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

The City of Carthage sued Union Pacific Railroad Co. for breach of contract, claiming UP failed to maintain several bridges. On summary judgment, the district court ruled that the City’s breach-of-contract claim was barred by the five-year statute of limitations. The City argues that the ten-year statute of limitations applies here because its claim seeks an equitable remedy.   The Eighth Circuit affirmed. The court explained that the City’s claim accrued in February 2013, at the latest. On February 15, 2013, the City wrote UP demanding the repair of the bridges—establishing that the City was on notice of a potentially actionable injury. The City waited until 2019—over five years later—to sue UP. The City’s claim is barred by the five-year statute of limitations. Further, here, UP did not engage in any affirmative act during the limitations period. Without more, a failure to act does not justify the continuing wrong rule. View "City of Carthage, Missouri v. Union Pacific Railroad Co." on Justia Law

Core and Main LP (“C&M”) supplies water, wastewater, storm drainage, and fire protection products and services to commercial and governmental customers. C&M acquired the assets of Minnesota Pipe and Equipment Company (“MPE”), which supplied the same products and services in areas of Minnesota and South Dakota. Defendant, one of the shareholders, was part of MPE’s management team. Defendant started work at Dakota Supply Group, Inc. (“DSG”), a C&M competitor. C&M brought a diversity action against Defendant and DSG, asserting breach of the Employment Agreement’s noncompete and confidentiality covenants, tortious interference, and related claims. The district court granted Defendants’ Rule 12(b)(6) motion to dismiss for failure to state a claim. The main issue on appeal is whether the court correctly concluded that the Noncompetition Agreement was a later agreement and, therefore, its Entire Agreement provision superseded the restrictive covenants.   The Eighth Circuit concluded that the breach of contract and tortious interference claims turn on fact-intensive issues that cannot be determined on the pleadings. Accordingly, the court reversed the dismissal of those claims and otherwise affirmed. The court explained that it agreed with C&M that it is at least plausible the two Agreements covered different subject matters, making Rule 12(b)(6) dismissal inappropriate. The Noncompetition Agreement restricting MPE shareholders from engaging or investing in a competing business was geographically broad, but its duration was precisely limited to a specific term for each restricted party. In addition, the court concluded that in the context of the multiple agreements that completed the Asset Purchase transaction, the term “prior or contemporaneous” in the Noncompetition Agreement’s Entire Agreement provision is ambiguous. View "Core and Main, LP v. Ron McCabe" on Justia Law

Martinique Properties, LLC filed a complaint against Certain Underwriters at Lloyd’s, London (Underwriters), seeking to vacate an arbitration award. The district court dismissed the complaint for failure to state a claim for vacatur. Martinique Properties appealed. Martinique Properties argues that the appraisal award must be vacated because the appraisers “used figures and measurements which are contrary to the actual conditions of the Property” and failed to “consider certain buildings” and certain portions of a damaged roof when determining the appraisal award. These alleged errors, Martinique Properties argues, show that the appraisers were either “guilty of misconduct” or “so imperfectly executed” their powers that “a mutual, final, and definite award . . . was not made,” two of the four grounds for vacating an award under the FAA.   The Eighth Circuit affirmed. The court found that Martinique Properties has alleged only factual errors that challenge the merits of the appraisal award, and the court has no authority to reconsider the merits of an arbitration award, even when the parties allege that the award rests on factual errors. Accordingly, the appraisers’ use of certain figures and measurements in calculating the amount of loss here, and their alleged failure to consider particular buildings and portions of roof damage, even if incorrect, are not sufficient for vacatur under the FAA. View "Martinique Properties, LLC v. Certain Underwriters at Lloyd's of London" on Justia Law

A U.S. Postal Service (USPS) vehicle allegedly ran over A.M.L.’s foot on July 18, 2018. A.M.L.’s mother sent a Claim for Damage, Injury or Death (Standard Form 95) to USPS in August 2018. A year later, A.M.L.’s attorney sent a demand letter that set forth A.M.L.’s medical expenses. After USPS denied liability, A.M.L. (by and through her parent) filed suit against the United States under the Federal Tort Claims Act (FTCA). The government moved to dismiss the suit for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1), arguing that A.M.L. had failed to exhaust her administrative remedies before bringing suit. The district court dismissed the suit, and A.M.L. appealed, arguing that her claims satisfied the FTCA’s presentment requirement.   The Eighth Circuit reversed and remanded. The court held that Sections 2672 and 2675(b) do not require that a claim set forth a single-dollar amount, but that it must express the maximum value of the asserted claim. Accordingly, the expression of a range complies with the statute’s requirements because it presents the maximum value of the claim. A.M.L.’s claim of “$250,000 to $275,000” thus presented a sum certain in compliance with the FTCA’s presentment requirement. View "A.M.L. v. United States" on Justia Law

Plaintiffs are three skiers who purchased an Ikon Pass for the 2019–20 ski season. Each pass provided purchasers with unlimited ski access at participating Ikon resorts in North America. Along with their Ikon Pass, Plaintiffs purchased an optional Ski Pass Preserver insurance policy from Arch. After Plaintiffs purchased their passes, state and local governments issued orders, colloquially called “stay-at-home orders,” to prevent the spread of COVID-19. In response to these orders, ski resorts throughout North America closed with approximately one-third of the ski season remaining. Plaintiffs sought reimbursement for the loss of their ski pass benefits under the policy based on the Season Pass Interruption coverage. Arch denied their claims. The company took the position that the stay-at-home orders were not quarantines under the policy, later posting a “blanket denial” for such claims on its website. Plaintiffs filed one master consolidated class action complaint on behalf of themselves and a nationwide putative class of individuals who purchased the Ski Pass Preserver policy for the 2019–20 ski season. The district court concluded that Plaintiffs did not plausibly allege a covered loss because the term “quarantined,” as used in the policy, did not encompass stay-at-home orders that merely limited travel and activities.   The Eighth Circuit affirmed. The court explained that the ordinary person at the time the Ski Pass Preserver policy was purchased would have understood “quarantined” to mean the compulsory isolation of the insured. Reading the policy as a whole, this is the only reasonable construction, and the court agreed with the district court that the policy language is unambiguous. View "Mark Rossi v. Arch Insurance Company" on Justia Law

Employees at C.H. Robinson Worldwide, Inc. jumped ship to join Traffic Tech, Inc. C.H. Robinson then sued five of those former employees and Traffic Tech, raising various state-law claims, including tortious interference with a contractual relationship. After the case was removed to federal court, the district court granted summary judgment in favor of the former employees and Traffic Tech. The district court also awarded attorney fees to the former employees and Traffic Tech   The Eighth Circuit affirmed the district court’s dismissal of Plaintiff’s claim for tortious interference with prospective economic advantage, reversed the judgment in all other respects, and vacated the district court’s order awarding attorney fees and costs. The court held that Minnesota law applies to the interpretation and enforceability of Defendants’ employment contracts. The court remanded for the district court to consider whether C.H. Robinson’s claims or disputes against Peacock arose in California or elsewhere under Peacock’s employment contract. The court further remanded for the district court to substantively analyze whether all or part of the former employees’ contracts are unenforceable and, if not, whether the claims for breach of contract and tortious interference with a contractual relationship survive summary judgment. View "C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc." on Justia Law

Plaintiff sued Credit Bureau Services, Inc. and C.J. Tighe (collectively, the “collectors”) for unfair debt-collection practices. The district court granted judgment as a matter of law to Plaintiff and the plaintiff class. The collectors appealed, alleging amongst various issues, (i) Plaintiff does not have Article III standing, (ii) the district court erred in allowing her to introduce an issue at trial without notice, (iii) the district court erred in determining that the NCPA requires a judgment before collecting prejudgment interest, (iv) the district court abused its discretion in finding Plaintiff an adequate class representative, and (v) the district court abused its discretion in certifying the FDCPA class.   The Eighth Circuit vacated the district court’s judgment. The court held that Plaintiff did not suffer a concrete injury in fact as a result of the alleged statutory violations, thus, she lacks Article III standing. The court explained that Plaintiff contends that she suffered an injury in fact when the collectors demanded interest on her debts without a judgment. However, the court reasoned that Plaintiff only received the letter and never paid any part of the interest or principal. Without suffering a tangible harm, Plaintiff must point to an injury that “has a ‘close relationship’ to a harm ‘traditionally’ recognized as providing a basis for a lawsuit in American courts.” Here, Plaintiff has not shown any harm that bears a “close relationship” to the type of injury that results from reliance on a misrepresentation or wrongful interference with property rights. View "Kelly Bassett v. Credit Bureau Services, Inc." on Justia Law

Plaintiff sued Minnesota Life Insurance Company and Securian Life Insurance Company, alleging that their denial of her claim for life insurance benefits violated the Employee Retirement Income Security Act (“ERISA”). The district court dismissed her complaint under the Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim.   The Eighth Circuit affirmed. The court concluded that the district court properly dismissed Plaintiff’s Section 1132(a)(3) claim. First, her contention that Minnesota Life and Securian failed to notify her husband of his conversion right does not amount to a breach of fiduciary duty because the terms of her husband’s policy did not require notice, and Plaintiff points to no provision of ERISA that would require such notice. Second, her assertion that Minnesota Life and Securian misrepresented that her husband’s conversion window would be extended rests on a misreading of the February 24 letter; Minnesota Life and Securian made no such representation. View "Kristina Powell v. Minnesota Life Insurance Co." on Justia Law

The United States Department of Agriculture (“USDA”) permanently disqualified Euclid Market Inc. (“Euclid Market”) from the Supplemental Nutrition Assistance Program (“SNAP”) after it determined Euclid Market had unlawfully trafficked SNAP benefits. After the USDA issued its final decision, Euclid Market filed an action in federal court under 7 U.S.C. Section 2023, requesting the district court set aside the USDA’s final decision. The district court found Euclid Market did not meet its burden to show the USDA’s action was invalid and entered judgment in favor of the government. Euclid Market appealed. Euclid Market argued that the district court erred by requiring it to produce transaction-specific evidence for every transaction raised by the USDA to meet its burden of proof.   The Eighth Circuit vacated the judgment and remanded. The court agreed with Euclid Market that the transaction-specific standard is erroneous and that the district court applied such a standard in this case. A store’s failure to provide transaction-specific evidence for every transaction does not inherently doom its case. Concluding otherwise would create unnecessary tension with the fundamental principles of evidence. Further, a hardline rule that a store cannot prevail without transaction-specific evidence for each transaction raised by the USDA is inconsistent with the district court’s rightful discretion in weighing all of the relevant, admissible evidence to determine the validity of the disqualification by a preponderance of the evidence. View "Euclid Market Inc. v. United States" on Justia Law

Plaintiff brought a putative class action against Cash Advance Centers, Inc., alleging a violation of the Telephone Consumer Protection Act, 47 U.S.C. Section 227. Counsel purporting to represent Cash Advance Centers, Inc., moved to compel arbitration based on arbitration provisions contained in loan agreements between Plaintiff and non-party Advance America, Cash Advance Centers of Missouri, Inc. The district court denied the motion to compel. Counsel also moved to substitute Advance America, Cash Advance Centers of Missouri, Inc., for Cash Advance Centers, Inc., as the party defendant, but the district court denied that motion as well.
The Eighth Circuit affirmed. The court explained only parties to a lawsuit may appeal an adverse judgment. Because Advance America, Cash Advance Centers of Missouri, Inc., is not a party to the lawsuit, its notice of appeal is insufficient to confer jurisdiction on the Court. The non-party Advance America, Cash Advance Centers of Missouri, Inc., made no appearance in connection with the motion, and the court’s order addressed only a motion advanced by the party Defendant. The notice of appeal also names Cash Advance Centers, Inc., the party Defendant, as an appellant. But while attorneys purporting to represent Cash Advance Centers, Inc., filed a notice of appeal, counsel acknowledged at oral argument that she represented only non-party Advance America, Cash Advance Centers of Missouri, Inc., and not Cash Advance Centers, Inc. View "Kamisha Stanton v. Cash Advance Centers, Inc" on Justia Law