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Breach of Contract and Sentencing Cases Decided

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By FindLaw Staff on February 16, 2010 12:41 PM

The Eighth Circuit decides two cases today, one involving an alleged breach of a settlement agreement reached in bankruptcy proceedings, and another the appropriate sentence for a "walkaway escape" from a federal prison camp.

American Prairie Constr. Co. v. Hoich, No. 08-1288, concerned an action to enforce a settlement agreement allegedly reached by the parties in a bankruptcy proceeding.  After a bench trial, the district court entered judgment for plaintiff.

The Eighth Circuit affirmed the district court's denial of defendant's motion to dismiss and its motion to recuse the district judge, because the statements in the district court's opinions and in the trial transcripts manifestly did not demonstrate a deep-seated favoritism or antagonism, nor did they display a disposition so extreme as to render fair judgment impossible.  However, the court of appeals reversed the district court's order enforcing the settlement agreement on the ground that the parties did not have a meeting of the minds on an essential term.

US v. Jackson, No. 08-3979, involved a criminal defendant's appeal from his sentence for a "walkaway escape" from a federal prison camp.

The Eighth Circuit affirmed defendant's sentence on the ground that, even if the district court was incorrect in holding that an 18 U.S.C. section 751(a) conviction for a walkaway escape qualified as a crime of violence, the sentencing court's harmless error in applying the Sentencing Guidelines did not require a remand.  This was because the district court sentenced defendant below the career-offender Guidelines and within the range that would have applied had the court found the career-offender provisions inapplicable.

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