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

This case is a class action involving commercial truck drivers who claimed they were not paid properly by Werner Enterprises, Inc., and Drivers Management, LLC. The drivers alleged that they were not adequately compensated for off-duty time spent on short rest breaks and time spent resting in their trucks’ sleeper-berths. The case has been appealed multiple times, with the court previously vacating a jury verdict in favor of the drivers because the district court improperly allowed the drivers to submit an expert report after the deadline. On remand, the district court entered judgment in favor of the defendants. The drivers appealed again, and the court vacated the judgment and remanded the case back to the district court to conduct an analysis regarding whether the expert report should be excluded as a discovery sanction and whether the district court should appoint an independent expert.On remand, the district court concluded that exclusion of the drivers’ expert report was the appropriate sanction for its late disclosure and that appointment of an independent expert was not appropriate. It then entered judgment in favor of the defendants. The drivers appealed this decision, asserting that the district court erred in its analysis. The defendants cross-appealed, asserting that the drivers’ notice of appeal was untimely, requiring dismissal of the appeal.The United States Court of Appeals for the Eighth Circuit rejected the defendants’ contention on cross-appeal and affirmed the judgment of the district court. The court found that the district court did not abuse its discretion in excluding the expert report and denying the drivers’ motion for a new trial. The court also found that the district court did not err in declining to appoint an expert and in entering judgment in favor of the defendants. View "Petrone v. Werner Enterprises, Inc." on Justia Law

The plaintiff, Chiya Lloyd, filed a complaint against FedLoan Servicing LLC, Equifax Information Services, LLC, Trans Union, LLC, and Experian Information Solutions, Inc., alleging violations of the Fair Credit Reporting Act (FCRA). The case centered around Lloyd's nine federal student loans serviced by FedLoan, which reported to Experian that Lloyd's payments for certain months were overdue. Lloyd disputed these delinquencies, and Experian requested further information from FedLoan. After several rounds of disputes and investigations, all delinquent marks were removed from Lloyd's credit report. However, Lloyd initiated a civil action against the defendants, alleging that FedLoan failed to properly investigate the accuracy of the information it reported to Experian, and Experian failed to follow its procedures to discover FedLoan’s mistakes.The district court granted summary judgment in favor of Experian, finding that Lloyd could not show Experian failed to follow reasonable procedures or conduct a reasonable reinvestigation. The court also granted summary judgment in favor of FedLoan, concluding that Lloyd did not present sufficient evidence of damage to support her claim.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court found that Experian had followed the steps set forth by the FCRA for conducting a reinvestigation, and Lloyd failed to show that Experian did not satisfy its statutory requirements. The court also found that Lloyd failed to present a cognizable claim against Experian. Regarding FedLoan, the court found that Lloyd failed to present evidence sufficient to allow a jury to find that FedLoan’s investigation was unreasonable. The court also found that Lloyd failed to provide sufficient evidence to raise a jury question that she sustained actual damages from FedLoan’s reporting. Therefore, her claim failed. View "Lloyd v. FedLoan Servicing" on Justia Law

Michael Jones, a pretrial detainee, filed a lawsuit against the City of St. Louis and four city employees, alleging that they held him in custody for eight months after his criminal charges were dismissed and failed to inform him of his right to be released. Jones's lawsuit, filed under 42 U.S.C. § 1983, included claims under both state and federal law. The defendants moved to dismiss all fourteen counts of the lawsuit. The district court dismissed seven counts, leaving no federal due process claims against the individual defendants at issue on appeal. The defendants appealed the denial of their motion to dismiss the remaining counts, arguing that Jones failed to allege plausible constitutional violations and that they were entitled to qualified immunity from damage claims.The United States Court of Appeals for the Eighth Circuit reviewed the denial of qualified immunity de novo, accepting the factual allegations in Jones's First Amended Complaint as true. The court found that Jones failed to allege specific facts of personal involvement in, or direct responsibility for, a deprivation of his constitutional rights by the individual defendants. The court also found that Jones's allegations that the defendants "should have known" that he was incarcerated despite his charges being dismissed failed to state a claim under either the Fourth Amendment or the Due Process Clause.The court reversed the denial of qualified immunity and directed that the remaining counts be dismissed with prejudice. The case was remanded for further proceedings consistent with the court's opinion. The court did not rule on the state law claims of false imprisonment, leaving that for the district court to resolve on remand. View "Jones v. City of St. Louis" on Justia Law

The plaintiff, Marvel Jones, a civilly committed individual at Norfolk Regional Center in Nebraska, filed a pro se civil rights complaint against the Nebraska Department of Correctional Services (NDCS), several correctional facilities, and unnamed individuals. Jones alleged that the institutions' policies and the individuals' actions obstructed his right to legal assistance and unlawfully limited his access to the courts while he was incarcerated. He claimed that the NDCS's law library policies, which prohibit prison librarians and legal aides from assisting inmates in conducting legal research and other legal activities, violated his federal rights.The defendants moved to dismiss the case, citing sovereign immunity and the applicable statutes of limitations. The district court granted the motion, finding that Jones's claims against the correctional facilities and the individual defendants in their official capacities were indeed barred by sovereign immunity and the statutes of limitations. However, the court did not dismiss the claims against the unnamed individual defendants in their individual capacities. Instead, it conditionally dismissed the case against NDCS, requiring it to provide Jones with the requested names and addresses of the unnamed defendants. NDCS appealed this decision.The United States Court of Appeals for the Eighth Circuit found that the district court's order violated NDCS's sovereign immunity. The court noted that once the district court concluded that NDCS was entitled to sovereign immunity, it lacked the authority to hold NDCS in as a litigant, even on a relatively minor disclosure condition. The court reversed and vacated the portion of the district court’s order that conditioned NDCS’s dismissal on its disclosure of the identities and addresses of the unnamed defendant employees and remanded for further proceedings consistent with this opinion. View "Jones v. Dept. of Correctional Services" on Justia Law

The case involves a group of former detainees at the Medium Security Institution (MSI) in St. Louis, who alleged that they were subjected to inhumane conditions in violation of the Eighth and Fourteenth Amendments. They sought to represent classes of pre-trial and post-conviction detainees, asserting that both categories of detainees were subjected to poor physical conditions and inadequate operations. After the district court denied their first motion to certify, the plaintiffs returned with new proposed classes and renewed their motion. The district court granted the renewed motion, and the City of St. Louis appealed.The district court had initially denied the plaintiffs' motion to certify four classes, citing the open-ended class periods and the City's undisputed improvements to conditions at MSI over time. However, the court suggested that a more focused claim covering a more discrete time period and a more uniform class might be appropriate for class certification. In response, the plaintiffs filed a renewed motion for class certification, proposing four new, more narrowly defined classes. The district court granted the renewed motion, certifying the four new classes.The City of St. Louis appealed the district court's decision to the United States Court of Appeals for the Eighth Circuit, challenging both the decision to certify the classes and several of its procedural aspects. The appellate court reversed the certification of the classes and remanded the case for further proceedings. The court found that the district court had abused its discretion in certifying the classes, as the classes were not "sufficiently cohesive to warrant adjudication by representation." The court also found that the district court had erred in describing the standard for liability and had failed to conduct a rigorous analysis of the requirements for class certification. View "Cody v. City of St. Louis" on Justia Law

A group of Arkansas landowners sued Lawrence County, alleging that a bridge constructed by the county had caused their farms to flood, constituting an unlawful taking of their properties without just compensation, in violation of the U.S. and Arkansas Constitutions. The landowners claimed that the bridge acted as a dam, forcing excessive water into the Cache River, which then spilled onto their farms. They presented expert testimony to support their claims and sought damages based on the fair rental value of their properties during the period of the alleged taking.The district court upheld a jury award of nearly $350,000 to the landowners but rejected their request for an order to tear down the bridge. The county appealed the damages award, arguing that the landowners had failed to offer sufficient evidence of damages since they did not calculate the value of crops actually lost. The landowners cross-appealed the denial of their request for injunctive relief.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision on the damages award, holding that the evidence permitted the jury to make a fair and reasonable approximation of damages. The court found that the landowners were not obliged to prove damages by providing evidence of the amount of crops they expected to grow versus the amount of crops they actually grew due to increased flooding. Instead, they were entitled to recover the fair rental value of the property during the period of the taking.However, the court vacated the district court's order denying injunctive relief and remanded for the court to give the landowners' request a more focused consideration. The court found that the district court had relied heavily on the law of standing, which was not at issue, and had ventured into areas that had little bearing on a proper evaluation of the request for injunctive relief. View "Watkins v. Lawrence County, Arkansas" on Justia Law

Cory Sessler, a religious preacher, and his group were preaching loudly at a commercial festival in Davenport, Iowa. The festival was held in a fenced-off area of the city's downtown streets and sidewalks, which were typically considered a "traditional public forum". However, during the festival, pedestrian access was controlled and vendors had rented spaces to sell goods. Sessler and his group, who were not paying vendors, were asked by police officers to relocate outside the fences due to complaints from nearby vendors. Sessler later sued the officers and the city, alleging a violation of his First Amendment rights.The district court denied Sessler's request for a preliminary injunction, a decision which was affirmed by the appellate court. After discovery, the district court granted summary judgment to the defendants, concluding that the officers did not violate Sessler's rights and that they were protected by qualified immunity. The court also granted summary judgment to the city on the official-policy claims.The United States Court of Appeals for the Eighth Circuit agreed that qualified immunity applied to the claims against the officers. The court found that it was unclear whether the fenced-off city streets and sidewalks remained a "traditional public forum" or served as a less-protected "limited public forum" during the festival. The court also found that no reasonable trier of fact could conclude that the officers' actions were anything but content neutral or that such actions were unreasonable. The court affirmed the judgment of the district court. View "Sessler v. City of Davenport, Iowa" on Justia Law

The United States Court of Appeals for the Eighth Circuit reviewed a case involving a group of plaintiffs who owned properties near proposed wind turbine sites in Page County, Iowa. The plaintiffs sued the county, its board of supervisors, and county officials after the board issued a commercial wind energy permit to Shenandoah Hills Wind Project, LLC (SHW). The plaintiffs claimed that the issuance of the permit violated the Due Process Clause of the Fourteenth Amendment, the Iowa Constitution, Iowa Code, and county ordinances. They also claimed that county officials violated the Iowa Open Meetings Act by holding nonpublic meetings on SHW's application. The defendants removed the case to federal court based on the federal due process claim.The district court dismissed the federal due process claim for lack of prudential standing and as implausibly pleaded under Federal Rule of Civil Procedure 12(b)(6). It also dismissed the state claims as time-barred under Iowa law and implausibly pleaded under Rule 12(b)(6). After the district court's decision, the county revoked the permit. Despite the revocation, the plaintiffs appealed the district court's order.The Court of Appeals held that the county's revocation of SHW's permit mooted the plaintiffs' claims, except for their claims under the Iowa Open Meetings Act. The court affirmed the district court's exercise of supplemental jurisdiction over these remaining claims and its dismissal of them. The court vacated the remainder of the district court's order and remanded the case to the district court with instructions to dismiss the non-Open Meetings claims as moot. View "Hunter v. Page County, Iowa" on Justia Law

KOKO Development, LLC, a real estate developer, contracted with Phillips & Jordan, Inc., DW Excavating, Inc., and Thomas Dean & Hoskins, Inc. (TD&H) to develop a 180-acre tract of land in North Dakota. However, the project faced numerous issues, leading KOKO to sue the defendants for breach of contract and negligence. KOKO did not disclose any expert witnesses before the trial, leading the district court to rule that none of its witnesses could give expert testimony. Consequently, the district court granted the defendants' motion for summary judgment, finding that without expert witnesses, KOKO could not establish its claims.The district court's decision was based on the complexity of the issues involved in the case, which required expert testimony. The court found that KOKO's negligence and breach of contract claims required complex infrastructure and engineering analysis, which was beyond the common knowledge or lay comprehension. KOKO appealed the decision, arguing that the district court erred in finding that it did not properly disclose witnesses providing expert testimony and that expert testimony was necessary for the case.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court found that KOKO did not identify the witnesses that would provide expert testimony and did not meet the requirements of Rule 26(a)(2). The court also agreed with the district court that the negligence and breach of contract claims required expert testimony due to the complexity of the issues in the case. The court concluded that the district court did not abuse its discretion by excluding the three witnesses' expert testimony and requiring expert testimony for the negligence and breach of contract claims. View "KOKO Development, LLC v. Phillips & Jordan, Inc." on Justia Law

A high-speed police chase initiated by a deputy from Pottawattamie County, Iowa, ended in a collision in Nebraska, injuring Kirstie Wade and her children. Wade sued Pottawattamie County in a Nebraska federal district court for damages. However, the district court dismissed the case, citing a lack of personal jurisdiction over the Iowa county.The case was then brought before the United States Court of Appeals for the Eighth Circuit. The court had to determine whether the Nebraska federal district court had personal jurisdiction over Pottawattamie County. Personal jurisdiction depends on both a forum state’s long-arm statute and general due-process principles. Nebraska’s long-arm statute authorizes “the exercise of personal jurisdiction consistent with the Constitution of the United States,” which means that the exercise of personal jurisdiction over Pottawattamie County must be “consistent with” due process.The court considered two types of jurisdiction: general and specific. General jurisdiction, which allows a court to hear any and all claims against a party, was ruled out as Pottawattamie County’s contacts with Nebraska were not continuous and systematic. However, the court found that specific jurisdiction, which covers only those claims arising out of or relating to a party’s contacts with the forum, was applicable. The court reasoned that the deputies had purposefully availed themselves of the benefits and protections of Nebraska’s laws by choosing to continue the chase across the border, and they could have reasonably anticipated being brought to court in Nebraska if something went wrong.The United States Court of Appeals for the Eighth Circuit reversed the district court's decision, ruling that the Nebraska federal district court did have personal jurisdiction over Pottawattamie County. The case was remanded for further proceedings. View "Wade v. Pottawattamie County" on Justia Law