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

The Stewarts purchased an RV in 2013 from Spitler, who financed their purchase through a bank loan. The RV was equipped with a refrigerator manufactured by Norcold. In 2016, the RV was destroyed in a fire that the Stewarts alleged was caused by the Norcold refrigerator. The Stewarts brought product liability claims against Norcold seeking damages including the market value of the RV, emergency expenses, the value of the lost personal property, and the payoff of the loan balance on the RV.During a summary judgment motion hearing, the Stewarts affirmed that the amount of the loan constituted “the alleged damages that are the subject of this lawsuit,” stating, “we are not seeking recovery of the damage to the RV.” The district court’s order granting Norcold summary judgment stated that “the only claim that remains … is for the loan payoff amount of $43,201.85.”On appeal, the Stewarts asserted that they “retained a damage claim against [Norcold]” for $106,885, which includes damages for the market value of the RV, emergency expenses, and the value of their personal property. The Eighth Circuit affirmed. The Stewarts waived any challenge to the district court’s determination that the loan payoff amount was the only damage claim at issue. View "Stewart v. Norcold, Inc." on Justia Law

Plaintiff filed suit against the Bank of the West in state court, seeking to set aside the trustee's sale of his property. After the claim was dismissed, plaintiff filed an amended complaint adding U.S. Bank as a defendant. The case was removed to federal district court where it was ultimately dismissed.The Eighth Circuit affirmed the district court's dismissal orders, concluding that the federal law violations as alleged in the second amended complaint all occurred prior to the institution and maintenance of any foreclosure activity. Therefore, they were not defects in the trustee's sale under Nebraska law. The court also concluded that the district court did not abuse its discretion in denying defendant's motion for leave to file a third amended complaint where the motion was procedurally defaulted and granting leave would be futile. View "Anderson v. Bank of the West" on Justia Law

This case stemmed from plaintiffs' action alleging that nuclear waste materials from various St. Louis sites leaked into Coldwater Creek and its 100-year floodplain in St. Louis County, damaging their health and property. Following Cotter's removal to federal court on the basis of the Price-Anderson Act (PAA), the district court concluded that the PAA did not apply and remanded to state court. After plaintiffs amended their complaint in state court, Cotter filed a third party action for contribution against seven defendants, including Mallinckrodt, which then removed the entire lawsuit under the PAA and other bases. The district court granted the motion and Cotter appealed.After determining that the court has jurisdiction over the appeal, the Eighth Circuit concluded that the district court abused its discretion by determining that the PAA does not apply to plaintiffs' claims against Cotter because Cotter lacked an applicable license or indemnity agreement. Contrary to the district court's ruling, the court concluded that the PAA provides federal question jurisdiction over all "nuclear incidents," regardless of whether the defendant had an applicable license or indemnity agreement. The court explained that the PAA's text and history support its conclusion. In this case, the PAA Act provides original federal question jurisdiction for all nuclear incidents regardless of whether the defendant had an applicable indemnity agreement. View "In Re: Cotter Corporation" on Justia Law

The Eighth Circuit dismissed, based on lack of jurisdiction, plaintiffs' appeal of a district court order staying a federal action for trademark infringement and unfair competition pending resolution of common trademark license issues in a long-pending state court litigation between the parties. The court concluded that the stay order is neither a final order under 28 U.S.C. 1291 nor a collateral interlocutory order that may be appealed. In this case, the district court did not abuse its discretion in concluding that if the Lomax Parties prevail on their broad allegations in state court, then the state proceedings will fully dispose of the claims in federal court. View "Window World International v. O'Toole" on Justia Law

Plaintiffs, relatives of individuals who worked at the Tyson Foods pork processing facility that contracted COVID-19 and later died, filed suit alleging claims for fraudulent misrepresentation and gross negligence. Plaintiffs contend that Tyson's actions in March and April of 2020 caused their relatives' deaths. Tyson removed the cases to federal court and then the district court remanded to state court.The Eighth Circuit affirmed and concluded that Tyson has failed to show that it was performing a basic governmental task or operating pursuant to a federal directive in March and April of 2020. Therefore, Tyson was not acting under a federal officer at the time that plaintiffs' relatives contracted COVID-19 and is not eligible for removal under the federal officer removal statute. The court also concluded that Tyson has abandoned the federal question argument concerning removal by failing to brief it, either in its initial brief or by supplemental brief, after the Supreme Court decided BP P.L.C. v. Mayor and City Council of Baltimore, 141 S.Ct. 1532 (2021), permitting alternative arguments against remand to be raised. View "Buljic v. Tyson Foods, Inc." on Justia Law

The Eighth Circuit affirmed in part and reversed in part in an action challenging the district court's award of attorney's fees and costs. The court concluded that the district court did not abuse its discretion in setting the attorneys' rates or in excluding the managing partner's hours as unwarranted. However, the district court abused its discretion by excluding all hours related to plaintiff's three summary judgment motions and 1.6 hours for two oppositions: to a successful motion for extension of time to file the answer, and to a successful motion to continue the trial. Finally, the court need not appoint a new judge for remand where judicial rulings alone almost never constitute a valid basis for a bias or partiality motion, and judicial remarks that are critical or disapproving of, or even hostile to a party ordinarily do not support a bias or partiality challenge. The court remanded for further proceedings. View "Burton v. Nilkanth Pizza Inc." on Justia Law

The Eighth Circuit affirmed the district court's award of attorney's fees to plaintiffs in an action alleging violations of the McKinney-Vento Act (MVA), the Rehabilitation Act (RA), the Americans with Disabilities Act (ADA), and the Equal Protection Clause of the Fourteenth Amendment. The court declined to take up an issue regarding whether the MVA provides a private right of action for students experiencing homelessness and their families for the first time on appeal. The court explained that the State never raised an argument in the district court that the students and their mothers lacked a cause of action or that they could not recover attorneys' fees for time spent pursuing the claim. The court also concluded that the district court did not abuse its discretion in making the State jointly and severally liable for the fees imposed against the district defendants. View "Scott C. v. Missouri Department of Elementary and Secondary Education" on Justia Law

In a previous opinion, the district court affirmed a $34.3 million jury verdict in favor of the class represented by plaintiff and reversed the district court's denial of prejudgment interest. The court then remanded the matter for the district court to reconsider plaintiff's motion for prejudgment interest. State Farm appealed.The Eighth Circuit affirmed the district court's award of prejudgment interest, concluding that plaintiff was entitled to prejudgment interest at the 4% rate contained in the contract, and the district court did not err in calculating the amount of interest due and awarding plaintiff $4,521,674 in prejudgment interest. View "Vogt v. State Farm Life Insurance Co." on Justia Law

After a tractor manufactured by CNH caught fire, Floyd filed suit against CNH in federal court under a theory of product liability, claiming that its insureds owned the tractor and other property on the tractor, both of which were damaged in the fire, and that Floyd was subrogated to its insureds' claims against CNH because Floyd had paid its insureds' claim for the damage. The district court dismissed the case for lack of subject matter jurisdiction under 28 U.S.C. 1332.The Eighth Circuit affirmed and concluded that section 1332's amount-in-controversy requirement was not satisfied in this case. The court concluded that the Iowa Supreme Court would hold that the economic-loss doctrine permits recovery only for the other property and not for the product itself. Accordingly, the Iowa Supreme Court would bar recovery in tort for damage that a defective product causes to itself, even if the plaintiff also seeks recovery for damage to other property. Here, Floyd's recovery is limited as a matter of law to the alleged $22,787.81 in damage to property other than the tractor. The court denied the motion to certify a question of law to the Iowa Supreme Court and upheld the district court's dismissal based on lack of subject matter jurisdiction. View "Floyd County Mutual Insurance Ass'n v. CNH Industrial America LLC" on Justia Law

The Eighth Circuit affirmed the district court's award of over $3 million in attorney fees and expenses to plaintiffs in a settlement involving Missouri's foster-care system. Plaintiffs filed suit on behalf of a group of foster children, alleging that Missouri did not have adequate procedures in place to guard against the overuse of psychotropic drugs. The court concluded that the district court properly placed the burden on plaintiffs to support the hours claimed. The district court then evaluated the billing records, attorney-by-attorney, and disregarded any entries that were excessive or vague, leaving no doubt that plaintiffs had failed to prove their entitlement to all the fees and expenses they had requested. The court also concluded that the district court did not abuse its discretion in setting the fee award and rejected defendants' contentions to reduce the award. View "M.B. v. Tidball" on Justia Law