8th U.S. Circuit Court of Appeals Digest: April 29, 2026

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Civil Rights

§1983

Wrongful Arrest; Qualified Immunity

Plaintiff appealed the summary judgment dismissal of his §1983 complaint against defendant. Defendant Officer Harris responded to a noise complaint at plaintiff’s home. The encounter escalated when plaintiff, who had two decades of law enforcement experience, began questioning defendant and his partner about their law enforcement experience and refusing defendant’s orders to cease using foul language while outside. When plaintiff continued to use foul language, defendant began to place plaintiff in handcuffs and executed a takedown maneuver when plaintiff resisted. Plaintiff was charged with disorderly conduct, resisting arrest, and public intoxication, but the charges were dismissed when plaintiff had no further infractions for a year. Plaintiff claimed defendant violated his First and Fourth Amendment rights, but the district court determined that defendant was entitled to qualified immunity.

Where plaintiff had demonstrated hostility toward defendant, continued to advance toward him as plaintiff’s wife tried to block his path, and suggested that the situation would require an immediate emergency response, defendant had a reasonable basis to conclude that plaintiff was engaging in disorderly conduct.

Judgment is affirmed.

Ward v. City of Sherwood (MLW No. 84659/Case No. 24-3316 – 10 pages) (U.S. Court of Appeals, 8th Circuit, Colloton, J.) Appealed from U.S. District Court, Eastern District of Arkansas, Wilson, J.

Constitutional Law

First Amendment Violation

As-Applied Challenge; Trespassing Statute

Plaintiff appealed the district court’s dismissal of its complaint. Plaintiff, along with several other animal welfare groups, sued Iowa officials to enjoin the enforcement of Iowa’s “trespass-surveillance” statute, which outlawed knowingly placing a recording device on trespassed property and imposed harsher penalties than the ordinary trespass statute. Plaintiff asserted as-applied challenges to the statute, arguing that it violated plaintiff’s members’ First Amendment rights by preventing them from recording on property open to the public when the owner asks them to leave but does not ask them to stop recording.

Where plaintiff conceded that the statute served a substantial state interest in protecting citizens’ privacy and where a property owner’s trespassing of a visitor from their property necessarily included a demand that the visitor stop recording on the property, the statute was narrowly tailored to serve the state’s interests.

Judgment is affirmed.

People for the Ethical Treatment of Animals, Inc. v. Iowa Citizens for Community Improvement (MLW No. 84652/Case No. 25-1750 – 12 pages) (U.S. Court of Appeals, 8th Circuit, Grasz, J.) Appealed from U.S. District Court, Southern District of Iowa, Rose, J.

Criminal Law

Aggravated Identity Theft

Upward Variance; Substantive Reasonableness of Sentence

Defendant challenged the substantive reasonableness of the sentence imposed following his conviction for aggravated identity theft and the special conditions of his supervised release. Defendant assumed the identity of a man whom he had worked with at a hot dog cart, using the man’s identity for several decades to evade criminal liability for auto theft and later obtaining employment under the man’s name. When the man reported that someone had stolen identity, defendant successfully sought the man’s prosecution and institutionalization. However, DNA testing uncovered defendant’s deception, leading to his guilty plea to aggravated identity theft. The district court varied upwards from the Guidelines range of 12 to 18 months to sentence defendant to 144 months, stating that the Guidelines did not account for the egregiousness of defendant’s conduct.

Where the district court cited the fact that defendant’s crime involved manipulating the criminal justice system to prosecute and institutionalize an innocent man, and based the special conditions of supervised release upon defendant’s own admission of his mental health issues, including suicidal ideation, there was no abuse of discretion in its upward variance.

Judgment is affirmed.

U.S. v. Keirans (MLW No. 84651/Case No. 25-1339 – 7 pages) (U.S. Court of Appeals, 8th Circuit, Gruender, J.) Appealed from U.S. District Court, Northern District of Iowa, Williams, J.

Child Sexual Abuse

Exclusion of Polygraph Results; Complete Defense

Defendant appealed his conviction for aggravated sexual abuse of a child and aggravated sexual contact of a child after sexually touching his minor stepdaughter on multiple occasions. Pretrial, the government sought to admit statements defendant had made during an interview with an FBI agent. The district court ruled that testimony from the agent and a redacted transcript from the interview could be admitted, but the parties were barred from telling the jury that defendant had failed a polygraph before the interview. On appeal, defendant argued that the exclusion of his polygraph results precluded him from presenting a defense that his statements during the interview were made to “explain away” the results.

Where the concerns over admitting potentially unreliable polygraph results, including the potential for jury confusion and overcomplicating the trial, outweighed any benefit the context provided by the results would have for defendant’s defense, the district court did not abuse its discretion in refusing to admit the results.

Judgment is affirmed.

U.S. v. Hudspeth (MLW No. 84654/Case No. 25-1434 – 8 pages) (U.S. Court of Appeals, 8th Circuit, Loken, J.) Appealed from U.S. District Court, District of South Dakota, Theeler, J.

Drug and Firearm Offenses

Substantive Reasonableness of Sentence; Appointment of New Counsel

Defendant challenged the substantive reasonableness of the sentence imposed following his guilty plea to drug and firearms offenses, and requested appointment of new counsel.

Where the record showed no abuse of discretion by the district court, the court affirmed defendant’s sentence.

Judgment is affirmed.

U.S. v. Morgan (MLW No. 84661/Case No. 25-2308 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Western District of Missouri, Bough, J.

Escape

Revocation of Supervised Release; Substantive Reasonableness of Sentence

Defendant challenged the substantive reasonableness of the sentences imposed following his guilty plea to escape and the revocation of his supervised release, with the district court imposing consecutive sentence on the revocation and defendant’s new conviction.

Where the district court adequately considered the relevant statutory sentencing factors, there was no abuse of sentencing discretion.

Judgment is affirmed.

U.S. v. Miller (MLW No. 84657/Case No. 25-2890 & 25-2892 – 3 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Southern District of Iowa, Ebinger, J.

Felon in Possession of Ammunition

Motion to Suppress Evidence; Sufficiency of Evidence

Defendant appealed his conviction and sentence for being a felon in possession of ammunition, arguing that the district court erred in denying his motion to suppress evidence and statements and determining that there was sufficient evidence to prove that the ammunition involved traveled in interstate commerce. Defendant also challenged the imposition of an offense level enhancement for obstruction of justice.

Where police lawfully stopped defendant’s vehicle because an object was obstructing the driver’s vehicle and the vehicle’s owner had a suspended license, and defendant’s visual condition and behavior suggested intoxication, the officers lawfully extended the stop, such that the evidence flowing from the stop was admissible.

Judgment is affirmed.

U.S. v. Hallmon (MLW No. 84653/Case No. 24-1837 – 16 pages) (U.S. Court of Appeals, 8th Circuit, Grasz, J.) Appealed from U.S. District Court, District of Minnesota, Menendez, J.

Firearm Offense

Above-Guidelines Sentence; Substantive Reasonableness of Sentence

Defendant appealed the above-Guidelines sentence imposed following his guilty plea to a firearm offense, challenging the substantive reasonableness of the sentence.

Where the district court considered the statutory sentencing factors, including the mitigating factors highlighted by defendant, there was no abuse of discretion as the district court had conducted an individualized assessment.

Judgment is affirmed.

U.S. v. Thomas (MLW No. 84660/Case No. 24-3627 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Eastern District of Arkansas, Rudofsky, J.

Revocation of Supervised Release

Above-Guidelines Sentence; Substantive Reasonableness of Revocation Sentence

Defendant appealed the above-Guidelines sentence imposed following the revocation of her supervised release, challenging the substantive reasonableness of the sentence.

Where the district court adequately considered the relevant statutory sentencing factors, there was no abuse of discretion in varying upward from the Guidelines range due to defendant’s conduct on supervised release.

Judgment is affirmed.

U.S. v. Patterson (MLW No. 84656/Case No. 25-2086 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Western District of Arkansas, Brooks, J.

Sentence Reduction

First Step Act; Denial of Motion

Defendant appealed the denial of his motion for a sentence reduction under the First Step Act.

Where defendant failed to establish extraordinary and compelling reasons, there was no error in denying a sentence reduction.

Judgment is affirmed.

U.S. v. Archer (MLW No. 84658/Case No. 25-2935 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Western District of Arkansas, Hickey, J.

Immigration

Removal Proceedings

Motion to Reopen; Withholding of Removal

Petitioner sought review of the BIA’s denial of his motion to reopen his removal proceedings and motion to remand. Petitioner, an Indian national, entered the U.S. without inspection and sought asylum, withholding of removal, and protection under the Convention Against Torture, claiming he had been persecuted in India for campaigning against the ruling political party. An IJ found petitioner not credible, denied his applications, and ordered him removed to India. Petitioner did not appeal but instead later moved to reopen the removal proceedings so he could seek a U-visa. The IJ denied the motion, finding that petitioner was unlikely to succeed in obtaining a U-visa. The BIA affirmed.

Where petitioner failed to demonstrate a prima facie case of eligibility for a U-visa because he had not submitted proof that he applied for a visa, there was no error in declining to reopen the proceedings.

Petition is denied.

Chaudhari v. Blanche (MLW No. 84650/Case No. 25-2106 – 6 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Petition for review of an order of the Board of Immigration Appeals.

Torts

Product Liability

Minnesota Law; Online Storefront Liability

Plaintiff appealed the district court’s denial of its request to certify a question for the Minnesota Supreme Court. Rochelle Zappa purchased a replacement battery for her cellphone through Amazon from a seller that was promoted on the website and used Amazon’s infrastructure to fulfill the order. The battery later caught fire while charging, causing substantial damage to Zappa’s workplace. Plaintiff, the insurer of Zappa’s employer, sued Amazon, the seller, and the unknown manufacturer in Minnesota state court. When Amazon removed the case to federal court, plaintiff dropped its claims against everyone other than Amazon and sought to certify the question of whether an online storefront like Amazon was strictly liable under Minnesota products liability law. The district court instead made an “Erie guess” that Minnesota law would not hold marketplaces like Amazon strictly liable.

Where there was no clear guidance from Minnesota state courts about Amazon’s liability under the state’s strict products liability law, the court decided to certify the question to the Minnesota Supreme Court to decide in the first instance.

Question certified to Minnesota Supreme Court.

Berkley Regional Insurance Company v. John Doe Battery Manufacturer (MLW No. 84655/Case No. 24-2159 –7 pages) (U.S. Court of Appeals, 8th Circuit, Stras, J.) Appealed from U.S. District Court, District of Minnesota, Tostrud, J.