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

Inline filed suit against its competitor, Graphic, alleging antitrust and tortious interference claims related to the susceptor-packaging market. The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Graphic, holding that the district court did not err concluding that there was no genuine dispute of material fact regarding whether Graphic fraudulently procured patents on packaging concepts and designs through false claims of inventorship of the asserted patents and fraudulently concealed prior sales of drawing sample sleeves. In this case, Inline cannot establish that Graphic committed knowing and willful fraud and thus his monopolization claim under 15 U.S.C. 2 failed. Because Inline did not evidence fraud related to Graphic's procurement of the asserted patents and its prior sales of drawing sample sleeves 50019D/F, it has not established why the same set of facts and evidence would render Graphic's patent-infringement litigation objectively baseless. Therefore, the court affirmed the district court's dismissal of the sham-litigation claim.The court affirmed the district court's dismissal of the discount-bundling claim because Inline failed to show that Graphic held sufficient monopoly or market power, and the district court adequately assessed the record and did not abuse its discretion in dismissing Inline's economic expert's untimely market opinion. Finally, the court held that the district court did not abuse its discretion in rejecting Inline's exclusive dealing claim and tortious interference claim. View "Inline Packaging, LLC v. Graphic Packaging International, LLC" on Justia Law

The Ritchie entities filed suit seeking to recover millions of dollars they loaned Tom Petters, a convicted fraudster, and two of his companies. The Ritchie entities alleged that defendants helped conceal the fraud so that they could recover millions they had tied up with Petters' companies. The district court dismissed the claims as time-barred.The Eighth Circuit first held that the district court had subject matter jurisdiction under the Edge Act, and the court need not decide whether the district court also had subject matter jurisdiction under 28 U.S.C. 1334(b). Furthermore, the district court was correct to apply New York choice-of-law principles to determine that Illinois law applied to the question of whether the action was time-barred.The court also held that the district court erred in concluding that Illinois's statute of limitations applied to three of the plaintiffs because the pleadings do not definitively establish their claims accrued in Illinois. The district court did not err in finding that the remaining claims were untimely under Illinois law and that the doctrines of discovery rule, equitable estoppel, and equitable tolling did not apply. The court also held that the district court did not abuse its discretion by failing to grant the Ritchie entities leave to amend their complaint yet again because the Ritchie entities failed to submit a motion to amend or indicate what a proposed amended pleading would have stated. Finally, the court reversed the dismissal of the Ritchie Cayman entities' claims against JP Morgan Europe in order for the district court to permit jurisdictional discovery if it deems necessary to determine whether it has personal jurisdiction over JP Morgan Europe. View "Ritchie Capital Management v. JP Morgan Chase & Co." on Justia Law

CRST filed suit against TransAm, alleging that TransAm wrongfully recruited and hired several long-haul truck drivers who were under contract with CRST. The district court granted TransAm's motion for summary judgment and dismissed all of CRST's claims with prejudice.The Eighth Circuit held that the district court erred with respect to the causation element but did not err with respect to the existence of a valid contract element, and that the record contains sufficient evidence to support the intentional and improper interference element. The court also held that the district court erred in granting TransAm's motion for summary judgment on CRST's unjust enrichment claim. Finally, the court held that the district court did not abuse its discretion in finding the drivers were not indispensable parties. Accordingly, the court reversed and remanded the district court's order granting TransAm's motion for summary judgment and affirmed the district court's determination that the drivers are not indispensable parties to the proceedings. View "CRST Expedited, Inc. v. Transam Trucking, Inc." on Justia Law

The Eighth Circuit affirmed judgments against DatabaseUSA for copyright infringement and Vinod Gupta for breach of contract. After Gupta founded Infogroup, he and the company entered a separation agreement. Then Gupta found DatabaseUSA two years later.The court held that a reasonable juror, based on the evidence at trial, could have found Infogroup owned a valid copyright; a reasonable juror could have concluded that DatabaseUSA copied the original elements of Infogroup's work; and, because of spoliation, DatabaseUSA's two arguments against copying fail. Finally, the court affirmed the $11.2 million award for the copyright infringement claim and the $10 million award for the breach of contract claim. View "Infogroup, Inc. v. DatabaseUSA.com LLC" on Justia Law

The Eighth Circuit affirmed the district court's order granting Jet Midwest and PMC's motion for a preliminary injunction to prevent Appellant Ohadi and Woolley from foreclosing on the assets of JMG until the parties conduct an expedited trial on the merits of the underlying fraudulent transfer act.The court held that the district court properly applied the Dataphase factors and did not abuse its discretion in making the reasonable decision to grant the preliminary injunction to maintain the status quo and expedite the trial to further develop the record. In this case, the district court did not abuse its discretion in determining that Jet Midwest demonstrated a likelihood of success on the merits where there was no dispute that the sale initially contained parts from Jet Midwest's Aircraft and that Jet Midwest had a purchase money interest in the Aircraft; Jet Midwest would suffer irreparable harm if Ohadi and Woolley were allowed to proceed with the foreclosure sale; Ohadi and Woolley's burden is outweighed by the serious potential harm Jet Midwest would face if Ohadi and Woolley conducted a foreclosure sale of its possible interests; and the district court did not abuse its discretion in finding that the public interest favored enforcing the injunction to prevent fraud. View "Jet Midwest International Co. v. Ohadi" on Justia Law

Trustees of three employee benefit funds filed suit against Charps and others, alleging that defendants breached collective bargaining agreements by not contributing to the employee benefit funds for work performed by the affiliates, in violation of the Employee Retirement Income Security Act (ERISA). The district court granted summary judgment to defendants, awarding them attorney's fees and costs.The Eighth Circuit held that defendants did not owe contributions for the affiliates' work where the trustees have not shown a genuine issue that the defendant companies formed a relationship of alter ego, joint venture, or joint enterprise. Furthermore, the collective bargaining agreements did not require defendants to contribute for the work of Charps' affiliates. The court also held that the trustees did not meet their burden in opposing summary judgment on their claim that the district court failed to address Charps' liability for contributions based on its own employees' work, and the district court did not abuse its discretion in denying, as duplicative, the trustees' motion to compel production of the spreadsheets.Accordingly, the court affirmed the judgment in 18-3007, but reversed and remanded in 19-1206. On remand, the district court should award costs that are taxable under 28 U.S.C. 1821 and 1920. In regard to the nontaxable costs, the district court may determine whether they may be awarded as attorney's fees. View "Johnson v. Charps Welding & Fabricating, Inc." on Justia Law

Ambassador Press filed suit against Durst Image for fraud, alleging that the printing press that was purchased from Durst Image did not have the speed or durability Durst Image represented at the time of the purchase.The Eighth Circuit affirmed the district court's grant of Durst Image's motion to dismiss, holding that the district court correctly determined that Ambassador Press did not plausibly allege common law fraud. The court also held that the district court properly determined that reliance was not pleaded with particularity and properly granted the motion to dismiss. View "Ambassador Press, Inc. v. Durst Image Technology U.S., LLC" on Justia Law

A corporation that acquires substantially all the assets of an unrelated competitor at a secured creditor's private foreclosure sale, in an agreement that declines to assume the competitor's liabilities, is not liable as the competitor’s successor for unpaid pre-acquisition inventory purchases from a third party. The Eighth Circuit affirmed the district court's grant of summary judgment dismissing Westfeldt's counterclaims for successor liability, unfair trade practices, conversion, and unjust enrichment, primarily on the ground that Westfeldt failed to submit evidence that the foreclosure and asset sale were anything but bona fide business transactions.The court held that buying USR assets from Great Western at a foreclosure sale in an agreement that disclaimed assumption of USR liabilities protected Ronnoco from claims that the asset purchase was tainted by commercially inadequate consideration. In this case, Westfeldt offered no evidence that it was prejudiced by the asset sale. Furthermore, there was no evidence that, absent the alleged fraud by Ronnoco, USR would have been able to pay off its entire debt to Great Western and then make payment to Westfeldt. Finally, the district court properly rejected Westfeldt's remaining claims. View "Ronnoco Coffee, LLC. v. Westfeldt Brothers, Inc." on Justia Law

Continental appealed from a jury determination that it had tortiously interfered with the business relationship of plaintiff and CTAP. The Eighth Circuit affirmed and held that the evidence was sufficient to support a conclusion that Continental acted with intent to interfere in the plaintiff-CTAP business relationship, either by desiring to bring the interference about or knowing that the interference was substantially certain to occur; sufficient evidence existed to permit the jury to find that Continental’s interference was improper and that Continental was the legal cause of plaintiff's injury; substantial evidence supported the jury's award of punitive damages; and the district court did not err by denying Continental's motion for a new trial. The court also held that the district court did not abuse its discretion when instructing the jury on improper interference. View "Janvrin v. Continental Resources, Inc." on Justia Law

Lamar maintained and operated a billboard on land that it leased from R.E.D. After R.E.D. and Landmark executed an agreement under which Landmark agreed to pay R.E.D. in exchange for, among other things, the right to receive rent from Lamar, Landmark sued R.E.D. for breach of contract and sued R.E.D. and Defendant Van Stavern for fraudulent and negligent misrepresentation.The Eighth Circuit affirmed the district court's judgment and held that the district court did not err by excluding the testimony of defendants' expert witness where the expert's opinions were not relevant because they were not supported by facts in the record. Furthermore, the district court did not err by denying defendants' request for reconsideration, because the discovery deadlines had passed and defendants failed to offer a substantial justification for their delay. Finally, the court held that the damages award were not duplicative and affirmed the attorneys' fee award. View "Landmark Infrastructure Holding Co. v. R.E.D. Investments, LLC" on Justia Law