8th U.S. Circuit Court of Appeals Digest: May 27, 2026

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Civil Rights

§1983

Charging Fees to Inmates; Due Process Violation

Plaintiffs appealed the dismissal of their complaint under §1983 for lack of standing and failure to state a claim. Plaintiffs, former inmates of defendants’ jail, alleged that defendants violated their Fourteenth Amendment due process rights by charging inmates fees for booking, room, and board, and collecting those fees by obtaining confessions of judgment from inmates by withholding their personal effects.

Where plaintiffs adequately alleged an injury-in-fact through the deprivation of funds by the charged fees and that the confessions of judgment precluded them from adequately challenging the imposition of the fees, they had standing to pursue their claims.

Judgment is vacated and remanded.

Roberts v. Thompson (MLW No. 84809/Case No. 25-1475 – 10 pages) (U.S. Court of Appeals, 8th Circuit, Gruender, J.) Appealed from U.S. District Court, Northern District of Iowa, Williams, J.

§1983

Injunctive and Declaratory Relief; Younger Abstention

Plaintiff appealed the dismissal of his §1983 action seeking declaratory and injunctive relief.

Where the district court properly abstained from adjudicating the case under the Younger doctrine, the court upheld the dismissal.

Judgment is affirmed.

Alvar v. Minnesota (MLW No. 84810/Case No. 25-3447 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, District of Minnesota, Menendez, J.

Constitutional Law

Second Amendment

Gun Permit; Reciprocity Rules

Plaintiff appealed the dismissal of his lawsuit. Plaintiff was a long-haul truck driver with Georgia and Florida firearms permits who wished to drive through Minnesota while carrying a firearm. However, Minnesota did not grant reciprocity to Florida and Georgia firearm permits. Plaintiff argued that these reciprocity rules violated the Second Amendment, but the district court dismissed the claim.

Where Minnesota’s shall-issue permitting regime did not violate the Second Amendment, the state’s reciprocity rules merely exempted some individuals from the permitting process and did not specifically restrict arms-bearing conduct.

Judgment is affirmed.

McCoy v. Jacobson (MLW No. 84818/Case No. 25-3036 – 5 pages) (U.S. Court of Appeals, 8th Circuit, Grasz, J.) Appealed from U.S. District Court, District of Minnesota, Tunheim, J.

Criminal Law

Child Pornography

Substantive Reasonableness of Sentence; Sentencing Discretion

Defendant appealed the sentence imposed following his guilty plea to production of child pornography, challenging the substantive reasonableness of the sentence. Defendant argued that the district court weighed the seriousness of his offense too heavily, failing to give enough weight to various mitigating factors.

Where the district court considered the mitigating factors highlighted by defendant and chose to impose a within-Guidelines sentence, there was no abuse of sentencing discretion.

Judgment is affirmed.

U.S. v. Hurkes (MLW No. 84808/Case No. 24-2283 – 3 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, District of South Dakota, Kornmann, J.

Drug and Firearm Offenses

Calculation of Guidelines Range; Downward Variance

Defendant appealed the sentence imposed following his guilty plea to drug and firearm offenses, arguing that the district court erred in calculating his Guidelines range and in not varying downward based on a policy disagreement with the Guidelines’ treatment of methamphetamine.

Where defendant did not dispute the quantity of drugs attributed to him, there was no error in the calculation of his Guidelines range, and the district court was not obligated to consider the distinction between a pure drug and a mixture containing a drug when fashioning the sentence.

Judgment is affirmed.

U.S. v. Williams (MLW No. 84816/Case No. 24-3119 – 5 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Eastern District of Missouri, Schelp, J.

Drug Offense

Appeal Waiver; Substantive Reasonableness of Sentence

Defendant challenged the substantive reasonableness of the sentence imposed following his guilty plea to a drug offense pursuant to a plea agreement containing an appeal waiver.

Where defendant could not challenge the voluntariness of his sentence on appeal without having moved to withdraw his guilty plea, the court dismissed defendant’s sentencing challenge based on the appeal waiver in his plea agreement.

Appeal is dismissed.

U.S. v. Moss (MLW No. 84813/Case No. 25-2611 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, District of Nebraska, Buescher, J.

Drug Offense

Downward Variance; Substantive Reasonableness of Sentence

Defendant appealed the sentence imposed following his guilty plea to a drug offense, challenging the substantive reasonableness of the sentence.

Where the district court did not abuse its discretion in declining to vary even further downward, the court rejected defendant’s sentencing challenge.

Judgment is affirmed.

U.S. v. Haywood (MLW No. 84819/Case No. 25-3273 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Western District of Arkansas, Brooks, J.

Illegal Reentry

Revocation of Supervised Release; Substantive Reasonableness of Sentence

Defendant appealed the sentence imposed following his guilty plea to illegal reentry as a felon and the revocation sentence imposed following the revocation of his supervised release for a prior offense, challenging the substantive reasonableness of the sentences.

Where the district court adequately considered the statutory sentencing factors and imposed within-Guidelines sentences, the court found no abuse of sentencing discretion.

Judgment is affirmed.

U.S. v. Mejia-Fraijo (MLW No. 84814/Case No. 25-3237 & 25-3242 – 5 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Northern District of Iowa, Strand, J.

Possession of Firearm by Unlawful Drug User

Constitutionality of Statute; Overruling Prior Precedent

Defendant appealed his conviction for possession of a firearm as an unlawful drug user, asserting a facial challenge to the statute of conviction. Defendant acknowledged circuit precedent foreclosing his argument but asked the court to overrule those prior cases.

Where the panel was bound by the decisions of a prior panel, the court was constrained to reject defendant’s constitutional challenge.

Judgment is affirmed.

U.S. v. Joshua (MLW No. 84811/Case No. 25-1337 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Southern District of Iowa, Ebinger, J.

Prohibited Person in Possession of Firearm

Motion to Suppress; Lawful Basis for Traffic Stop

Defendant appealed his conviction for being a prohibited person in possession of a firearm, challenging the denial of his motion to suppress the firearm found during his traffic stop. Defendant argued that the officer lacked reasonable suspicion or probable cause to stop defendant’s vehicle.

Where photographic evidence supported the district court’s determination that defendant’s windshield was sufficiently cracked as to impair his vision under applicable state law, the officer had reasonable suspicion of a traffic violation.

Judgment is affirmed.

U.S. v. Witt (MLW No. 84815/Case No. 24-2683 – 3 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, District of South Dakota, Schreier, J.

Supervised Release

Writ of Garnishment; Quashal

Defendant appealed the sentence imposed following the revocation of his supervised release. The district court had quashed the writ of garnishment imposed on defendant.

Where the writ had been quashed, defendant’s challenge was moot as the court could grant no further relief.

Appeal is dismissed.

U.S. v. Warren (MLW No. 84820/Case No. 25-3538 – 2 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, Eastern District of Arkansas, Marshall, J.

Wire Fraud

Sentence Reduction; Eligibility

Defendant appealed the denial of his motion to reduce his sentence. Defendant was convicted for wire fraud, money laundering, transporting stolen money and tax fraud. After defendant’s conviction, the Sentencing Commission adopted a two-level offense reduction for defendants with no criminal history who had not personally caused substantial financial hardship. The district court determined that defendant was ineligible under this provision and denied his motion for a sentence reduction.

Even if defendant’s crime had not caused a substantial financial hardship, the district court did not abuse its discretion in denying a sentence reduction based on its consideration of the statutory sentencing factors.

Judgment is affirmed.

U.S. v. Garbacz (MLW No. 84812/Case No. 25-2172 – 4 pages) (U.S. Court of Appeals, 8th Circuit, per curiam) Appealed from U.S. District Court, District of South Dakota, Schreier, J.

Employer-Employee

Pension Fund

Withdrawal Liability; Exemption

Defendant appealed the district court’s judgment affirming an arbitration award in favor of plaintiff. Defendant, which operated a pension fund, sought to impose withdrawal assessments upon plaintiff under ERISA. However, the arbitrator concluded that plaintiff qualified for an exemption from withdrawal liability for the building and construction industry.

Where the arbitrator used the more accurate method of counting the number of plaintiff’s employees who were engaged in the building and construction industry, there was no error in concluding that substantially all of plaintiff’s employees were engaged in the industry, thus entitling plaintiff to the withdrawal liability exemption.

Judgment is affirmed.

General Electric Company v. Boilermaker-Blacksmith National Pension Trust (MLW No. 84817/Case No. 25-1442 – 5 pages) (U.S. Court of Appeals, 8th Circuit, Kelly, J.) Appealed from U.S. District Court, Western District of Missouri, Wimes, J.