Justia Civil Rights Opinion Summaries

Plaintiffs, the husband and uncle of decedent, filed suit against defendants alleging state law tort claims and violations of decedent's federal constitutional rights. The court held that the district court properly dismissed plaintiffs' malpractice claim for failure to comply with Minnesota Statutes section 145.682 and that the magistrate judge did not abuse her discretion in denying plaintiffs' motion to extend deadlines to serve expert affidavits. The court also held that the district court properly dismissed plaintiffs' Federal Tort Claims Act (FTCA), 28 U.S.C. 2401(b), claim for lack of jurisdiction and that plaintiffs have not alleged error in the district court's determinations in regards to the dismissal of their 42 U.S.C. 1983 cause of action. The court affirmed the district court's order dismissing the Bivens action against Federal defendants and affirmed the district court's dismissal of the equal protection claim. Finally, the court rejected challenges to discovery and pretrial rulings.

Plaintiff, a Missouri inmate, moved for leave to proceed in forma pauperis in his appeal of the district court's dismissal of his civil rights action before service of process, pursuant to 28 U.S.C. 1915A, for failure to state a claim. The court concluded that plaintiff was ineligible under the "three strikes" provision in section 1915(g) to proceed in forma pauperis on appeal and denied the motion.

Plaintiffs brought this action against defendants, social service employees, alleging that they violated 42 U.S.C. 1983 and state law by recommending that custody of their son be granted to his grandparents. According to plaintiffs, this recommendation resulted in the untimely death of their son. The court affirmed the district court's grant of summary judgment to the state employees after concluding that they were entitled to qualified immunity on the federal claims and official immunity on the state claims.

Defendant pled guilty to two counts of wire fraud in connection with a mortgage fraud scheme. At sentencing, the district court calculated an advisory sentencing guidelines range of thirty-three to forty-one months' imprisonment based on a total offense level of twenty and a criminal history category of I. The district court sentenced Defendant to a term of thirty-three months' imprisonment, and Defendant appealed the sentence. The Eighth Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in sentencing Defendant to thirty-three months' imprisonment, as the sentence was substantively reasonable and the district court did not commit significant procedural error.

Defendant pled guilty to production of child pornography for photographs she took of her daughters at ages six and two. The district court sentenced Defendant to 216 months, departing and varying downward from Defendant's guideline sentence of 360 months. Defendant challenged her sentence on appeal as substantively unreasonable. The Eighth Circuit Court of Appeals affirmed, holding (1) the record demonstrated that the district court carefully considered the 18 U.S.C. 3553(a) factors in light of the mitigating evidence presented and the gravity of the offense; and (2) the district court did not abuse its discretion in imposing the sentence and that Defendant's sentence was not unreasonable.

In 1994, Defendant was convicted of sex crimes in Kentucky. When Defendant moved to North Dakota in 2008, he was required to register as a sex offender. Because Defendant did not have a residence for a short while, he did not properly register. North Dakota then filed a criminal complaint against Defendant, charging him with failure to comply with registration requirements. The trial court convicted Defendant as charged. Defendant appealed, arguing that the state district court erred in interpreting N.D. Cent. Code 12.1-32-15(7) as requiring him to register within three days even though he had not obtained an address. The Supreme Court affirmed. Defendant subsequently filed a petition for relief under the Antiterrorism and Effective Death Penalty Act (AEDPA) in federal court that included an amended claim arguing he was denied due process of law by the state's attorney interpreting the statute to include persons who have no residence to register. The district court granted the certificate of appealability on the amended claim. The Eighth Circuit Court of Appeals affirmed, holding that, under the AEDPA and Bouie v. City of Columbia, the state court's interpretation of its own statute was not an unforeseeable and retroactive expansion of statutory language.

Nicole Walker and Bart Hyde pled guilty to conspiring to manufacture and distribute methamphetamine. Defendants appealed their respective sentences, arguing that the district court clearly erred in calculating the drug quantity attributable to each of them. Hyde also argued that the district court erred in imposing an obstruction of justice enhancement and failed to reduce Hyde's sentence for acceptance of responsibility. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court did not rely on unreliable evidence or apply an overly broad definition of conspiracy; (2) the district court did not clearly err in determining Defendants distributed "ice" as defined in the Sentencing Guidelines; (3) the district court did not err in applying an obstruction of justice enhancement based on the court's determination that Defendant intentionally gave false testimony; and (4) the district court did not err in denying a reduction for acceptance of responsibility.

Defendant was convicted of being a felon and an unlawful drug user in possession of a firearm. Pursuant to a conditional plea agreement, Defendant appealed the district court's denial of his motion to suppress as well as a condition of supervised release that the district court imposed. The Eighth Circuit Court of Appeals affirmed, holding (1) no Fourth Amendment violation occurred when a law enforcement officer extended the duration of the traffic stop to inquire as to Defendant's warrant status; and (2) the district court did not abuse its discretion when it recognized the threat of cross addiction and responded by imposing a special condition of supervised release that prohibited Defendant from the use of alcohol and from entering establishments whose primary source of income is derived from the sale of alcohol.

Defendant pleaded guilty to possession with intent to distribute 100 kilograms or more of marijuana. The plea agreement recited that Defendant was subject to a mandatory minimum sentence of five years in prison but that he could be eligible for a safety valve reduction upon the condition that he truthfully provide to the government all information he had concerning the offense. At sentencing, the district court concluded the safety value reduction did not apply and imposed a sixty-month sentence. The Eighth Circuit Court of Appeals affirmed, holding that because Defendant did not provide the government truthful information and evidence about the relevant crimes before sentencing, the court had no choice but to deny a safety valve reduction.

Tracy and Steve Lind filed this suit after Defendants attached funds in the Linds' joint bank account pursuant to Minnesota's garnishment laws. The Linds alleged that Defendants deprived Tracy of her due process rights in violation of 42 U.S.C. 1983 and that Defendants violated the Fair Debt Collection Practices Act (FDCPA). The district court dismissed both claims, concluding (1) Tracy had received constitutionally sufficient notice and an opportunity for a hearing; and (2) the Linds failed to allege any independent violation of the FDCPA in the complaint. The Eighth Circuit Court of Appeals affirmed, holding (1) because Tracy had actual notice and an opportunity for a postdeprivation hearing, her due process rights were not violated when Defendants attached funds from the Linds' joint bank account pursuant to the Minnesota garnishment statutes; and (2) the district court did not err in dismissing the Linds' FDCPA claim, as the Linds alleged no specific acts that demonstrated violations of the Act.