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

WBI Energy Transmission, Inc. sought to build a natural gas pipeline through McKenzie County, North Dakota. After obtaining a certificate of public convenience and necessity from the Federal Energy Regulatory Commission, WBI attempted to acquire the necessary easements through voluntary sales. When one family refused to sell, WBI filed a federal condemnation action under the Natural Gas Act. After three years of negotiations, the parties agreed on the amount of just compensation for the easement, but the issue of attorney fees remained unresolved.The United States District Court for the District of North Dakota ruled that WBI was responsible for the family's attorney fees based on North Dakota law, which allows for such fees in condemnation proceedings. The district court relied on the precedent set by Petersburg School District of Nelson County v. Peterson.The United States Court of Appeals for the Eighth Circuit reviewed the case and determined that the availability of attorney fees depends on whether state or federal law governs the compensation due. The court concluded that federal law applies because WBI was exercising the federal eminent-domain power delegated under the Natural Gas Act. The court noted that the Fifth Amendment's requirement for just compensation does not include attorney fees unless explicitly provided by statute. The Natural Gas Act does not mention attorney fees, and thus, the default rule under the Fifth Amendment applies. Consequently, the court vacated the district court's award of attorney fees, holding that WBI is not obligated to pay the family's attorney fees. View "WBI Energy Transmission, Inc. v. 189.9 rods in Twsp. 149" on Justia Law

Lisa and Peter Woodward incurred a debt of $2,214.44 for their child's dental care, which was placed with Credit Service International Corporation (CSIC) for collection. CSIC filed a claim in conciliation court, but the Woodwards did not receive notice as the summons was sent to their previous address. CSIC obtained a default judgment and attempted to garnish the Woodwards' wages. The Woodwards hired attorney Kevin Giebel, who filed a lawsuit claiming violations of Minnesota garnishment laws and the Fair Debt Collection Practices Act (FDCPA). CSIC and Muske removed the case to federal court and offered a judgment of $2,002.00 plus reasonable attorney’s fees and costs, which the Woodwards accepted.The United States District Court for the District of Minnesota granted the Woodwards' motion for attorney’s fees in part, awarding $12,075.00 out of the $29,139.00 sought. The court used the lodestar method to determine the reasonable fee, concluding that $350 per hour was appropriate and that only 34.5 of the 72.4 hours claimed were reasonable. The Woodwards requested permission to file a motion for reconsideration, which the court denied, stating that the request did not meet the standard for reconsideration and merely reargued previously considered matters.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court found no merit in the Woodwards' arguments regarding the denial of their initial motion for attorney’s fees, the reduction of the hourly rate, and the number of hours deemed reasonable. The appellate court concluded that the district court did not abuse its discretion in its rulings and that the fee award was appropriate given the circumstances of the case. View "Woodward v. Credit Service Intl. Corp." on Justia Law

Diana Delgado owed money on a department store credit card, and Midland Credit Management, Inc. purchased the debt and sued her in Minnesota state court. Delgado did not respond to the summons, leading to a default judgment in favor of Midland. Instead of seeking reconsideration or appealing the default judgment, Delgado filed a federal lawsuit against Midland, alleging violations of the Fair Debt Collection Practices Act, including that Midland tried to collect the debt without owning it.The United States District Court for the District of Minnesota dismissed Delgado's case, concluding that the issue of debt ownership had already been resolved in the state-court action and gave the default judgment issue-preclusive effect. Delgado appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that a Minnesota state-court default judgment can have issue-preclusive effect in a subsequent federal lawsuit. The court relied on the Minnesota Supreme Court's decision in Herreid v. Deaver, which established that a default judgment is conclusive on the facts essential to its existence, even if the defendant did not participate in the proceedings. The court found that Midland's ownership of the debt was essential to the default judgment and that Delgado had a full and fair opportunity to contest the issue in state court.The Eighth Circuit affirmed the district court's judgment, concluding that the default judgment was a final determination on the merits and that applying collateral estoppel did not work an injustice in this case. View "Delgado v. Midland Credit Mgmt., Inc." on Justia Law

McKenzie County, North Dakota, sued the United States and the Department of the Interior, claiming ownership of mineral royalties under certain lands. The County argued that previous litigation had settled the matter in its favor. The United States contended that the prior litigation involved different lands and that the County’s claim was untimely. The district court ruled in favor of the County, and the United States appealed.The United States District Court for the District of North Dakota had previously granted judgment for the County, concluding that the 1930’s Condemnation Judgments and a 1991 Judgment quieted title to the disputed minerals in favor of the County. The district court held that the County’s claim was not barred by the Quiet Title Act’s statute of limitations and that the All Writs Act and Rule 70 empowered it to enforce its prior judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court’s decision. The Eighth Circuit held that the All Writs Act could not be used to circumvent the Quiet Title Act’s requirements. The court determined that the 1991 Judgment did not include the tracts listed in the 2019 Complaint and that the County’s claim under the Quiet Title Act was untimely. The court concluded that the County knew or should have known of the United States’ adverse claim to the mineral royalties by December 2003, thus triggering the Quiet Title Act’s 12-year statute of limitations. The Eighth Circuit instructed the district court to enter judgment in favor of the United States. View "McKenzie County, ND v. United States" on Justia Law

James M. Saylor, an inmate, sued the Director of Nebraska’s Department of Correctional Services, alleging deprivation of accommodations, unlawful placement in solitary confinement, and discrimination based on his disability (PTSD). Saylor had previously been assaulted by other inmates in 2002, leading to his PTSD diagnosis. He had won a $250,000 judgment in 2010 for the Department's failure to prevent the attack and provide adequate care. Saylor had filed multiple lawsuits in federal and state courts regarding his confinement conditions, all of which were dismissed.The United States District Court for the District of Nebraska dismissed Saylor's current complaint, concluding that his claims were barred by res judicata. Saylor argued that his claims were based on new facts occurring after his previous lawsuits, specifically the rescission of accommodations and his placement in solitary confinement in 2018.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's dismissal. The court held that Saylor's claims were barred by res judicata because they arose from the same nucleus of operative facts as his previous lawsuits. The court noted that Saylor's proposed amended complaint in his earlier federal case (Saylor I) included an ADA claim based on the same facts, and thus, he could have brought the ADA claim at that time. The court also found that Saylor's new allegations did not constitute new specific discriminatory events but were merely additional evidence of the same ongoing issues.The court further held that the district court did not abuse its discretion in denying Saylor's motions for an extension of time to amend the complaint, to alter or amend the judgment, and for leave to file a third amended complaint, as these motions were either procedurally deficient or futile. The judgment of the district court was affirmed. View "Saylor v. Jeffreys" on Justia Law

Plaintiffs Tiffaney Whitt, on behalf of her minor children, and Jeremiah Parker, Whitt’s adult son, filed a lawsuit against Kearney School District and Durham School Services, L.P., due to racial harassment experienced by Parker and his siblings on a school bus operated by Durham. Plaintiffs alleged a 42 U.S.C. § 1981 claim against Durham, asserting they were third-party beneficiaries of the contract between Kearney and Durham, which required safe, harassment-free transportation.The United States District Court for the Western District of Missouri denied Durham’s motion to dismiss and motion for summary judgment, which challenged the validity of Plaintiffs’ § 1981 claim. Durham then filed a motion to compel arbitration based on an arbitration clause in its contract with Kearney. The district court denied this motion, concluding that Durham waived its right to enforce the arbitration clause by not raising it earlier in the litigation. Durham appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Durham knew of its right to arbitrate, as it possessed the contract containing the arbitration clause, and acted inconsistently with that right by engaging in extensive litigation and discovery before filing the motion to compel arbitration. The court also noted that the district court’s consideration of prejudice to Plaintiffs, although erroneous, did not affect the substantial rights of the parties. The appellate court rejected Durham’s argument that it could not have known to seek arbitration until the district court’s summary judgment ruling and found that Durham’s actions were inconsistent with preserving its right to arbitrate. The court also denied Plaintiffs’ request to adopt a process for certifying interlocutory appeals as frivolous and their request for costs under Fed. R. App. P. 38. View "Parker v. Durham School Services, L.P." on Justia Law

Deidre Parker, a black woman, was employed as a Program Management Assistant by the Risk Management Agency (RMA) of the USDA starting in March 2011. She filed an EEOC complaint in 2013, which was settled in 2015. Parker alleged that after the settlement, she experienced race and gender discrimination, retaliation, constructive discharge, and a hostile work environment. Her duties diminished after a change in the timekeeping system, and she was tasked with cleaning out file cabinets. She requested additional work and development opportunities but did not act on them. Parker received two letters of counseling for disruptive conduct and filed EEOC complaints in 2017 and 2018, alleging discrimination and retaliation.The United States District Court for the Western District of Missouri granted summary judgment in favor of the USDA on all counts. The court limited its review to events occurring after the 2015 settlement agreement, finding that Parker had waived claims arising before that date. The court found that Parker failed to establish a prima facie case of discrimination or retaliation under the McDonnell Douglas framework, as most of the conduct did not constitute an adverse employment action, and there was no evidence supporting an inference of discrimination. Her hostile work environment claims failed due to a lack of causal link between the USDA’s conduct and her race or gender, and her constructive discharge claim failed because she did not prove that her workplace was intolerable or that the USDA intended for her to quit.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that the district court did not abuse its discretion in limiting the scope of Parker’s claims to conduct occurring after the settlement agreement. The court also found that Parker failed to demonstrate a causal nexus between the alleged adverse actions and her race or gender, and that her claims of hostile work environment, constructive discharge, and retaliation were unsupported by sufficient evidence. View "Parker v. United States" on Justia Law

Evanston Insurance Company issued commercial umbrella liability policies to Nooter, LLC, covering the period from July 1, 1981, to July 1, 1985. Evanston sought a declaration in the Eastern District of Missouri that it no longer had a duty to defend or indemnify Nooter in ongoing state court asbestos-related personal injury litigation. Evanston claimed that its policy limits were exhausted as of December 29, 2022, after tendering the remaining available limits to Nooter.Previously, Nooter and Evanston litigated insurance coverage issues in Missouri state court, where it was determined that Evanston had a duty to defend and indemnify Nooter against asbestos exposure claims. The Missouri Court of Appeals affirmed a jury verdict against Evanston for breach of contract and vexatious refusal to pay claims. Nooter filed a motion for contempt in state court, which was denied, but the court noted that Evanston's tender of policy limits did not fulfill its duty to defend.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's dismissal of Evanston's complaint based on claim preclusion. The court held that Missouri's prohibition on claim splitting applied, as the claims arose from the same contracts and transactions involved in the state court litigation. The court found that Evanston's indemnity and defense obligations had already been decided by Missouri courts, and thus, the federal court lacked jurisdiction over the claims. The court also affirmed the denial of Evanston's motion to amend the complaint and the motion to deposit funds as moot. The dismissal was without prejudice to Evanston's ability to seek relief in state court. View "Evanston Insurance Company v. Nooter, LLC" on Justia Law

Tennessee and sixteen other states challenged a regulation by the Equal Employment Opportunity Commission (EEOC) under the Pregnant Workers Fairness Act, which mandates reasonable accommodations for pregnancy-related conditions, including abortion. The states argued that the regulation unlawfully required them to accommodate employees seeking abortions, conflicting with their policies. They sought an injunction and a declaratory judgment against the rule, claiming it was arbitrary, exceeded EEOC's authority, violated the First Amendment and federalism principles, and was unconstitutional under Article II.The United States District Court for the Eastern District of Arkansas dismissed the case, ruling that the states lacked standing as they did not demonstrate an imminent injury or that the alleged injuries were redressable. The court found the risk of enforcement speculative and compliance costs not directly traceable to the rule. The court also dismissed the states' motion for a preliminary injunction as moot and for failing to show irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that the states had standing as they were the direct objects of the EEOC's regulation, which imposed new obligations on them. The court found that the states were injured by the regulatory burden itself and that setting aside the rule would remedy this injury. The court concluded that the states' need to comply with the rule constituted an injury in fact, caused by the EEOC's action, and redressable by a favorable judicial decision. The case was remanded for further proceedings without addressing the merits of the claims. View "State of Tennessee v. EEOC" on Justia Law

Seven states challenged a rule by the Department of Education that modified an existing income contingent repayment (ICR) plan for federal student loans, known as the Saving on a Valuable Education (SAVE) plan. This plan altered payment thresholds, stopped interest accrual, and forgave loan balances after as little as ten years of repayment. The states argued that the Secretary of Education exceeded statutory authority by forgiving loans through an ICR plan.The United States District Court for the Eastern District of Missouri found that the states were likely to succeed on their claim and issued a preliminary injunction against the rule’s early loan forgiveness provisions. Both parties appealed: the federal officials sought to vacate the preliminary injunction, while the states requested a broader injunction.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the states were likely to succeed in their claim that the Secretary’s authority to promulgate ICR plans does not include loan forgiveness at the end of the payment period. The court held that the statute requires ICR plans to be designed for borrowers to repay their loan balances in full through payments that can fluctuate based on income during the payment term. The court determined that the Secretary had exceeded this authority by designing a plan where loans are largely forgiven rather than repaid.The Eighth Circuit affirmed the entry of the preliminary injunction but concluded that the district court erred by not enjoining the entire rule. The court remanded the case with instructions to modify the injunction to cover the entire SAVE Rule and the revived forgiveness provisions under the previous REPAYE plan. View "State of Missouri v. Trump" on Justia Law