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| Conwed Corp. v. Union Carbide Corp., Nos. 04-3386 / 04-3855,
UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT, April 18, 2006, Filed
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Overview: In a subrogation action to recover workers' compensation benefits from third-party defendant, under Minn. Stat. § 176.061, the district court properly applied the jury's allocation of fault to the lesser of the benefits paid or the jury verdict, but the reduction only should have applied once--the initial reduction by defendant's fault was error.
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| United States v. Shafer, No. 04-4001,
UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT, April 18, 2006, Filed
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Overview: Attack on voluntariness of plea was not properly before appellate court, because defendant failed to first raise the issue in the district court by seeking to withdraw his guilty plea; rather, at sentencing defendant affirmatively represented he wished to maintain his plea. Plea foreclosed all pre-plea non-jurisidictional attacks on conviction.
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