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

In 2022, NavSav Holdings, LLC, a Texas insurance company, acquired Universal Group, Ltd., a Nebraska insurance company. Following the acquisition, NavSav required Universal’s employees to sign noncompete and nonsolicitation covenants, which included Texas choice-of-law and forum-selection clauses. In June 2023, three employees—Austin Michael Beber, Cody Roach, and Jackie Damon—resigned from NavSav and joined a rival company, taking customers with them. NavSav claimed these customers were worth approximately $510,000 in annual premiums.Beber, Roach, and Damon filed lawsuits in Nebraska state court seeking declaratory and injunctive relief, arguing that Nebraska law should apply and the covenants were unenforceable. NavSav filed a lawsuit in Texas state court against the three employees and their new employer, seeking to enforce the covenants under Texas law. The Nebraska cases were removed to the United States District Court for the District of Nebraska, and the Texas case was removed to the United States District Court for the Eastern District of Texas. The Nebraska federal court issued antisuit and preliminary injunctions in favor of the employees, preventing NavSav from litigating in Texas and enforcing the covenants.The United States Court of Appeals for the Eighth Circuit reviewed the case. It vacated the antisuit injunctions for Roach and Damon, affirming only Beber’s antisuit injunction, as his Nebraska case was filed first. The court vacated all preliminary injunctions, finding that the district court erred in its analysis of irreparable harm, which should focus on the individual movants rather than state public policy. The court remanded Beber’s case for consideration of his request for declaratory relief and instructed the district court to evaluate the status of the Texas litigation for Roach and Damon’s cases to determine appropriate actions. The court dismissed NavSav’s appeal regarding the forum-selection clauses for lack of jurisdiction. View "Beber v. Navsav Holdings, LLC" on Justia Law

Officer Blayne Newton of the Kansas City, Missouri Police Department shot and killed Donnie Sanders during a traffic stop. Sanders’s children, Latetia Nunley and Zahleyiah Fielder, filed a lawsuit against Officer Newton under 42 U.S.C. § 1983, alleging a violation of Sanders’s Fourth Amendment right to be free from excessive force. Officer Newton sought summary judgment based on qualified immunity, which the district court denied, citing genuine issues of material fact. Officer Newton appealed the denial of qualified immunity.The United States District Court for the Western District of Missouri denied Officer Newton’s motion for summary judgment, finding that there were disputed facts essential to the analysis of the totality of the circumstances, including the nature of the threats made by Sanders and his level of compliance with commands. The court highlighted discrepancies between Officer Newton’s testimony and the forensic evidence from the autopsy, which suggested that Sanders was shot in a manner inconsistent with Newton’s account of Sanders pointing something at him.The United States Court of Appeals for the Eighth Circuit reviewed the case. Officer Newton argued that the district court erred in denying him qualified immunity and that the excessive-force claim was barred under the Eleventh Amendment. The appellate court dismissed the appeal for lack of jurisdiction, stating that it could not resolve genuine disputes of material fact in favor of the party seeking summary judgment. The court emphasized that the factual record was unsettled and disputed, preventing it from determining whether Newton’s actions were objectively reasonable or whether they violated clearly established law. The court concluded that the district court’s finding of a material factual dispute precluded it from granting qualified immunity at this stage. View "Nunley v. Newton" on Justia Law

Eric Poemoceah, an Oklahoma resident and member of the Comanche Nation, participated in a protest against the Dakota Access Pipeline at the Standing Rock Reservation in North Dakota. On February 22, 2017, while attempting to negotiate with law enforcement officers for the peaceful exit of elders from the protest site, Poemoceah was tackled and arrested by officers, including Benjamin Swenson. He sustained injuries, including a pelvic fracture, and was charged with obstruction of a government function, a charge that was later dismissed.The United States District Court for the District of North Dakota dismissed Poemoceah’s complaint with prejudice, granting the defendants' motions to dismiss. The court found that the defendants were entitled to qualified immunity on the First and Fourth Amendment claims and dismissed the remaining claims as inadequately pled. Poemoceah’s request for leave to amend his complaint was also denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Poemoceah plausibly alleged a Fourth Amendment excessive force claim against Swenson, as the facts suggested that Swenson's use of force was not objectively reasonable. However, the court affirmed the dismissal of Poemoceah’s deliberate indifference to medical needs claim, First Amendment retaliation claim, supervisory liability claims, Monell claim against Morton County, and the intentional infliction of emotional distress claim under North Dakota law. The court also found no abuse of discretion in the district court’s denial of Poemoceah’s motion to amend his complaint. The case was affirmed in part, reversed in part, and remanded for further proceedings on the Fourth Amendment claim against Swenson. View "Poemoceah v. Morton County" on Justia Law

Absolute Essence LLC sought to enter the medical marijuana market in Arkansas but was unable to secure a license. The company invested over a million dollars in the application process, including finding a location and addressing zoning issues. The Arkansas Medical Marijuana Commission outsourced the review process to Public Consulting Group, Inc., which scored 197 applications in two weeks. Absolute Essence received a low score and alleged that the scoring process was manipulated, with conflicts of interest among the scorers favoring larger, established players and resulting in racial disparities in license awards.The case was initially filed in state court, alleging tortious interference, fraud, racial discrimination, and civil conspiracy. The defendants removed the case to the United States District Court for the Eastern District of Arkansas, which dismissed the case for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court found that Absolute Essence's tortious interference claim failed because it did not establish a precise business expectancy with a specific third party. The fraud claim was dismissed due to a lack of justifiable reliance, as the company’s actions predated the involvement of the outside scorers. The race-discrimination claims were dismissed for failing to allege intentional discrimination, as the complaint only suggested a disparate impact without sufficient factual support. Finally, the civil conspiracy claim was dismissed because it could not stand without an underlying tort.The Eighth Circuit affirmed the district court's judgment, concluding that Absolute Essence did not plead enough facts to support any of its claims. View "Absolute Essence LLC v. Public Consulting Group LLC" on Justia Law

Daniel’la Deering, an in-house lawyer for Lockheed Martin, was terminated and subsequently sued the company for discrimination and retaliation. While her discrimination claim was dismissed at the summary judgment stage, her retaliation claim was set to go to trial. However, during the litigation, Deering misled Lockheed Martin and the district court about her employment status and income. She falsely claimed to be employed by nVent and did not disclose her higher-paying job elsewhere, even submitting false information in a deposition, declaration, and settlement letters.The United States District Court for the District of Minnesota, presided over by Judge David S. Doty, found that Deering’s actions constituted intentional, willful, and bad-faith misconduct. Lockheed Martin discovered the deception shortly before the trial, leading to an emergency motion for sanctions. The district court dismissed Deering’s case with prejudice and awarded Lockheed Martin $93,193 in attorney fees. Deering’s motions for a continuance and reconsideration were also denied by the district court.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court did not abuse its discretion in dismissing the case due to Deering’s prolonged and intentional deception. The court emphasized that dismissal was appropriate given the severity and duration of the misconduct. Additionally, the appellate court found no abuse of discretion in the district court’s denial of Deering’s motions for a continuance and reconsideration. However, the appellate court dismissed Deering’s appeal regarding the attorney fee award due to a premature notice of appeal. View "Deering v. Lockheed Martin Corp." on Justia Law

Ryan Davis and Anthony Crane ordered wet ready-mix concrete from Simon Contractors for a garage floor project. Both had limited experience with concrete, though Davis had experience with a similar product called thinset. The concrete was delivered in two truckloads, and Davis and Crane worked without proper protective equipment. They suffered severe chemical burns from prolonged contact with the wet concrete.The United States District Court for the District of Nebraska held a jury trial. Davis and Crane claimed Simon Contractors was negligent for failing to warn about the dangers of wet concrete. The jury found in favor of Simon Contractors. Davis and Crane appealed, arguing errors in jury instructions and the admission of evidence about Davis’s prior litigation.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court correctly instructed the jury on the sophisticated user and assumption of risk defenses under Nebraska law. The court held that Davis and Crane’s experience with similar products and the warnings provided were sufficient for the jury to conclude they knew or should have known the risks. The court also found no error in the assumption of risk instruction, as evidence showed Davis and Crane were aware of the dangers and failed to take necessary precautions.Regarding the cross-examination about Davis’s prior litigation, the court ruled that any error in admitting this evidence was harmless. The probative questions were about Davis and Crane’s knowledge of the risks, and the evidence on these issues was clear. The court affirmed the district court’s judgment in favor of Simon Contractors. View "Davis v. Simon Contractors, Inc." on Justia Law

In 2020, the Springfield R-12 School District mandated "equity training" for its employees. Two employees, Brooke Henderson and Jennifer Lumley, attended the training and later sued the school district and several officials under 42 U.S.C. § 1983. They claimed that the training compelled them to speak on matters of public concern and engaged in viewpoint discrimination, violating their First and Fourteenth Amendment rights. The training included interactive sessions and online modules that required participants to discuss prompts and select "correct" answers to questions about equity and diversity.The United States District Court for the Western District of Missouri granted summary judgment in favor of the school district, ruling that the plaintiffs lacked standing because they did not suffer an injury in fact. The court also deemed the lawsuit frivolous and awarded attorney’s fees to the school district. The plaintiffs appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's dismissal, agreeing that the plaintiffs did not establish an injury in fact. The court found that the plaintiffs' fear of punishment for their speech during the training was speculative and not objectively reasonable. The court also concluded that the plaintiffs' completion of online modules did not constitute a First Amendment injury. However, the Eighth Circuit reversed the award of attorney’s fees, determining that the plaintiffs' claims were not frivolous given the nuanced and unsettled nature of the constitutional issues involved. View "Henderson v. Springfield R-12 School District" on Justia Law

Elizabeth Holt, a former insurance agent for Medicare Medicaid Advisors, Inc. (MMA), alleged that MMA and several insurance carriers (Aetna, Humana, and UnitedHealthcare) violated the False Claims Act (FCA). Holt claimed that MMA engaged in fraudulent practices, including falsifying agent certifications and violating Medicare marketing regulations, which led to the submission of false claims to the Centers for Medicare and Medicaid Services (CMS).The United States District Court for the Western District of Missouri dismissed Holt's complaint. The court found that no claims were submitted to the government, the alleged regulatory violations were not material to CMS’s contract with the carriers, and the complaint did not meet the particularity standard required by Federal Rule of Civil Procedure 9(b). The court also denied Holt's motion for reconsideration, which introduced a fraudulent inducement theory and requested leave to amend the complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's dismissal, agreeing that Holt's allegations did not meet the materiality requirement under the FCA. The court applied the materiality standard from Universal Health Services, Inc. v. United States ex rel. Escobar, considering factors such as whether the government designated compliance as a condition of payment, whether the violations were minor or substantial, and whether the government continued to pay claims despite knowing of the violations. The court found that the alleged violations did not go to the essence of CMS’s contract with the carriers and were not material to the government's payment decisions.The Eighth Circuit also upheld the district court's denial of Holt's motion for reconsideration and request to amend the complaint, concluding that adding a fraudulent inducement claim would be futile given the immateriality of the alleged violations. View "United States ex rel. Holt v. Medicare Medicaid Advisors" on Justia Law

A fire damaged a hotel owned by Shri Ganesai, LLC, which had an insurance policy with AmGuard Insurance Company. The policy also covered the mortgagee, Academy Bank, N.A. AmGuard denied Shri's claim, suspecting arson by Shri's principal, Alex Patel. During the investigation, the building suffered additional damage from vandalism and frozen pipes. Shri and Academy sued AmGuard for breach of contract and vexatious refusal to pay. The jury found in favor of the plaintiffs, awarding damages for the fire, vandalism, and freeze damage.The United States District Court for the Western District of Missouri denied AmGuard's motions for judgment as a matter of law and a new trial. AmGuard appealed, challenging the viability of Academy's vexatious-refusal claim, the exclusion of certain evidence, and the sufficiency of the evidence regarding damages from vandalism and frozen pipes. The district court had granted summary judgment to AmGuard on Shri's vexatious-refusal claim but allowed the remaining claims to proceed to trial.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decisions. The court held that Academy's vexatious-refusal claim was viable despite the settlement of the underlying breach-of-contract claim, as AmGuard's delay in payment constituted vexatious conduct. The court also found no abuse of discretion in the district court's exclusion of certain evidence, including the testimony of a witness and parts of Patel's deposition. Additionally, the court ruled that sufficient evidence supported the jury's findings on the timing and extent of the vandalism and freeze damage, and that the expert testimony admitted was reliable. The court concluded that the district court did not err in denying AmGuard's motions for judgment as a matter of law or a new trial. View "Academy Bank, N.A. v. Amguard Insurance Company" on Justia Law

During a night of civil unrest in Des Moines, Iowa, police and Polk County deputies arrested 14 individuals. The arrestees claimed their Fourth Amendment rights were violated and sued 53 defendants under 42 U.S.C. § 1983. The district court issued a comprehensive opinion with around 800 rulings on various motions for summary judgment and qualified immunity, leading to multiple appeals.The United States District Court for the Southern District of Iowa denied qualified immunity to several officers and granted summary judgment to some plaintiffs. The Des Moines defendants appealed these decisions, arguing they had probable cause to arrest anyone in the vicinity of the protests for misdemeanors such as participation in a riot, unlawful assembly, and failure to disperse. The district court found that the officers lacked probable cause or arguable probable cause for these arrests, as they did not provide specific evidence linking the plaintiffs to violent behavior or failure to disperse.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decisions de novo. The court affirmed the denial of qualified immunity to Officers Herman, Holtan, and McCarthy on Klingenberg's unlawful arrest claim, and dismissed Officer Lawler's appeal for lack of jurisdiction. The court also dismissed appeals from Captain Hardy and other officers regarding Lard's and DeBrossard's unlawful arrest claims and Lard's excessive force claim. The court affirmed the grant of summary judgment to the Patton group on their unlawful arrest claims and denied qualified immunity to the Des Moines defendants on the plaintiffs' malicious prosecution claims. Additionally, the court affirmed the grant of summary judgment to the plaintiffs on their phone seizure claims against Officer Youngblut and denied him qualified immunity.The court reversed the district court's denial of qualified immunity to Deputy Smith on Timberlake's unlawful arrest claim, finding no clearly established duty for Smith to ensure the lawfulness of the arrest before taking custody. Finally, the court affirmed the grant of qualified immunity to Officer Holtan and Deputy Callahan on Dunn's and Fugate's unlawful arrest claims, concluding they had arguable probable cause under Iowa's failure to disperse statute. The case was remanded for further proceedings consistent with these rulings. View "Dunn v. Does" on Justia Law