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

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

Ward v. City of Sherwood, Arkansas

2026-04-28T07:30:50-08:00

Robert Ward brought a lawsuit against Officer Matt Harris, alleging that Harris violated his constitutional rights during an arrest that took place after officers responded to a noise complaint at Ward’s home. When the officers requested information for a report, Ward questioned their authority, used profanity, and repeatedly ignored requests to stop using foul language in the presence of children. The situation escalated, and after Ward made a reference to “Code 3,” a law enforcement term associated with urgent response, Harris arrested Ward. During the arrest, Ward resisted, leading Harris to use a takedown maneuver that resulted in Ward’s head injury. Ward was charged with disorderly conduct, resisting arrest, and public intoxication. The charges were dismissed after a year with no further violations. The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of Officer Harris on all claims, finding that Harris was entitled to qualified immunity. The court concluded that Harris had at least arguable probable cause for the arrest and that his conduct did not violate clearly established statutory or constitutional rights. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether Harris’s actions violated Ward’s clearly established rights. The Eighth Circuit held that Harris had arguable probable cause to arrest Ward for disorderly conduct under Arkansas law, as Ward’s actions could reasonably be viewed as threatening or tumultuous. The court also found no First Amendment violation, as Ward failed to provide objective evidence that others engaging in similar conduct were not arrested. Regarding the use of force, the court held that the takedown maneuver in response to resistance did not violate a clearly established right. The court further determined that the public intoxication charge did not result in a seizure to support a malicious prosecution claim. The judgment granting summary judgment to Harris was affirmed. View "Ward v. City of Sherwood, Arkansas" on Justia Law

Berkley Regional Ins. Co. v. Amazon.com, Inc.

2026-04-27T07:30:50-08:00

An employee of a Minnesota company purchased a third-party replacement battery for her cellphone through an online marketplace. The battery, sold by a Chinese company and shipped via the marketplace’s fulfillment program, malfunctioned and caused a fire, resulting in significant property damage. The employer’s insurer covered the loss and then pursued recovery from the online marketplace, the battery’s seller, and the manufacturer. The insurer’s claims against all parties except the online marketplace were eventually dropped. After the case was removed to the United States District Court for the District of Minnesota, the insurer sought to have the court certify to the Minnesota Supreme Court the question of whether the online marketplace could be strictly liable for the defect under Minnesota law. The district court, however, declined to certify the question and instead made its own prediction (“Erie guess”) that Minnesota law would not hold the marketplace strictly liable for third-party goods it fulfills but does not sell. On appeal, the United States Court of Appeals for the Eighth Circuit determined that the issue presented is novel, unsettled under Minnesota law, and implicates significant public policy concerns. The appellate court decided it was appropriate to certify the legal question to the Minnesota Supreme Court, rather than attempt its own prediction. The court certified the question of whether, under Minnesota law, an e-commerce company that allows an unrelated party to sell a defective product through its website and provides order-fulfillment services is strictly liable for harm caused by the defect. The Eighth Circuit stayed further proceedings pending the Minnesota Supreme Court’s response. The holding is that the court will certify this question to the Minnesota Supreme Court and not decide the merits of strict liability itself. View "Berkley Regional Ins. Co. v. Amazon.com, Inc." on Justia Law

United States v. Hudspeth

2026-04-24T07:30:52-08:00

Oscar Hudspeth, a member of the Oglala Sioux Tribe, was convicted by a jury of two sex abuse offenses involving his young stepdaughter, D.J., which occurred when she was between five and seven years old and living in his home. The prosecution’s evidence included D.J.’s testimony about the abuse and statements Hudspeth made during a post-polygraph interview with an FBI agent, where he admitted to inappropriate touching. Prior to trial, both parties agreed to exclude any reference to the polygraph test from evidence, and the district court admitted a redacted version of the interview transcript omitting mention of the polygraph. In the United States District Court for the District of South Dakota, Hudspeth moved to either exclude the entire interview or, alternatively, to ensure all polygraph references were redacted. When it became clear that a redacted version would be admitted, Hudspeth changed his position, seeking to admit the entire interview, including polygraph references, to provide context for his admissions. The district court admitted the redacted interview and excluded polygraph references, noting that Hudspeth had earlier agreed to the exclusion. Hudspeth was ultimately found guilty and sentenced to the mandatory minimum term. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether excluding polygraph references violated Hudspeth’s constitutional right to present a complete defense. The court held that the exclusion did not violate his constitutional rights or constitute an abuse of discretion. It found that polygraph evidence is generally unreliable and disfavored, and that the exclusion was neither arbitrary nor disproportionate. The court concluded that even if there was error, it was harmless beyond a reasonable doubt due to the strength of the prosecution’s case. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Hudspeth" on Justia Law

United States v. Hallmon

2026-04-24T07:30:51-08:00

Police in Bloomington, Minnesota, stopped a vehicle after observing a suspended object hanging from the rearview mirror and learning that the vehicle’s registered owner, Damion Kent Hallmon, had a suspended license. Hallmon was driving, accompanied by his fiancée, Ieisha McGrone, and their two children. During the stop, police observed a bag that appeared to contain marijuana, prompting a search of the vehicle. In a handbag on the front passenger seat, officers found a loaded pistol. Both Hallmon and McGrone made statements regarding the gun, with Hallmon ultimately admitting ownership and describing the firearm. Hallmon was arrested and charged with being a felon in possession of ammunition. Before trial in the United States District Court for the District of Minnesota, Hallmon moved to suppress the evidence and statements from the stop, and to dismiss the indictment on Second Amendment grounds. A magistrate judge recommended denial of the suppression motions, and the district court adopted this recommendation and denied the dismissal motion. At trial, the government presented testimony that the ammunition traveled in interstate commerce. Hallmon attempted to introduce recorded jail calls with McGrone, but the district court excluded them as hearsay. The jury found Hallmon guilty, and the district court imposed a two-level sentencing enhancement for obstruction of justice, sentencing him to 74 months’ imprisonment and three years’ supervised release. 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 stop, search, and seizure were constitutional; Hallmon was not in custody for Miranda purposes when making statements; sufficient evidence supported the interstate commerce element; exclusion of the jail calls was proper; the obstruction of justice enhancement was warranted; and existing circuit precedent foreclosed Hallmon’s Second Amendment challenge. View "United States v. Hallmon" on Justia Law

Iowa Citizens for Community Improvement v. Reynolds

2026-04-23T07:31:59-08:00

Iowa enacted a statute, Iowa Code § 727.8A, which imposes heightened criminal penalties for using cameras or electronic devices to record or transmit images or data while trespassing on private property. Five animal-welfare organizations challenged this law, alleging it violates their members’ First Amendment rights by chilling their ability to record protests and activities, especially in spaces generally open to the public where they may be asked to leave but not specifically told to stop recording. Previously, the United States District Court for the Southern District of Iowa found the statute facially unconstitutional and permanently enjoined its enforcement. However, the United States Court of Appeals for the Eighth Circuit reversed that decision, noting that the statute could be constitutionally applied in some circumstances and remanded the case for further proceedings. On remand, two groups, including Iowa Citizens for Community Improvement (ICCI), pursued as-applied challenges, contending that the law chills their speech when it is used to prevent them from recording after being asked to leave premises otherwise open to the public. The district court dismissed these as-applied challenges, finding that the statute could be applied to their conduct without violating the First Amendment. On appeal, the United States Court of Appeals for the Eighth Circuit considered whether ICCI had standing, whether the case was ripe, and whether applying the statute in these circumstances violated the First Amendment. The court found that ICCI had standing and the case was ripe. It held that applying § 727.8A to prohibit recording while trespassing—even in spaces otherwise open to the public—does not violate the First Amendment because the statute is a content-neutral, narrowly tailored time, place, and manner restriction serving Iowa’s substantial interests in protecting property and privacy rights. The court affirmed the district court’s dismissal of ICCI’s as-applied challenge. View "Iowa Citizens for Community Improvement v. Reynolds" on Justia Law

United States v. Keirans

2026-04-23T07:31:58-08:00

A man assumed the identity of a former coworker, William Woods, and used that identity for nearly three decades to obtain employment, financial accounts, and legal documents. He paid taxes and conducted virtually all aspects of his life under the stolen identity. When the real Woods, who had become homeless, tried to reclaim his identity after discovering fraudulent activity, he was unable to answer certain security questions at a bank and was mistakenly reported as the impostor. The man using Woods’s identity convinced law enforcement that Woods was the fraudster, leading to Woods’s arrest, prosecution, and incarceration. Woods spent over a year in jail and several months in a mental institution before his identity was finally vindicated through a police investigation and DNA evidence. The United States District Court for the Northern District of Iowa convicted the impostor, Matthew Keirans, after he pleaded guilty to making a false statement to a National Credit Union Administration insured institution and aggravated identity theft. The district court calculated an advisory guidelines range of 12 to 18 months, plus a mandatory 24 months, but imposed an upwardly varied sentence of 144 months’ imprisonment, citing the egregiousness of the conduct and the impact on the real Woods. The court also imposed special conditions of supervised release, requiring mental health and substance abuse evaluations and treatment if recommended, based on Keirans’s history and the deceit involved in maintaining his assumed identity. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the sentence for substantive reasonableness under the abuse-of-discretion standard. The appellate court held that the district court did not abuse its discretion in imposing either the lengthy sentence or the special conditions of supervised release, finding both to be justified by the facts and the law. The judgment of the district court was affirmed. View "United States v. Keirans" on Justia Law

Female Athletes United v. Keith Ellison

2026-04-15T07:30:56-08:00

A high school student, who is a transgender girl but was assigned male at birth, played on a varsity girls’ softball team in Minnesota under a 2016 state athletic bylaw permitting students to participate in sporting activities consistent with their gender identity. Female Athletes United (FAU), an organization advocating for women’s sports, sued Minnesota officials and local school boards, alleging that permitting the student’s participation violated the rights of its members under Title IX by denying them effective accommodation and equal treatment. FAU claimed its members suffered various harms, such as lost athletic opportunities and emotional distress, and sought a preliminary injunction to prohibit “male athletes” from competing against its members in girls’ sports involving contact or competitive skill. The United States District Court for the District of Minnesota found that FAU had standing because one member’s team was scheduled to play against the transgender athlete’s team. However, the district court denied the preliminary injunction on two grounds: first, that FAU lacked a private right of action for its Title IX claims, because they were based on a disparate impact (rather than intentional discrimination) theory, and second, that FAU failed to satisfy the requirements for preliminary injunctive relief. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court agreed that, under Title IX and controlling Supreme Court precedents, there is only a private right of action for claims of intentional discrimination, not for disparate impact. It found FAU’s claims were based on allegations of negative effects rather than intentional disparate treatment or deliberate indifference. The court concluded that FAU’s allegations did not support a claim of intentional discrimination. Thus, the Eighth Circuit affirmed the denial of the preliminary injunction, holding that FAU lacked a private right of action for its Title IX claims. View "Female Athletes United v. Keith Ellison" on Justia Law

United States v. Parrow

2026-04-15T07:30:55-08:00

Law enforcement conducted an investigation into drug trafficking activities involving Paul Parrow after a confidential informant, N.G., made several controlled purchases of various drugs from him. Surveillance linked Parrow to a residence where drugs and related paraphernalia were later found during a warranted search. At trial, multiple co-conspirators and customers testified to Parrow’s ongoing distribution of methamphetamine, heroin, and fentanyl. The defense sought to introduce the drug convictions of Clemmie Kirk, co-owner of the searched residence, to suggest Kirk’s opportunity and knowledge regarding the drugs found there, but these convictions were admitted only for impeachment, not for the purpose of establishing opportunity or knowledge under Rule 404(b). The United States District Court for the Southern District of Iowa excluded the convictions as reverse Rule 404(b) evidence and instructed the jury they could only consider them for credibility assessment. The court also addressed a discovery issue when the government failed to disclose that a witness, D.B., was the “concerned citizen” referenced in police notes. As a sanction, the court struck D.B.’s undisclosed testimony about Parrow’s drug trafficking but denied the defense’s motion for a mistrial. Parrow was found guilty by a jury of conspiracy to distribute and possession with intent to distribute controlled substances, and he received concurrent 300-month prison sentences. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court’s exclusion of Kirk’s prior convictions as reverse Rule 404(b) evidence was an abuse of discretion regarding the possession charge because the convictions were relevant to the issue of who possessed the drugs and their exclusion was not harmless. The conviction for possession with intent to distribute was vacated and remanded for a new trial. The court affirmed the district court’s judgment on all other issues, including the handling of the discovery sanction. View "United States v. Parrow" on Justia Law

Nuuh Na'im v. Beck

2026-04-15T07:30:54-08:00

An inmate at an Arkansas state prison injured his right pinky finger while playing basketball, resulting in a dislocation. He was treated initially by infirmary staff with a splint and pain medication, and an x-ray was ordered. The x-ray showed no fracture but confirmed the dislocation. After a week, a doctor and a nurse attempted to realign the finger but were unsuccessful, so they provided additional pain management and referred him to an orthopedic surgeon. The finger was reset by a specialist over a month after the original injury. The inmate followed the prison grievance process, complaining about pain, the delay in seeing a provider, and subsequent delays in receiving further care. The United States District Court for the Eastern District of Arkansas reviewed the inmate’s claims. The court dismissed the claims related to delay in care for failure to exhaust administrative remedies, as the inmate did not specifically name the doctor and nurse responsible for the alleged delay in his grievances. The district court granted summary judgment to the doctor and nurse on the remaining claim regarding their care on May 19, finding no deliberate indifference. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the inmate did not properly exhaust his administrative remedies against the doctor and nurse for claims of delayed care, since he failed to name them as required by prison policy. Further, the appellate court agreed with the district court that the care provided on May 19 did not constitute deliberate indifference under the Eighth Amendment. The court concluded that no reasonable jury could find that the medical staff acted with deliberate indifference, and thus affirmed the district court’s dismissal and grant of summary judgment. View "Nuuh Na'im v. Beck" on Justia Law

Briscoe v. St. Louis County

2026-04-10T07:30:52-08:00

Police investigated an armed carjacking in St. Louis County after using an electronic tracking feature to follow stolen AirPods, which appeared to be located at a residence on Wylin Court. Based on this information, Detective Joseph Percich applied for a search warrant and submitted an affidavit outlining the investigation and his belief that evidence related to the crime would be found at the address. A county judge issued a no-knock search warrant. The county’s SWAT team executed the warrant, forcibly entered the home, and detained the family living there, who had no connection to the carjacking. The AirPods were ultimately found in the street outside the house. The family sued St. Louis County and Detective Percich in the United States District Court for the Eastern District of Missouri. Their complaint included claims under 42 U.S.C. § 1983 for an alleged Franks v. Delaware violation (claiming the affidavit contained misstatements and omissions), excessive force in the use and conduct of the SWAT team, unreasonable seizure, municipal liability for an unconstitutional SWAT policy, and a state law claim under Missouri’s Sunshine Law. The district court dismissed all of the federal claims, granting Detective Percich qualified immunity and finding that the plaintiffs failed to state viable claims. The court also declined to exercise supplemental jurisdiction over the state law claim. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. The appellate court held that the plaintiffs did not adequately allege that Detective Percich knowingly or recklessly included false statements or omitted material information in his affidavit, so no Franks violation occurred. The court also affirmed the finding of qualified immunity for Detective Percich on the excessive force and seizure claims. The court concluded there was no sufficient allegation of an unconstitutional county policy. Finally, it upheld the district court’s decision to decline jurisdiction over the Sunshine Law claim, affirming the judgment in its entirety. View "Briscoe v. St. Louis County" on Justia Law

United States v. Farmer

2026-04-10T07:30:52-08:00

Jessie Farmer pleaded guilty in 2016 to two counts of using a communication facility to distribute methamphetamine, for which he received the statutory maximum sentence of 96 months’ imprisonment and one year of supervised release. After completing his prison term, Farmer began supervised release in 2024. The probation office later alleged that Farmer committed multiple violations of his release conditions, including missing drug tests and testing positive for drugs. The government petitioned to revoke his supervised release based on these violations. The United States District Court for the Western District of Arkansas reviewed the petition. Farmer argued that because he had already served the statutory maximum prison term for his offense, any additional imprisonment after revocation would violate his Fifth and Sixth Amendment rights unless a jury found the violations beyond a reasonable doubt. The district court denied Farmer’s motion to dismiss, found by a preponderance of the evidence that he committed ten violations, revoked his supervised release, and imposed a new prison sentence of twelve months, the statutory maximum for his supervised release violation. On appeal, the United States Court of Appeals for the Eighth Circuit considered whether Farmer’s revocation sentence under 18 U.S.C. §§ 3583(e) and 3583(g) violated his constitutional rights to due process and trial by jury. The court concluded that the relevant Supreme Court guidance, particularly the controlling concurrence in United States v. Haymond, does not require application of the Apprendi line of cases to supervised release revocations under these sections. The Eighth Circuit held that the district court’s revocation and sentence did not violate Farmer’s constitutional rights, because the statutes did not require punishment for a new offense, preserved judicial discretion, and limited the sentence to the original statutory maximum. The judgment of the district court was affirmed. View "United States v. Farmer" on Justia Law

Schmit v. Trimac Transportation, Inc.

2026-04-09T07:30:52-08:00

Jason Schmit, a truck driver for Trimac Transportation, Inc., was diagnosed with Parkinson’s disease in 2018. Following his diagnosis, Trimac provided informal accommodations, allowing Schmit to perform tasks that avoided climbing, pulling hoses, or making certain connections, and adjusting his work schedule to end earlier in the day. In 2021, after a new terminal manager was hired, Schmit was asked to formalize his accommodation requests, which Trimac largely approved. However, Schmit encountered difficulties, including changes in internal shop procedures that affected his ability to perform required tasks, disputes about hauling heavy loads, and disciplinary actions for job violations. Schmit complained to Human Resources about alleged harassment and difficulties related to his disability, but Trimac concluded its policies were being properly enforced. In August 2021, following a dispute, Schmit left work and Trimac treated his departure as a resignation. Schmit later applied for and received Social Security disability benefits, representing that his condition made it impossible for him to work. The United States District Court for the District of South Dakota dismissed Schmit’s state law claims for failure to exhaust administrative remedies and granted summary judgment to Trimac on the remaining claims. The district court found genuine disputes existed regarding whether Schmit resigned or was fired and whether there was discriminatory intent, but determined that Schmit’s statements to the Social Security Administration prevented him from showing that he was a “qualified individual” under the ADA. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that Schmit failed to adequately explain the contradiction between his representations to the Social Security Administration and his litigation position, barring his ADA claim. The court also concluded that Schmit failed to establish a hostile work environment, retaliation, or wrongful termination under South Dakota law. The judgment of the district court was affirmed. View "Schmit v. Trimac Transportation, Inc." on Justia Law

United States v. Robertson

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

Law enforcement officers in Cedar Rapids, Iowa, observed activity consistent with drug transactions in the parking lot of Jim’s Foods, a location known for narcotics activity. Officers saw a man leave a nearby house, interact with vehicles, and enter the back seat of a Chevrolet Cruze, with Antonio Clarence Robertson in the front seat. After further observation, including witnessing a hand-to-hand transaction, officers noticed the Chevy leave its parking spot and exit the lot without coming to a complete stop before entering the roadway. The officers initiated a traffic stop for violation of Iowa Code § 321.353, which requires vehicles emerging from private driveways to stop before entering public roads. A search, conducted with the driver’s consent, uncovered prescription pills and marijuana on Robertson, leading to his charge for possession with intent to distribute. The United States District Court for the Northern District of Iowa heard Robertson’s motion to suppress the evidence obtained during the stop, which he argued was unlawful because the parking lot did not qualify as a “private driveway” under Iowa law. The district court found the officers’ testimony credible regarding the private nature of the lot and concluded the stop was lawful. Robertson pled guilty but reserved his right to appeal the suppression ruling. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The appellate court held that the officers had an objectively reasonable basis to believe a traffic violation occurred, as the lot was not open to the public as a matter of right and thus was a “private driveway” within the meaning of Iowa law. The court affirmed the district court’s denial of the motion to suppress and upheld the conviction. View "United States v. Robertson" on Justia Law

United States v. Mejia

2026-04-07T07:30:55-08:00

After law enforcement officers found six grams of heroin and 453 grams of methamphetamine in Edgar Mejia’s car outside a casino, Mejia informed them he also owned a trailer. Upon searching the trailer, officers discovered a hidden compartment containing two firearms and 541 grams of heroin. Mejia attempted to have Gregory Johnson, his alleged co-conspirator, remove the drugs and guns before police could find them, but Johnson was unsuccessful. Recorded jailhouse calls captured Mejia instructing Johnson on accessing the compartment and discussing the contents and their value. Mejia faced four federal charges, pleaded guilty to possession with intent to distribute heroin and being a felon in possession of a firearm, and was tried and convicted by a jury on conspiracy to distribute heroin and possessing a firearm in furtherance of drug trafficking. The United States District Court for the Western District of Missouri sentenced Mejia to 322 months in prison and imposed supervised release conditions, including work or community service requirements. Mejia appealed, challenging the sufficiency of the evidence for his conspiracy conviction and two aspects of his sentencing: the inclusion of an expunged marijuana conviction in his criminal history calculation and the community service condition of his supervised release. The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that there was sufficient evidence to support the conspiracy conviction, as the jailhouse calls and circumstances supported a reasonable inference that Mejia and at least one other person agreed to distribute heroin. The court also concluded that any error in counting the expunged conviction was harmless because the district court made clear that the sentence would be the same regardless. The appellate court dismissed Mejia’s challenge to the community service condition as unripe, since it would not take effect for decades and was contingent on future events. The judgment of the district court was otherwise affirmed. View "United States v. Mejia" on Justia Law

North Star Mutual Ins. Co. v. Rodin

2026-04-07T07:30:54-08:00

An individual was injured while working in a farm shop operated by two defendants, allegedly due to carbon monoxide exposure from a portable heater. The farm’s liability insurance policy, issued by an insurer, covered bodily injuries occurring on the property but contained a pollution exclusion provision. The injured party filed suit in state court, claiming serious injuries caused by the carbon monoxide emission. The insurer then brought a declaratory judgment action in federal district court, seeking a determination that it was not obligated to defend or indemnify the insured farm operators for the state court suit, arguing that the pollution exclusion applied because carbon monoxide is a “pollutant” as defined by the policy. The United States District Court for the District of North Dakota granted summary judgment for the insurer. It found that the pollution exclusion in the insurance policy unambiguously barred coverage for the injuries alleged, because carbon monoxide is a gaseous contaminant and therefore a “pollutant” under the policy’s definition. The court declared that the insurer had neither a duty to defend nor indemnify the insured farm operators in the underlying state court action. On appeal, the United States Court of Appeals for the Eighth Circuit considered whether North Dakota law required a different interpretation of the pollution exclusion and whether the question should be certified to the North Dakota Supreme Court. The court declined to certify, finding that North Dakota insurance contract law was sufficiently clear. Reviewing the summary judgment ruling de novo, the court held that the policy’s pollution exclusion unambiguously excluded coverage for injuries resulting from carbon monoxide discharge and affirmed the district court’s judgment. The Eighth Circuit thus held that the insurer had no duty to defend or indemnify the insured farm operators for the injury claim arising from carbon monoxide exposure. View "North Star Mutual Ins. Co. v. Rodin" on Justia Law

Iowa Safe Schools v. Reynolds

2026-04-06T07:01:30-08:00

Several educators, parents, students, and a nonprofit organization challenged two provisions of an Iowa law affecting public schools. The law restricts classroom instruction on gender identity and sexual orientation for students in kindergarten through sixth grade and requires school officials to notify parents if a student requests accommodations affirming their gender identity, such as using a different pronoun. The plaintiffs, asserting facial constitutional challenges, argued the provisions were overbroad and vague, infringing on First Amendment and due process rights. Previously, the United States District Court for the Southern District of Iowa granted a preliminary injunction against these provisions. The district court found that the terms “program” and “promotion” in the instruction restriction were overly broad and infringed on protected speech, and determined that the parental notification law was impermissibly vague due to the undefined use of “accommodation.” The district court severed what it considered unconstitutional portions of the statutes and enjoined their enforcement. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. It held that the statutes, when read with the canon of constitutional avoidance, could reasonably be interpreted in a way that avoided constitutional problems and that the statutory language was sufficiently clear. The appellate court found the plaintiffs did not demonstrate that unconstitutional applications of the laws substantially outweighed constitutional ones in their facial challenge. It further determined that the term “accommodation” was not unconstitutionally vague. The Eighth Circuit concluded that the district court abused its discretion in granting the preliminary injunction and vacated that injunction as to all challenged provisions, remanding the case for further proceedings on the merits. View "Iowa Safe Schools v. Reynolds" on Justia Law

Penguin Random House, LLC v. Robbins

2026-04-06T07:01:29-08:00

A group of plaintiffs, including publishers, authors, educators, and a parent of a student, challenged provisions of an Iowa law (Senate File 496) requiring public school libraries to remove books containing “descriptions or visual depictions of a sex act.” The law also imposed penalties on educators who failed to comply. The plaintiffs argued that these provisions violated their First Amendment rights, both as to students’ access to information and as to the right of authors and publishers to communicate with their intended audience. The United States District Court for the Southern District of Iowa initially granted a preliminary injunction, preventing enforcement of the challenged provisions. The court concluded that the plaintiffs were likely to prevail, holding that the unconstitutional applications of the law substantially outweighed constitutional ones. It declined to apply the standard set out in Hazelwood School District v. Kuhlmeier, instead relying on the obscenity standard from Ginsberg v. State of New York and the “substantial and reasonable government interest” test from the plurality in Board of Education, Island Trees Union Free School District No. 26 v. Pico. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. The Eighth Circuit held that the Hazelwood standard—whether the restrictions are “reasonably related to legitimate pedagogical concerns”—applies to school library curation. The court determined that the Iowa law’s book restrictions addressed legitimate pedagogical concerns and were neither amorphous nor unreasonable. Because the plaintiffs could not show a likelihood of success on the merits under the correct standard, the Eighth Circuit vacated the preliminary injunction and remanded the case for further proceedings on the merits. View "Penguin Random House, LLC v. Robbins" on Justia Law

United States v. Boyer

2026-04-06T07:01:28-08:00

Alvin Boyer developed a relationship with Shayla Tilton, whose estranged husband, Freddie Tilton, confronted Boyer via threatening messages. Over several days, Boyer communicated with both Shayla and Freddie, ultimately sharing with Freddie the details of his plans to meet Shayla at a motel. At Freddie’s direction, Boyer made arrangements for Shayla to enter the motel room, unaware to Shayla that Freddie would be present. When Shayla arrived, Freddie assaulted her with a firearm and other weapons. After the incident, Boyer and Freddie exchanged messages indicating Boyer’s concern for his own safety but also referencing his role in facilitating the meeting. The case was tried in the United States District Court for the Western District of Missouri, where Boyer was charged with kidnapping and conspiracy to commit kidnapping. At trial, Boyer argued he lacked knowledge of Freddie’s intent to assault Shayla. The government introduced evidence of Boyer’s pending assault charges in Arkansas, over his objection. The jury found Boyer guilty on both counts. At sentencing, the district court imposed two concurrent 20-year sentences, below the advisory Guidelines range after considering all arguments. The United States Court of Appeals for the Eighth Circuit reviewed Boyer’s appeal, which challenged the admission of the pending charges evidence, the denial of his motion for judgment of acquittal, and the reasonableness of his sentence. The appellate court held that any error in admitting the pending charges was harmless, as the evidence of Boyer’s knowledge and involvement was substantial. The court found the evidence sufficient for a reasonable jury to convict on conspiracy. Regarding the sentence, the court concluded the district court did not abuse its discretion. The Eighth Circuit affirmed the convictions and sentence. View "United States v. Boyer" on Justia Law

Duncan v. Bayer CropScience LP

2026-04-06T07:01:27-08:00

A group of farmers and farming entities brought suit against several manufacturers, wholesalers, and retailers of seeds and crop-protection chemicals, alleging that these defendants conspired to obscure pricing data for these “crop inputs.” The plaintiffs claimed that this conspiracy, which included a group boycott of electronic sales platforms and price-fixing activities, forced them to pay artificially high prices. They sought to represent a class of individuals who had purchased crop inputs from the defendants or their authorized retailers dating back to January 1, 2014. The plaintiffs asserted violations of the Sherman Act, the Racketeer Influenced and Corrupt Organizations Act (RICO), and various state laws, seeking both damages and injunctive relief. After the cases were consolidated in the United States District Court for the Eastern District of Missouri, the defendants moved to dismiss the consolidated amended complaint. The district court granted the motion, finding that the plaintiffs failed to state a claim under the Sherman Act because they did not adequately allege parallel conduct among the defendants. The RICO claims were also dismissed with prejudice, and the court declined to exercise supplemental jurisdiction over the state law claims. The district court dismissed the antitrust claim with prejudice, noting that the plaintiffs had prior notice of the deficiencies and had multiple opportunities to amend. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo and affirmed the district court’s judgment. The appellate court held that the plaintiffs failed to adequately plead parallel conduct or provide sufficient factual detail connecting specific defendants to particular acts. It concluded that the complaint’s group pleading and conclusory allegations did not meet the plausibility standard required to survive a motion to dismiss. The court also ruled that the dismissal with prejudice was proper given the plaintiffs’ repeated failures to cure the deficiencies. View "Duncan v. Bayer CropScience LP" on Justia Law

United States v. Wilburn

2026-04-03T07:30:59-08:00

A sheriff’s deputy found Robert Wilburn asleep in the driver’s seat of a Chevrolet Camaro that was parked partially off a roadway with its hazard lights flashing. An open beer can was visible in the center cup holder, and the deputy smelled alcohol and marijuana on Wilburn. Upon searching the Camaro, the deputy found a loaded handgun next to the center console, a box of ammunition, and an extra magazine. The vehicle was registered to Samira Swift, who had purchased the firearm eleven days earlier. Wilburn, a twice-convicted felon, was on parole at the time, having been released from home confinement the day before Swift purchased the firearm. Wilburn was indicted for unlawful possession of a firearm and ammunition as a felon. The United States District Court for the Eastern District of Arkansas admitted evidence of Wilburn’s 2021 conviction for the same offense under Federal Rule of Evidence 404(b), as well as evidence that Wilburn had been released on parole shortly before the firearm’s purchase. At trial, the jury found Wilburn guilty, and the court sentenced him to 100 months in prison. On appeal to the United States Court of Appeals for the Eighth Circuit, Wilburn challenged the district court’s evidentiary rulings and argued that the evidence was insufficient to support his conviction. The Eighth Circuit reviewed the evidentiary rulings for abuse of discretion and the sufficiency of the evidence de novo. The court held that admitting Wilburn’s prior conviction and the parole release evidence was not an abuse of discretion, as both were relevant to knowledge and intent, and their probative value was not substantially outweighed by unfair prejudice. The court also concluded that the evidence was sufficient to sustain the conviction. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "United States v. Wilburn" on Justia Law

Jet Midwest International Co., Ltd v. Ohadi

2026-04-02T07:30:56-08:00

After Jet Midwest International Co., Ltd. made a $6.5 million loan to Jet Midwest Group, LLC (JMG) for the purchase of a Boeing 737-700, JMG defaulted on repayment. Jet Midwest sued for breach of contract, and when it could not collect on its judgment due to JMG’s lack of funds, Jet Midwest brought claims under the Missouri Fraudulent Transfer Act against several individuals and entities (the Ohadi/Woolley defendants), alleging the improper transfer of assets to avoid payment. Following a bench trial, Jet Midwest prevailed on its claims, and the district court awarded money damages, interest, and set a schedule for further motions on attorney’s fees and costs. Previously, the United States District Court for the Western District of Missouri awarded Jet Midwest over $6.5 million in attorney’s fees and costs. The United States Court of Appeals for the Eighth Circuit vacated this award, finding the district court had not properly performed a lodestar calculation for attorney’s fees and had not analyzed which costs were recoverable under federal law. On remand, Jet Midwest reduced its fee request but sought a multiplier; the district court ultimately awarded $5.8 million in attorney’s fees, granted prejudgment interest at 14 percent, and included expert witness fees and other litigation costs. Both sides appealed aspects of this award. The United States Court of Appeals for the Eighth Circuit held that the district court properly calculated and awarded $5.8 million in attorney’s fees but erred in awarding expert witness fees as part of attorney’s fees, as Jet Midwest failed to provide sufficient evidence that such fees were recoverable under the relevant standards. The Eighth Circuit also held that the district court erred in applying a 14 percent prejudgment interest rate and ordered that Missouri’s statutory rate of nine percent should apply. Additionally, the court clarified that, after August 6, 2020, the federal postjudgment interest rate under 28 U.S.C. § 1961(a) governs. The case was affirmed in part, reversed in part, and remanded for further proceedings consistent with these rulings. View "Jet Midwest International Co., Ltd v. Ohadi" on Justia Law

Cunningham v. Olson

2026-04-02T07:30:55-08:00

A man whose only prior felony conviction had been expunged by a Missouri state court was arrested by a Missouri State Highway Patrol trooper for possessing a firearm as a convicted felon. The trooper had accessed his criminal history report, which still listed the expunged conviction with a notation indicating it was “Closed Pursuant to Chapter 610 RSMo.” However, the Missouri State Highway Patrol did not train officers to understand this notation meant the conviction was expunged and could not serve as a basis for arrest. The man informed the trooper of his expungement at the scene, but she stated she had to rely on the report’s information. Following his arrest, the plaintiff filed suit under 42 U.S.C. § 1983 in Missouri state court, asserting claims for damages and prospective relief against the Highway Patrol’s superintendent and others. The case was removed to the United States District Court for the Western District of Missouri. The superintendent moved to dismiss the official-capacity claim on sovereign immunity grounds and the individual-capacity failure-to-train claim on qualified immunity grounds. The district court denied both motions, prompting the defendants to file an interlocutory appeal. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of immunity de novo. The appellate court held that the current superintendent was a proper Ex parte Young defendant for purposes of prospective relief, as he had sufficient connection to the dissemination practices that risked future constitutional violations. The court also held that the plaintiff had plausibly alleged a Fourth Amendment violation and deliberate indifference by the former superintendent regarding failure to train. Accordingly, the Eighth Circuit affirmed the district court’s denial of sovereign and qualified immunity. View "Cunningham v. Olson" on Justia Law

Quijano-Duran v. Bondi

2026-04-02T07:30:53-08:00

A mother and her minor daughter, both citizens of El Salvador, entered the United States in 2017 without valid entry documents. The mother applied for asylum, withholding of removal, and protection under the Convention Against Torture, claiming that a criminal gang in El Salvador had repeatedly threatened her family with violence and kidnapping in attempts to extort money. Although her family partially complied with the gang’s demands and was not physically harmed, she asserted that returning to El Salvador would put her and her children at risk, as the gang had widespread influence and the Salvadoran government could not protect them. An immigration judge found the mother's testimony not credible due to inconsistencies and determined that, even if her testimony were credible, the threats did not amount to past persecution, the alleged social groups were not cognizable, and she could relocate within El Salvador. The judge denied all claims for relief. The Board of Immigration Appeals (BIA) affirmed, concluding that she had not established past persecution or a well-founded fear of future persecution. The BIA also determined that her argument that the immigration judge was biased was waived because she raised it only in a conclusory manner and abandoned it in her appellate brief. The United States Court of Appeals for the Eighth Circuit reviewed the BIA’s decision as the final agency action. The court held that the BIA properly applied its waiver rule and did not err in finding the due process claim waived, as the argument was inadequately raised and not meaningfully pursued. The court also concluded it lacked jurisdiction to review the Department of Homeland Security’s exercise of prosecutorial discretion regarding enforcement priorities. The petition for review was denied. View "Quijano-Duran v. Bondi" on Justia Law

Galtere, Inc. v. Harvest Capital Asset Mgmt.

2026-04-01T07:01:36-08:00

The dispute arose from a business venture related to agricultural investments in Brazil. In 2007, an investment firm transferred funds totaling over $800,000 to another company to cover farm-related expenses, allegedly with the understanding that these funds would be repaid once the farm became profitable and prior to any distributions to owners. The parties later executed a written document summarizing their agreement, which stated that the investment firm would recover its funding when a newly formed management company generated fees. Despite the farm ultimately turning a profit years later, the management company never generated fees and the transferred funds were never repaid. The United States District Court for the Southern District of Iowa considered claims for breach of contract, promissory estoppel, and unjust enrichment. The court found that the written contract unambiguously set out the terms of repayment, which were not satisfied because the management company never generated fees. It also concluded that the document was fully integrated, barring admission of extrinsic evidence to vary its terms. The court granted summary judgment to the defendants on all claims, finding no genuine dispute of material fact. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the summary judgment rulings de novo. The appellate court held that the record did not contain sufficient evidence to support the claim that the written agreement was not fully integrated. It also found that the lack of an integration clause and the plaintiff’s testimony did not create a genuine dispute about integration. The court concluded that, because the contract was fully integrated, extrinsic evidence could not be used to alter its terms, and that implied contract and quasi-contract claims were precluded. The Eighth Circuit affirmed the judgment of the district court. View "Galtere, Inc. v. Harvest Capital Asset Mgmt." on Justia Law

United States v. Isham

2026-04-01T07:01:35-08:00

Mark Isham and C.K. were in a long-term relationship, living together intermittently. In March 2023, after C.K. stayed with Isham following her release from a treatment center, the two drank alcohol and argued, resulting in Isham physically assaulting C.K. on two separate occasions. Several days after the second assault, C.K., who is an amputee, called 911 and reported being held against her will and physically abused. Police officers responded to Isham’s home, spoke separately to both individuals, and eventually arrested Isham after he admitted to hitting C.K. C.K. was hospitalized and required surgery for a fractured jaw. The United States District Court for the District of Minnesota heard Isham’s pretrial motions. The court denied Isham’s motion to suppress statements he made to officers before being arrested, concluding he was not in custody during the questioning. The court also partially granted a government motion to admit evidence of Isham’s prior assaults against C.K., allowing testimony about more recent incidents but excluding older ones. At trial, the jury acquitted Isham of assault with a dangerous weapon but convicted him of assault resulting in serious bodily injury and assault resulting in substantial bodily injury to an intimate partner. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the suppression motion de novo and found that Isham was not subjected to custodial interrogation before his arrest, as the questioning was brief, non-coercive, and Isham voluntarily participated. The appellate court also held that the district court did not abuse its discretion in admitting evidence of prior assaults, finding it relevant to issues raised at trial and adequately limited by jury instructions. The judgment of the district court was affirmed. View "United States v. Isham" on Justia Law

United States v. Goodlow

2026-04-01T07:01:34-08:00

A member of the Lower Brule Sioux Tribe, the defendant moved onto the Swallow Ranch, located in the Cuny Table area of the Pine Ridge Indian Reservation, in 2022. He lived in a camper and worked as a ranch hand. During his time there, he developed a relationship with a 15-year-old girl, A.S., whom he taught to train horses and later groomed and sexually abused. The abuse occurred at various locations on and near the ranch, including a campground, a rock formation, and his camper. On one occasion, he also abused A.S.’s 12-year-old sister, N.S. The defendant further solicited nude photos from A.S. and from another minor, C.J.E., through Snapchat. When confronted by family members about the abuse, he denied the allegations and messaged N.S., urging her to claim A.S. was lying to protect himself from potential jail time. An FBI agent later investigated, uncovering evidence of the defendant’s communications and the sexual abuse. The United States District Court for the District of South Dakota tried the case. A jury convicted the defendant on multiple counts, including sexual abuse of a minor, abusive sexual contact, attempted sexual exploitation of a minor, attempted receipt of child pornography, and witness tampering. The district court denied the defendant’s motion for judgment of acquittal and sentenced him to 480 months in prison. Reviewing the appeal, the United States Court of Appeals for the Eighth Circuit affirmed the convictions for sexual abuse, abusive sexual contact, attempted sexual exploitation, and attempted receipt of child pornography, holding that sufficient evidence supported the jury’s findings. However, the court vacated the witness tampering conviction, finding insufficient evidence that the defendant contemplated a particular, foreseeable proceeding as required by law. The Eighth Circuit also vacated the entire sentence and remanded for resentencing in light of the vacated conviction. View "United States v. Goodlow" on Justia Law

Mick v. Gibbons

2026-04-01T07:01:33-08:00

A man experiencing a severe mental health crisis was shot and killed by a law enforcement officer after a prolonged standoff at his family’s ranch. Family members had contacted emergency services, reporting his deteriorating condition, threats of suicide, and the presence of firearms. Multiple law enforcement agencies responded, including the Custer County Sheriff’s Office and the Nebraska State Patrol (NSP). After failed negotiation attempts, the NSP disabled the man’s vehicle, and as he exited and approached officers unarmed, he was fatally shot by an NSP officer. The personal representative of the decedent’s estate filed a lawsuit in the United States District Court for the District of Nebraska, bringing claims under 42 U.S.C. § 1983 against various officers, the Sheriff’s Office, and the NSP training supervisor. Claims against the NSP officers in their official capacities were dismissed due to Eleventh Amendment immunity, as were claims against most officers in their individual capacities except for the officer who fired the shots. During discovery, the plaintiff served a Rule 30(b)(6) deposition subpoena on the non-party Nebraska State Patrol regarding officer training. The NSP moved to quash, citing state sovereign immunity. Both the magistrate judge and the district court denied the motion, relying on earlier circuit precedent that government entities are subject to federal discovery rules. Upon interlocutory appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of NSP’s motion to quash. The appellate court held that state sovereign immunity does, in this instance, bar enforcement of the deposition subpoena because the requested discovery was disruptive and infringed on the state’s autonomy and resources. The court clarified that prior circuit statements to the contrary were non-binding dicta and not controlling. The Eighth Circuit reversed the district court’s order. View "Mick v. Gibbons" on Justia Law

United States v. Williams

2026-04-01T07:01:33-08:00

The case involves a defendant who, along with others, participated in two separate home invasion robberies targeting the residence of Michael Robertson. Surveillance footage captured Williams and others attempting to break in one night, and returning the following night to forcibly enter, simulating a police raid. During the second invasion, gunshots were fired by others, resulting in the death of Jessica Brandon, though Williams was not armed at that time. Substantial quantities of drugs and cash were found in the home, suggesting the motive was robbery of a drug dealer. Williams was indicted in the United States District Court for the District of Nebraska on charges including murder with a firearm during a crime of violence and two counts of interference with commerce by robbery. He pleaded guilty and was initially sentenced to a total of 660 months’ imprisonment. After the Supreme Court decided in United States v. Taylor that Hobbs Act robbery does not qualify as a crime of violence under 18 U.S.C. § 924, Williams’s conviction for murder with a firearm was vacated by the United States Court of Appeals for the Eighth Circuit, which remanded the case for resentencing on the two remaining robbery counts. Upon resentencing, the district court imposed consecutive sentences of 222 months for each count, resulting in a total of 444 months. Williams appealed, arguing the district court erred in applying the sentencing package doctrine, failed to adequately explain the equal sentences for each count, and imposed an unreasonable sentence. The United States Court of Appeals for the Eighth Circuit held that application of the sentencing package doctrine was proper, the district court’s explanation was sufficient, and the sentence was not substantively unreasonable. The court affirmed the amended judgment. View "United States v. Williams" on Justia Law

Gasca v. Precythe

2026-03-31T07:31:23-08:00

A group of parolees who had been detained challenged the procedures used by the Missouri Department of Corrections for revoking parole, arguing that these procedures violated their due process rights. The plaintiffs brought a class action suit under 42 U.S.C. § 1983 on behalf of all adult parolees in Missouri who currently face or will face parole revocation proceedings. The district court issued an order in 2020 requiring the Department to implement certain changes. After further proceedings, the plaintiffs sought and were awarded attorneys’ fees for their partial success and for monitoring the Department’s compliance. The Missouri Department of Corrections appealed the district court’s fee awards, arguing that the Prison Litigation Reform Act (PLRA) limited the attorneys’ fees that could be awarded. The district court had repeatedly rejected the Department’s argument, finding that the PLRA’s fee cap did not apply because the certified class included parolees who were not detained and because some of the relief benefited non-detained parolees. The district court issued its final judgment in January 2025 and permanently enjoined the Department while awarding additional attorneys’ fees. The United States Court of Appeals for the Eighth Circuit considered whether the PLRA’s attorneys’ fee cap under 42 U.S.C. § 1997e(d) applied to the class action. The Eighth Circuit held that the fee cap does apply because the certified class consisted of individuals who are, or will be, detained during parole revocation proceedings and thus fall under the statutory definition of “prisoner.” The court also found that the PLRA’s fee cap section is not limited to actions challenging prison conditions. The Eighth Circuit vacated the fee awards and remanded the case for the district court to recalculate the fee awards in accordance with the PLRA’s limitations. View "Gasca v. Precythe" on Justia Law

Get Loud Arkansas v. Jester

2026-03-31T07:31:21-08:00

Get Loud Arkansas and other plaintiffs challenged an Arkansas State Board of Election Commissioners rule that required all voter registration applications to have a handwritten or “wet” signature, excluding digital or electronic signatures. The controversy arose after Get Loud developed an online voter registration tool, which allowed applicants to sign digitally and resulted in a significant increase in voter registrations, particularly among young voters. Following publicity about the tool’s success, the Arkansas Secretary of State instructed county clerks to reject electronically signed applications. Despite an opinion by the Arkansas Attorney General affirming the legality of electronic signatures, the Board adopted a rule requiring wet signatures, which forced Get Loud to modify its operations, reduce the effectiveness of its registration efforts, and expend additional resources. The plaintiffs filed suit in the United States District Court for the Western District of Arkansas, arguing that the rule violated the Materiality Provision of the Civil Rights Act of 1964, 52 U.S.C. § 10101(a)(2)(B), which prohibits denying the right to vote based on immaterial errors or omissions on voter registration applications. The district court found that the rule likely violated federal law and granted a preliminary injunction, preventing enforcement of the wet signature requirement. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision. The appellate court held that Get Loud had standing due to direct interference with its core activities. The court concluded that Arkansas’s rule was not material in determining voter qualifications, as election officials did not use signature type to assess eligibility and had previously accepted both wet and digital signatures without issue. The Eighth Circuit affirmed the district court’s injunction, holding that enforcing the rule violated the Materiality Provision and that the balance of equities favored the plaintiffs. View "Get Loud Arkansas v. Jester" on Justia Law

United States v. Sims

2026-03-30T07:01:38-08:00

Richard Sims was charged with several offenses stemming from a conspiracy to distribute methamphetamine. In October 2023, he pleaded guilty to five counts and a forfeiture allegation without a plea agreement. Before sentencing, Sims sought to withdraw his guilty plea, citing confusion about the consequences of the plea, diminished mental capacity due to prior brain surgeries, and health issues including cancer and vision and hearing impairments. He also requested new counsel. The district court held a status conference, denied his motion to withdraw the plea, but granted his request for new counsel. Following this, the United States District Court for the Western District of Missouri sentenced Sims in January 2025. The advisory Sentencing Guidelines range for his offenses was 360 months to life in prison. The government requested a 360-month sentence, while Sims, referencing his acceptance of responsibility and serious health problems, requested the statutory minimum of 120 months. The district court considered Sims’s health issues and age but also noted his significant criminal history and the seriousness of the offense, ultimately imposing a below-guidelines sentence of 240 months. On appeal to the United States Court of Appeals for the Eighth Circuit, Sims challenged the district court’s denial of his motion to withdraw his guilty plea and the substantive reasonableness of his sentence. The appellate court held that Sims’s general claims of ineffective assistance of counsel were not supported by the record and were more appropriate for post-conviction proceedings. It further found that the district court did not err in concluding Sims was competent to plead guilty and was not required to order a competency evaluation. Regarding sentencing, the Eighth Circuit determined that the district court properly considered Sims’s health and other relevant factors, and did not abuse its discretion in imposing a 240-month sentence. The appellate court affirmed the district court’s judgment. View "United States v. Sims" on Justia Law

Missouri River Energy Services v. FERC

2026-03-30T07:01:37-08:00

Missouri River Energy Services provides electricity to municipal utilities in several Midwest states and joined the Southwest Power Pool, an independent regional transmission organization, in October 2015. Prior to Missouri River’s integration, Southwest Power Pool had already allocated all available long-term firm transmission rights, which are financial instruments designed to protect load-serving entities from congestion charges on the transmission grid. Since joining, Missouri River has requested long-term transmission rights but has not received any, because existing rights holders had already claimed the available capacity. After repeatedly receiving no long-term rights, Missouri River filed a complaint with the Federal Energy Regulatory Commission (FERC) in 2023. Missouri River argued that the allocations by Southwest Power Pool violated both the governing tariff and FERC’s Order No. 681, and that FERC’s rejection of its complaint was arbitrary and capricious. FERC denied the complaint, finding no violation of the tariff or Order No. 681, and determined that Missouri River was not entitled to a specific allocation of long-term rights under federal law or the tariff. Missouri River then sought review in the United States Court of Appeals for the Eighth Circuit. The court held that the Federal Power Act and Order No. 681 require that long-term transmission rights be made available to the class of load-serving entities, but do not guarantee individual entities such as Missouri River a specific allocation. The court further concluded that Southwest Power Pool had properly implemented its tariff, including the simultaneous feasibility test and procedures for handling parallel flows and shift factors, and that FERC’s decision was supported by substantial evidence. The Eighth Circuit denied Missouri River’s petition for review, upholding FERC’s order. View "Missouri River Energy Services v. FERC" on Justia Law

Woods v. City of St. Louis, Missouri

2026-03-30T07:01:36-08:00

After being employed by the City of St. Louis as a corrections officer for over two decades, the plaintiff was transferred to a clerk typist position in the City’s towing division following an injury. In her new role, she uncovered and reported numerous instances of apparent misconduct and fraud involving the unlawful sale or transfer of vehicles by employees at the tow lot. She conveyed her concerns to various city officials, including her supervisors, the mayor’s office, and the comptroller’s office, and ultimately disclosed the information to the media. Following these disclosures, she experienced workplace retaliation and was ultimately terminated by the Director of the Department of Streets the day after a news story, which included information she had provided, was broadcast. The United States District Court for the Eastern District of Missouri dismissed the First Amendment claim against the City but allowed the First Amendment retaliation claim against the Director, in his individual capacity, to proceed to trial. The jury found in favor of the plaintiff, concluding that her protected speech was a motivating factor in her termination, and awarded compensatory and punitive damages. The district court denied the Director’s post-trial motions for judgment as a matter of law and for a new trial. The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the Director failed to preserve his qualified immunity defense for appeal and found that there was sufficient evidence for the jury to find that the plaintiff’s protected speech motivated her termination. The court further determined that the district court did not abuse its discretion in admitting contested evidence or in denying a new trial, and that there was enough evidence for punitive damages. The Eighth Circuit affirmed the district court’s judgment. View "Woods v. City of St. Louis, Missouri" on Justia Law

Holt v. Payne

2026-03-27T07:01:26-08:00

An inmate in an Arkansas maximum-security unit, who is Muslim, challenged a change in prison policy regarding meals served during Ramadan. Previously, fasting Muslims received a “double-portion” dinner after sunset and a standard breakfast before dawn. In 2023, the prison discontinued the double-portion dinner, providing only standard portions for both meals, but continued to serve them at the appropriate times for religious observance. The meals together provided at least 2,000 calories per day. The inmate often skipped the provided breakfast during Ramadan, preferring to eat commissary food instead, which he could easily obtain. The United States District Court for the Eastern District of Arkansas, Central Division, granted summary judgment to the prison officials, concluding that the new meal policy did not violate the inmate’s rights under the Eighth Amendment or the Religious Land Use and Institutionalized Persons Act (RLUIPA). The court found that the inmate’s allegations of hunger and physical symptoms were not corroborated by medical evidence, and that the inmate’s ability to supplement with commissary food meant he was not denied adequate nutrition. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the prison’s policy did not impose a substantial burden on the inmate’s religious exercise under RLUIPA. The court emphasized that the inmate’s claimed need for 3,000 calories was not rooted in religious belief, but rather based on the institution’s general meal plan. The record showed that the meals provided were nutritionally adequate and that the inmate voluntarily skipped breakfast, supplementing from the commissary. Because the inmate failed to show a genuine dispute of material fact regarding a substantial burden on his religious exercise, the Eighth Circuit affirmed the district court’s judgment. View "Holt v. Payne" on Justia Law

Lozano v. United States

2026-03-27T07:01:25-08:00

In 2005, John Lozano pleaded guilty to four federal felony charges, including conspiracy to distribute methamphetamine and firearm offenses. Due to prior felony convictions, including a Missouri marijuana conviction, Lozano was classified as a career offender under the federal sentencing guidelines, resulting in an enhanced sentence of 322 months. In 2022, Missouri adopted a constitutional amendment legalizing certain marijuana offenses and requiring the expungement of related nonviolent convictions. In 2023, Lozano’s prior marijuana conviction was vacated by a Missouri court under this amendment. After the expungement, Lozano filed a motion under 28 U.S.C. § 2255 in the United States District Court for the Western District of Missouri, seeking to vacate his federal sentence. He argued that the vacated marijuana conviction should not have counted toward his career offender status. The government moved to dismiss, contending that Lozano’s motion was “second or successive” because he had previously filed § 2255 motions in 2009 and 2016, and that the expungement did not affect his guidelines calculation because it was not based on legal error or innocence. The district court granted the motion to dismiss on both grounds. Reviewing the case, the United States Court of Appeals for the Eighth Circuit held that Lozano’s motion was not “second or successive” under § 2255 because his claim was newly ripe, arising only after his conviction was expunged in 2023. Nonetheless, the court concluded that the Missouri expungement order did not warrant resentencing. Under the federal guidelines, only convictions vacated due to innocence or legal error are excluded from career offender calculations; Lozano’s expungement was not based on such grounds. Accordingly, the Eighth Circuit affirmed the dismissal of Lozano’s § 2255 motion. View "Lozano v. United States" on Justia Law

United States v. Kaeding

2026-03-27T07:01:24-08:00

The case concerns a defendant who, during the early months of the COVID-19 pandemic, submitted multiple fraudulent applications for Paycheck Protection Program (PPP) and Economic Injury Disaster Loans (EIDL) using false information and forged documents. The defendant, with family members, obtained over $650,000 in loan proceeds by falsely representing the status and finances of various companies. The fraudulent scheme was uncovered when a lender alerted authorities to suspicious details in one application. Law enforcement executed a search warrant at the defendant’s home, conducted an interview, and discovered evidence of fraud. After initial plea negotiations failed, the defendant traveled to Colombia and did not return voluntarily, prompting an international effort that resulted in his apprehension and extradition to the United States. The United States District Court for the District of Minnesota presided over pretrial matters, including the defendant’s motions to suppress statements made during the home search, requests for new counsel, and pretrial detention issues. The court denied motions to suppress, finding the defendant was not in custody during the interview, and conducted extensive Faretta hearings to confirm the defendant’s voluntary waiver of counsel and decision to proceed pro se. The defendant’s requests for continuances and additional trial accommodations were denied, and the trial proceeded with standby counsel reappointed partway through. The jury convicted the defendant on all counts, and the court applied a sentencing enhancement for obstruction of justice based on the defendant’s actions in fleeing to Colombia. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The appellate court held that the defendant was not in custody during the initial interview, his waiver of counsel was knowing and voluntary, the denial of continuances and trial accommodations did not deprive him of a fair trial, and the obstruction-of-justice sentencing enhancement was properly applied. The district court’s judgment was affirmed. View "United States v. Kaeding" on Justia Law

United States v. Opdahl

2026-03-27T07:01:23-08:00

The defendant lived with his parents in Fargo, North Dakota. One evening, after his mother found him inhaling compressed air, an argument ensued. During the dispute, the defendant left the room and returned with a gun, firing it into the ceiling. He refused to relinquish the firearm, pointed it at himself, and then at his father. Law enforcement, including SWAT negotiators, were called and, after several hours, the defendant surrendered. A search of the home revealed several firearms, including a Polymer80 pistol with an attached Glock switch (a machinegun conversion device), a silencer, and various firearm parts and ammunition in the basement, which was the defendant's bedroom. The United States District Court for the District of North Dakota reviewed the case. The defendant was charged with possession of a machinegun and possession of a firearm silencer. He moved to dismiss the indictment, arguing it failed to state the essential elements of the offenses, specifically the knowledge requirement. The district court denied the motion. At trial, a jury convicted the defendant on both counts, finding sufficient evidence of his knowledge regarding the characteristics of the firearms. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the indictment was legally sufficient and whether the evidence supported the convictions. The court held that the indictment sufficiently alleged the required knowledge element by tracking the statutory language and including phrases such as “knowingly possess.” The court also found that circumstantial evidence and the defendant’s statements supported the jury’s finding that he knew the pistol was capable of automatic fire and that he knowingly possessed the silencer. The Eighth Circuit affirmed the district court’s judgment, upholding both convictions. View "United States v. Opdahl" on Justia Law

Cincinnati Insurance Company v. Rymer Companies, LLC

2026-03-27T07:01:23-08:00

A tornado struck Goodhue County, Minnesota, damaging the roof of a mall owned by Rymer Companies, LLC. The roof had preexisting water damage, and the dispute centered on whether the insurance company, Cincinnati Insurance Company, was liable only for the tornado-related damage or for the cost of a full roof replacement, which was necessary to comply with local building codes. Cincinnati estimated its liability at about $10,000 for the tornado damage, while Rymer argued that a new roof was required, costing up to $1.7 million. After the parties could not agree, Cincinnati initiated a declaratory judgment action in federal court, and an appraisal panel awarded $23,226 for "mall roof repair." The United States District Court for the District of Minnesota initially concluded that any increased repair costs were Rymer’s responsibility, finding that the costs resulted from preexisting damage rather than the tornado. On appeal, the United States Court of Appeals for the Eighth Circuit held that it was sufficient if the tornado was a "but-for" cause of the county’s enforcement of the building code, and remanded the case for further proceedings, including clarification of the ambiguous appraisal award. Upon remand, the district court sought clarification from the appraisal panel as to whether the award covered repairs to the roof’s surface or just the flashing. The majority of the panel clarified that only flashing replacement was included. Rymer attempted to introduce later statements by the panel’s umpire to expand the scope of the award, but the district court held that such testimony is relevant only to allegations of panel misconduct, not to reinterpret or enlarge an award. The United States Court of Appeals for the Eighth Circuit affirmed this decision, holding that under Minnesota law, district courts may seek clarification of ambiguous appraisal awards, and that appraiser testimony cannot be used to expand or alter an award unless there is evidence of fraud or wrongdoing. View "Cincinnati Insurance Company v. Rymer Companies, LLC" on Justia Law