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

Jamestown Villas v. State Farm

2026-09-04T07:30:13-08:00

A hailstorm caused damage to the roofs of nine condominium units owned by a homeowners’ association in Minnesota. The damage was mainly to roof-valley metals, which required the replacement of surrounding shingles. The association and its insurer, State Farm, agreed that repairs were necessary, but disagreed on whether available replacement shingles met the policy requirement of being of “like kind and quality.” This determination would affect whether State Farm needed to pay for full roof replacement or just repairs to the damaged sections. To resolve the dispute, the association invoked the insurance policy’s appraisal provision. A three-member panel was formed, consisting of appraisers selected by each party and an umpire. The panel inspected the site and evaluated the replacement shingles. By a two-to-one vote, it awarded $52,482.81 as the total replacement cost, rejecting a more expensive full reroofing. The panel’s answers to clarification questions about the appearance of the shingles caused confusion, but further clarification revealed that all the replacement shingles were the same, with differences in appearance attributed to factors like shading or fading. The United States District Court for the District of Minnesota reviewed the appraisal award, sought clarification from the panel, and ultimately granted summary judgment in favor of State Farm, confirming the award. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under Minnesota law, appraisal awards are given every presumption of validity and are binding unless ambiguous. The panel’s award was clear and not ambiguous, and the panel had settled the dispute over whether the replacement shingles were of “like kind and quality.” The Eighth Circuit affirmed the district court’s judgment, confirming the appraisal award and rejecting further review of the adequacy of the amount. View "Jamestown Villas v. State Farm" on Justia Law

Sack v. City of St. Louis

2026-09-04T07:30:13-08:00

A former applicant for the position of police commissioner in St. Louis alleged that after a competitive selection process, he and another white male candidate were certified as the only eligible finalists. The mayor publicly stated she did not want to select either finalist because both were white males, emphasizing the city’s diversity. The city then abandoned the original selection process, reopened the search with lower minimum qualifications, and ultimately hired a different white male candidate after two Black finalists withdrew. The plaintiff, who was ranked first and asserted he was entitled to the position under civil service rules, claimed the process was reopened solely due to the race of the finalists. The United States District Court for the Eastern District of Missouri denied the defendants’ motion to dismiss on the grounds of failure to state a claim and qualified immunity. The court found that the plaintiff had plausibly alleged an adverse employment action and a violation of clearly established equal protection rights, relying on the Supreme Court’s decision in Ricci v. DeStefano, which prohibits invalidating a selection process based on race. The defendants argued that the plaintiff suffered no adverse employment action since a white male was ultimately selected and asserted that the plaintiff had no entitlement to the promotion. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed only the denial of qualified immunity. The appellate court held that, accepting the allegations as true, the complaint sufficiently alleged that the defendants’ actions violated the plaintiff’s clearly established right to equal protection by reopening the hiring process for racial reasons and denying him promotion. The court also found the complaint adequately alleged personal involvement by each defendant. The Eighth Circuit affirmed the district court’s order denying qualified immunity and left the underlying claims to be resolved in further proceedings. View "Sack v. City of St. Louis" on Justia Law

United States v. Dubray

2026-09-04T07:30:12-08:00

Three men, including Dubray, went to a woman’s home in South Dakota intending to confront another individual about an alleged assault earlier that day. One of Dubray’s companions kicked open the locked door, and two entered the house while Dubray remained outside. After an altercation inside, Dubray allegedly kicked the homeowner in the face as she tried to close the door. Dubray, along with the others, was charged with first degree burglary, two counts of assault with a dangerous weapon, and witness tampering. At trial, Dubray was convicted on the burglary and assault counts but acquitted of witness tampering. The United States District Court for the District of South Dakota presided over Dubray’s trial, where he challenged various evidentiary rulings and jury instructions. The district court excluded testimony about 911 calls made from the home, denied Dubray’s proposed jury instruction regarding the “open to the public” status of the home, admitted photographs of the crime scene, and denied motions for judgment of acquittal and for a new trial. Dubray appealed these decisions. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not err in excluding the sheriff’s testimony about 911 calls, as it was not probative of the home’s public status and risked confusing the jury. The district court properly refused Dubray’s proposed jury instruction, given the lack of evidentiary support and reliance on inapplicable law. The appellate court concluded that the photographs and related testimony were properly admitted, and any speculative testimony was prompted by Dubray’s own questioning. The court found sufficient evidence to support the jury’s verdict and affirmed the district court’s denial of Dubray’s motions for judgment of acquittal and for a new trial. The Eighth Circuit affirmed Dubray’s conviction and sentence. View "United States v. Dubray" on Justia Law

WPX Energy Williston, LLC v. Jones

2026-09-04T07:30:11-08:00

WPX Energy, a non-Indian oil and gas company, obtained rights-of-way from the Bureau of Indian Affairs to access land owned by members of the Three Affiliated Tribes on the Fort Berthold Reservation. The Fettigs, tribal members and landowners, consented to the grants and also entered into side letter agreements with WPX Energy, imposing conditions such as prohibiting smoking and hunting, and specifying fines for violations. In 2020, the Fettigs filed suit in the Three Affiliated Tribes District Court, alleging WPX Energy violated the no-smoking provision. WPX Energy argued that the tribal court lacked jurisdiction, as it is a non-Indian entity, but the tribal district court, through Judge Jones, found it had jurisdiction under the Montana consensual relationship exception. The Fettigs also pursued an administrative claim with the Bureau, which was denied on the basis that the side letter agreements were not incorporated into the grants. WPX Energy sought a preliminary injunction in the United States District Court for the District of North Dakota, claiming the tribal court lacked jurisdiction. The district court granted the injunction, but the United States Court of Appeals for the Eighth Circuit previously vacated it, requiring exhaustion of tribal remedies. After the Three Affiliated Tribes Supreme Court affirmed tribal jurisdiction, WPX Energy again sought relief in federal court, which again granted a preliminary injunction. Judge Jones appealed this second grant. On review, the United States Court of Appeals for the Eighth Circuit held that the tribal court had jurisdiction under the first Montana exception because the dispute arose from a commercial relationship created by the side letter agreements, which were independently negotiated and not governed by federal law. The court also found that normal litigation costs did not constitute irreparable harm. The Eighth Circuit vacated the preliminary injunction and remanded for further proceedings. View "WPX Energy Williston, LLC v. Jones" on Justia Law

The Iowa Farm Sanctuary v. Univ. of MO Vet Health Center

2026-09-03T07:30:28-08:00

Employees of a nonprofit animal sanctuary took possession of six injured sheep following a highway accident in Missouri, after being authorized to do so by a law enforcement officer. The sanctuary’s director transported the sheep to a university veterinary hospital and paid a deposit for care. With the director’s consent, two sheep were euthanized due to critical injuries. Subsequently, the hospital denied the sanctuary further information about the remaining sheep, citing the arrival of the owner. The sanctuary was also denied access to the sheep and their medical records. Shortly thereafter, the sanctuary learned that, at the owner’s direction, the four remaining sheep had been euthanized. The sanctuary’s state court action for recovery of the sheep became moot when it was discovered the sheep were deceased. The Iowa Farm Sanctuary and its director then filed a federal lawsuit in the United States District Court for the Western District of Missouri against the university, its veterinary hospital, and certain personnel, alleging violations of procedural and substantive due process under the Fourteenth Amendment, and an unreasonable seizure under the Fourth Amendment. The district court dismissed the complaint, ruling that Missouri’s lien laws provided an adequate remedy for the loss, and that the complaint otherwise failed to state a claim. The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court held that the plaintiffs lacked standing to seek injunctive relief, as the alleged future injury was too speculative. On the merits, the court found that the existence of an adequate post-deprivation remedy under Missouri law precluded the procedural due process claim. The court further held that the complaint did not plausibly allege a substantive due process violation, nor was there an unreasonable seizure under the Fourth Amendment, as the euthanasia was performed with the owner’s consent. The district court’s judgment was affirmed, except that the injunctive relief claim was dismissed without prejudice. View "The Iowa Farm Sanctuary v. Univ. of MO Vet Health Center" on Justia Law

BNSF Railway Co. v. Dept. of Labor

2026-09-03T07:30:28-08:00

Dale Gourneau worked as a carman for BNSF Railway Company, inspecting railroad cars to ensure compliance with safety regulations. In January 2020, BNSF terminated Gourneau following a disciplinary proceeding. Gourneau subsequently filed a whistleblower complaint with the Occupational Safety and Health Administration of the Department of Labor, alleging that BNSF unlawfully retaliated against him for reporting hazardous safety conditions in good faith. After administrative proceedings, an Administrative Law Judge found in favor of Gourneau, ordering reinstatement, backpay, compensatory damages, punitive damages, and attorneys’ fees. The Administrative Review Board affirmed the ALJ’s decision and order. BNSF petitioned the United States Court of Appeals for the Eighth Circuit for review, arguing that the Department’s process violated the company’s Seventh Amendment right to a jury trial. The United States Court of Appeals for the Eighth Circuit examined whether the administrative adjudication of Gourneau’s claims for legal remedies—liability, backpay, compensatory damages, and punitive damages—implicated the Seventh Amendment. The court determined that Gourneau’s claim was analogous to a common-law wrongful discharge action and sounded basically in tort, entitling BNSF to a jury trial. The court rejected arguments that the “public rights” exception allowed agency adjudication without a jury trial, finding that Gourneau’s claim was a standalone suit between private parties and not so integrated into a regulatory scheme as to justify agency resolution without a jury. The court concluded that Congress may not avoid a jury trial by assigning such disputes to an agency. The Eighth Circuit granted the petition for review, vacated the order of the Administrative Review Board, and remanded the case for further proceedings consistent with its opinion, holding that BNSF is entitled to a jury trial on Gourneau’s claims for legal remedies before any equitable claims are adjudicated. View "BNSF Railway Co. v. Dept. of Labor" on Justia Law

Pennsylvania Insurance Co. v. Federal Express Corp.

2026-09-03T07:30:26-08:00

Sonia Breslow purchased a $250,000 watch from Jacob & Company, which was shipped from New York to the Iron Horse Golf Club in Montana. The Club repackaged the shipment and sent it via Federal Express (FedEx) “priority overnight” to a UPS store in Arizona. The shipping label did not declare a value for the package. Video evidence showed that after FedEx took possession, the yellow bag containing two boxes was no longer secured by a zip tie, and at the Scottsdale facility, an employee removed one box from the bag. Ultimately, FedEx delivered the bag to the UPS store, but the watch was missing. Sonia filed an insurance claim, and Pennsylvania Insurance paid the Breslows the purchase price, then sued FedEx as their subrogee. Pennsylvania Insurance initially brought claims for negligence, conversion, unjust enrichment, breach of contract, and civil theft in Nebraska state court. FedEx removed the case to the United States District Court for the District of Nebraska. The district court ruled that the Airline Deregulation Act preempted the claims for negligence, unjust enrichment, and civil theft, dismissed the conversion claim for lack of evidence, and found breach of contract but limited FedEx’s liability under the shipping contract to $100. The case proceeded to a bench trial, where the court found the breach and upheld the liability limit, entering judgment for Pennsylvania Insurance in the amount of $100. The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The court held that the Airline Deregulation Act preempts state-law claims relating to FedEx’s package handling and transportation services. It found no error in the district court’s dismissal of the conversion claim and upheld the liability limit of $100, concluding that the Club had adequate notice and opportunity to purchase greater coverage. The court also affirmed that Pennsylvania Insurance had standing as subrogee and that FedEx breached the contract. View "Pennsylvania Insurance Co. v. Federal Express Corp." on Justia Law

XTO Energy, Inc. v. Commerce and Industry Ins. Co.

2026-09-03T07:30:25-08:00

After an explosion and fire at an oil and gas well in North Dakota, XTO Energy, Inc., the well’s owner and operator, sought insurance coverage for compensation paid to injured workers. XTO had retained Missouri Basin as a contractor, and their agreement required Missouri Basin to maintain insurance supporting indemnity obligations. Missouri Basin obtained a second-layer umbrella policy from Commerce and Industry Insurance Company. This policy contained a pollution exclusion, which could be avoided if five specific conditions in a “time element exception” were met, including a requirement that any pollution incident be reported to Commerce within twenty-one days of being known to the insured. XTO failed to provide this notice within the required timeframe. Berkley National Insurance Company, another insurer, initially sought a declaration in the United States District Court for the District of North Dakota that it owed no indemnity obligation due to a pollution exclusion in its policy. XTO counterclaimed against Berkley and brought a third-party complaint against Commerce, seeking coverage. The district court granted summary judgment to XTO, finding that although XTO had not met the notice requirement, Commerce had waived this defense by not objecting promptly, and that Commerce failed to demonstrate prejudice from the late notice. The court ultimately ordered Commerce to pay damages to XTO. On appeal, the United States Court of Appeals for the Eighth Circuit found that the pollution exclusion in Commerce’s policy unambiguously barred coverage for XTO’s claim. The court held that XTO failed to satisfy the conditions of the time element exception, and Commerce did not waive its right to deny coverage by relying on the exclusion rather than on late notice. The court also held that North Dakota law did not require Commerce to show prejudice in these circumstances. Additionally, the court concluded that exceptions in Berkley’s policy were not incorporated into Commerce’s policy. The Eighth Circuit reversed the district court’s judgment and vacated the award. View "XTO Energy, Inc. v. Commerce and Industry Ins. Co." on Justia Law

B. P. v. Blanche

2026-09-02T07:30:11-08:00

B.P., a citizen of Guatemala, entered the United States unlawfully in 2001. In 2016, he was coerced by a cartel member to sell cocaine until his arrest in 2018. Afterward, he cooperated with the Drug Enforcement Agency as a confidential informant, aiding in the convictions of cartel members. Following his cooperation, he pleaded guilty to conspiracy to distribute a controlled substance and received a reduced sentence. The Department of Homeland Security issued a final administrative removal order against him in November 2020 due to his aggravated felony conviction. B.P. feared torture if removed to Guatemala and underwent a reasonable-fear interview, which he initially failed, but the Immigration Judge vacated that finding and placed him in withholding-only proceedings. The Immigration Judge denied B.P. relief under asylum, withholding of removal, and deferral of removal under the Convention Against Torture (CAT), finding his testimony not credible and insufficient. B.P. appealed only the CAT denial to the Board of Immigration Appeals (BIA), which remanded for additional fact-finding. On remand, the IJ again denied CAT relief, and the BIA affirmed and dismissed his second appeal. B.P. then petitioned the United States Court of Appeals for the Eighth Circuit for review. The United States Court of Appeals for the Eighth Circuit held that it lacked jurisdiction to review B.P.'s petition, as he sought review only of a CAT order, which is not a final order of removal under 8 U.S.C. § 1252(a)(1). The court further determined that equitable tolling does not apply to the 30-day filing deadline for petitions for review of removal orders. Consequently, the court dismissed B.P.'s petition for review. View "B. P. v. Blanche" on Justia Law

Perez v. Blanche

2026-09-02T07:30:10-08:00

A citizen of Mexico, after experiencing psychological and physical abuse during childhood and a troubled relationship as a teenager, attempted to enter the United States in 2019. She was apprehended at the border, ordered removed, and deported. She attempted entry again later that year, was again detained, and the prior removal order was reinstated and executed. In 2020, she unlawfully entered the country and lived with her child’s father. She was arrested in 2025 for driving without a license. Following her arrest, the Department of Homeland Security served her with a notice of intent to reinstate the previous removal order. She expressed fear of returning to Mexico and was referred to an asylum officer for a reasonable fear determination. The asylum officer found she did not have a reasonable fear of persecution or torture if returned to Mexico. She sought review by an immigration judge, who affirmed the asylum officer’s negative finding. Without a positive reasonable fear determination, she was not eligible to apply for withholding of removal or deferral of removal under the Convention Against Torture. She then petitioned the United States Court of Appeals for the Eighth Circuit for review of the immigration judge’s decision. The United States Court of Appeals for the Eighth Circuit held that it lacked jurisdiction under 8 U.S.C. § 1252(a)(1) to review the immigration judge’s decision affirming the asylum officer’s negative reasonable fear finding. The court determined that such a decision is not a “final order of removal,” nor does it affect the validity of a final order of removal. As such, the petition for review was dismissed for lack of jurisdiction. The government’s motion for summary disposition was denied as moot. View "Perez v. Blanche" on Justia Law

Union Pacific Railroad Company v. STB

2026-08-31T07:30:16-08:00

A municipal corporation operating a large regional commuter rail system in the Chicago area provided rail service on lines owned by a freight rail company. For decades, this service was conducted under a series of agreements, but in 2019, the freight rail company announced it would cease operating the commuter trains. Following litigation, the freight company obtained a declaratory judgment that it had no ongoing obligation to provide such service. While the commuter rail operator began transitioning to run the service itself, the parties failed to reach agreement on compensation for continued use of the lines. With no long-term agreement in place and negotiations at an impasse, the commuter rail operator applied to the federal Surface Transportation Board for terminal trackage rights, which would allow it to use the lines despite the lack of agreement. The Surface Transportation Board granted the application, finding the lines to be terminal facilities for a reasonable distance from the terminal, and that the use would be practicable, in the public interest, and not substantially impair the freight carrier’s operations. The Board did not set compensation or use conditions at that time but pledged to do so retroactively if the parties could not agree. The freight rail company sought review of this decision in the United States Court of Appeals for the Eighth Circuit. The Eighth Circuit held that the Board acted within its statutory authority in granting terminal trackage rights to the commuter operator, including over the full extent of the lines at issue, and properly concluded the public interest was served. However, the court found that the Board erred by granting immediate rights without first ensuring that compensation was paid or adequately secured, as required by statute. The court vacated the Board’s order and remanded for further proceedings, allowing time for the parties to address compensation. View "Union Pacific Railroad Company v. STB" on Justia Law

Fitil v. Riley

2026-08-31T07:30:15-08:00

During the aftermath of George Floyd’s death, Tosun Fitil participated in a protest in Omaha, Nebraska, holding a sign to honor Floyd and Zachary Bear Heels. The Omaha Police Department deployed numerous officers, including SWAT member Justyn Riley. When unrest escalated, officers responded to thrown water bottles with pepper balls, which further intensified the confrontation. Amidst this, Fitil stepped forward to confront the officers. As rocks were thrown toward Officer Riley, he threw a flashbang device that detonated near Fitil’s head, causing serious injuries including burns, ruptured eardrums, concussion, and lasting hearing and balance problems. Fitil filed suit in the United States District Court for the District of Nebraska, asserting claims under 42 U.S.C. § 1983 for violations of his First Amendment rights (free speech and assembly) and the Fourth Amendment (excessive force). At summary judgment, the district court denied qualified immunity for both claims, finding that factual disputes remained and a reasonable jury could conclude Riley had effectuated a seizure by deploying the flashbang. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court determined that it had jurisdiction only to address the denial of qualified immunity on the Fourth Amendment claim, not the First Amendment claim, because the district court had not explicitly ruled on qualified immunity for the latter. The Eighth Circuit held that the law was not clearly established regarding whether the use of a flashbang in an open area to disperse protestors amounted to a seizure under the Fourth Amendment. Therefore, it reversed the district court’s denial of qualified immunity on the excessive force claim, dismissed the remainder of the appeal for lack of jurisdiction, and remanded for further proceedings. View "Fitil v. Riley" on Justia Law

Jim Daws Trucking, LLC v. Daws, Inc.

2026-08-31T07:30:15-08:00

After purchasing a trucking company through an asset purchase agreement, Jim Daws Trucking, LLC (JDT) alleged that the sellers—James and Lana Daws, Daws, Inc., and other affiliated entities—violated the APA’s noncompete provision by engaging in competing trucking operations. The APA included a $12 million purchase price, with $4.5 million allocated to goodwill, and a five-year noncompete clause barring the sellers from participating in trucking nationwide. After the relationship between Jim Daws and JDT deteriorated, Jim Daws left JDT and communicated with former employees about starting new trucking ventures, allegedly causing JDT to lose significant personnel and drivers. The United States District Court for the District of Nebraska granted a temporary restraining order, then a preliminary injunction, prohibiting Jim Daws and associates from engaging in trucking or advising new trucking companies nationwide, except for operating certain pre-existing businesses. The district court determined that the noncompete provision was valid and enforceable under Nebraska law, that JDT was likely to prevail on its breach of contract claim, and that irreparable harm existed due to loss of goodwill. The district court also ordered Jim Daws to release $500,000 in funds from an account used for JDT’s operations and set a $480,000 bond based on potential lost revenue. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of the preliminary injunction, the order to release funds, and the bond amount. The appellate court affirmed the district court’s decisions, holding that the noncompete provision was reasonable in scope and duration given the sale of goodwill and the nature of the trucking business. The court found no clear error in the district court’s factual findings, no abuse of discretion in ordering the release of funds as injunctive relief, and no abuse of discretion in setting the amount of the bond. View "Jim Daws Trucking, LLC v. Daws, Inc." on Justia Law

United States v. Smith

2026-08-31T07:30:13-08:00

In May 2023, law enforcement officers in North Dakota responded to a report of gunshots fired into electrical equipment at a substation owned by two power cooperatives. Near the scene, officers searched a car and found a gun case and medication labeled with Cameron Smith’s name. A tow truck employee identified Smith as the driver and indicated he had dropped Smith off at a nearby hotel. Officers located Smith at the hotel, detained him, and obtained surveillance footage showing him with duffel bags later found in a dumpster. The bags contained firearms and ammunition matching shell casings at the substation. Officers obtained warrants to test the bags for DNA and to search Smith’s residence and devices. Smith was charged with destruction of an energy facility in North Dakota and later in South Dakota for a similar incident. The United States District Court for the District of North Dakota denied Smith’s motion to suppress evidence, ruling that the evidence would have been inevitably discovered even absent the challenged searches. Smith then entered a conditional guilty plea, reserving his right to appeal the suppression ruling. At sentencing, the district court applied a 12-level upward departure under the sentencing guidelines and imposed consecutive sentences totaling 300 months, plus over $2 million in restitution. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the denial of Smith’s motion to suppress, finding that the modified warrant affidavit supported probable cause and that the evidence was admissible under the inevitable discovery doctrine. The court also concluded that Smith’s appeal waiver barred his challenge to the restitution order. However, the appellate court found procedural error in the calculation of the sentencing guideline range, holding that the evidence did not support a finding that Smith’s motive was to intimidate or coerce a civilian population as required for the sentencing departure. The court vacated the sentence and remanded for resentencing. View "United States v. Smith" on Justia Law

Public Interest Legal Foundation, Inc. v. Simon

2026-08-28T08:00:11-08:00

An organization based in Virginia requested access to Minnesota’s Registered Voter List under a federal statute, asserting it was entitled to the records despite Minnesota’s exemption from the law. Minnesota denied the request, citing its exemption as a state with continuous election-day registration since August 1, 1994. The organization also sought the information under a Minnesota statute, but was again denied because no Minnesota-registered voter joined the request. The organization acknowledged it could obtain the information by recruiting a Minnesota voter but did not do so. It then filed suit, claiming Minnesota’s exemption from the federal disclosure requirement was unconstitutional, alleging informational injury and other adverse consequences. The United States District Court for the District of Minnesota reviewed the case. Minnesota moved to dismiss, and the United States intervened to defend the statute’s constitutionality. The district court dismissed the organization’s claim on the merits, concluding that the “equal sovereignty” principle does not apply to Congress’s authority under the Elections Clause. On appeal, the United States Court of Appeals for the Eighth Circuit considered whether the organization had Article III standing. The court reviewed standing de novo and focused on whether the plaintiff had suffered a concrete injury in fact. The court held that a purely informational injury does not satisfy Article III’s requirements and found the plaintiff’s alleged downstream consequences insufficient, as they lacked a nexus to the interests Congress sought to protect. The court concluded the plaintiff failed to allege a concrete injury and therefore lacked standing. The Eighth Circuit vacated the district court’s judgment and remanded with instructions to dismiss the complaint for lack of jurisdiction. View "Public Interest Legal Foundation, Inc. v. Simon" on Justia Law

Post v. Bisignano

2026-08-28T07:30:16-08:00

The plaintiff experienced ongoing pain, numbness, and tingling in both hands and upper extremities, which led her to stop working her retail job in June 2016 following surgeries on both hands and forearms. Despite subsequent surgeries and ongoing treatment—including physical therapy and additional procedures on her shoulders—she continued to report symptoms, though medical records at times showed normal strength and range of motion. Throughout this period, she reported being able to perform various daily activities, such as driving, doing housework, and caring for family members, though some medical providers imposed restrictions on lifting weight. The plaintiff applied for disability insurance benefits for a closed period from June 3, 2016 to August 5, 2021. An administrative law judge (ALJ) reviewed her application, considering her medical records, her function report, and opinions from treating and reviewing physicians. The ALJ determined that she had the residual functional capacity to perform sedentary work, which allows for lifting up to ten pounds, and found that she could frequently handle, finger, and reach for objects. Based on this assessment and testimony from a vocational expert regarding available jobs, the ALJ concluded that the plaintiff was not disabled. The United States District Court for the Eastern District of Missouri affirmed the ALJ’s decision. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The Eighth Circuit held that the ALJ’s determination was supported by substantial evidence, particularly in the evaluation and reliance on a medical opinion that was consistent with the claimant’s activities and medical records. The court concluded that the ALJ’s residual functional capacity finding and the denial of disability benefits fell within the permissible zone of choice and therefore affirmed the judgment. View "Post v. Bisignano" on Justia Law

United States v. Gladney

2026-08-28T07:30:14-08:00

Federal law enforcement intercepted thousands of phone calls between April and June 2021, some of which involved the defendant discussing marijuana and firearm transactions. In April 2022, following a traffic stop, officers detected a strong marijuana odor and, after a brief struggle, arrested the defendant. A search of his vehicle uncovered firearms, large quantities of marijuana, codeine, and cash. The next day, a Glock switch was found in the patrol car where the defendant had been held. He was initially charged in May 2022 by indictment for offenses relating to this incident and later indicted again with 34 codefendants in a broader drug conspiracy case in November 2022. The United States District Court for the Eastern District of Arkansas denied the defendant’s motion to dismiss the indictment on Speedy Trial Act and Sixth Amendment grounds. The trial jury convicted him on several counts, including conspiracy to distribute marijuana, possession with intent to distribute marijuana, possession of a firearm in furtherance of a drug trafficking crime, and use of a communications facility in furtherance of a drug crime. He was acquitted on others, including possession of a machinegun. The district court sentenced him to a total of 150 months’ imprisonment. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed challenges to the indictment’s timeliness, evidentiary rulings admitting certain rap lyrics, and the reasonableness of the sentence. The court held that there was no violation of the Speedy Trial Act or the Sixth Amendment, finding that necessary continuances were justified and adequately explained. The court also concluded that the district court did not abuse its discretion in admitting limited rap lyric evidence, nor did it err in its application of sentencing enhancements or in declining a reduction for acceptance of responsibility. The court affirmed the convictions and the sentence imposed by the district court. View "United States v. Gladney" on Justia Law

Romantix-Fargo, Inc. v. City of Fargo

2026-08-27T07:30:18-08:00

A business specializing in adult products sought to open a store in downtown Fargo, North Dakota, in a zone designated for mixed-use development. The proposed store intended to sell items such as lingerie and sexual wellness products, but not sexually explicit media like books or DVDs. To proceed, the business’s landlord applied for a change-of-use permit to allow retail sales and service at the location. The City of Fargo, through its Director of Planning and Development, denied the application, concluding that the business constituted an "Adult Bookstore" as defined by the city’s municipal code, which prohibited such establishments in the downtown zone. The city’s decision was upheld by both the Fargo Board of Adjustment and the Board of City Commissioners. Following these administrative decisions, the business filed suit in the United States District Court for the District of North Dakota, raising constitutional claims including violations of the First Amendment, the imposition of a prior restraint, denial of procedural due process, and unconstitutional vagueness in the city’s code. The business also challenged the Commissioners’ decision under state law, arguing it was arbitrary and capricious. While the lawsuit was pending, Fargo amended its code to explicitly prohibit “Sexual Device Shops” in the relevant zone. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the dismissal of all federal claims, holding that the business’s planned activities were not protected expressive conduct under the First Amendment, the permit process was not a prior restraint, and the business received adequate procedural process. The court also found the city’s ordinance was not unconstitutionally vague. However, the court determined that denying the permit as an “Adult Bookstore” was arbitrary and capricious under state law, reversed the dismissal of the state-law claim, and remanded for further proceedings regarding possible relief. View "Romantix-Fargo, Inc. v. City of Fargo" on Justia Law

United States v. Parrott

2026-08-27T07:30:17-08:00

The case involves a defendant who was indicted for participating in a drug conspiracy involving methamphetamine and marijuana. Three witnesses testified that they purchased or sold methamphetamine with the defendant at his residence, and that he was involved in distributing significant quantities of narcotics. Text messages and other evidence corroborated these accounts. Law enforcement also established connections between the defendant and his alleged drug suppliers, including evidence from a GPS tracker and observations of meetings. Additional evidence showed that the defendant possessed firearms in the same location where he stored and distributed drugs. A jury in the United States District Court for the District of Nebraska found the defendant guilty of conspiring to distribute and possess with intent to distribute 500 grams or more of methamphetamine. At sentencing, the district court found the defendant responsible for over 11,000 grams of methamphetamine, applied enhancements for firearm possession and for maintaining a premises for drug distribution, and imposed a 300-month sentence after varying downward from the advisory guideline range. The defendant challenged multiple aspects of his trial and sentencing, including evidentiary rulings, the admission of expert and co-conspirator testimony, denial of motions in limine, and sentencing enhancements. The United States Court of Appeals for the Eighth Circuit reviewed and affirmed the district court’s decisions. The appellate court held that the district court did not abuse its discretion or commit clear error in its evidentiary rulings, the admission of expert and co-conspirator testimony, or the application of sentencing enhancements. The court also found that the evidence was sufficient for the jury’s verdict and that any trial errors were either nonexistent or harmless. The sentence imposed was found to be substantively reasonable. Accordingly, the judgment of the district court was affirmed. View "United States v. Parrott" on Justia Law

West Series of Lockton Companies, LLC v. Kaufman

2026-08-26T07:30:15-08:00

Two individuals, both former members of several Missouri limited liability companies operating as a commercial insurance brokerage, entered into contracts with their company containing Missouri choice-of-law and forum-selection clauses, as well as customer non-solicitation covenants. The agreements required members to follow certain operating agreements, which included a provision allowing termination of membership interests upon 30 days’ notice. Despite this, both individuals resigned “effective immediately” and began working for a competitor. The company sued them in federal court in Missouri to enforce the contractual terms, while the former members filed lawsuits in California state court seeking to void the agreements. The United States District Court for the Western District of Missouri granted summary judgment for the company on the enforceability of the Missouri forum-selection and choice-of-law clauses, finding the individuals breached the forum-selection clauses by suing in California. The court also found the customer non-solicitation covenants enforceable to the extent the company sought to enforce them. However, it granted summary judgment to the former members on claims that they breached the notice provision and related fiduciary duties, and on certain other contract and tort claims. The court awarded the company attorneys’ fees for the Missouri litigation but only nominal damages for the forum-selection clause breaches, declining to award fees incurred in the California actions. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings on the enforceability of the choice-of-law and forum-selection clauses, as well as the customer non-solicitation covenants. It reversed the findings on the notice provision and fiduciary duty, holding these were breached, and directed entry of judgment for the company on those claims. The court vacated the nominal damages for the forum-selection clause breaches, instructing the district court to determine actual damages, and affirmed the attorneys’ fee awards to the company. The case was remanded for further proceedings consistent with these holdings. View "West Series of Lockton Companies, LLC v. Kaufman" on Justia Law

Holland v. Simmerman

2026-08-25T07:30:13-08:00

During an Alcoholics Anonymous meeting in Sikeston, Missouri, George Holland experienced a severe mental health crisis, displaying incoherent speech and ultimately brandishing a small pistol, which he placed in his mouth. The other attendees exited safely, leaving Holland alone and armed inside. Police responded and engaged with Holland from a concealed position outside an open door, repeatedly commanding him to drop his weapon. For most of the encounter, Holland neither pointed the firearm at officers nor threatened them directly. After about fifteen minutes, Holland moved into clear view, holding the gun to his temple. In a sudden motion, he lowered the firearm and shifted his left arm toward it, prompting Officer Martin Simmerman to fire. Holland retreated, and Simmerman, followed by other officers, pursued him into the corridor, firing additional shots. Simmerman discharged fifteen rounds in total, striking Holland at least six times, resulting in Holland’s death. The Holland family brought suit against Simmerman and the City of Sikeston in the United States District Court for the Eastern District of Missouri, alleging excessive force under 42 U.S.C. § 1983, wrongful death, battery, and Monell claims. The defendants moved to dismiss, providing body camera footage. The district court found that the video evidence contradicted key allegations in the complaint, concluded that Simmerman was entitled to qualified and official immunity, and dismissed all claims with prejudice. On appeal, the United States Court of Appeals for the Eighth Circuit found that while the video evidence contradicted the allegation that Holland took no menacing action before the first volley of shots, it did not conclusively show the events during the subsequent volleys. The court held that Simmerman was entitled to qualified immunity for the initial shots but not for the later volleys, as the complaint plausibly alleged excessive force as to those shots. The appellate court reversed the dismissal of the excessive force claim, remanded for reconsideration of the related state-law and Monell claims, and affirmed in all other respects. View "Holland v. Simmerman" on Justia Law

Prunty v. Obregon

2026-08-25T07:30:12-08:00

A police officer in Jonesboro, Arkansas, encountered Jayden Prunty standing in the street holding a plastic bag late at night in an area known for high crime. The officer, identifying himself and stating he was conducting drug interdiction, approached Prunty, claimed to smell marijuana, and repeatedly told him to “come here.” Prunty denied the accusation, became visibly nervous, and walked away. When Prunty began to run, the officer caught him and pushed him to the ground. During the ensuing struggle, a firearm discharged, and the officer was shot in the leg. The officer then drew his own weapon and fatally shot Prunty. Prunty was later pronounced dead at the hospital. The administrators of Prunty’s estate brought a civil rights action in the United States District Court for the Eastern District of Arkansas under 42 U.S.C. § 1983, alleging violations of the Fourth and Fourteenth Amendments. The district court granted summary judgment in favor of the officer, finding that the officer’s actions did not violate clearly established rights and that he was entitled to qualified immunity. The court determined that the officer had reasonable suspicion to detain Prunty based on the odor of marijuana, Prunty’s nervous behavior, and attempted flight, and that his use of force was objectively reasonable under the circumstances. Reviewing the case de novo, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the officer did not seize Prunty until applying physical force, at which point reasonable suspicion existed. The court also found the officer’s use of force, including the takedown and subsequent use of deadly force after being shot, was objectively reasonable. Accordingly, the officer was entitled to qualified immunity, and the grant of summary judgment was affirmed. View "Prunty v. Obregon" on Justia Law

United States v. Burton

2026-08-25T07:30:12-08:00

Law enforcement officers responded to a report of a possible drug overdose at a residence in Onamia, Minnesota. Upon arrival, they found Jeremy Burton unconscious with drug paraphernalia present. After being revived with Narcan, officers noticed a handgun magazine protruding from Burton’s shorts. During the encounter, another individual tried to prevent officers from retrieving the firearm, but it was ultimately secured. Burton was transported to a hospital and found to have multiple controlled substances in his system. He was charged as a felon in possession of a firearm, with a sentencing enhancement under the Armed Career Criminal Act due to prior convictions. The United States District Court for the District of Minnesota presided over Burton’s trial. The court granted the government’s motion in limine to exclude expert testimony from a pharmacologist regarding the effects of drugs on Burton’s mental state, finding voluntary intoxication was not a defense to the charge. At trial, Burton testified that someone had planted the gun on him while he was unconscious, but the jury found him guilty. The district court sentenced him to 240 months of imprisonment, which was a downward variance from the applicable guidelines range. Burton appealed, arguing error in excluding the expert testimony and that his sentence was substantively unreasonable. The United States Court of Appeals for the Eighth Circuit reviewed the district court’s evidentiary ruling for abuse of discretion and, where constitutional issues were implicated, de novo. The appellate court held that voluntary intoxication is not a defense to being a felon in possession of a firearm, and thus the exclusion of the expert testimony was proper. The court also found that the sentence was substantively reasonable, given the district court’s consideration of both aggravating and mitigating factors. Accordingly, the Eighth Circuit affirmed the judgment of the district court. View "United States v. Burton" on Justia Law

United States v. Carter

2026-08-25T07:30:11-08:00

Darius Carter, a convicted felon, and his girlfriend, Sarah Mason, sought to obtain firearms but were ineligible to purchase them themselves. They recruited Carter’s mother to serve as a “straw buyer,” who purchased two guns from a pawn shop after Carter and Mason made most of the payments. She falsely certified on federal forms that she was the actual buyer. Months later, Mason was found dead from a gunshot wound to the head, which led investigators to uncover the gun-buying scheme. Carter was subsequently charged with making and conspiring to make false statements in connection with acquiring firearms. The United States District Court for the Eastern District of Missouri allowed the government at trial to present evidence that Mason died under suspicious circumstances, over Carter’s objection that this testimony was irrelevant and prejudicial. Carter was convicted on both counts by a jury. At sentencing, the government presented further evidence implicating Carter in Mason’s murder, arguing for a significant sentence enhancement on the basis that he used one of the illegally purchased firearms to commit the killing. The district court found by a preponderance of the evidence that Carter had committed first-degree murder with one of the guns, applying a sentencing guideline cross-reference that dramatically increased his advisory sentencing range. Carter was sentenced to 180 months’ imprisonment. On appeal, the United States Court of Appeals for the Eighth Circuit held that although the district court abused its discretion by admitting irrelevant evidence regarding the suspicious nature of Mason’s death, the error was harmless given the overwhelming evidence of Carter’s guilt. The court also found no clear error in the district court’s factual findings at sentencing and held that applying the homicide cross-reference under the Sentencing Guidelines was proper. Accordingly, the appellate court affirmed the district court’s judgment. View "United States v. Carter" on Justia Law

United States v. Roy

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

Two children, John and Jane, lived primarily with their maternal grandfather under an informal arrangement, while their parents, Nicole Roy and Harrison Dudley, Sr., retained responsibility for their medical care. Medical professionals discovered severe health issues: Jane, age two, suffered from life-threatening anemia and a scalp infection, while John, age six, had significant developmental delays and both children had untreated head lice. Roy and Dudley repeatedly failed to follow through with prescribed treatments, missed follow-up appointments, and did not address the children's medical and hygiene needs, despite receiving explicit instructions and assistance from healthcare providers. A grand jury indicted Roy and Dudley for felony child neglect and felony child endangerment under the Major Crimes Act, alleging the offenses occurred on the Red Lake Indian Reservation. After a trial in the United States District Court for the District of Minnesota, a jury convicted both defendants on all counts. The district court sentenced Roy to twelve months and one day and Dudley to four months of imprisonment, with both receiving three years of supervised release and special assessments. Roy’s appeal became moot due to her death, while Dudley appealed, challenging the sufficiency of the evidence and the legality of his sentence. The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that sufficient evidence supported Dudley’s convictions, finding that a rational jury could conclude he willfully deprived the children of necessary care and recklessly endangered their health. The court also held that Dudley’s term of supervised release and the imposition of special federal assessments were lawful under the Major Crimes Act and relevant federal statutes. The Eighth Circuit affirmed the judgment as to Dudley and vacated the judgment as to Roy, remanding with instructions to dismiss her indictment. View "United States v. Roy" on Justia Law

Vick v. Vertical Enterprise, LLC

2026-08-20T09:31:38-08:00

After Missouri legalized recreational marijuana in 2022, local governments were permitted to impose an additional sales tax on dispensaries selling recreational marijuana. Dispensaries passed this tax on to their customers. However, the Missouri Supreme Court later ruled that counties could not levy this additional tax on dispensaries located within incorporated areas such as cities or towns. Following this ruling, a class of customers sued several dispensaries, alleging that the dispensaries unlawfully retained the collected county tax and sought restitution. The dispensaries removed the action to the United States District Court for the Western District of Missouri under the Class Action Fairness Act (CAFA). The plaintiffs then amended their complaint to limit the class to Missouri citizens and moved to remand the case to state court, arguing that the Local Controversy Exception to CAFA applied. The district court initially found that three of the four required elements for the exception were met but that the class had not sufficiently shown that more than two-thirds of its members were Missouri citizens. After a second amendment explicitly limited the class to Missouri citizens, the district court found all requirements met and remanded the case to state court. On appeal, the United States Court of Appeals for the Eighth Circuit considered whether the operative pleading for determining CAFA jurisdiction was the first or second amended complaint. The court, relying on the Supreme Court’s decision in Royal Canin U.S.A., Inc. v. Wullschleger, held that the most recent amended complaint governs jurisdiction. The Eighth Circuit also agreed that the Local Controversy Exception was satisfied and affirmed the district court’s remand order, holding that federal jurisdiction no longer existed once the class was limited to Missouri citizens. View "Vick v. Vertical Enterprise, LLC" on Justia Law

Minnesota Voters Alliance v. Ellison

2026-08-20T07:31:14-08:00

Several individuals and a nonprofit organization in Minnesota, focused on election integrity, wished to publicly advocate their interpretation that certain felons—specifically those still on supervised release—are constitutionally ineligible to vote in Minnesota. State law, however, allows felons to vote once released from incarceration, regardless of whether they are on parole or probation. Concerned about possible prosecution under a Minnesota statute that criminalizes knowingly false statements about voter eligibility made within 60 days of an election, the plaintiffs sought to continue their advocacy without facing criminal or civil penalties. After the Minnesota Supreme Court held that the group lacked standing to challenge the felon voting law in state court, the plaintiffs filed suit in the United States District Court for the District of Minnesota. They sought declaratory and injunctive relief against the enforcement of the election disinformation statute, arguing it violated the First Amendment. In response, the Anoka County Attorney filed a counterclaim, seeking to restrain the plaintiffs from violating the law and to obtain damages. The district court dismissed the plaintiffs’ complaint and denied a preliminary injunction, concluding that the law could constitutionally restrict their speech. The plaintiffs appealed the denial of a preliminary injunction while the counterclaim remained pending. The United States Court of Appeals for the Eighth Circuit reviewed the denial of preliminary injunctive relief and found that the plaintiffs had standing due to both actual and imminent injuries. The court held that the statute at issue regulated protected political speech based on its content and was therefore subject to strict scrutiny. The court determined that Minnesota’s law was not narrowly tailored to serve a compelling state interest, as it both overreached and underreached in its restriction of speech, and also authorized unconstitutional prior restraints. The Eighth Circuit reversed the denial of a preliminary injunction in part, affirmed in part, and remanded for entry of a preliminary injunction in favor of the plaintiffs. View "Minnesota Voters Alliance v. Ellison" on Justia Law

United States v. Nesbitt

2026-08-20T07:31:13-08:00

In this case, two individuals, after forming a close association in Kansas City, Missouri, participated in a series of criminal acts. These included the theft of an AR-15 rifle, armed robberies targeting drug dealers, and two fatal shootings—one at a restaurant parking lot and another involving a resident of their apartment complex who had tipped off the police about their involvement in the first murder. The defendants also engaged in acts of witness tampering, evidence tampering, and intimidation, including efforts to recover the murder weapon and threats against potential witnesses. Law enforcement ultimately apprehended the perpetrators, and a federal grand jury indicted them on multiple counts, including drug conspiracy, firearm offenses, murder, robbery, and tampering-related charges. The United States District Court for the Western District of Missouri denied the defendants’ motions to sever their trials and allowed certain grand jury testimony into evidence. A jury found both defendants guilty on nearly all counts. The district court subsequently sentenced one defendant to four consecutive life sentences and the other to five. The government dismissed two counts for double jeopardy concerns after the Supreme Court’s decision in Lora v. United States, and both defendants appealed, raising challenges related to the severance denial, evidentiary rulings, sufficiency of the evidence, jury instructions, and sentencing. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The appellate court held that the denial of the severance motion was not an abuse of discretion, the evidence was sufficient to support all challenged convictions, and the admission of grand jury testimony was proper under Federal Rule of Evidence 801(d)(1)(a). The jury instructions on Hobbs Act robbery were found to be consistent with Supreme Court precedent. The court declined to review the reasonableness of the sentences for one count under the concurrent sentence doctrine, as the defendants were already serving multiple consecutive life sentences. View "United States v. Nesbitt" on Justia Law

United States v. Ellingburg

2026-08-20T07:31:12-08:00

In December 1995, Holsey Ellingburg, Jr. robbed a bank. He was convicted by a jury in August 1996 and sentenced in November 1996 by the United States District Court for the Western District of Missouri, which ordered him to pay $7,567.25 in restitution. At the time of his offense, the Victim and Witness Protection Act of 1982 (VWPA) governed restitution, limiting liability to twenty years after judgment. However, the Mandatory Victim Restitution Act (MVRA), enacted after his offense but before his conviction, extended the government’s ability to collect restitution to the later of twenty years after judgment or twenty years after release from imprisonment, and made interest awards mandatory unless the defendant was unable to pay. After his release in 2022, Ellingburg challenged the continued enforcement of his restitution order, arguing that retroactive application of the MVRA violated the Ex Post Facto Clause. The district court held that the MVRA’s extended liability period did not increase Ellingburg’s punishment and rejected his petition. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed, reasoning that MVRA restitution was not criminal punishment and therefore did not implicate the Ex Post Facto Clause. Ellingburg sought review in the Supreme Court, which reversed, holding that MVRA restitution is criminal punishment under the Ex Post Facto Clause, and remanded for further proceedings on whether the MVRA’s extended liability period increased his punishment. On remand, the United States Court of Appeals for the Eighth Circuit determined that the MVRA applied to Ellingburg because he was convicted after its enactment. The court held that retroactive application of the MVRA’s extended liability period increased Ellingburg’s punishment by prolonging his restitution liability well beyond what the law permitted at the time of his offense. The court therefore concluded that applying the MVRA to Ellingburg violated the Ex Post Facto Clause, vacated the district court’s judgment, and remanded for further proceedings. View "United States v. Ellingburg" on Justia Law

Holmes v. Bax

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

Three individuals residing in Missouri, each of whom had significant difficulties applying for or recertifying their eligibility for SNAP benefits due to problems with the Missouri Department of Social Services (DSS) call center and application procedures, brought a lawsuit. They alleged wrongful denial of benefits and failure to provide reasonable accommodations for disabilities. All three eventually received SNAP benefits after joining the lawsuit but expected to need continued assistance. Empower Missouri, a nonprofit organization, also joined the suit, asserting that DSS’s practices forced it to divert resources to address these systemic problems. In the United States District Court for the Western District of Missouri, the plaintiffs claimed violations of specific provisions of the SNAP Act, the Due Process Clause of the Fourteenth Amendment, and the Americans with Disabilities Act (ADA), seeking declaratory and injunctive relief. The district court found that all plaintiffs had standing, rejected arguments that their claims were moot, and determined that DSS’s practices violated their due process and ADA rights. The court granted summary judgment in favor of the plaintiffs and issued a broad remedial order requiring systemic changes to DSS’s SNAP administration, including detailed operational requirements and ongoing reporting. On appeal, the United States Court of Appeals for the Eighth Circuit held that the individual plaintiffs had standing for their due process and ADA claims, but Empower Missouri did not, as its advocacy expenditures alone did not confer standing. The court determined that the SNAP Act provisions cited did not create individual rights enforceable under 42 U.S.C. § 1983 or an implied private right of action. It affirmed the district court’s summary judgment for the individual plaintiffs on their due process and ADA claims, except for one plaintiff’s ADA claim, which lacked evidence of a requested accommodation. The Eighth Circuit vacated the district court’s permanent injunction, finding it overbroad and issued without proper consideration of adequate legal remedies, and remanded for further proceedings. View "Holmes v. Bax" on Justia Law

Burnett v. Spring Way Center, LLC

2026-08-19T07:30:59-08:00

A group of Missouri home sellers brought a class action lawsuit in federal court, alleging that the National Association of Realtors (NAR) and several large real estate brokerage firms conspired to inflate buyer-broker commissions through a rule requiring sellers to offer compensation to buyers’ brokers via Multiple Listing Services (MLSs). The plaintiffs claimed this arrangement artificially increased transaction costs for sellers and buyers nationwide due to NAR’s market dominance. The class was initially limited to Missouri, Illinois, and Kansas home sellers using certain MLSs. After a trial in the United States District Court for the Western District of Missouri, a jury found the defendants liable for violating antitrust laws and awarded significant damages. While post-trial motions were pending, similar lawsuits emerged across the country. The parties began global settlement negotiations addressing claims from related cases, including those involving different MLSs and trade associations, such as the Real Estate Board of New York (REBNY). The settlement required NAR and others to pay over $1 billion and implement practice changes, including eliminating the contested rule. The settlement class expanded to nearly all U.S. home sellers using any MLS from 2014 to 2024. Following extensive notice and a fairness hearing, the district court certified the nationwide class, approved the settlement as fair under Federal Rule of Civil Procedure 23, and addressed all objections, including those from non-appearing objectors. On appeal, several objectors and interested parties challenged the settlement, raising issues about class scope, adequacy, fairness, the inclusion of unrelated claims, attorneys’ fees, due process, and the fairness hearing procedures. The United States Court of Appeals for the Eighth Circuit reviewed for abuse of discretion and found that the district court properly applied the relevant legal standards, including Rule 23(e). The Eighth Circuit affirmed the district court’s approval of the nationwide class-action settlement, holding that it was fair, reasonable, and adequate, and that the process satisfied constitutional and procedural requirements. View "Burnett v. Spring Way Center, LLC" on Justia Law

Falasco v. USAA Casualty Insurance Company

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

The dispute arose after an insured, Joseph Russell Falasco, filed a claim with his insurer, USAA Casualty Insurance Company, following a fire that destroyed his partially restored 1974 Porsche 911S. After the incident, USAA began an investigation, sent a reservation of rights letter, and ultimately relied on an appraisal by a third party, CCC Intelligent Solutions, to value the vehicle. USAA’s valuation was based on comparable vehicles that Falasco disputed as inappropriate, and the company initially withheld settlement pending the outcome of a special investigations unit review, which ultimately found no intentional wrongdoing. After further dispute over the valuation, USAA eventually paid Falasco based on a higher appraisal obtained during litigation. The United States District Court for the Eastern District of Arkansas granted partial summary judgment to USAA on Falasco’s claims of bad faith and unfair claims settlement practices, concluding that the undisputed facts showed USAA had reasonably attempted to discharge its contractual obligations in good faith. The breach of contract claim proceeded to a jury trial, where Falasco prevailed and was awarded damages for the value of the car. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the partial summary judgment de novo. The court held that under Arkansas law, bad faith requires affirmative misconduct by the insurer that is dishonest, malicious, or oppressive, and that mere negligence, mistakes, or honest errors in judgment do not meet this standard. The appellate court found no evidence that USAA’s conduct—including its valuation methods, investigation for potential fraud or arson, alleged misrepresentations, and attempts to obtain the vehicle’s title—rose to the level of bad faith. The court affirmed the district court’s grant of summary judgment in favor of USAA on the bad faith claim. View "Falasco v. USAA Casualty Insurance Company" on Justia Law

United States v. Rice

2026-08-18T07:31:06-08:00

Travon Rice, at age 15, was convicted in Arkansas state court of first degree battery and possession of a handgun by a minor after shooting two men during a planned meeting. He was sentenced to 96 months in prison and released to supervision in April 2022. Two months later, police found images on Rice’s social media showing him with a modified Glock pistol, and during a subsequent home visit, officers discovered six firearms, several of which were stolen. Rice, as a convicted felon, was prohibited from possessing firearms. He admitted to the possession and posting the images. A federal grand jury indicted him for felony possession of a firearm and possession of a machinegun. Before the United States District Court for the Eastern District of Arkansas, Rice pleaded guilty to possession of a machinegun, and the government dismissed the other charge. The Presentence Investigative Report calculated an advisory guideline range of 57 to 71 months. Rice requested a lower sentence based on his age, difficult upbringing, and efforts at rehabilitation, and also asked for his federal sentence to run concurrently with any undischarged state sentence. The district court instead imposed a 90-month sentence, upwardly varying from the guideline range, and ordered it to run consecutively to any undischarged state sentence. The court justified the variance by citing Rice’s repeated recidivism, his violent record, and the failure of prior sentences to deter him. Rice appealed to the United States Court of Appeals for the Eighth Circuit, arguing that the sentence was substantively unreasonable and that the district court failed to properly consider the relevant statutes and guidelines regarding consecutive sentences. The Eighth Circuit held that the district court did not abuse its discretion in imposing an upward variance or in ordering the federal sentence to run consecutively. The district court’s judgment was affirmed. View "United States v. Rice" on Justia Law

United States v. Rondeau

2026-08-17T07:31:01-08:00

The case involved Anfernee Rondeau, who was convicted by a jury of aggravated sexual abuse of a minor under federal law. The incident occurred in April 2024, when Rondeau, after a night of heavy drinking with his girlfriend G.W.B., was present in a home with G.W.B. and her six-year-old daughter, C.A. During the night, a young witness, C.W.B., observed Rondeau on top of C.A., moving in a manner suggestive of sexual activity. C.W.B. intervened, pushing Rondeau off C.A., and later witnessed C.A. in apparent pain, adjusting her clothing. Physical evidence included male DNA on C.A.’s body, though the profile was inconclusive. Rondeau later participated in a pre-polygraph interview, during which he became emotional, apologized in writing for his actions, but declined to complete the polygraph examination. The case was first tried in the United States District Court for the District of South Dakota, where Rondeau was found guilty and sentenced to the statutory minimum of 360 months. Prior to trial, the district court granted Rondeau’s motion to exclude references to his aborted polygraph, but this was later withdrawn, allowing limited discussion. During trial, references to the polygraph arose in testimony and closing arguments without contemporaneous objection from the defense. Rondeau moved for a mistrial based on these references, but the district court denied the motion, opting for a curative instruction instead. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed two main issues: sufficiency of the evidence and whether references to Rondeau’s refusal to complete the polygraph examination constituted plain error. The appellate court held that the evidence was sufficient for a reasonable jury to convict, and that the references to the polygraph did not constitute reversible plain error. The court affirmed the conviction and sentence. View "United States v. Rondeau" on Justia Law

McKee v. Brady

2026-08-17T07:31:00-08:00

Jessica McKee, a pretrial detainee at the Steele County Detention Center in Minnesota, suffered from Crohn’s disease. During her detention, she communicated with jail medical staff, including Nurse Jessica Brady, regarding various medical needs. McKee requested accommodations such as a lower bunk due to alleged seizures and pain, dietary changes to address her Crohn’s disease, and access to her prescription medication. Brady denied the bunk request due to lack of documentation, approved dietary changes as requested by McKee, and communicated with outside care providers to obtain medical records. When McKee reported worsening symptoms, Brady called her for an in-person evaluation and referred her to the emergency room, where McKee was hospitalized and suffered complications. McKee filed a lawsuit under 42 U.S.C. § 1983, asserting that Brady was deliberately indifferent to her serious medical needs in violation of her Fourteenth Amendment rights. Nurse Brady moved for summary judgment on the basis of qualified immunity. The United States District Court for the District of Minnesota denied Brady’s motion, finding that a reasonable jury could conclude that Brady was deliberately indifferent to McKee’s medical needs. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment de novo. The Eighth Circuit concluded that McKee failed to show that Brady’s actions violated a clearly established constitutional right. The court found that Brady responded to each of McKee’s requests, followed appropriate procedures within her authority, and was not deliberately indifferent as defined by precedent. The court further determined that any negligence did not rise to the level of a constitutional violation. Accordingly, the Eighth Circuit held that Brady was entitled to qualified immunity and reversed the district court’s order denying summary judgment. View "McKee v. Brady" on Justia Law

United States v. Peterson

2026-08-17T07:31:00-08:00

A 21-year-old man engaged in sexually explicit communications and exchanged illicit images with a 15-year-old minor through Snapchat. The minor’s parents discovered the messages, reported them to authorities in Sarpy County, Nebraska, and provided the minor’s phone and Snapchat details. Law enforcement in Nebraska obtained search warrants from local judges to gather information from Snap Inc. in California and Google in California related to the suspect’s account. The investigation identified the suspect’s location in Kansas City, Missouri, and federal authorities subsequently obtained and executed a search warrant at his residence, seizing electronic devices that contained child pornography. After the investigation, a federal grand jury indicted the defendant on multiple counts related to child pornography. Prior to entering a guilty plea, the defendant moved to suppress all evidence obtained in the case, arguing that the Nebraska judges lacked authority to issue search warrants for data held outside Nebraska, and that the evidence collected was therefore obtained in violation of his constitutional rights. A magistrate judge in the United States District Court for the Western District of Missouri recommended denying the motion, and the district court adopted that recommendation. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the motion to suppress, applying a mixed standard of review: clear error for factual findings and de novo for legal conclusions. The court held that Nebraska law expressly authorized state judges to issue search warrants for service on out-of-state entities. The court also found that the federal rules concerning the territorial limits of federal magistrate judges did not apply to state judges. Additionally, even if there were defects in the warrants, the Leon good-faith exception would apply because law enforcement reasonably relied on the judges’ determinations. The Eighth Circuit affirmed the district court’s denial of the suppression motion. View "United States v. Peterson" on Justia Law

Matias-Pablo v. Blanche

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

A Guatemalan woman and her minor son entered the United States without authorization in June 2018 and were subsequently placed in removal proceedings. The woman conceded removability but requested asylum, withholding of removal, and protection under the Convention Against Torture (CAT), alleging she suffered prolonged physical, sexual, and emotional abuse at the hands of her partner, Jose Vasquez. She claimed the abuse occurred because she belonged to two particular social groups: “Guatemalan females” and “Guatemalan females without protection,” and asserted that the Guatemalan government was unable or unwilling to protect her. An Immigration Judge denied all requested relief, finding she had not demonstrated eligibility for asylum, withholding of removal, or CAT protection. The Board of Immigration Appeals affirmed, holding there was insufficient evidence to establish a nexus between the alleged persecution and her claimed social group membership, and agreeing that the record did not show she would likely be tortured in Guatemala with government acquiescence. The United States Court of Appeals for the Eighth Circuit reviewed the Board’s decision under the substantial evidence standard. The court found that the record did not compel a conclusion contrary to the finding that her social group membership was not “one central reason” for the abuse, as required for asylum or withholding of removal. Instead, the evidence reflected domestic violence motivated by personal and relational factors, not by her status as a member of a protected group. The court also concluded that the evidence did not compel a finding that she would more likely than not face torture in Guatemala with government acquiescence, citing steps taken by the Guatemalan government to combat domestic violence. Accordingly, the Eighth Circuit denied the petition for review. View "Matias-Pablo v. Blanche" on Justia Law

United States v. Kucera

2026-08-13T07:01:09-08:00

Richard Kucera was introduced by a co-defendant to two minor girls, E.B. and A.W., and paid them to allow him to take pornographic images and engage in sexual activity. After being indicted by a federal grand jury, he was arrested and interviewed by FBI agents. During the interview, Kucera asked whether he should have a lawyer, but agents proceeded to read him his Miranda rights, which he indicated he understood and waived in writing before making incriminating statements. Kucera asserted throughout the proceedings that he believed the girls were adults, based on representations from his co-defendant and the girls. The United States District Court for the District of South Dakota denied Kucera’s motion to suppress his post-arrest statements, finding that he had not unequivocally invoked his right to counsel and that his waiver of rights was knowing, voluntary, and intelligent. At trial, Kucera objected to the government’s proposed jury instructions for both the sex trafficking and child pornography charges. He argued that the sex trafficking instruction improperly allowed conviction if he had a “reasonable opportunity to observe” the victims, regardless of knowledge of their age, and that this language was vague and amended the indictment. He also contended that the child pornography instructions improperly omitted a knowledge requirement regarding the victims’ ages or a mistake-of-age defense. The district court rejected these objections and used the challenged instructions. The jury convicted Kucera on two counts each of sex trafficking and child pornography, and he was sentenced to 300 months’ imprisonment. The United States Court of Appeals for the Eighth Circuit affirmed. The court held that Kucera did not unambiguously invoke his right to counsel, and his Miranda waiver was valid. It also held that the jury instructions on both the sex trafficking and child pornography counts were proper under the relevant statutes and Eighth Circuit precedent, and that the statutes and instructions were not unconstitutionally vague or otherwise erroneous. View "United States v. Kucera" on Justia Law

Shamrock Hills, LLC v. State of Iowa

2026-08-12T07:31:01-08:00

A residential contractor in Iowa received warning notices from the Iowa Insurance Division, alleging that its business activities and advertising involved unlicensed public adjusting, which is regulated by two Iowa statutes. These statutes require public adjusters to be licensed and prohibit residential contractors from representing or negotiating insurance claims on behalf of property owners for the same project on which they perform work. Violations can lead to significant penalties. After the contractor was notified of alleged violations related to its advertising and communications with consumers, it challenged the constitutionality of the statutes, claiming they are void for vagueness and infringe upon First Amendment rights, both facially and as applied. The United States District Court for the Southern District of Iowa dismissed the contractor’s suit. The court found that the State of Iowa and its Insurance Division were immune under the Eleventh Amendment. It further held that the contractor failed to state a cognizable claim under the First or Fourteenth Amendments, concluding the statutes regulated conduct, not speech, and were not unconstitutionally vague. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed in part, reversed in part, and remanded. The appellate court held that the statutes are not facially unconstitutional and are not void for vagueness. However, the court found that the district court erred by not adequately analyzing the contractor’s as-applied First Amendment challenge. Specifically, when the statutes were applied to restrict the contractor from telling insureds that it would assist or advise them in navigating the insurance claims process, the law regulated speech. The court reversed the dismissal of the as-applied First Amendment claim and remanded for further proceedings, while affirming the rejection of the facial and vagueness challenges. View "Shamrock Hills, LLC v. State of Iowa" on Justia Law

United States v. Mulamba

2026-08-12T07:31:01-08:00

Law enforcement began investigating after a mother reported that an adult man had offered her sixteen-year-old daughter vape pens in exchange for sex. Officers identified the man as the appellant and corroborated the report through interviews, social media messages, and vehicle information. During an interview at the appellant’s home, officers observed behavior indicating he was deleting information from his phone when asked about his contact with the minor. Concluding that evidence was at risk of imminent destruction, officers seized his phone without a warrant. The appellant subsequently signed a consent form for the search but only after officers inaccurately stated they already had a warrant. Later, a warrant was obtained based on an affidavit summarizing the investigation. The search revealed child sexual abuse material involving a different minor. The United States District Court for the District of South Dakota reviewed the appellant’s motion to suppress evidence obtained from his phone, arguing the seizure was unconstitutional and the search warrant was invalid due to factual omissions and misrepresentations in the supporting affidavit. The magistrate judge recommended denying the motion, and the district court adopted that recommendation. The appellant then entered a conditional guilty plea, preserving his right to appeal the suppression ruling. The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the warrantless seizure of the phone was justified by probable cause and exigent circumstances because officers reasonably believed evidence was about to be destroyed. The court also found that, even after correcting for alleged errors and omissions in the warrant affidavit, there remained probable cause to support the warrant. The court rejected the appellant’s arguments for suppression and affirmed the district court’s denial of the motion to suppress. View "United States v. Mulamba" on Justia Law

Christensen v. Union Pacific Railroad Co.

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

Ross Christensen worked as a conductor for Union Pacific Railroad Company. In January 2015, while off duty, he suffered an ischemic stroke. Christensen’s recovery was described as good by his treating physicians, who eventually cleared him to return to work. However, Union Pacific’s Health and Medical Services department required him to undergo a fitness-for-duty evaluation. After reviewing his medical records, company physicians imposed work restrictions due to his increased risk for seizures, preventing him from performing his duties as a conductor. These restrictions were initially set for one year but were later extended to five years based on updated medical information and Federal Motor Carrier Safety Administration (FMCSA) guidelines. Despite additional review and Christensen’s requests for reconsideration, Union Pacific maintained these restrictions, and Christensen did not return to his conductor position. After failing to resume work, Christensen filed suit in 2023 in the United States District Court for the District of Nebraska, alleging disparate treatment under the Americans with Disabilities Act (ADA). He eventually proceeded only on his claim under 42 U.S.C. § 12112(a). Union Pacific moved for summary judgment, arguing both that Christensen could not prove discrimination using the McDonnell Douglas framework and that it was entitled to summary judgment under the ADA’s “direct threat” affirmative defense. The district court focused on the direct threat defense, finding that Union Pacific had established it through individualized assessment, reasonable reliance on medical evidence, and use of current medical guidelines. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that Union Pacific had sufficiently established its direct threat defense as a matter of law. It found no genuine dispute of material fact regarding the individualized assessment, objective reasonableness, or reliance on the best available medical evidence. The appellate court affirmed the district court’s judgment in favor of Union Pacific. View "Christensen v. Union Pacific Railroad Co." on Justia Law

Chernyy v. Roesler

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

While incarcerated at the Saline County, Nebraska jail, Anna Chernyy was sexually assaulted by Corrections Officer Monty Roesler. Sheriff Alan Moore, who oversaw jail operations and policy but did not directly supervise correctional officers, had implemented a zero-tolerance sexual assault policy and ensured staff received Prison Rape Elimination Act (PREA) training. Roesler, hired in 2015, completed the required training and was previously investigated for minor incidents, including receiving a note from an inmate and allegedly making suggestive comments, neither of which resulted in findings of inappropriate relationships. On the same day that jail staff received anonymous tips about Roesler and Chernyy, Chernyy reported the assault. Moore responded immediately by initiating investigations and terminating Roesler after confirmation of the assault. Chernyy brought suit under state tort law and 42 U.S.C. § 1983 against Roesler, Moore (in individual and official capacities), and Saline County, alleging violations of her Eighth Amendment rights due to failure to protect and failure to train. The United States District Court for the District of Nebraska denied summary judgment to the defendants, ruling that factual disputes precluded a determination of qualified immunity for Moore and municipal liability for Saline County. The United States Court of Appeals for the Eighth Circuit reviewed the denial of summary judgment de novo. The Eighth Circuit held that Moore was entitled to qualified immunity because Chernyy failed to show that Moore violated a clearly established right; specifically, there was no evidence that Moore was deliberately indifferent to a substantial risk of serious harm, nor that his conduct was clearly inappropriate in light of such risk. The court also held that, since Moore did not violate any clearly established constitutional right, Saline County could not be held liable under Monell v. Department of Social Services. The Eighth Circuit reversed the district court’s decision and remanded for entry of summary judgment in favor of Moore and the County. View "Chernyy v. Roesler" on Justia Law

Maniktala v. CIR

2026-08-11T07:01:06-08:00

Nate and Jaya Maniktala, shareholders of an S-corporation, claimed research and development tax credits on their joint tax returns for 2018 and 2019. The IRS subsequently determined that the corporation was not entitled to the credits and issued a notice of deficiency to the Maniktalas, stating that they had until March 19, 2024, to file a petition with the United States Tax Court to contest the deficiency. However, the Maniktalas did not receive the notice until July 9, 2024, and filed their petition on July 19, 2024, well after the 90-day deadline. The United States Tax Court dismissed the Maniktalas’ petition, ruling that it lacked jurisdiction because the petition was not filed within the statutory period prescribed by 26 U.S.C. § 6213(a). The Maniktalas appealed, contending that the 90-day deadline is not jurisdictional and, therefore, is subject to equitable tolling, which could allow their late filing to be considered. The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the filing deadline in 26 U.S.C. § 6213(a) is not jurisdictional but is instead a claim-processing rule. The court concluded that Congress did not clearly attach jurisdictional consequences to the 90-day deadline and that the deadline is presumptively subject to equitable tolling. The court found no clear statutory language rebutting this presumption. The Eighth Circuit reversed the Tax Court’s decision and remanded the case for the Tax Court to determine, in the first instance, whether the Maniktalas qualify for equitable tolling of the filing deadline. View "Maniktala v. CIR" on Justia Law

United States v. Elk

2026-08-11T07:01:05-08:00

A minor, B.L.E., disclosed at age 15 that Lloyd Elk, her mother’s former romantic partner, had sexually abused her multiple times between the ages of five and seven while living together on the Pine Ridge Indian Reservation. B.L.E. described repeated acts of sexual assault, threats by Elk to harm her or her family if she reported the abuse, and her fear of coming forward. After her disclosure, the FBI became involved, and a federal grand jury indicted Elk on several counts, including aggravated sexual abuse of a minor, abusive sexual contact, and witness tampering. The United States District Court for the District of South Dakota admitted testimony under Federal Rules of Evidence 413 and 414 from another alleged victim, S.F.H., over Elk’s objection. The court found this testimony relevant and not overly prejudicial. Elk’s motion for judgment of acquittal was denied, and a jury convicted him on the remaining counts after the government dismissed two charges. The district court sentenced Elk to concurrent terms, including 600 months for aggravated sexual abuse of a minor and 300 months for witness tampering. Elk appealed, challenging the sufficiency of the evidence for witness tampering, the admission of prior bad act evidence, and the reasonableness of his sentence. The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that sufficient evidence supported the witness tampering conviction, applying the "reasonable likelihood" standard from Fowler v. United States. The court also determined that the district court did not abuse its discretion in admitting evidence of prior sexual assaults, as the probative value was not substantially outweighed by prejudice. Finally, the appellate court found the 600-month sentence substantively reasonable, given the district court’s consideration of mitigating factors and imposition of a sentence below the Guidelines range. The court affirmed the district court’s judgment. View "United States v. Elk" on Justia Law

United States v. Handley

2026-08-11T07:01:05-08:00

Malachi Handley was stopped by police officers in Cedar Rapids, Iowa, due to a broken brake light on his vehicle. During the stop, an officer detected the smell of marijuana but was uncertain if it originated from the vehicle or a nearby apartment. A K-9 unit was called to conduct a drug sniff, and during the sniff, the drug dog’s snout entered the open window of Handley’s vehicle for about one second before indicating the presence of narcotics. Based on this indication, officers searched the vehicle and discovered a firearm and marijuana. A grand jury indicted Handley for being a felon in possession of a firearm and possessing a stolen firearm. He moved to suppress the evidence, arguing that his Fourth Amendment rights were violated when the dog’s snout entered his car. The United States District Court for the Northern District of Iowa agreed that the dog’s entry constituted an unreasonable, warrantless search because probable cause was lacking before the intrusion. However, the court denied the suppression motion, concluding that the officers acted in objectively reasonable reliance on then-binding appellate precedent from the Eighth Circuit, specifically United States v. Lyons. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed whether the district court erred in declining to apply the exclusionary rule. The Eighth Circuit held that the dog’s entry into Handley’s vehicle was a Fourth Amendment search under intervening Supreme Court precedent. However, the exclusionary rule did not apply because the officers reasonably relied on binding Eighth Circuit precedent at the time of the search. Therefore, the court affirmed the district court’s denial of the motion to suppress. View "United States v. Handley" on Justia Law

Tobacco v. McKennan

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

A Native American woman was recruited in 2017 to work as a Clinical Research Manager at a health research institute that focuses on underserved populations, including Native Americans. She supervised a small team and was initially hired, in part, because her background was seen as beneficial for engaging Native American study participants and diversifying management. Over several years, she led or participated in research studies, experienced workplace conflicts, and alleged that she and her assistant were subject to “tokenism” and disparate treatment. In 2022, following complaints about workplace discrimination, disputes over recruitment methods, and changes in her role, the institute’s leadership eliminated her position as part of a reduction in force (RIF) to meet a 5% budget improvement mandate. Her salary was funded mostly by internal, non-grant money, unlike other managers whose salaries were grant-funded. She filed suit in the United States District Court for the District of South Dakota, alleging race discrimination in violation of Title VII and state law. The district court granted summary judgment for the employer, finding that she failed to establish a prima facie case of race discrimination and failed to show that the RIF was a pretext for unlawful discrimination. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. Applying the McDonnell Douglas burden-shifting framework, the court assumed without deciding that a prima facie case was made, but held that the employer had articulated a legitimate, non-discriminatory reason for the termination: budgetary constraints and the unique funding of her position. The appellate court further found that the plaintiff did not present sufficient evidence for a reasonable jury to conclude that this stated reason was pretextual or that racial discrimination was a determinative factor in her termination. The Eighth Circuit affirmed the district court’s judgment. View "Tobacco v. McKennan" on Justia Law

Doe v. Anoka County

2026-08-10T07:30:57-08:00

In 2004, a fourteen-year-old girl was sexually assaulted in Anoka County, Minnesota. She provided evidence for a rape kit, which was submitted to the Anoka County Sheriff’s Office. Detective Johnson was assigned to her case and assured her mother that no DNA was obtained, though in reality the kit was never tested. The suspect was charged but not convicted. In 2015, it was discovered that the Sheriff’s Office had hundreds of untested rape kits, including hers. Sixteen years after the assault, her kit was finally tested, revealing DNA evidence implicating the original suspect, and criminal charges were pursued again. After these events, she brought suit against Anoka County, Sheriff Stuart, and Detective Johnson in the United States District Court for the District of Minnesota. She asserted claims under the Fourteenth Amendment and the Minnesota Constitution for equal protection violations, a claim under the Minnesota Human Rights Act, a “failure to train” claim under 42 U.S.C. § 1983, and state tort claims for negligence and intentional infliction of emotional distress (IIED). The district court dismissed her MHRA and negligence claims but allowed the other claims to proceed, finding she had standing in light of Eighth Circuit precedent. On appeal, the United States Court of Appeals for the Eighth Circuit concluded that the plaintiff lacked standing to bring her federal constitutional claims for alleged failures to investigate or train, following Supreme Court and Eighth Circuit precedent holding that crime victims generally lack standing to challenge law enforcement or prosecutorial discretion in investigating crimes, even when alleging class-based discrimination. The Eighth Circuit vacated the district court’s judgment on the federal claims and remanded with instructions to dismiss those claims for lack of standing. The court remanded the IIED claim for the district court to determine whether standing existed for that state-law claim. View "Doe v. Anoka County" on Justia Law

Williams v. MO Department of Corrections

2026-08-06T07:01:16-08:00

A man named Austen May died by suicide while incarcerated at a Missouri Department of Corrections (MODOC) facility in July 2021, following a prior suicide attempt and ongoing mental health treatment. Correctional officers and a supervising sergeant failed to perform required periodic checks of May’s cell for nearly three hours, during which May obscured the cell window. When officers eventually entered, May was found deceased. Kristine Williams, May’s mother, filed suit against MODOC and several employees, alleging state law wrongful death and federal constitutional claims, including deliberate indifference to a suicide risk. The United States District Court for the Eastern District of Missouri denied motions to dismiss brought by MODOC, Loflin, Yount, and Noisworthy. The court held that MODOC was not entitled to sovereign immunity because Williams plausibly alleged a dangerous condition exception under Missouri law. It also found that the correctional officers and sergeant were not entitled to qualified immunity on the constitutional claim, reasoning that Williams sufficiently alleged they knew of May’s suicide risk and were deliberately indifferent. Additionally, the court denied official immunity for the state wrongful death claim, concluding that the required checks were ministerial duties and thus not protected, and found the public duty doctrine did not bar the claim. Reviewing the case, the United States Court of Appeals for the Eighth Circuit reversed the district court’s rulings. The appellate court held that Williams’s allegations did not plausibly establish a dangerous condition under Missouri law, so MODOC was entitled to sovereign immunity. It also found Williams failed to allege that the officers had actual knowledge of May’s suicide risk, entitling them to qualified immunity. Lastly, the court determined the duties in question were discretionary, not ministerial, so official immunity applied. The case was remanded for further proceedings. View "Williams v. MO Department of Corrections" on Justia Law

Lacsina v. Blanche

2026-08-06T07:01:15-08:00

A lawful permanent resident, originally from the Philippines, was admitted to the United States in 1982. In 2013 and 2015, he pleaded guilty in California state court to receiving stolen property and possession of methamphetamine, respectively. Based on these convictions, the Department of Homeland Security initiated removal proceedings in 2024, charging him with inadmissibility as having committed a crime involving moral turpitude and a controlled substance offense. An Immigration Judge found both charges supported by the convictions and ordered his removal to the Philippines. The resident appealed this removal order to the Board of Immigration Appeals, challenging the finding that his property offense was a crime involving moral turpitude. The Board dismissed the appeal, agreeing with the Immigration Judge’s analysis, and declined to address the controlled substance conviction, finding the property offense alone sufficient to sustain removal. After being removed from the country, the resident moved to reopen his proceedings, arguing that his convictions had since been vacated by a California court. The Board denied this motion, relying on the “departure bar” regulation, which prohibits motions to reopen after removal, and concluded it lacked jurisdiction. The United States Court of Appeals for the Eighth Circuit reviewed both the Board’s dismissal of the appeal and the denial of the motion to reopen. The court held that the “departure bar” regulation, which prevents noncitizens from filing motions to reopen after removal, is invalid because it conflicts with the governing statute, which imposes no such geographic limitation. The court granted the petition as to the statutory motion to reopen, denied review regarding sua sponte reopening, and remanded the case to the Board for further proceedings. The main holding is that the Board cannot refuse to consider a statutory motion to reopen on the basis of the “departure bar” when the statute does not impose such a restriction. View "Lacsina v. Blanche" on Justia Law

United States v. Sutton

2026-08-05T07:01:20-08:00

Todd Sutton, Jr. was arrested in Iowa for driving with a suspended license, an aggravated misdemeanor. He was taken to the Cerro Gordo County Jail, where officials intended to place him in a communal intake dormitory with other detainees due to his cooperative behavior. Prior to being housed in the dormitory, jail policy required a visual strip search for detainees arrested for at least a serious misdemeanor. During this search, officials discovered a plastic bag containing methamphetamine concealed beneath Sutton’s genitals. Sutton was subsequently indicted for possession of methamphetamine with intent to distribute. Sutton moved to suppress the evidence found during the strip search, arguing it was an illegal search under the Fourth Amendment. The motion was first reviewed by a magistrate judge, who recommended denial. The United States District Court for the Northern District of Iowa adopted the magistrate’s recommendation over Sutton’s objection. Sutton then entered a conditional guilty plea, reserving his right to appeal the denial of his suppression motion. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s denial of the motion to suppress, applying a clear error standard for factual findings and de novo review for legal conclusions. The Eighth Circuit held that, under the Supreme Court’s decision in Florence v. Board of Chosen Freeholders of County of Burlington, jail officials may conduct strip searches of detainees who will be housed with others, even absent reasonable suspicion or probable cause, unless substantial evidence shows the search was unnecessary or unjustified. The court found no such evidence in Sutton’s case and affirmed the district court’s denial of the motion to suppress, concluding the strip search did not violate Sutton’s Fourth Amendment rights. View "United States v. Sutton" on Justia Law

Riles v. Koster

2026-08-05T07:01:20-08:00

Thomas Riles, who suffers from Gardner syndrome and requires regular medical intervention using a Barnett Continent Intestinal Reservoir (BCIR), was arrested for speeding while urgently seeking a restroom to drain his BCIR. During his arrest and subsequent detention at Carroll County Detention Center (CCDC), Riles alleged that officers failed to provide him with necessary medical supplies and assistance, despite his repeated requests and clear communication about his medical needs. As a result, Riles experienced complications, including permanent damage to his BCIR, leading to a significant alteration in his lifestyle and employment capabilities. Riles filed a lawsuit in the United States District Court for the Western District of Arkansas, asserting claims under 42 U.S.C. § 1983 for deliberate indifference to his serious medical needs against several defendants, including Officer Laralyn Koster. The district court granted summary judgment in favor of most defendants but denied it as to Koster on the deliberate indifference claim, concluding that a reasonable jury could find, based on the evidence, that Koster was aware of and disregarded Riles’s substantial risk of serious harm. Koster appealed this denial, arguing she was entitled to qualified immunity. The United States Court of Appeals for the Eighth Circuit reviewed the interlocutory appeal. The court determined it lacked jurisdiction to consider the appeal because the issues raised involved disputed facts and credibility determinations, which are not within the scope of interlocutory review under the collateral order doctrine. The court held that its authority extends only to abstract legal questions and not to factual disputes that a jury must resolve. Accordingly, the Eighth Circuit dismissed Koster’s appeal for lack of jurisdiction. View "Riles v. Koster" on Justia Law

FA ND Chev, LLC v. BAPTKO, Inc.

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

In 2018, BAPTKO, Inc., wholly owned by Robert Kupper, agreed to sell two car dealerships in North Dakota to Foundation Automotive Corp. The agreement included provisions regarding inventory management prior to closing, contingent earnout payments based on dealership performance, and an attorney’s fees clause for prevailing parties in disputes. Foundation Automotive Corp. later assigned its interests to two LLCs connected to each dealership. After the sale, relations deteriorated: the LLCs sued Kupper and related entities for breach of non-compete and tortious interference, while BAPTKO counterclaimed for unpaid earnout payments, asserting the performance targets had been met. The United States District Court for the District of North Dakota consolidated the actions. It granted partial summary judgment for the Kupper parties, holding that the Foundation parties were obligated to make the earnout payments. The district court denied summary judgment on the amount of damages, finding factual disputes. The Foundation parties conceded nonpayment but argued they were excused due to BAPTKO’s alleged prior breaches, particularly regarding inventory management. The district court rejected this argument, determining that any such breaches did not excuse performance but might affect the damages offset. At trial, the jury found BAPTKO had not breached the agreement. The district court also awarded attorney’s fees to BAPTKO, including amounts spent defending Kupper personally, and denied the Foundation parties’ post-trial motions. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The appellate court held that the district court properly granted partial summary judgment, concluding that no reasonable jury could find BAPTKO’s alleged breaches defeated the object of the agreement. The appellate court also held that limitations on expert testimony and jury instructions were not abuses of discretion, and that the attorney’s fee award, including amounts for Kupper’s defense, was supported by the agreement and not an abuse of discretion. View "FA ND Chev, LLC v. BAPTKO, Inc." on Justia Law

Northland Management & Construction, LLC v. City of Parkville

2026-08-03T07:30:52-08:00

Northland Management & Construction, LLC developed four lots in a Missouri subdivision, including Lot 9. The City of Parkville had approved the subdivision’s Sixth Plat, which contemplated grading Lot 9 at a continuous slope to its southern property line. During construction, Northland filled in an existing swale, installed piers to stabilize the home, and created a new swale that diverted stormwater runoff to both Lot 9 and neighboring Lot 3. The City became concerned about erosion and water flow, ultimately requiring Northland to seek a grading permit under Section 520 of the municipal code. Northland refused, believing the permit was unnecessary due to the approved plat. The City denied a final Certificate of Occupancy (CO), prompting Northland to file suit for the CO and damages for the inability to sell Lot 9 at full value. The United States District Court for the Western District of Missouri held a bench trial, where it ruled in favor of Northland on its Missouri state law inverse condemnation and equal protection claims. The court ordered the City to issue a final CO and awarded damages based on the difference in the lot’s value with and without a CO. The City complied with the order but appealed, challenging both the legal and factual bases for the district court’s rulings and the calculation of damages. The United States Court of Appeals for the Eighth Circuit affirmed the district court’s findings that Northland graded Lot 9 consistent with the approved plat and accepted practice, and that the City’s application of Section 520 was unreasonable. The appellate court also upheld the equal protection claim, finding Northland was treated differently from similarly situated property owners without rational basis. However, the court reversed the damages award, holding that compensation must reflect only the temporary diminution in value during the period the CO was withheld, and remanded for recalculation of damages. View "Northland Management & Construction, LLC v. City of Parkville" on Justia Law

Hamby v. State of Iowa

2026-08-03T07:30:51-08:00

The plaintiff, a Hasidic Jewish inmate formerly housed at Iowa State Penitentiary, submitted numerous grievances and a religious accommodation request, alleging that the Iowa Department of Corrections and its officials interfered with his religious practice. The grievances included issues such as access to a mikveh, use of candles with open flames, and use of religious funds for attorney fees. Under the Iowa Department of Corrections’ policy, these grievances were reviewed by a religious coordinator and could be appealed to a statewide committee. Several grievances were denied, others were marked as untimely or improper, and the plaintiff claimed he attempted to appeal all adverse decisions but often encountered obstacles. After discovery, defendants moved for summary judgment in the United States District Court for the Southern District of Iowa. A magistrate judge recommended dismissing all claims, finding that sovereign immunity barred claims against Iowa and its Department of Corrections; most claims were barred for failure to exhaust administrative remedies; prospective-relief claims were mooted by the plaintiff’s transfer to another prison; some damages claims were time barred; and remaining claims lacked merit. The district court adopted the magistrate’s report and granted summary judgment against the plaintiff. The United States Court of Appeals for the Eighth Circuit reviewed the summary judgment de novo. The court held that Iowa had consented to suit under RLUIPA, so sovereign immunity did not bar the plaintiff’s RLUIPA claims for prospective relief against the Department of Corrections. The court determined that the district court improperly disregarded the plaintiff’s declaration regarding exhaustion of administrative remedies and reversed the dismissal of claims relating to several grievances and the accommodation request. The court also found that some prospective-relief claims against statewide officials were not moot. It reversed in part, affirmed in part, and remanded for further proceedings consistent with its opinion. View "Hamby v. State of Iowa" on Justia Law

Pennington v. BHP Billiton Petrol

2026-08-03T07:30:51-08:00

Owners of mineral interests in Arkansas leased their interests to various oil and gas companies through private agreements. These leases required the companies to pay royalties based on gross proceeds, meaning royalties should be calculated without deducting post-production costs. In 2019, Flywheel, the operator for these leases, began deducting post-production costs from the first 1/8 royalty payment, relying on Ark. Code Ann. § 15-72-305, which refers to “net proceeds.” This change reduced the royalty amounts paid to the lessors, who then filed suit alleging breach of lease obligations. The United States District Court for the Eastern District of Arkansas reviewed the claims and granted summary judgment in favor of the oil and gas companies. The district court interpreted Ark. Code Ann. § 15-72-305 to permit deductions of post-production expenses from the first 1/8 royalty, regardless of lease terms. It relied on its own prior rulings and declined to follow an Arkansas Court of Appeals decision stating that the statute does not require deduction of post-production expenses. The district court also considered but ultimately rejected the impact of a legislative amendment, Act 1024, passed during the appeal, which clarified the meaning of “net proceeds.” The United States Court of Appeals for the Eighth Circuit reviewed the district court’s interpretation of Arkansas law de novo. The appellate court held that Ark. Code Ann. § 15-72-305(a)(3) is ambiguous regarding permissible deductions and determined, based on legislative clarification and the Arkansas Court of Appeals’ interpretation, that deductions from the royalty are not allowed beyond those specifically permitted by the lease. The court concluded that Act 1024 clarified the original legislative intent. It reversed the district court’s summary judgment and remanded for further proceedings consistent with its interpretation. View "Pennington v. BHP Billiton Petrol" on Justia Law

United HealthCare Services, Inc. v. AmerisourceBergen Corporation

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

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

United States v. Ketcher

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

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

King v. Texas Insurance Company

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

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

Hibbert v. MC Realty Group, LLC

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

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

Rolfsrud v. Continental Resources, Inc.

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

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

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

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

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

Iowans for Alternatives v. Mosiman

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

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

United States v. Owl

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

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

Rennenger v. Aquawood, LLC

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

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

United States v. Dominquez

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

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

Fayetteville Public Library v. Murray

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

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

Weems Industries, Inc. v. Teknor Apex Company

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

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

Knight v. Cambria Company, LLC

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

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

United States v. Bogan

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

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

Goforth v. Transform Holdco, LLC

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

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

United States v. Longie

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

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

United States v. Striplin

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

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

Jones v. City of St. Louis, Missouri

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

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

Joseph v. Thomas-Grace Const. Inc.

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

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

Audette v. Lake of the Woods County

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

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

RMS v. Commerce Bank

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

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

United States v. Berry

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

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

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

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

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

Elsharkawy v. Chisago Lakes Board of Education

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

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

United States v. Wako

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

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

United States v. Reis

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

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

G.T. v. Liberty Mutual Fire Insurance Company

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

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

United States v. Denby

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

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

United States v. Mendez

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

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

United States v. Redmon

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

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

United States v. Baxter

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

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

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

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

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

Lackie v. Noe

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

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

United States v. Drayton

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

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

United States v. Caster

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

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

United States v. Loggins

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

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

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

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

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

United States v. Dat

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

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

Murphy v. Continental Resources, Inc.

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

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

United States v. Zephier

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

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

Wilbur-Ellis Company v. Gompert

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

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

Carnes v. Blehm

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

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

Miller-Fields v. Londregan

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

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

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

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

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

McInnis v. Bolin

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

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