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

Articles Posted in Civil Procedure
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Plaintiffs, Arkansas prisoners who are or were on death row for capital murder convictions, filed suit alleging that Arkansas's method of execution violated the Eighth Amendment. In an effort to obtain the necessary information about the existence of known and available alternatives that would significantly reduce a substantial risk of severe pain, they served subpoenas on several state correctional departments, including the NDCS. After the NDCS objected, the district court determined that the Eleventh Amendment did not categorically bar the subpoena. NDCS appealed. While the appeal was pending, the Arkansas district court dismissed the inmates' suit and the Nebraska Supreme Court ordered public disclosure of the documents.The Eighth Circuit held that this case has been rendered moot where there is no effective relief that the court could grant because the materials at issue are already public. The court explained that requiring the return or destruction of the subpoenaed documents would provide no effective relief, and the court declined to do either. Finally, no exception to the mootness doctrine is applicable here. View "McGehee v. Nebraska Department of Correctional Services" on Justia Law

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This case arose from an ongoing dispute about whether plaintiffs had a contractual obligation to provide PS Finance with certain payments that plaintiffs received on behalf of a client.The Eighth Circuit held that the district court properly dismissed the claims against PS Finance based on the Rooker-Feldman doctrine. In this case, plaintiffs brought these claims in Arkansas after the New York court already ruled that whether plaintiffs owe money to PS Finance is a matter subject to arbitration. The court explained that, by proceeding with the claims in the district court, plaintiffs necessarily asked the federal court to review and reject the New York court's ruling that claims concerning amounts owed under the contract must be resolved in arbitration. View "Parker Law Firm v. The Travelers Indemnity Co." on Justia Law

Posted in: Civil Procedure
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Aspen agreed to pay FBR, an investment banking firm, 1.25 percent of the aggregate consideration paid to Aspen’s shareholders in the event of an acquisition or merger. Markel subsequently became the parent of Aspen and agreed to pay Aspen shareholders $135,700,000 in cash plus additional compensation based on the future value of Aspen’s business. FBR provided a fairness opinion and received 1.25 percent of the cash consideration. Aspen shareholders obtained “contingent value rights” to the additional compensation (CVR Holders) and challenged Markel’s valuation of the CVRs. The Delaware District Court has not yet issued a valuation opinion. FBR indicated its intent to claim 1.25 percent of the additional compensation.The CVR Holders sought a declaratory judgment that FBR is not entitled to further payment. FBR removed to the District of Nebraska, which dismissed the action because the CVR Holders failed to establish Article III standing. The Eighth Circuit affirmed. While the Holders' contract-based claims to a share of the additional compensation may be a legally protected interest, they have not suffered an injury that is concrete and particularized and actual or imminent. The final amount of the additional compensation has not been determined; no payments have been made. The Holders' only injury in fact is not fairly attributable to FBR asserting a competing claim, and cannot be redressed at this time by the judicial decision they seek. The additional compensation will be paid by Markel, a non-party. View "Yeransian v. B. Riley & Co., LLC" on Justia Law

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Plaintiff filed suit against various officials of an Arkansas jail, where he had been held as a pretrial detainee. After he was transferred to a facility in Texas, some of the defendants moved to stay the case. Although the case had already entered discovery, a magistrate judge granted the stay. Plaintiff then filed an objection to the motion to stay and a motion for relief from the magistrate order. The district court never acted on the motions, referred back to the magistrate judge, who then denied relief.The Eighth Circuit dismissed the appeal for lack of jurisdiction, holding that the court does not have jurisdiction to hear a direct appeal of a magistrate judge's order on a nondispositive pretrial matter. In this case, without a decision of a district court, this court lacked jurisdiction to proceed any further. View "Devine v. Walker" on Justia Law

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After the school districts sought modification of existing desegregation consent decrees to allow their exemption from Arkansas's Public School Choice Act, Ark. Code. Ann. 6–18–1906, the district court granted the motions and modified the consent decrees to explicitly limit the transfer of students between school districts. The Department appealed, alleging that the modification imposed an impermissible interdistrict remedy.The Eighth Circuit affirmed, holding that there was a substantial change in Arkansas law after the consent decrees were enacted and the district court's modification was not an impermissible interdistrict remedy. The court explained that the district court did not abuse its discretion in considering and crediting evidence of white flight when it determined that a substantial change in circumstances had occurred warranting modification of the consent decrees. Furthermore, based on the court's review of the record and the large degree of deference given to the district court, the court could not find that the district court abused its discretion in modifying the consent decrees. View "United States v. Arkansas Department of Education" on Justia Law

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Plaintiff filed suit against Allied Pilots in state court for conversion and unjust enrichment, arguing that he was entitled to keep his whole profit sharing payment rather than give some of it to the union for "dues." The union removed to federal court, contending that plaintiff's claims are preempted by the Railway Labor Act (RLA). The district court held that state law claims fell away due to preemption and the federal claims did not survive summary judgment.The Eighth Circuit reversed and held that the district court erred by relying on the complete-preemption doctrine, finding that the RLA wholly displaced plaintiff's state law claims. In this case, the RLA does not require disputes between an employee and a union to be heard by an adjustment board, so there is no federal cause of action at all, much less an exclusive one. Accordingly, the court vacated the district court's judgment and instructed the district court, on remand, to return this case to state court. View "Krakowski v. Allied Pilots Ass'n" on Justia Law

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An August 14, 2019 subpoena duces tecum ordered the IDPS to appear before the court's grand jury and provide documents relating to the investigation of an ISP officer for misconduct or use of excessive force. IDPS complied with five of the listed document categories but filed a motion to quash categories 3 and 4, which seek any and all records relating to the investigation of Officer John Doe for misconduct and any and all records relating to complaints made against Officer John Doe.The Eighth Circuit affirmed the district court's order denying IDPS's motion to quash and rejected IDPS's assertion that quashing the subpoena is needed to protect the Fifth Amendment rights of IDPS employees who participated in internal investigations; the procedural protections established by Kastigar v. U.S., 406 U.S. 401 (1972), and Garrity v. New Jersey, 385 U.S. 493 (1967), provide sufficient protection from the improper use of compelled statements; the Fifth Amendment allows the government to prosecute using evidence from legitimate independent sources; and the district court did not abuse its Federal Rule of Criminal Procedure 17(c)(2) discretion in deciding that IDPS failed to meet its substantial burden to show that compliance with the challenged portions of the grand jury subpoena would be "unreasonable or oppressive" when balanced against the interests of the government in enforcing the subpoena. View "In Re: Grand Jury Subpoena Dated August 14, 2019" on Justia Law

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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

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After movant filed a putative class action against SquareTrade, plaintiff filed a similar suit. Movant moved to intervene in plaintiff's suit, plaintiff and SquareTrade then reached a proposed class settlement, and the district court in plaintiff's case denied the motion to intervene.The Eighth Circuit affirmed, holding that, although movant is situated so that disposing of plaintiff's action may impair his interests, movant is adequately represented by plaintiff, who seeks the same relief for the same claims as movant. Furthermore, there was insufficient evidence that the plaintiff settlement constituted a reverse auction. Therefore, the motion to intervene was properly denied. Finally, the court lacked jurisdiction to review the denial of the motion for stay under the first-to-file rule based on lack of pendent jurisdiction. View "Swinton v. Starke" on Justia Law

Posted in: Civil Procedure
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After Cody Franklin died in police custody, his father, as administrator of his estate, sued the police officers who struggled with Franklin the night he died, and against the municipalities who employed them. The elder Franklin asserted claims under 42 U.S.C. 1983 for excessive force, and claims under state law for battery and wrongful death. The district court entered summary judgment in favor of the municipalities and all but two of the officers. Those officers filed an interlocutory appeal, arguing they were entitled to qualified immunity on all claims. After review, the Eighth Circuit agreed with the officers with respect to the federal claims, and remanded. With respect to the state claims, the Court remanded for further proceedings, including a determination whether to exercise supplemental jurisdiction over those claims. View "Franklin v. Franklin County, Arkansas" on Justia Law