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

Sleep Number partnered with Defendants and through their partnership, Defendants’ inventions were adapted to create SleepIQ technology. After two years as employees, Defendants informed Sleep Number that they wished to pursue their own venture. The parties entered into a consulting agreement requiring Defendants to disclose and assign to Sleep Number the rights to inventions within a defined Product Development Scope (“PDS”).Sleep Number sued Defendants., asserting ownership of the inventions claimed in certain patent applications filed by UDP with the United States Patent and Trademark Office (“USPTO”). The district court granted Sleep Number’s motion for a preliminary injunction preventing the defendants from further prosecuting or amending the patent applications.   The Eighth Circuit affirmed the district court’s grant of Plaintiff’s motion for a preliminary injunction. The court held that the district court did not err in determining that Sleep Number had a fair chance of success on the merits of its claims; nor did the court err in concluding that Sleep Number has demonstrated a threat of irreparable harm in the absence of an injunction; further the remaining factors of the balance of the harms and public interest both weighed in favor of Sleep Number. The court reasoned that the plain meaning of the language in the consulting agreements clearly and unambiguously places the inventions described in the patent applications within the PDS. Finally, absent an injunction, Sleep Number faces a threat of harm if it cannot participate in the patent-prosecution process for the patent applications. View "Sleep Number Corporation v. Steven Young" on Justia Law

Plaintiff sued Defendants claiming they violated the Fair Labor Standards Act and the Arkansas Minimum Wage Act. The district court entered an order granting summary judgment to Defendants. After the court entered its order, but before the clerk had entered a separate judgment dismissing Plaintiff’s claims, Plaintiff filed a notice stating that he had accepted an offer of judgment that Defendants had extended in which they agreed to pay him four thousand dollars plus costs and reasonable attorneys' fees.   Plaintiff maintained that, under Rule 68(a), he could accept the offer anytime up to fourteen days after Defendants had served him with it, and therefore it had survived the court's grant of summary judgment. The clerk nevertheless entered judgment consistent with the summary-judgment order. Plaintiff moved the court to amend the judgment to reflect the terms in the offer of judgment. The district court, relying on Perkins, granted Plaintiff’s motion, and the clerk entered a new judgment. Defendants appealed, maintaining that the judgment should have reflected the court's summary judgment ruling rather than the offer of judgment.   The Eighth Circuit affirmed the district court’s ruling and denied Defendants' requested relief and affirmed the district court’s denial of Plaintiff’s motion for recusal and from the court’s order granting Plaintiff only one dollar in attorneys' fees. The court reasoned that only its’ en banc court may overrule a prior panel's decision. Further, the court held that the district court did not abuse its discretion in awarding only one dollar in fees. View "Stetson Skender v. Eden Isle Corporation" on Justia Law

Plaintiffs did not purchase flood insurance for their house after the sellers told them that the property was not in a FEMA flood zone. Within weeks the area flooded, the home was destroyed and Plaintiffs sued the property sellers, the Federal Emergency Management Agency, and private contractors.   Plaintiffs alleged that either FEMA or the Strategic Alliance for Risk Reduction (“STARR”) made the 2010 Change to the 100-year flood-line estimate and SFHA designation. They alleged that STARR is a joint venture by Defendants Stantec Consulting Services, Inc., Dewberry Engineers, Inc., and Atkins North America, Inc., but do not name STARR itself as a defendant. Atkins and Stantec filed a Motion to Dismiss under Federal Rule of Civil Procedure 12(b)(6), extending the federal-contractor defense. The district court granted the motion.   The Eighth Circuit affirmed the district court’s decision granting Defendant’s motion to dismiss. The court held that Plaintiffs fail to state a claim because their complaint does not contain sufficient factual matter to show they are entitled to relief from Defendants. The court reasoned that Plaintiff’s complaint does not state how Atkins, Stantec and Dewberry work within STARR or which entity was responsible for any acts through STARR. Further, the complaint fails to state a claim for negligent misrepresentation against Atkins, Dewberry, and Stantec because the Plaintiffs provide “only naked assertions devoid of further factual enhancement” for three elements. Finally, the complaint similarly failed to state a claim for fraudulent misrepresentation because it does not plead which defendant made what representation. View "Derek Christopherson v. Robert Bushner" on Justia Law

Defendant was found incompetent to stand trial for the criminal charges against him. Defendant filed seventeen pro se motions seeking either release, a competency evaluation, or an order compelling his counsel to file a Sec. 4247(h) motion for a hearing to determine discharge. The court addressed whether the court had jurisdiction over Defendant’s direct appeal from a magistrate judge’s order. The parties argue the magistrate judge’s order was a “final order” authorized by the district court’s order of reference and Western District of Missouri Local Rule 72.1(c).The court reasoned that it has jurisdiction over “final decisions of the district courts of the United States”, thus without a “decision of a district court” it lacks jurisdiction to proceed any further. Defendant argues the parties implicitly consented to have the magistrate judge decide the motions at hand. But the parties’ consent does not save the appeal. Parties may consent to have a magistrate judge conduct any civil proceeding when the magistrate judge is “specially designated to exercise such jurisdiction by the district court”. Here, the district court did not specially designate the magistrate judge to exercise such jurisdiction. Thus, the court dismissed the Defendant’s appeal for lack of jurisdiction. View "United States v. Timothy O'Laughlin" on Justia Law

Plaintiff alleges he was unlawfully assaulted, pepper-sprayed, detained in an unlawful mass arrest, and ultimately incarcerated. He sued the City of St. Louis and multiple police officers for First, Fourth, and Fourteenth Amendment violations, conspiracy to deprive him of civil rights, and supplemental state law claims. One officer moved to dismiss the 1983 claims, arguing plaintiff’s amended complaint failed to state a claim and he is entitled to qualified immunity. The only allegations relating to the defendant’s involvement are that he was working on September 17 and took custody of the plaintiff’s bicycle lying in the street at the time of his arrest. These allegations do not establish a causal link between the plaintiff and the specific wrongs the defendants as a whole allegedly committed. Further, the defendant is entitled to qualified immunity because the amended complaint did not contain specific and plausible allegations linking the defendant to overt acts alleged as part of the conspiracy of all the defendants. The assertion that he agreed to participate in those acts does not state a plausible claim.Finally, the circuit court held that the district court erred in denying the other defendants' motion to dismiss. The defendants are entitled to qualified immunity because the intracorporate conspiracy doctrine was not clearly established. View "Michael Faulk v. Gerald Leyshock" on Justia Law

Plaintiff was seriously injured when a pledge of the defendant fraternity snuck into her room and slit her throat after a night of drinking. The plaintiff filed tort claims against the fraternity and related parties (“the fraternity”). Plaintiff claimed primary and vicarious liability.Applying Nebraska law, the Eighth Circuit affirmed the dismissal of the plaintiff’s primary liability claims, finding that the attack was not a foreseeable result of the fraternity’s forced hazing. The attacker’s criminal conduct was an intervening cause, severing the chain of causation. As to the plaintiff’s vicarious liability claims, the court held that the plaintiff failed to prove that any supposed agents of the fraternity were negligent under Nebraska law.The Eighth Circuit also held that social host liability does not apply. Nebraska’s Minor Alcoholic Liquor Liability Act provides a cause of action related to the “negligence of an intoxicated minor.” Here, the attacker was convicted of second-degree assault, which requires a finding that he acted knowingly or intentionally. This precludes a finding that the attacker acted negligently. View "Teresa Spagna v. Collin Gill" on Justia Law

Based upon its belief that Walmart has failed to comply with the terms of an injunction, Cuker sought to initiate contempt proceedings against Walmart, requesting supplemental damages for Walmart's post-verdict use of its trade secrets.The Eighth Circuit affirmed and concluded that the district court did not err in denying the request to commence contempt proceedings because Cukor had failed to make a prima facie case showing a violation of, or refusal to follow, a court order. In this case, Cuker's claim that the district court did not consider its arguments or evidence is belied by the record. Upon review of the record and Cuker's arguments, the court stated that Cuker's challenges to the district court's order go to the weight the court gave its evidence, not a failure to consider the evidence. View "Wal-Mart Stores, Inc. v. Cuker Interactive, LLC" on Justia Law

Robinson filed a 42 U.S.C. 1983 lawsuit six years and one day after police officers arrested and allegedly beat him. The day before he sued was Veterans Day, so federal courthouses were closed. The defendants argued that his claims were untimely. The district court asked whether some of the claims were really timely filed because the limitations period, which ordinarily would have ended on a “legal holiday,” actually “continue[d] to run until the end of the next day.” Fed. R. Civ. P. 6(a)(1)(C). Despite the hint, Robinson never made that argument himself, so the court dismissed the claims.The Eighth Circuit reversed in part. Robinson’s privacy, excessive force, and false-arrest claims were timely. Robinson’s failure to argue the federal-holiday rule was forfeiture, not waiver, as it involved inaction rather than acquiescence. Once the district court raised the federal-holiday rule, Robinson’s counsel thought there was little point in pressing the issue. Forfeiture is excusable in limited, well-defined circumstances, including when “the proper resolution is beyond any doubt,” for “purely legal issue[s]” that do not require “additional evidence or argument.” Here, how the federal-holiday rule works is clear, none of the relevant dates are in dispute, and everyone agrees that a six-year statute of limitations applies; this “purely legal issue” that is “beyond doubt.” Robinson’s malicious-prosecution claim, however, does not state” a constitutional claim and was properly dismissed. View "Robinson v. Norling" on Justia Law

A judgment creditor’s attorney, Rodenburg, mailed the consumer debtor, Ojogwu a copy of the garnishment summons Rodenburg had served on garnishee US Bank, knowing that Ojogwu had retained counsel after the default judgment was entered and that he disputed the debt. The district court held that Minn. Stat. 571.72(4), which requires that copies of papers served on a third-party garnishee “be served by mail at the last known mailing address of the debtor not later than five days after the service is made upon the garnishee” was inconsistent with, and therefore preempted by, the federal Fair Debt Collection Practices Act: “Without the prior consent of the consumer . . . or the express permission of a court of competent jurisdiction, a debt collector may not communicate with a consumer in connection with collection of any debt . . . if the debt collector knows the consumer is represented by an attorney with respect to such debt.” 15 U.S.C. 1692c(a)(2).The Eighth Circuit ordered the dismissal of the case. Under recent Supreme Court precedent, Ojogwu lacks Article III standing to pursue this claim in federal court because he failed to allege and the record does not show that he suffered concrete injury-in-fact from Rodenburg’s alleged violation of section 1692c(a)(2). View "Ojogwu v. Rodenburg Law Firm" on Justia Law

Alissa's Flowers filed suit against State Farm, alleging that it had overpaid its premiums to State Farm in light of its significantly lower exposure rate due to COVID-19. State Farm moved to dismiss the amended complaint, arguing that Missouri law required that Alissa's Flowers bring its claims before the director of the Missouri Department of Insurance.The Eighth Circuit affirmed the district court's dismissal of the complaint, concluding that the administrative review process set forth in Mo. Rev. Stat. 379.348 applies in the commercial insurance context and to plaintiff's claims in this case. The court explained that the district court properly determined that Alissa's Flowers was required to exhaust administrative remedies because the claims, in essence, constitute a challenge to State Farm's rates, rating plan, rating system and underwriting rules. Finally, the complaint should not have been dismissed for lack of subject matter jurisdiction, but rather for lack of authority to grant relief. View "Alissa's Flowers, Inc. v. State Farm Fire & Casualty Co." on Justia Law