Justia U.S. 8th Circuit Court of Appeals Opinion SummariesArticles Posted in Civil Procedure
C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc.
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
Posted in: Civil Procedure, Contracts, Labor & Employment Law, Personal Injury
Kelly Bassett v. Credit Bureau Services, Inc.
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
Posted in: Civil Procedure, Class Action, Consumer Law
Kristina Powell v. Minnesota Life Insurance Co.
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
Posted in: Civil Procedure, ERISA, Insurance Law
Euclid Market Inc. v. United States
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
Kamisha Stanton v. Cash Advance Centers, Inc
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
Posted in: Arbitration & Mediation, Civil Procedure, Class Action, Consumer Law
Ahern Rentals, Inc. v. EquipmentShare.com, Inc.
Ahern Rentals, Inc. (Ahern), alleges that two competitors— EquipmentShare.com, Inc. (EquipmentShare) and EZ Equipment Zone, LLC (EZ)— misappropriated its trade secrets to gain an unfair advantage in the construction equipment rental industry. The district court first dismissed EZ from the lawsuit, ruling that Ahern failed to state a plausible claim for relief against it. Later, the district court dismissed the case altogether, ruling that Ahern’s remaining claims against EquipmentShare were duplicative of claims against EquipmentShare in several other ongoing lawsuits brought by Ahern. Ahern appealed both rulings, arguing that the district court erred in dismissing its claims. The Eighth Circuit reversed. The court reasoned that, according to Ahern, EquipmentShare developed programs by exploiting Ahern’s trade secrets. Ahern also alleged that the market information used by EZ to develop profitable utilization and rental rates is based on Ahern’s trade secrets illegally obtained by EquipmentShare. Taking all factual allegations as true, Ahern pled enough facts to make it entirely plausible that EZ is at least using systems developed by EquipmentShare through the exploitation of Ahern’s trade secrets. Further, the court found that Ahern has pled sufficient facts to state a claim against EZ for unjust enrichment. It is not disputed that Ahern’s trade secrets are a benefit with real economic value. And, as alleged in the complaint, EquipmentShare and EZ have used the benefit to their advantage. Finally, Ahern plausibly alleges malfeasance in the acquisition of these confidential trade secrets. Thus, the district court erred in dismissing Ahern’s claims against EZ for civil conspiracy and unjust enrichment. View "Ahern Rentals, Inc. v. EquipmentShare.com, Inc." on Justia Law
Posted in: Civil Procedure, Intellectual Property, Personal Injury
WinRed, Inc. v. Keith Ellison
WinRed, a “conduit” political action committee (PAC), centralizes donations to Republican-affiliated candidates and committees. WinRed helps them set up a WinRed.com webpage where donors contribute. WinRed collects and distributes the earmarked contributions. WinRed.com’s technical and maintenance services are at least partly performed by a separate entity, WinRed Technical Services, LLC (WRTS). The relationship between WinRed and WRTS is not clear, but the Eighth Circuit accepts WinRed’s affidavit that it operates exclusively in the domain of federal elections. The district court dismissed WinRed, Inc.’s request for a declaratory judgment and preliminary injunction preventing the Attorneys General from (1) investigating WinRed’s activities with respect to contributions; and (2) bringing a deceptive-practice action against it for those activities.” The Eighth Circuit affirmed. The court explained that WinRed gives two reasons to look beyond the statutory text. Neither succeeds. The court held that WinRed errs from the start by attacking a disclaimer mandate where none exists. Minnesota’s consumer-protection law prohibits deceptive practices, and federal law does not preempt Minnesota’s enforcing it against WinRed. Because an enforceable state law underlies General Ellison’s investigation, the investigation may proceed. View "WinRed, Inc. v. Keith Ellison" on Justia Law
ResCap Liquidating Trust v. Primary Residential Mortgage
ResCap Liquidating Trust (“ResCap”) pursued indemnification claims against originator Primary Residential Mortgage, Inc. (“PRMI”), a Nevada corporation. ResCap asserted breach of contract and indemnification claims, seeking to recover a portion of the allowed bankruptcy claims for those holding units in the liquidating trust. The district court concluded that ResCap had established each element of its contractual indemnification claim. The district court awarded ResCap $10.6 million in attorney’s fees, $3.5 million in costs, $2 million in prejudgment interest, and $520,212 in what it termed “post-award prejudgment interest” for the period between entry of judgment and the order awarding attorney’s fees, costs, and prejudgment interest. Defendant appealed. The Eighth Circuit remanded for a recalculation of postjudgment interest but otherwise affirmed. The court explained that the district court held that, as a matter of Minnesota law governed by Section 549.09, a final judgment was not “finally entered” until its Judgment in a Civil Case resolving attorney’s fees, costs, and interest was entered on April 28, 2021, and therefore Minnesota’s ten percent prejudgment rate applied in the interim period. But Section 1961(a) does not say “final judgment,” it says “money judgment.” The district court, on August 17, 2020, entered a “money judgment.” Thus, the district court erred in applying Minnesota law to calculate interest after August 17, 2020, rather than 28 U.S.C. Section 1961(a). View "ResCap Liquidating Trust v. Primary Residential Mortgage" on Justia Law
Posted in: Bankruptcy, Business Law, Civil Procedure, Contracts, Insurance Law
United States v. Dewayne Gray
Defendant appealed a judgment of the district court committing him to the custody of the Attorney General for medical care and treatment under 18 U.S.C. Section 4246. The court found that Defendant presently suffered from a mental disease or defect as a result of which his release from custody posed a substantial risk of bodily injury to another person or serious damage to the property of another. The Eighth Circuit affirmed, concluding that the findings underlying the commitment were not clearly erroneous. The court explained that the district court’s finding that Defendant posed a substantial risk to persons or property was adequately supported in the record. The court relied on the unanimous recommendation of the experts. The experts observed that the most reliable predictor of future violence is past violence, and they detailed Defendant’s history of random and unpredictable violent actions. The court further found that the parties have not made a sufficient showing to justify sealing the briefs in this appeal. View "United States v. Dewayne Gray" on Justia Law
Jane Doe v. United States
Plaintiff sued the government pursuant to the Federal Tort Claims Act (FTCA), asserting multiple negligent and intentional tort causes of action after being sexually assaulted by an employee of the United States Department of Veterans Affairs (VA). The government moved to dismiss for lack of subject matter jurisdiction. The district court granted the government’s motion. Plaintiff appealed the district court’s determination that the assault occurred outside the scope of the employee’s employment. The Eighth Circuit affirmed. The court explained that the FTCA makes clear that the scope-of-employment test is defined by state law, not the employer. Plaintiff argued that the district court erred in concluding that the provider’s duties were restricted to providing battlefield acupuncture therapy (BFA). The court explained that initially, the provider denied sexually assaulting or massaging Plaintiff. He later admitted to the sexual assault and admitted that it was inappropriate for him to massage a patient. He also failed to document anything that occurred after the BFA therapy, including the massage. This is consistent with the finding that the massage and subsequent sexual assault exceeded the scope of his treatment authority. The court explained that in light of the pleadings and undisputed evidence, the district court did not err, determining that the provider acted outside the scope of his employment. View "Jane Doe v. United States" on Justia Law