Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Lakeside appealed from the district court's grant of summary judgment in favor of Producers on Lakeside's state-law claim for fraudulent misrepresentation, negligent misrepresentation, and unjust enrichment involving payment for the feed and care of the hogs at issue. The court affirmed the district court's grant of summary judgment in favor of Producers on Lakeside's fraudulent misrepresentation claim where Lakeside was unable to establish that Producers made any false representations; affirmed the district court's grant of summary judgment on the fraudulent nondisclosure claim where Producers was under no legal obligation to disclose information to Lakeside; held that the district court did not abuse its discretion in excluding Lakeside's expert testimony where such testimony was not needed to inform the district court on the legal issues; affirmed the district court's grant of summary judgment in favor of Producers on the issue of negligent misrepresentation where Producers was not in the business or profession of supplying information or guidance to Lakeside but rather the two conducted themselves at arm's length; and held that it was not unjust to allow Producers to retain the benefit of these particular happenings when a shortfall existed, as it was not inequitable to allow a contracting party the right to fulfillment of contractual obligations, which in this case included the payment of fees contemplated by the Hog Program.

Several Nebraska farmers filed suit under 42 U.S.C. 1983, alleging their due process rights were violated when Nebraska officials ordered the farmers to cease drawing water from the Niobrara Watershed without providing a predeprivation hearing. The court agreed with the district court that the farmers have not suffered a deprivation of their property rights where the property right held by the farmers was expressly conditioned on the Nebraska Department of Natural Resources' (DNR) determination of watershed capacity. Therefore, the farmers had no legitimate claim to the water when the DNR determined that there was a scarcity and the issuance of Closing Notices was necessary to satisfy the needs of senior appropriators. The court also held that the district court was permitted to dismiss without prejudice the pendent state-law ultra vires claim in light of its grant of summary judgment on the section 1983 claim.

Debtors, owners and operators of a farm and ranch, appealed from the judgment of the bankruptcy court denying their discharge pursuant to 11 U.S.C. 727(a)(5). The court held that the bankruptcy court did not clearly err in finding that debtors failed to adequately explain the loss of cattle. Accordingly, the judgment denying debtors' discharge was affirmed.