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

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

Farnsworth Coleman, the sole member of Coleman Consulting, LLC (CC), entered into a written Confidentiality Agreement with Domtar A.W. LLC (Domtar A.W.) in November 2016 to provide consulting services for a pulp mill in Ashdown, Arkansas. CC was compensated for its services and expenses at an agreed hourly rate. CC later claimed that an oral agreement was made with Domtar A.W. for additional compensation based on a percentage of increased profits from CC's recommendations, which Domtar A.W. denied. CC filed a lawsuit for breach of contract and unjust enrichment after Domtar A.W. terminated the consulting services in May 2017.The United States District Court for the Western District of Arkansas granted summary judgment in favor of Domtar A.W., concluding that the Arkansas statute of frauds barred CC's breach of contract claim because the alleged oral agreement could not be performed within one year. The court also found that CC failed to prove its unjust enrichment claim, as CC had been fully compensated for its services under the written agreement. CC's motion for reconsideration, based on newly discovered evidence, was denied.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court agreed that the oral agreement was subject to the statute of frauds and could not be performed within one year. The court also found that the part performance and detrimental reliance exceptions to the statute of frauds did not apply. Additionally, the court upheld the dismissal of the unjust enrichment claim, noting that CC had been paid for its services and could not use unjust enrichment to enforce an unenforceable oral contract. The denial of the motion for reconsideration was also affirmed, as CC failed to demonstrate due diligence in obtaining the new evidence. View "Coleman Consulting, LLC v. Domtar Corporation" on Justia Law

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.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 DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

Craig and Brianna Dulworth discovered that Experian, a credit-reporting agency, incorrectly reported their automobile loan as discharged through bankruptcy, despite their reaffirmation and continued payments. After Experian ignored their correction letters, the Dulworths sued in Indiana state court, alleging violations of the Fair Credit Reporting Act. Experian removed the case to federal court and issued broad subpoenas to the Dulworths' law firm, Stecklein & Rapp, seeking extensive information, including details about the firm's business structure and interactions with other clients.Stecklein & Rapp sought relief from the subpoenas in the United States District Court for the Western District of Missouri, where compliance was required. The district court found the requested materials irrelevant to the Dulworths' lawsuit, quashed the subpoenas, and awarded $93,243.50 in attorney fees and costs to Stecklein & Rapp. Experian appealed both the fee award and the discovery ruling.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision for abuse of discretion. The appellate court affirmed the district court's ruling, agreeing that the subpoenas were overly broad and irrelevant to the case. The court emphasized that the Fair Credit Reporting Act required Experian to conduct a reasonable reinvestigation upon receiving a dispute notice, regardless of whether the notice came directly from the consumer or through their attorney. The court also upheld the attorney fees award, noting that Experian failed to take reasonable steps to avoid imposing an undue burden on Stecklein & Rapp, justifying the sanctions under Rule 45(d)(1) of the Federal Rules of Civil Procedure. View "Stecklein & Rapp Chartered v. Experian Information Solutions, Inc." on Justia Law

Mychal Byrd was injured in an automobile accident caused by an unknown motorist and subsequently died from his injuries. Byrd's medical expenses, totaling $474,218.24, were covered by the Gilster-Mary Lee Corporation Group Health Benefit Plan, a self-funded plan subject to ERISA. Byrd had an automobile insurance policy with Nationwide Insurance Company, which provided $50,000 in uninsured-motorist coverage. After Byrd's death, his family sued Nationwide in state court to collect the insurance proceeds. The Plan intervened, removed the case to federal court, and claimed an equitable right to the insurance proceeds.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the Plan, determining that the Plan was entitled to the insurance proceeds under the plan document. The plaintiffs, initially proceeding pro se, did not respond to the motion for summary judgment. After obtaining counsel, they moved for reconsideration, which the district court denied. The plaintiffs then appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the district court lacked subject-matter jurisdiction. The appellate court determined that the plaintiffs' claim did not fall within the scope of ERISA's civil enforcement provisions because the plaintiffs were neither plan participants nor beneficiaries. Consequently, the claim was not completely preempted by ERISA, and the federal court did not have jurisdiction. The Eighth Circuit vacated the district court's judgment and remanded the case with instructions to return it to Missouri state court. View "Kellum v. Gilster-Mary Lee Corporation Group Health Benefit" on Justia Law

In 2021, Missouri enacted the Second Amendment Preservation Act, which declared certain federal firearms regulations as infringements on the right to keep and bear arms and invalid within the state. The Act prohibited state officials from enforcing these federal laws and allowed private citizens to sue state entities that did so, imposing penalties for violations. The United States sued Missouri, arguing that the Act violated the Supremacy Clause of the U.S. Constitution.The United States District Court for the Western District of Missouri denied Missouri's motions to dismiss for lack of standing and failure to state a claim. The court granted summary judgment in favor of the United States, ruling that the Act violated the Supremacy Clause and enjoined its implementation and enforcement. Missouri appealed the 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 the United States had standing to sue because the Act caused concrete and particularized injury by impairing federal law enforcement efforts. The court also ruled that the Act's attempt to invalidate federal law was unconstitutional under the Supremacy Clause. The court found that the Act was not severable, as its provisions were fundamentally interconnected with the invalidation of federal law. Consequently, the injunction against the Act's implementation and enforcement was upheld. View "United States v. State of Missouri" on Justia Law

Joshua Vogt died of a drug overdose while detained in a county jail. His daughter, Molly Vogt, filed a lawsuit under 42 U.S.C. § 1983, alleging that three officers deliberately disregarded his medical condition. The magistrate judge recommended summary judgment in favor of the officers, and the district court agreed. Molly Vogt appealed, arguing that a pending adverse-inference instruction against the officers created a material factual dispute regarding their deliberate indifference to Mr. Vogt’s medical condition.The United States District Court for the District of Minnesota initially reviewed the case. The magistrate judge found that the county had intentionally destroyed footage from Camera 18, which could have shown Mr. Vogt’s condition. Despite this, the magistrate judge recommended summary judgment for the officers, concluding that even with the adverse inference, the available evidence did not support a finding of deliberate indifference. The district court adopted these recommendations, leading to the current appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that to establish a § 1983 medical indifference claim, the plaintiff must show that officers acted with deliberate indifference to a pretrial detainee’s objectively serious medical needs. The court found that the officers repeatedly checked on Mr. Vogt, questioned him about his condition, and called for emergency medical help when his condition worsened. The court concluded that the adverse inference regarding the missing footage did not create a genuine issue of material fact sufficient to preclude summary judgment. The court affirmed the district court’s decision, granting summary judgment to the officers. View "Vogt v. Crow Wing County" on Justia Law

A Columbia County resident, Roderick McDaniel, was shot and killed by Deputy Charles McClinton outside an apartment complex in Magnolia, Arkansas. McDaniel was a suspect in a first-degree murder case, and an arrest warrant had been issued for him. Deputy McClinton encountered McDaniel in a white SUV, which matched the description of the vehicle used in the crime. When McDaniel attempted to flee by reversing into McClinton's patrol car and then accelerating forward, McClinton fired a single shot, killing McDaniel. A loaded handgun, later confirmed to be the murder weapon, was found near McDaniel.The United States District Court for the Western District of Arkansas denied Deputy McClinton's motion for summary judgment based on qualified immunity. The court found that there were material factual disputes, particularly regarding whether McDaniel was driving the SUV forward toward McClinton when he was shot. The court concluded that McClinton was not entitled to qualified immunity because it was clearly established that using deadly force against a suspect merely for fleeing, even in a vehicle, was unreasonable.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 Deputy McClinton was entitled to qualified immunity. The court reasoned that McClinton had probable cause to believe McDaniel was a dangerous felon who had committed first-degree murder and was still armed. Therefore, using deadly force to prevent McDaniel's escape was constitutionally permissible. The court also noted that McClinton's conduct did not violate McDaniel's clearly established rights, as existing precedent did not clearly prohibit the use of deadly force in such circumstances. The case was remanded with instructions to enter summary judgment in favor of Deputy McClinton and dismiss the case. View "Arnold v. McClinton" on Justia Law

David Burke died after falling down retractable steps attached to his motorhome. His estate, wife, and children filed product liability claims against Lippert Components, Inc., and LCI Industries, who had purchased the product brand after the Burkes bought the vehicle. The plaintiffs alleged negligence, design defects, manufacturing defects, and inadequate instructions and warnings. They later sought to add the previous owners of the product brand as defendants and amend the scheduling order, but the district court denied these motions and granted summary judgment in favor of Lippert and LCI.The United States District Court for the Northern District of Iowa denied the plaintiffs' motions to amend the complaint and the scheduling order, citing unreasonable delay. The court then granted summary judgment for Lippert and LCI, finding that they did not manufacture, distribute, or sell the steps in question, and thus were not liable under Iowa law. The plaintiffs appealed these decisions.The United States Court of Appeals for the Eighth Circuit affirmed the district court's rulings. The appellate court held that Lippert and LCI were not required to plead an affirmative defense regarding successor liability, as their defense negated an essential element of the plaintiffs' claims. The court also found that Lippert and LCI did not assume liability through the purchase agreement and that expert testimony was necessary to support the claim of inadequate post-sale warnings. Finally, the court agreed that the plaintiffs failed to show good cause for their delayed motions to amend the complaint and scheduling order. The judgment of the district court was affirmed. View "Burke v. Lippert Components, Inc." on Justia Law