these modules violated a federal regulation requiring “steady burning” stop lamps, a term not specifically defined in the relevant regulation. After a four-year investigation, NHTSA sent letters to both distributors in July 2023, stating that the modules rendered vehicles noncompliant with federal law and threatening to notify the distributors’ customers of this conclusion. The letters also warned of significant civil penalties for continued installation of the modules. The distributors filed suit in the United States District Court for the Western District of Arkansas, seeking declaratory and injunctive relief to prevent NHTSA from notifying their customers and to challenge the agency’s conclusion about their products. Before ruling on a preliminary injunction, the district court dismissed the case sua sponte, holding that NHTSA’s actions were not “final agency action” under the Administrative Procedure Act and thus not subject to judicial review. The court suggested in a footnote that the plaintiffs were unlikely to succeed on the merits but did not conduct a full analysis of the injunction request. On appeal, the United States Court of Appeals for the Eighth Circuit reversed. The appellate court determined that the NHTSA’s July 2023 letters constituted final agency action because they marked the consummation of the agency’s decision-making process and carried direct legal consequences for the distributors and their customers. The court held that the district court erred in dismissing the case for lack of final agency action, and remanded for further proceedings, including consideration of the injunction request. View "Brake Plus NWA, Inc. v. Department of Transportation" on Justia Law

Farella v. Anglin

2026-05-18T07:31:28-08:00

Two individuals were arrested by the Bentonville Police Department in Arkansas and appeared before a state district court judge two days and one day after their respective arrests. During these initial hearings, the judge set bail amounts for each individual without providing them with legal representation. Only after setting bail did the judge determine that they were indigent and appoint counsel for future proceedings. Both individuals remained incarcerated for several weeks before ultimately pleading guilty and being sentenced to time served. Following their experiences, these individuals, acting on behalf of a class of similarly situated pretrial detainees, filed suit in the United States District Court for the Western District of Arkansas. They alleged that the judge’s practice of setting bail without first appointing counsel violated their rights under the Sixth and Fourteenth Amendments. They sought declaratory and injunctive relief requiring that indigent defendants be provided with counsel at the start of their initial bail hearings. The district court denied motions to dismiss, certified the class, and ultimately granted summary judgment in favor of the plaintiffs. The district court held that the plaintiffs’ right to counsel attached at the initial hearing and that the bail-setting constituted a critical stage, thus granting declaratory and injunctive relief against the judge. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The Eighth Circuit held that the plaintiffs lacked Article III standing because they failed to show an ongoing or imminent injury that could be redressed by the prospective relief sought. The court found that the possibility of facing the same situation again was too speculative and that the requested relief would not redress any past harm already suffered. As a result, the Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss for lack of standing. View "Farella v. Anglin" on Justia Law

United States v. Little

2026-05-15T07:30:59-08:00

Law enforcement in St. Louis received a tip that an individual, later identified as Antone Little, was distributing drugs from a residence. Surveillance confirmed drug transactions, including sales of crack cocaine and fentanyl. Upon executing a search warrant, officers found firearms, drug paraphernalia, and over 1,600 pills marked as oxycodone but containing fentanyl. During an interview, Little made statements indicating he knew the pills were counterfeit oxycodone containing fentanyl. Little was indicted on multiple counts and entered a plea agreement, pleading guilty to being a felon in possession of a firearm and possession of a controlled substance with intent to distribute. The United States District Court for the Eastern District of Missouri held a sentencing hearing at which conflicting testimony was presented regarding Little’s knowledge and intent. The court found that Little knowingly possessed and marketed fentanyl pills as oxycodone, applied a four-level sentencing enhancement under USSG § 2D1.1(b)(13)(A), and sentenced Little to 235 months in prison. The court also found Little permanently ineligible for federal benefits under 21 U.S.C. § 862(a)(1)(C). Little appealed both the enhancement and the denial of benefits. The United States Court of Appeals for the Eighth Circuit reviewed the sentence. The appellate court held that the district court did not clearly err in crediting the evidence that Little marketed fentanyl as oxycodone, nor did it err in applying the four-level enhancement. The appellate court also found that any error in applying the enhancement would have been harmless because the district court would have imposed the same sentence as an alternative. However, the appellate court held that the district court erred in permanently denying federal benefits, as Little did not have the requisite prior convictions for distribution offenses. The Eighth Circuit affirmed the prison sentence but vacated the permanent denial of federal benefits. View "United States v. Little" on Justia Law

United States v. Belt

2026-05-15T07:30:58-08:00

Bailey Belt and Theodora Belt were charged under the Major Crimes Act for assaulting and murdering Elijah Morrison on the Cheyenne River Sioux Indian Reservation. On the night in question, an argument between the parties escalated into violence, culminating in Elijah being beaten and run over by a car. Surveillance footage from a nearby residence captured portions of the incident, but the video contained gaps. Key physical evidence included Elijah’s blood on Theodora’s car and a DNA mixture on the car’s windshield. The case was tried before the United States District Court for the District of South Dakota. At trial, the government introduced the surveillance footage despite defense objections regarding its authenticity, particularly because the camera owner was deceased and could not testify about the gaps in the video. The jury convicted both Bailey and Theodora. At sentencing, the district court applied a “vulnerable victim” enhancement, finding Elijah was especially susceptible to harm at the time he was run over. Bailey and Theodora appealed to the United States Court of Appeals for the Eighth Circuit, challenging the admission of the surveillance footage and, in Bailey’s case, the application of the vulnerable victim sentencing enhancement. The Eighth Circuit found that the district court did not abuse its discretion in admitting the surveillance footage, concluding that the government met the low bar for authentication based on the totality of the circumstances and corroborating evidence. The court further held that the vulnerable victim enhancement was properly applied, as Elijah became unusually vulnerable during the course of the offense, and this vulnerability was not a factor already incorporated in the relevant sentencing guideline. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Belt" on Justia Law

Everest Stables, Inc. v. Porter, Wright LLP

2026-05-14T07:31:35-08:00

A Minnesota thoroughbred horse breeding and racing company and its CEO became dissatisfied with the legal work of three separate law firms in various matters, including business contract drafting and litigation. They hired an attorney employed by a national law firm to pursue legal malpractice claims against their prior counsel. Engagement letters for some of this representation included a provision selecting Ohio law to govern the attorney-client relationship. The malpractice actions against the original firms were unsuccessful, with adverse judgments in both federal and state courts. Following these outcomes, the company and CEO sued their new attorneys in federal court in Minnesota, alleging malpractice, breach of contract, breach of fiduciary duty, and fraud. The defendants counterclaimed for unpaid legal fees. The United States District Court for the District of Minnesota dismissed the malpractice, contract, and fiduciary duty claims related to two of the underlying matters (those involving Dorsey and Foley) as time-barred under Ohio’s one-year statute of limitations, which the court applied pursuant to the contractual choice-of-law provision. The court held that plaintiffs did not meet the rare standard for substituting Minnesota’s longer statute of limitations. For the remaining malpractice claim (involving Rambicure), the district court granted summary judgment to the defendants because plaintiffs failed to serve the expert disclosure affidavit required by Minnesota law within the deadline, and expert testimony was necessary to establish a prima facie case. The court also dismissed related fraud claims on the same grounds. The United States Court of Appeals for the Eighth Circuit affirmed. It held that Ohio’s one-year statute of limitations barred the malpractice, contract, and fiduciary duty claims arising from the Dorsey and Foley matters. It also held that dismissal of the Rambicure-related claims and the fraud claims for failure to serve the required expert disclosure affidavit was proper, as expert testimony was necessary to support those claims. The court affirmed the district court’s judgment in favor of the defendants on all claims. View "Everest Stables, Inc. v. Porter, Wright LLP" on Justia Law

United States v. Tetzlaff

2026-05-13T07:01:28-08:00

A federal inmate was prosecuted for an altercation inside the Forrest City Federal Correctional Complex that resulted in another inmate’s death. Witnesses testified that the defendant punched the victim in the head after accusing him of stealing a contraband cell phone. The victim was rendered unconscious, and other inmates observed a serious head laceration. Despite appearing lucid for some time after the incident, the victim suffered worsening symptoms, ultimately collapsed, and died from blunt force head trauma, which an autopsy classified as homicide. The defendant was charged with manslaughter and assault causing serious bodily injury. The United States District Court for the Eastern District of Arkansas presided over a jury trial. The jury found the defendant guilty of assault causing serious bodily injury but was unable to reach a verdict on the manslaughter count, which was later dismissed. The district court sentenced the defendant to 120 months’ imprisonment, to run consecutively to an existing sentence, and applied a seven-level sentencing enhancement for causing permanent or life-threatening injury. During the trial, the district court limited the defendant’s cross-examination of a key witness concerning the details of his prior convictions and certain alleged credibility issues. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that there was sufficient evidence to support the conviction for assault causing serious bodily injury, and the district court did not err in limiting cross-examination, as the defendant was able to challenge the witness’s credibility adequately. The court found no reversible prosecutorial misconduct in the government’s statements during trial and concluded that the applied sentencing enhancement was supported by the record. The Eighth Circuit affirmed the district court’s judgment in all respects. View "United States v. Tetzlaff" on Justia Law

United States v. Evans

2026-05-12T07:30:51-08:00

Antonio Evans was indicted on six counts, including conspiracy to distribute and distribution of a controlled substance under federal law. These offenses allow for enhanced mandatory minimum sentences if the defendant has a prior “serious drug felony.” Evans previously was convicted under Iowa law for possession with intent to deliver cocaine, an offense meeting the statutory criteria for a serious drug felony if additional facts are established: that Evans served more than 12 months in prison and was released within 15 years before the new offense. The government filed notice before trial to seek the enhancement, and both parties requested jury instructions on the incarceration-related facts, but the district court did not submit those facts to the jury. After Evans’s conviction, and before sentencing, the Supreme Court decided Erlinger v. United States, clarifying that the Sixth Amendment requires a jury to find incarceration-related facts for such enhancements. Evans objected to the enhancement, asserting it could not be applied since no jury had found those facts. The United States District Court for the Northern District of Iowa agreed and initially planned to empanel a jury, but then vacated that order, concluding that the statutory procedure under 21 U.S.C. § 851 required the court—not a jury—to resolve the objection, creating a procedural conflict with the Sixth Amendment. The court set sentencing without the enhancement. The United States Court of Appeals for the Eighth Circuit reviewed this de novo. It held that, in this procedural posture, neither the court nor a jury could constitutionally or statutorily find the incarceration-related facts necessary to apply the enhanced mandatory minimum. The court affirmed the district court’s decision to sentence Evans without the enhancement, ruling that applying it would violate either Evans’s Sixth Amendment rights or federal statutory requirements. View "United States v. Evans" on Justia Law

Beard v. Lincoln Nat'l Life Ins. Co.

2026-05-11T07:30:55-08:00

Edward Beard, a participant in an employer-sponsored ERISA plan administered by Lincoln National Life Insurance Company, died after suffering a fall and subsequent subdural hematoma. Mr. Beard had stage IV pancreatic cancer and was taking a blood thinner due to an increased risk of blood clots. The fall occurred while he was rushing to the bathroom, and although an initial hospital visit revealed no issues, he was found unresponsive the following day and died after a second hospital visit revealed a large subdural hematoma. His wife, Tina Beard, filed a claim for accidental death and dismemberment (AD&D) benefits, asserting that his death resulted from an accidental injury. The United States District Court for the Southern District of Iowa reviewed the administrative record after Lincoln Life denied the claim. Lincoln Life concluded that Mr. Beard’s death was not solely the result of an accidental injury and invoked a plan exclusion since his blood thinner, used to treat his cancer-related clotting risk, contributed to his death. The district court granted judgment in favor of Lincoln Life, finding its interpretation of the plan reasonable and supported by substantial evidence, including medical reports indicating the blood thinner contributed to the fatal outcome. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the plan administrator’s decision for abuse of discretion, as the plan granted Lincoln Life discretionary authority to interpret its terms. The appellate court found that Lincoln Life’s interpretation of the plan terms and application of the exclusion were reasonable and supported by substantial evidence. The court held that Mrs. Beard failed to prove the loss resulted solely from an accident, and that Lincoln Life established the plan exclusion applied because the blood thinner contributed to Mr. Beard’s death. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "Beard v. Lincoln Nat'l Life Ins. Co." on Justia Law

United States v. Hayes

2026-05-11T07:30:52-08:00

After a violent home invasion, Terrance Hayes was hospitalized with multiple stab wounds, and the intruder died from gunshot wounds. Hayes told police he shot the intruder in self-defense with a gun allegedly taken from the intruder’s waistband. Subsequent police interviews with Hayes revealed conflicting accounts, and Hayes eventually admitted the gun had been in his home prior to the incident. Police found a handgun in Hayes’s residence. Hayes was later indicted for possession of a firearm by a felon, drug user, and person convicted of domestic violence, as well as possession of a stolen firearm. The United States District Court for the Northern District of Iowa, adopting a magistrate’s recommendation, denied Hayes’s motion to suppress statements made during interviews at the hospital and police station. The court found Hayes was not in custody during the initial hospital interview and that his statements at the police station were voluntary. Hayes then entered a conditional guilty plea to one count, preserving only the right to appeal the suppression ruling. The district court imposed an upwardly varied sentence of 90 months, citing Hayes’s criminal history. The United States Court of Appeals for the Eighth Circuit reviewed the suppression ruling under a mixed standard—clear error for factual findings, de novo for legal conclusions. The court affirmed the district court, holding Hayes was not in custody during the hospital interview, as his immobility was due to medical exigencies, not police restraint, and the interview was fact-finding rather than custodial. The court also found Hayes’s police station statements were voluntary and that he did not clearly invoke his right to remain silent. Finally, the court dismissed Hayes’s appeal regarding the substantive reasonableness of his sentence, as he knowingly and voluntarily waived that right in his plea agreement. View "United States v. Hayes" on Justia Law

Child v. Unum Life Insurance Co. of America

2026-05-11T07:30:50-08:00

After suffering a car accident more than 40 years ago, the plaintiff lost the use of her arms and legs and required substantial assistance with daily activities. She worked for a regional education agency for over three decades, during which her employer began offering group long-term care insurance through the defendant insurer. The policy was “guaranteed issue,” so preexisting conditions were not a barrier to enrollment, but it contained an “existing-loss provision” excluding coverage for losses of daily living activities that already existed on the policy’s effective date. The plaintiff, after consulting with both agency specialists and the insurer—without fully disclosing her limitations—enrolled in the policy and paid premiums for nearly 20 years. Upon retiring, she filed a claim for benefits based on her longstanding impairments. Her claim was denied, as her limitations predated the policy’s effective date. The plaintiff sued in state court, alleging breach of contract, fraudulent misrepresentation, and bad faith. After the case was removed to the United States District Court for the Northern District of Iowa, the defendant moved for summary judgment. The district court granted summary judgment to the insurer and dismissed the case, finding that the policy’s plain language did not cover losses existing before coverage began and that the plaintiff could not rely on the reasonable-expectations doctrine or statutory protections for preexisting conditions to obtain coverage. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The Eighth Circuit held that under the unambiguous terms of the policy and applicable Iowa law, the insurer was not required to cover losses that predated the effective date of coverage. The court also rejected the plaintiff’s arguments based on Iowa statutes, administrative rules, and the reasonable-expectations doctrine, as well as her claims for bad faith and fraudulent misrepresentation, concluding that the insurer had a reasonable basis for denial. View "Child v. Unum Life Insurance Co. of America" on Justia Law

Lupe Development Partners, LLC v. Baird

2026-05-07T07:31:35-08:00

Two plaintiffs obtained significant monetary judgments against a defendant, Deutsch, relating to a failed real estate project. Over the next several years, the plaintiffs attempted to enforce these judgments by seeking information about alleged fraudulent transfers from Deutsch to his wife, Baird, and their children. Multiple lawsuits and post-judgment discovery proceedings in Minnesota and New York courts ensued, including actions alleging Baird and her children received valuable assets as fraudulent conveyances. Repeated discovery efforts were largely unsuccessful, with courts in New York and during bankruptcy proceedings consistently finding no evidence justifying further inquiry into Baird’s finances. Despite these setbacks, the plaintiffs continued to pursue information about Baird’s assets, including through federal court subpoenas after a default judgment recognized the original state court awards. In the United States District Court for the District of Minnesota, a magistrate judge had previously limited discovery into Baird’s finances, explicitly stating that further discovery would only be permitted if the plaintiffs produced new evidence of fraudulent or voidable transactions. Ignoring this warning, the plaintiffs sought leave to depose their former counsel, the Scher Law Firm, regarding its prior investigations into the alleged fraudulent transfers. The magistrate judge denied the motion, finding that the requested discovery concerned Baird’s finances and that the plaintiffs had not presented any new evidence as required. The judge also imposed sanctions, ordering the plaintiffs to pay Baird’s costs and fees for responding to the motion, citing their willful disregard of court orders and ongoing harassment. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decisions. The Eighth Circuit held that denying the motion for leave to depose the Scher Law Firm was not an abuse of discretion, as the plaintiffs failed to meet the court’s condition for further discovery. The appellate court also upheld the imposition of sanctions, finding the plaintiffs’ conduct justified penalties and that the district court acted within its inherent authority. View "Lupe Development Partners, LLC v. Baird" on Justia Law

Bolin v. Wilkins

2026-05-07T07:31:34-08:00

Bradley Bolin was arrested in the early hours of April 1, 2020, on several misdemeanor and felony charges and was taken to the Benton County Detention Center. While in custody, Bolin was involved in multiple encounters with law enforcement officers. These included incidents in the booking area where he was tased after resisting orders, in a cell where he was shot with pepper balls while standing with his arms raised, another hallway incident where a deputy slammed him to the ground and struck him, and finally, a cell incident where he was again subjected to force, including knee strikes and taser stuns, resulting in significant injuries. The United States District Court for the Western District of Arkansas denied summary judgment to several officers who argued they were entitled to qualified immunity from Bolin’s claims under 42 U.S.C. § 1983, based on alleged excessive force in violation of the Fourteenth Amendment, as well as related state law claims. The officers appealed, challenging the denial of qualified immunity on legal grounds, including whether the evidence showed they violated clearly established rights. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s order de novo, considering the evidence in the light most favorable to Bolin. The appellate court reversed the denial of qualified immunity to Deputy Loya for his use of a taser in the Booking Lobby, finding the audio recording clearly contradicted the claim that Bolin was not resisting. However, the court affirmed the denial of qualified immunity for the other uses of force, holding that it was clearly established law that officers could not use significant force—such as pepper balls, violent takedowns, or taser stuns—against a non-threatening or non-resisting detainee under the circumstances presented. View "Bolin v. Wilkins" on Justia Law

Griffin v. OptumRx, Inc.

2026-05-06T07:30:52-08:00

A group of pharmacy benefit managers and related companies, including both benefit managers and mail-order pharmacies, were sued by the State of Arkansas in state court. The State alleged that these companies contributed to the opioid epidemic by facilitating and encouraging the misuse, abuse, and over-prescription of opioids, particularly through their negotiations with drug manufacturers for placement of opioid drugs on insurance formularies in exchange for rebates and fees. The State’s complaint asserted claims for public nuisance, negligence, and unjust enrichment under state law, and included allegations that the companies prioritized profits from rebates over public health concerns. After being sued, the defendant companies removed the case to the United States District Court for the Eastern District of Arkansas, citing the federal officer removal statute, 28 U.S.C. § 1442(a)(1), as well as the general removal statute. They argued that their actions were taken under the direction of federal officers, particularly in their roles administering federal health care programs, such as those governed by the Federal Employees Health Benefits Act (FEHBA). The State moved to remand, asserting that the complaint disclaimed any claims against federal officers or persons acting under them. The district court found the disclaimers sufficient and remanded the case to state court. On appeal, the United States Court of Appeals for the Eighth Circuit held that removal was proper under the federal officer removal statute. The court concluded that the defendant companies acted under the direction of federal officers when administering federal health plans and negotiating drug rebates, and that these actions were sufficiently related to the claims in the complaint. The court determined that the State’s disclaimers could not sever the connection between the challenged conduct and federal duties, given the indivisibility of negotiations on behalf of both federal and private clients. The Eighth Circuit therefore reversed the district court’s remand order. View "Griffin v. OptumRx, Inc." on Justia Law

Minnesota Telecom Alliance v. FCC

2026-05-06T07:30:50-08:00

Congress passed the Infrastructure Investment and Jobs Act, which included the Digital Equity Act of 2021, allocating $65 billion to expand affordable, high-speed broadband access across the United States, especially in underserved areas. The Act directed the Federal Communications Commission (FCC) to adopt rules to “facilitate equal access to broadband” and prevent “digital discrimination of access” based on characteristics such as income, race, and national origin. In response, the FCC adopted a final rule that prohibited both intentional discrimination (disparate treatment) and unintentional discrimination with disproportionate effects (disparate impact), applied to a broad range of entities influencing broadband access—not just internet service providers. Numerous telecommunications and broadband industry groups challenged this rule in several federal appellate courts. These cases were consolidated in the United States Court of Appeals for the Eighth Circuit. The industry petitioners argued that the statute did not authorize the FCC to impose liability based on disparate impact, nor to regulate entities beyond broadband providers. Public interest groups intervened to defend the rule, but also argued it did not go far enough. The Eighth Circuit reviewed the FCC’s rule under the Administrative Procedure Act. The court applied the Supreme Court’s most recent guidance on agency deference and statutory interpretation, emphasizing that courts must independently interpret statutes. It found that the statutory text did not authorize disparate impact liability and that the FCC exceeded its authority by applying the rule to entities other than broadband providers. As a result, the court held that the FCC’s rule was not in accordance with law and vacated the rule in its entirety. The court granted in part the industry petitioners’ request, denied the public interest groups’ petition, and left the FCC with the ongoing obligation to adopt lawful rules facilitating equal broadband access. View "Minnesota Telecom Alliance v. FCC" on Justia Law

United States v. Weatherspoon

2026-05-05T07:31:16-08:00

The defendant pleaded guilty to conspiring to commit wire fraud. From inside a Georgia prison, he and others targeted women in the medical profession, convincing them by phone that they had failed to appear in court and faced arrest unless they paid a bond. The scheme involved spoofing local police department phone numbers, impersonating police officers, meticulous research of victims, and coordinating with coconspirators outside the prison to collect money at bail bond companies. Over two years, two dozen victims across the country were defrauded, including some in the Southern District of Iowa. The United States District Court for the Southern District of Iowa calculated a sentencing range under the Sentencing Guidelines of 130–162 months, applying enhancements for “sophisticated means,” impersonating police officers, and for the defendant’s leadership role in a conspiracy involving at least five participants. The court denied a motion for a downward departure, finding that the defendant’s criminal history category was not substantially over-represented. The defendant challenged the application of the enhancements and the substantive reasonableness of the sentence, arguing that the scheme was not sufficiently sophisticated, that applying both enhancements for impersonation and sophistication was double counting, and that he was not an organizer or leader. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and the substantive reasonableness of the sentence for abuse of discretion. The appellate court held that the scheme was sufficiently sophisticated to warrant the enhancement, that applying both enhancements did not constitute double counting, and that the defendant’s role justified the leadership enhancement. The court found no abuse of discretion in the district court’s assessment of criminal history and concluded the sentence was reasonable. The judgment of the district court was affirmed. View "United States v. Weatherspoon" on Justia Law

Piper v. A.G.

2026-05-04T07:01:31-08:00

In 2000, Briley Piper and two others committed the murder of Chester Allan Poage in South Dakota, resulting in Piper being charged with multiple offenses, including first-degree felony murder. Prior to trial, Piper pled guilty to five crimes and was sentenced to death by the state circuit court. Over the years, Piper’s case returned to the South Dakota Supreme Court several times, both on direct appeal and in habeas proceedings. The South Dakota Supreme Court initially affirmed his conviction and sentence, later vacated the death sentence due to an invalid jury waiver, and remanded for jury resentencing. The jury again imposed a death sentence, which was affirmed. Piper then filed successive state habeas applications, challenging the validity of his guilty pleas and the effectiveness of his counsel, all of which were ultimately denied. After exhausting state remedies, Piper filed a federal habeas corpus petition in the United States District Court for the District of South Dakota, advancing thirteen claims; the district court denied relief on all, granting a certificate of appealability for several. The United States Court of Appeals for the Eighth Circuit expanded the certificate to include six claims. The court reviewed issues including the constitutionality of AEDPA deference after Loper Bright Enterprises v. Raimondo, South Dakota’s application of res judicata to preclude Piper’s challenge to his guilty pleas, the denial of an evidentiary hearing regarding alleged ineffective assistance of counsel, the adequacy of impeachment of a key witness, alleged failures to rebut a prosecution assertion about a defense witness, and cumulative prejudice. The Eighth Circuit held that AEDPA’s deference requirement remains constitutional and applicable after Loper Bright. It found Piper’s challenge to his guilty pleas procedurally defaulted under South Dakota’s consistently applied res judicata rules. The court concluded the district court did not err in denying an evidentiary hearing, found no prejudice in counsel’s performance regarding impeachment or rebuttal evidence, and reaffirmed that cumulative error does not warrant habeas relief in this circuit. The court affirmed the district court’s denial of habeas relief. View "Piper v. A.G." on Justia Law

Schlacks v. Chheda

2026-04-29T07:01:20-08:00

Two brothers, who are co-founders, directors, and major shareholders of a company, were involved in a business arrangement with a venture capital investor who was also a director and significant shareholder in the same company. The parties executed two option agreements and a partnership agreement related to the creation of a venture capital fund, which was to be capitalized with company shares. The brothers signed option agreements giving a corporate entity managed by the investor the right to acquire a portion of their shares. These agreements were twice amended, with the second amendment doubling the shares to be transferred—an action the brothers allege was done without their knowledge. Separately, a partnership agreement established the venture fund as a limited partnership under Delaware law, with all partners being corporate entities associated with the brothers and/or the investor. The partnership agreement included an arbitration clause governed by JAMS rules. When the investor’s entity tried to exercise its right to purchase shares, the brothers refused, disputing the validity of the second amendment. The investor and his entities initiated arbitration under the partnership agreement, prompting the brothers to sue for injunctions to stop arbitration. The defendants responded by moving to compel arbitration. The United States District Court for the Western District of Missouri denied all motions, including the motion to compel arbitration. The United States Court of Appeals for the Eighth Circuit reviewed the denial de novo. It held that the district court properly decided the question of arbitrability because the brothers, as non-signatories to the partnership agreement, were not bound by its arbitration clause. The appellate court further found that principles of equitable estoppel and agency law under Delaware law did not require the brothers to arbitrate, as they had not directly benefited from the agreement nor acted as agents of the signatories. The Eighth Circuit affirmed the district court’s decision. View "Schlacks v. Chheda" on Justia Law