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

The Eighth Circuit reversed the district court’s ruling denying the Deputy’s motion for qualified immunity in Plaintiff’s lawsuit, alleging that the Deputy’s conduct amounted to deliberate indifference to her seizure condition after she was arrested for driving while intoxicated. The Deputy asserted qualified immunity in his motion for summary judgment, which the district court denied.   The Eighth Circuit reversed. The court explained that the Deputy promptly attended to Plaintiff and asked her whether she was hurt or suffered from medical problems. She said no and did not advise him of her seizure disorder. Emergency medical personnel also observed Plaintiff and were content not to take her to the hospital, advising the Deputy that she had refused further treatment. He then took Plaintiff and her medications to jail. Barton I did not provide the Deputy with fair notice that his failure to seek further medical treatment for Plaintiff or to speak with the jailors about what Plaintiff’s boyfriend told him constituted deliberate indifference. Thus, Plaintiff failed to show that clearly established law prohibited the Deputy’s conduct, and the Deputy is entitled to qualified immunity. View "Kelly Martin v. Jordan Turner" on Justia Law

Show Me State Premium Homes wants its purchase of a foreclosed property to be free and clear of all other interests, including those belonging to the United States. Getting what it wants would require a “judicial sale.” After removing the case the United States filed a motion to dismiss. Its position was that there could be no foreclosure without a judicial sale. The district court agreed, declined to exercise supplemental jurisdiction over what remained, and remanded to state court.   The Eighth Circuit affirmed the judgment of the district court but modified the dismissal of the ejectment and damages claims to be without prejudice. The court explained that a buyer’s interest is only “inchoate” before it gets a valid deed, not after. And here, title vested once the bond company “exercised its right to have the legal title transferred.” No “judicial sale” ever took place, and it is too late to hold one now, meaning that the interests held by the United States have never been foreclosed. View "Show Me State Premium Homes, LLC v. George McDonnell" on Justia Law

Several cities in Minnesota alleged that a chemical in refined coal tar that was used in pavement sealants contaminated their stormwater ponds. They filed an action seeking damages from refiners and manufacturers of the tar. The “refiner” defendants take raw coal tar and refine it into a product used by the “manufacturer” defendants to create pavement sealants. The district court dismissed all of the claims against the refiners and dismissed all but three of the claims against the manufacturers. The Cities moved under Federal Rule of Civil Procedure 54(b) for entry of final judgment against the refiners. The district court, however, denied the motion because the Cities had not “demonstrated a danger of hardship or injustice through delay which would be alleviated by immediate appeal.” The Cities then entered into an agreement with the manufacturers, which provided that the Cities would conditionally dismiss their claims against the manufacturers. The Cities then appealed the district court’s decision dismissing claims against the refiners, and some of the refiners cross-appealed.   The Eighth Circuit dismissed the appeal for lack of jurisdiction. The court concluded that this conditional dismissal of the Cities’ claims against the manufacturers does not create a final decision under 28 U.S.C. Section 1291. The whole purpose of pairing the voluntary dismissal with the tolling agreement was to provide for reinstatement of the claims in the event of reversal—that is, to make the dismissal conditional. The court wrote that its only power to prevent the manipulation of appellate jurisdiction is a rigorous application of the final judgment requirement. View "City of Burnsville v. Koppers, Inc." on Justia Law

This case was brought by a class of sex offenders (Appellants) civilly committed to the Minnesota Sex Offender Program (MSOP) pursuant to the Minnesota Civil Commitment and Treatment Act: Sexually Dangerous Persons and Sexual Psychopathic Personalities, codified at Minnesota Statute Section 253D (MCTA). Appellants filed this action against various MSOP managers and officials, as well as the Commissioner of the Minnesota Department of Human Services (collectively, Appellees). On remand after a second appeal to this Court, the district court granted judgment in favor of Appellees on all of Appellants’ claims. Appellants appeal, challenging the district court’s judgment.   The Eighth Circuit affirmed. The court explained that Appellants contend that the district court erred by declining to address their treatment-related claims, alleging that the district court found them to be duplicative of previously decided counts. The court wrote that in making this finding, the district court did not dismiss or otherwise ignore any of the counts before it, which were all conditions-of-confinement and inadequate medical care claims. While Appellants attempted to “reanimate” these claims in a Fourth Amended Complaint, the district court denied the amendment, and Appellants do not challenge that decision on appeal. Accordingly, the court perceived no error in the district court’s treatment of Appellants’ treatment-related claims. Appellants additionally attacked the district court’s conclusion that the MSOP’s Behavioral Expectation Report policy is constitutional. But Appellants focused only on the impact of the policy on their treatment and fail to address the other legitimate government objectives it addresses—such as preserving institutional order at the MSOP. View "Kevin Karsjens v. Jodi Harpstead" on Justia Law

In March 2020, Concord Baptist Church of Jefferson City, Inc. (Concord Baptist) sustained damage to its facilities in a severe storm. After disagreements with its insurer, Church Mutual Insurance Company (Church Mutual), regarding the amount of loss, Concord Baptist initiated this action, alleging breach of contract and vexatious refusal to pay. The district court granted summary judgment in favor of Church Mutual, concluding that the undisputed facts demonstrated that Concord Baptist failed to comply with a cooperation clause contained in the insurance policy, which precluded coverage. Concord Baptist appealed.   The Eighth Circuit affirmed. The court explained that because Concord Baptist admits that it materially breached the policy, the court need not address Concord Baptist’s argument regarding whether the failure to submit to an EUO was a material breach. However, the court noted that Missouri courts have found a material breach where an insured failed to submit to an EUO before commencing an action against the insurer. Regarding the second element, whether Church Mutual suffered substantial prejudice from Concord Baptist’s material breach, the court agreed with the district court that the undisputed facts show that it did. Finally, as to the third element, whether Church Mutual exercised reasonable diligence in attempting to procure Concord Baptist’s cooperation, the court again agreed with the district court that the undisputed facts demonstrate Church Mutual’s diligence. View "Concord Baptist Church of Jefferson City v. Church Mutual Insurance Company" on Justia Law

Plaintiff, as personal representative of her brother, who was in pretrial custody at Phelps County Jail for about six months, filed a lawsuit for damages from inadequate medical care during her brother’s pretrial detention. The district court awarded the individual defendants and Phelps County summary judgment. Plaintiff argued the district court erred by entering summary judgment in favor of the individual defendants on her claim for deliberate indifference to a serious medical need. “   The Eighth Circuit affirmed. The court concluded there is not a genuine issue of material fact as to whether Defendants were deliberately indifferent. A correctional officer’s deference to a medical professional regarding a pretrial detainee’s medical care, standing alone, does not create a genuine issue of material fact on deliberate indifference to serious medical needs. Plaintiff, however, points to nothing in the record showing Defendants deliberately disregarded her brother’s condition while he was in the holdover cell during the final weeks of his pretrial detention. Instead, Plaintiff points to evidence that Phelps County employees were generally aware that her brother was suffering. This evidence, however, does nothing to address the focus of the court’s inquiry: whether Defendants deliberately disregarded Plaintiff’s brother’s serious medical need. Ultimately, the court concluded there is no genuine issue of material fact as to whether Defendants violated the Fourteenth Amendment. View "Lady Maakia Charlene Smith v. Richard Lisenbe" on Justia Law

The Federal Communications Commission (FCC) provides subsidies to encourage telecommunication companies to expand high-speed broadband internet services in rural areas where customer revenues would otherwise be insufficient to justify the cost of doing business. Venture Communications Cooperative (“Venture”) provides broadband services to rural South Dakota customers. James Valley Cooperative Telephone Company and its wholly owned subsidiary, Northern Valley Communications (collectively, “Northern Valley”), is a competing provider. Venture filed this lawsuit against Northern Valley. The primary claim is that Northern Valley violated 47 U.S.C. Section 220(e) by filing a Form 477 that “intentionally, deliberately, fraudulently, and maliciously misrepresented” information “for the sole unlawful purpose of harming [Venture]” by depriving Venture of FCC subsidies in census blocks where Northern Valley was deemed to be an unsubsidized competitor. The district court granted Northern Valley summary judgment, concluding “there is no evidence that Northern Valley willfully overreported its broadband capabilities.”   The Eighth Circuit affirmed. The court explained that Venture’s claim of intent to injure is belied by Northern Valley helping Venture by filing a letter with the FCC clarifying that Northern Valley did not offer voice service in the Overlap Area. The court likewise affirmed the dismissal of Venture’s tortious interference and civil conspiracy claims under South Dakota law. The court agreed with the district court that Venture proffered no evidence of an “intentional and unjustified act of interference” because Northern Valley complied with all FCC reporting requirements. As Northern Valley complied with the Telecommunications Act in filing Form 477 at issue, there is no plausible underlying tort alleged. Summary judgment is warranted on this claim. View "Venture Comm. Co-Op, Inc. v. James Valley Co-Op Telephone Co." on Justia Law

After Plaintiff twice lost out on a promotion, she sued Union Pacific for discrimination. The question is whether a dispute over the interpretation of a collective-bargaining agreement required dismissal. Union Pacific to sought dismissal under the Railway Labor Act, see 45 U.S.C. Section 151, et seq., which requires disputes over the interpretation of a collective-bargaining agreement to go to arbitration. The district court granted the motion to dismiss.   The Eighth Circuit affirmed. The court explained that the parties agree that this case does not involve an attempt to “form” or “secure” a collective-bargaining agreement, so it does not fall into the major-dispute category. In a failure-to-promote case like this one, Plaintiff must establish that (1) she “was a member of a protected group; (2) she was qualified and applied for a promotion to a position for which the employer was seeking applicants; (3) she was not promoted; and (4) similarly situated employees, not part of the protected group, were promoted instead.” The sticking point is whether she actually applied for either promotion: she says she did, but Union Pacific disagreed. Whether faxed resumes count as applications under the collective-bargaining agreement is something she will have to prove to establish her prima-facie case. Perhaps the best evidence of its importance was the prominent role it played at trial, especially in the questioning by Plaintiff’s attorney. In these circumstances, the issue is one for the National Railroad Adjustment Board to decide. View "Nancy Avina v. Union Pacific Railroad Co." on Justia Law

These appeals arise from a dispute over rights-of-way granted to WPX Energy Williston, LLC by the Bureau of Indian Affairs. The areas are located on allotments of land owned by members of the Fettig family within the Fort Berthold Indian Reservation. WPX Energy and the Fettigs agreed to a condition, which was incorporated into the grants, that bans smoking on the right-of-way land. In 2020, the Fettigs sued WPX Energy in the Three Affiliated Tribes District Court, alleging that the company breached the smoking ban. WPX Energy moved to dismiss for lack of jurisdiction. The tribal court concluded that it possessed jurisdiction over the case and denied the motion to dismiss. WPX Energy appealed the decision to a tribal appellate court. he district court concluded that WPX Energy had exhausted its tribal court remedies and that the tribal court lacked jurisdiction, so it granted a preliminary injunction.   The Eighth Circuit vacated the injunction and remanded to the district court with directions to dismiss the complaint without prejudice. The court concluded that WPX Energy did not exhaust its tribal court remedies and that a ruling in federal court on the question of tribal court jurisdiction was premature. The court explained that the policy of promoting tribal self-governance is not limited to tribal court proceedings that involve the development of a factual record. Rather, exhaustion of tribal court remedies “means that tribal appellate courts must have the opportunity to review the determinations of the lower tribal courts.” View "WPX Energy Williston, LLC v. Hon. B.J. Jones" on Justia Law

Plaintiff brought a lawsuit under 42 U.S.C. Section 1983, alleging that Isanti County, Minnesota (the “County”) violated his Fourth and Fourteenth Amendment rights when it unlawfully prosecuted him under the County’s solid waste ordinance (the “Solid Waste Ordinance”). Plaintiff also asserted Minnesota state law claims for false imprisonment, malicious prosecution, and abuse of process. The district court granted judgment on the pleadings as to the federal claims in favor of the County and declined to exercise supplemental jurisdiction on the remaining state law claims.The Eighth Circuit affirmed. The court explained that while Plaintiff’s opening brief lists 21 cases, which Plaintiff contends constitute proof the County used the Solid Waste Ordinance to wrongly prosecute property owners, none of these cases are properly before the court as they were not included in the complaint. Plaintiff’s complaint contains insufficient factual allegations to sustain a municipal liability claim. Accordingly, the court held that without a constitutional violation, there can be no Section 1983 liability. View "Keith Kiefer v. Isanti County" on Justia Law