Justia Government & Administrative Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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In this case heard before the United States Court of Appeals for the Eighth Circuit, the appellant, Dewanis Rogers, sought a reduced sentence under the First Step Act of 2018. Rogers had been found guilty in 2008 of conspiracy to distribute 50 grams or more of cocaine within 1,000 feet of a protected location, following two or more prior felony drug convictions. He received a mandatory sentence of life imprisonment, as prescribed by statute. In 2022, Rogers requested that his sentence be reduced under the provisions of the First Step Act. The district court denied this motion, determining that Rogers was ineligible for relief under the Act. Rogers appealed this decision, disputing his ineligibility.Upon review, the United States Court of Appeals for the Eighth Circuit held that even if Rogers was eligible for relief under the First Step Act, the district court could not have lawfully reduced his sentence due to the mandatory term of imprisonment prescribed by statute. The court explained that Congress had not expressly repealed the mandatory punishment for Rogers’s offense in the First Step Act, and that the change in law cited by Rogers did not appear in the sections of the Fair Sentencing Act of 2010 made retroactive by the First Step Act. Therefore, the court affirmed the district court's decision. View "United States v. Rogers" on Justia Law

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In this case, the United States Court of Appeals for the Eighth Circuit considered an appeal by several Missouri public officials who were denied qualified immunity by a lower court regarding five claims arising from a murder prosecution. The murder case, involving Donald Nash who was eventually convicted for the murder of Judy Spencer, was reopened in 2007, 25 years after the crime occurred. The officials based their case on a theory that DNA evidence found under Spencer's fingernails belonged to Nash, which they asserted could not have remained present if Spencer had washed her hair after their last encounter.Nash was convicted and spent 11 years in prison until the Missouri Supreme Court set aside his conviction in 2020. The charges were dismissed after DNA testing on the shoelace used to strangle Spencer supported Nash’s noninvolvement. Nash and his wife filed a lawsuit against the officials, claiming violations of rights including unlawful arrest and detention, fabrication of evidence, failure to investigate, violations of rights of access to courts, and violation of the right to familial and marital associations.The Eighth Circuit affirmed in part, reversed in part, and dismissed in part the appeals on the denial of qualified immunity. The court held that the officials were not entitled to qualified immunity on the claim of unlawful arrest and detention, finding that the omission of certain exculpatory facts from the probable cause affidavit negated probable cause for Nash's arrest. However, the court reversed the denial of qualified immunity for the claim alleging violation of the right to familial and marital associations, as this was not a clearly established constitutional right in 2008. The court dismissed the officials' appeal on the remaining claims due to lack of jurisdiction, as these involved genuine disputes of material fact to be resolved by a jury. View "Estate of Nash v. Folsom" on Justia Law

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In 2006, Charles H. Lester, Jr. was sentenced to 188 months' imprisonment and 5 years of supervised release for conspiring to distribute methamphetamine. After serving a portion of his supervised release term, the United States Probation Office filed a report recommending the early termination of Lester's supervision, citing his low risk of recidivism and compliance with the conditions of his supervision. The United States District Court for the Eastern District of Missouri denied this request, asserting that it did not have the authority to terminate Lester's supervised release early due to the requirement in 21 U.S.C. § 841(b)(1)(A) that a five-year term of supervised release be imposed, which the court interpreted as precluding early termination under 18 U.S.C. § 3583(e)(1).Upon appeal, the United States Court of Appeals for the Eighth Circuit disagreed with the district court's interpretation. The appellate court held that the language of § 841(b)(1)(A) requires the imposition of a five-year term of supervised release, but does not impact a district court's ability to later terminate an individual's supervised release after the individual has served at least one year, as provided in § 3583(e)(1). Thus, the district court retained discretion to consider whether Lester's supervised release could be terminated early under § 3583(e)(1). Consequently, the appellate court reversed the district court's order and remanded the case for further proceedings consistent with its opinion. View "United States v. Lester" on Justia Law

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In the case before the United States Court of Appeals for the Eighth Circuit, Curtis Stewart, an inmate in the Missouri correctional system, filed a 42 U.S.C. § 1983 action against various Missouri Department of Corrections (MDOC) officials, including MDOC Director Anne Precythe. Stewart alleged that he was subjected to excessive force and cruel and unusual punishment due to a policy of handcuffing and shackling prisoners to a steel bench for hours. Precythe filed a motion for judgment on the pleadings, asserting that she was entitled to qualified immunity. The district court denied Precythe’s motion with respect to qualified immunity.The appeal court reversed the district court's decision. It held that Stewart failed to plausibly allege that Precythe authorized a policy that permitted jailers to use excessive force where it was unnecessary or unprovoked. The court also found that the complaint did not plausibly allege that Precythe acquiesced in any such practice of unprovoked or unwarranted excessive force because it failed to allege a pattern of such conduct.The court further noted that Stewart’s allegations against Precythe regarding the restraint policy did not violate the Eighth Amendment. The court held that the allegations represented the kind of punishment necessary “to preserve internal order and discipline and to maintain institutional security.” There were no allegations that Precythe’s conduct in adopting and promulgating the policy was “repugnant to the conscience of mankind.” Therefore, the court concluded that Precythe was entitled to qualified immunity. The court reversed the district court's denial of qualified immunity to Precythe and remanded for further proceedings consistent with its opinion. View "Stewart v. Precythe" on Justia Law

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The United States Court of Appeals for the Eighth Circuit affirmed a lower court's ruling in a case involving Sarah Felts, who had been blocked on Twitter by Lewis E. Reed, the then-President of the St. Louis Board of Aldermen. Felts sued Reed in his official capacity under 42 U.S.C. § 1983, alleging that her First and Fourteenth Amendment rights had been violated. The district court ruled in favor of Felts, granting her declaratory relief, nominal damages, costs, and attorney’s fees. On appeal, the Board’s new President, Megan E. Green, challenged the district court's ruling.The court held that the act of blocking Felts on Twitter constituted a final municipal policy decision in the area of the City’s business associated with the office of the President of the Board of Aldermen. It also held that Reed administered the account under color of law as an official government account, and that blocking Felts violated her First and Fourteenth Amendment rights. The court further concluded that Reed, as the President of the Board of Aldermen, had the authority to establish the final social media policy for his office and that his decision to block Felts was a deliberate choice of a guiding principle and procedure to silence online critics. Therefore, the City of St. Louis was held liable under 42 U.S.C. § 1983. The court affirmed the district court's judgment granting Felts declaratory relief and nominal damages. View "Felts v. Green" on Justia Law

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The United States Court of Appeals for the Eighth Circuit ruled in a case brought by the State of Missouri against several Chinese entities, including the government of the People's Republic of China, the Wuhan Institute of Virology, and others. Missouri accused the defendants of negligence in relation to the COVID-19 pandemic, alleging that they allowed the virus to spread worldwide, engaged in a campaign to keep other countries from learning about the virus, and hoarded personal protective equipment (PPE). The court decided that most of Missouri's claims were blocked by the Foreign Sovereign Immunities Act, which generally protects foreign states from lawsuits in U.S. courts. However, the court allowed one claim to proceed: the allegation that China hoarded PPE while the rest of the world was unaware of the extent of the virus. The court held that this claim fell under the "commercial activity" exception of the Foreign Sovereign Immunities Act, as it involved alleged anti-competitive behavior that had a direct effect in the United States. The case was remanded for further proceedings on this claim. View "The State of Missouri v. The Peoples Republic of China" on Justia Law

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In this case, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision to grant summary judgment in favor of Officer Andrei Nikolov, who had been sued for excessive force under 42 U.S.C. § 1983. The case arose from an incident in which the officer shot Jennifer Morgan-Tyra multiple times after responding to a domestic-disturbance call. Upon arrival at the scene, the officer encountered an angry Morgan-Tyra holding a gun and shouting expletives at someone out of his view. When she did not comply with a command to drop the gun, Officer Nikolov fired at least nine shots, several of which struck Morgan-Tyra and caused severe and lasting injuries.In affirming the district court's judgment, the appeals court found that, even if Officer Nikolov's decision to shoot without warning was objectively unreasonable under the circumstances, he did not violate a clearly established right. The court noted that officers may use deadly force when there is probable cause to believe that a suspect poses a threat of serious physical harm, either to the officer or to others, and that a warning is less likely to be feasible in a high-pressure situation that requires a split-second judgment. The court also found that a reasonable officer in Nikolov's position would not have known whether Morgan-Tyra was the initial aggressor or a victim who had fought back, and that it was not clearly unreasonable to shoot her under the circumstances. Even considering Morgan-Tyra's version of facts, the court held that she was wielding the gun in a menacing fashion and appeared ready to shoot. Thus, the court concluded that Officer Nikolov is entitled to qualified immunity. View "Jennifer Morgan-Tyra v. Andrei Nikolov" on Justia Law

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The United States Court of Appeals for the Eighth Circuit affirmed the sentences of Theodore Browne and Karley Ann Smith, both of whom had pled guilty to conspiring to distribute 50 grams or more of methamphetamine. Browne claimed that the district court erred in determining that he transported 10 pounds of meth, which influenced his base offense level. However, the Appeals Court ruled that the district court's approximation of the drug quantity, based on witness testimonies, was not clearly erroneous. Browne also argued that the district court wrongly applied a 4-level role enhancement, contending that there was insufficient evidence to show he was an "organizer or leader" of the conspiracy. The Appeals Court disagreed, ruling that the district court's finding was not clearly erroneous based on witness testimonies. Smith argued that the district court abused its discretion by considering late-filed evidence in the government’s sentencing memorandum, which resulted in the imposition of an obstruction enhancement and the denial of an acceptance-of-responsibility reduction. The Appeals Court ruled that Smith had sufficient time to review and respond to the challenged exhibits, and that the district court did not err in finding obstruction of justice and rejecting the acceptance-of-responsibility reduction. View "United States v. Browne" on Justia Law

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The case involves Brandon Peterson, an inmate at Washington County Jail (WCJ), who filed a lawsuit alleging violations of his constitutional rights by various jail officials. The United States Court of Appeals for the Eighth Circuit, reviewing the case, had to decide on numerous instances of alleged excessive force, failure to intervene, and deliberate indifference to serious medical needs, as well as constitutional and state law claims.The court found that on several occasions of alleged excessive force, the officers' actions were justified given Peterson's disruptive and threatening behavior. Consequently, the court granted qualified immunity to the officers involved in these incidents. In the case of the failure to intervene claims, the court decided that without an underlying constitutional violation, there can be no liability for failure to intervene, resulting in the officers being granted qualified immunity for these claims as well.On the issue of deliberate indifference to Peterson's mental health condition, the court found that the prison officials had made efforts to address his condition and had not acted with deliberate disregard for his health. Therefore, the court reversed the district court's denial of qualified immunity to the officials involved.Regarding Peterson's claim of being subjected to unconstitutional conditions of confinement, the court remanded the case to the district court for it to address this issue. The court also remanded the case to the district court to decide on the state law and Monell claims. As such, the Appeals Court reversed in part, dismissed in part, and vacated in part the district court's decision, remanding the case for further proceedings consistent with the court’s opinion. View "Peterson v. Heinen" on Justia Law

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In November 2020, Autumn Hilger visited the Mount Rushmore National Memorial and slipped on a temporary access mat that was installed due to renovations, which resulted in her breaking her wrist. Hilger filed a negligence claim against the United States Government under the Federal Tort Claims Act (FTCA), seeking $2 million for her injuries. The Government denied her claim, leading her to sue and allege that the National Park Service (NPS), a government agency, negligently installed and maintained the access mat and failed to warn of its danger. The district court dismissed her claims for lack of subject matter jurisdiction, applying the discretionary-function exception to the FTCA. Hilger appealed the dismissal.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court used a two-step test to determine whether the discretionary-function exception applies, first asking whether the challenged conduct or omission is discretionary, meaning it involves judgment or choice and is not controlled by mandatory statutes or regulations. Hilger had conceded in her appeal that there were no such controlling statutes or regulations, leading the court to agree with the district court that the challenged conduct was discretionary. The second inquiry was whether the judgment or choice was based on considerations of social, economic, and political policy. The court found that Hilger's complaint did not contain sufficient factual allegations to rebut the presumption that the discretion was grounded in policy considerations. The court concluded that the decisions regarding the mat were susceptible to policy analysis and that safety concerns, which Hilger argued were key in this case, are a typical policy consideration when applying the discretionary-function exception. As such, the court affirmed the district court's order dismissing Hilger's claims for lack of subject matter jurisdiction. View "Hilger v. United States" on Justia Law