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

This case was brought by a class of sex offenders (Appellants) civilly committed to the Minnesota Sex Offender Program (MSOP) pursuant to the Minnesota Civil Commitment and Treatment Act: Sexually Dangerous Persons and Sexual Psychopathic Personalities, codified at Minnesota Statute Section 253D (MCTA). Appellants filed this action against various MSOP managers and officials, as well as the Commissioner of the Minnesota Department of Human Services (collectively, Appellees). On remand after a second appeal to this Court, the district court granted judgment in favor of Appellees on all of Appellants’ claims. Appellants appeal, challenging the district court’s judgment.   The Eighth Circuit affirmed. The court explained that Appellants contend that the district court erred by declining to address their treatment-related claims, alleging that the district court found them to be duplicative of previously decided counts. The court wrote that in making this finding, the district court did not dismiss or otherwise ignore any of the counts before it, which were all conditions-of-confinement and inadequate medical care claims. While Appellants attempted to “reanimate” these claims in a Fourth Amended Complaint, the district court denied the amendment, and Appellants do not challenge that decision on appeal. Accordingly, the court perceived no error in the district court’s treatment of Appellants’ treatment-related claims. Appellants additionally attacked the district court’s conclusion that the MSOP’s Behavioral Expectation Report policy is constitutional. But Appellants focused only on the impact of the policy on their treatment and fail to address the other legitimate government objectives it addresses—such as preserving institutional order at the MSOP. View "Kevin Karsjens v. Jodi Harpstead" on Justia Law

In March 2020, Concord Baptist Church of Jefferson City, Inc. (Concord Baptist) sustained damage to its facilities in a severe storm. After disagreements with its insurer, Church Mutual Insurance Company (Church Mutual), regarding the amount of loss, Concord Baptist initiated this action, alleging breach of contract and vexatious refusal to pay. The district court granted summary judgment in favor of Church Mutual, concluding that the undisputed facts demonstrated that Concord Baptist failed to comply with a cooperation clause contained in the insurance policy, which precluded coverage. Concord Baptist appealed.   The Eighth Circuit affirmed. The court explained that because Concord Baptist admits that it materially breached the policy, the court need not address Concord Baptist’s argument regarding whether the failure to submit to an EUO was a material breach. However, the court noted that Missouri courts have found a material breach where an insured failed to submit to an EUO before commencing an action against the insurer. Regarding the second element, whether Church Mutual suffered substantial prejudice from Concord Baptist’s material breach, the court agreed with the district court that the undisputed facts show that it did. Finally, as to the third element, whether Church Mutual exercised reasonable diligence in attempting to procure Concord Baptist’s cooperation, the court again agreed with the district court that the undisputed facts demonstrate Church Mutual’s diligence. View "Concord Baptist Church of Jefferson City v. Church Mutual Insurance Company" on Justia Law

Plaintiff, as personal representative of her brother, who was in pretrial custody at Phelps County Jail for about six months, filed a lawsuit for damages from inadequate medical care during her brother’s pretrial detention. The district court awarded the individual defendants and Phelps County summary judgment. Plaintiff argued the district court erred by entering summary judgment in favor of the individual defendants on her claim for deliberate indifference to a serious medical need. “   The Eighth Circuit affirmed. The court concluded there is not a genuine issue of material fact as to whether Defendants were deliberately indifferent. A correctional officer’s deference to a medical professional regarding a pretrial detainee’s medical care, standing alone, does not create a genuine issue of material fact on deliberate indifference to serious medical needs. Plaintiff, however, points to nothing in the record showing Defendants deliberately disregarded her brother’s condition while he was in the holdover cell during the final weeks of his pretrial detention. Instead, Plaintiff points to evidence that Phelps County employees were generally aware that her brother was suffering. This evidence, however, does nothing to address the focus of the court’s inquiry: whether Defendants deliberately disregarded Plaintiff’s brother’s serious medical need. Ultimately, the court concluded there is no genuine issue of material fact as to whether Defendants violated the Fourteenth Amendment. View "Lady Maakia Charlene Smith v. Richard Lisenbe" on Justia Law

The Federal Communications Commission (FCC) provides subsidies to encourage telecommunication companies to expand high-speed broadband internet services in rural areas where customer revenues would otherwise be insufficient to justify the cost of doing business. Venture Communications Cooperative (“Venture”) provides broadband services to rural South Dakota customers. James Valley Cooperative Telephone Company and its wholly owned subsidiary, Northern Valley Communications (collectively, “Northern Valley”), is a competing provider. Venture filed this lawsuit against Northern Valley. The primary claim is that Northern Valley violated 47 U.S.C. Section 220(e) by filing a Form 477 that “intentionally, deliberately, fraudulently, and maliciously misrepresented” information “for the sole unlawful purpose of harming [Venture]” by depriving Venture of FCC subsidies in census blocks where Northern Valley was deemed to be an unsubsidized competitor. The district court granted Northern Valley summary judgment, concluding “there is no evidence that Northern Valley willfully overreported its broadband capabilities.”   The Eighth Circuit affirmed. The court explained that Venture’s claim of intent to injure is belied by Northern Valley helping Venture by filing a letter with the FCC clarifying that Northern Valley did not offer voice service in the Overlap Area. The court likewise affirmed the dismissal of Venture’s tortious interference and civil conspiracy claims under South Dakota law. The court agreed with the district court that Venture proffered no evidence of an “intentional and unjustified act of interference” because Northern Valley complied with all FCC reporting requirements. As Northern Valley complied with the Telecommunications Act in filing Form 477 at issue, there is no plausible underlying tort alleged. Summary judgment is warranted on this claim. View "Venture Comm. Co-Op, Inc. v. James Valley Co-Op Telephone Co." on Justia Law

After Plaintiff twice lost out on a promotion, she sued Union Pacific for discrimination. The question is whether a dispute over the interpretation of a collective-bargaining agreement required dismissal. Union Pacific to sought dismissal under the Railway Labor Act, see 45 U.S.C. Section 151, et seq., which requires disputes over the interpretation of a collective-bargaining agreement to go to arbitration. The district court granted the motion to dismiss.   The Eighth Circuit affirmed. The court explained that the parties agree that this case does not involve an attempt to “form” or “secure” a collective-bargaining agreement, so it does not fall into the major-dispute category. In a failure-to-promote case like this one, Plaintiff must establish that (1) she “was a member of a protected group; (2) she was qualified and applied for a promotion to a position for which the employer was seeking applicants; (3) she was not promoted; and (4) similarly situated employees, not part of the protected group, were promoted instead.” The sticking point is whether she actually applied for either promotion: she says she did, but Union Pacific disagreed. Whether faxed resumes count as applications under the collective-bargaining agreement is something she will have to prove to establish her prima-facie case. Perhaps the best evidence of its importance was the prominent role it played at trial, especially in the questioning by Plaintiff’s attorney. In these circumstances, the issue is one for the National Railroad Adjustment Board to decide. View "Nancy Avina v. Union Pacific Railroad Co." on Justia Law

These appeals arise from a dispute over rights-of-way granted to WPX Energy Williston, LLC by the Bureau of Indian Affairs. The areas are located on allotments of land owned by members of the Fettig family within the Fort Berthold Indian Reservation. WPX Energy and the Fettigs agreed to a condition, which was incorporated into the grants, that bans smoking on the right-of-way land. In 2020, the Fettigs sued WPX Energy in the Three Affiliated Tribes District Court, alleging that the company breached the smoking ban. WPX Energy moved to dismiss for lack of jurisdiction. The tribal court concluded that it possessed jurisdiction over the case and denied the motion to dismiss. WPX Energy appealed the decision to a tribal appellate court. he district court concluded that WPX Energy had exhausted its tribal court remedies and that the tribal court lacked jurisdiction, so it granted a preliminary injunction.   The Eighth Circuit vacated the injunction and remanded to the district court with directions to dismiss the complaint without prejudice. The court concluded that WPX Energy did not exhaust its tribal court remedies and that a ruling in federal court on the question of tribal court jurisdiction was premature. The court explained that the policy of promoting tribal self-governance is not limited to tribal court proceedings that involve the development of a factual record. Rather, exhaustion of tribal court remedies “means that tribal appellate courts must have the opportunity to review the determinations of the lower tribal courts.” View "WPX Energy Williston, LLC v. Hon. B.J. Jones" on Justia Law

Plaintiff brought a lawsuit under 42 U.S.C. Section 1983, alleging that Isanti County, Minnesota (the “County”) violated his Fourth and Fourteenth Amendment rights when it unlawfully prosecuted him under the County’s solid waste ordinance (the “Solid Waste Ordinance”). Plaintiff also asserted Minnesota state law claims for false imprisonment, malicious prosecution, and abuse of process. The district court granted judgment on the pleadings as to the federal claims in favor of the County and declined to exercise supplemental jurisdiction on the remaining state law claims.The Eighth Circuit affirmed. The court explained that while Plaintiff’s opening brief lists 21 cases, which Plaintiff contends constitute proof the County used the Solid Waste Ordinance to wrongly prosecute property owners, none of these cases are properly before the court as they were not included in the complaint. Plaintiff’s complaint contains insufficient factual allegations to sustain a municipal liability claim. Accordingly, the court held that without a constitutional violation, there can be no Section 1983 liability. View "Keith Kiefer v. Isanti County" on Justia Law

The estate of Joseph A. Muff brings three conversion claims against Wells Fargo Bank for allegedly failing to detect that Joseph’s stepson, Josh Paige, was stealing money from Joseph by way of fraudulently endorsed checks. After denying the estate’s motion to amend its complaint, the district court granted summary judgment in favor of Wells Fargo on all three claims. The estate appealed.   The Eighth Circuit affirmed in part, vacated in part, and remanded to the district court. The court concluded that the district court did not abuse its discretion in denying the estate’s motion to amend its complaint. Further, the court explained that because the Muff Corporate and Muff Farm accounts were not controlled by Wells Fargo, any injury to those accounts under a theory of conversion is not fairly traceable to Wells Fargo. In other words, the estate has not demonstrated a “causal connection” between the “injury”—Josh’s inappropriately removing funds from said accounts—and the “conduct complained of”—Wells Fargo’s allegedly allowing this to take place. Moreover, even assuming the existence of a confidential relationship under Iowa law could give the estate standing to sue, the factual record fails to support the existence of a confidential relationship in the first place. Because the estate has not demonstrated standing, the court wrote that it lacks jurisdiction over Count 3. As with Count 2, the district court should have dismissed the claim instead of entering summary judgment for Wells Fargo. However, unlike Counts 2 and 3, the estate has standing to pursue Count 1 in federal court. View "Larry Muff v. Wells Fargo Bank NA" on Justia Law

Years after their father’s death, Appellees filed a diversity lawsuit against their stepmother, Defendant,and the executor of their father’s estate to adjudicate rights to property owned by their father and Defendant. Before the district court, Appellees argued that their father, H.C. “Dude” Crain, Jr. (Dude), breached a property settlement agreement (PSA) that he entered into with their mother, Marillyn Crain (Marillyn), pursuant to Dude and Marillyn’s divorce. The PSA— which the Logan County, Arkansas Chancery Court ruled was “contractual and nonmodifiable”—required Dude to maintain a will whereby he would leave “one-half of [his] estate” to Appellees. However, at Dude’s death, no such will existed. Instead, Defendant took sole possession of Dude’s separate property and retitled all jointly owned assets in her name. After the ruling that Dude breached the PSA, the district court imposed a constructive trust over all property Dude owned immediately prior to his death. The district court then used the principles set forth in the Restatement (Third) of Restitution to equitably divide the property, valued at nearly $100 million. Defendant appealed.   The Eighth Circuit affirmed. The court explained that although there is an open, ongoing probate action in Arkansas state court, the district court has never attempted to interfere with that court’s possession of any of the property at issue there. Rather, the district court adjudicated the parties’ rights to the property and imposed a constructive trust on it. Therefore, the court held that the probate exception to subject matter jurisdiction does not apply. View "Lisa Crain v. Shirley Crain" on Justia Law

Plaintiff sued a Missouri judge for putting his kids in jail twice, once after a custody hearing and again after ordering law enforcement to pick them up in Louisiana. The complaint alleged that Defendant’s action of placing Plaintiff’s children in jail and then later in a juvenile-detention facility violated their First, Fourth, and Fourteenth Amendment rights. Defendant argued that he should receive absolute immunity, but the district court disagreed and ruled that the case could proceed. At issue on appeal is whether judicial immunity shields these acts.   The Eighth Circuit affirmed in part, reversed in part, and remanded. The court explained that Defendant’s decision to personally escort the kids to jail took what would otherwise be a judicial act too far. Judges have the authority to order an officer or a bailiff to escort an unruly litigant to jail. The court wrote that Defendant crossed the line; however, when he personally escorted the kids to jail, stood there while they removed their clothes and belongings, and personally came back an hour later to release them. Further, the court explained that here, even if Defendant had no “express authority” to issue the pick-up order, he is immune because he had jurisdiction to issue one. He cannot be sued, in other words, no matter how erroneous his interpretation of the Uniform Child Custody Jurisdiction and Enforcement Act may be. View "D. Bart Rockett v. The Honorable Eric Eighmy" on Justia Law