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

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law

Curtis Temple, a cattle rancher and member of the Oglala Sioux Indian Tribe (OST), had his grazing permits on the Pine Ridge Indian Reservation expire on October 31, 2012. He reapplied for new permits, but another OST member, Donald Buffington, also applied. The OST allocation committee found Temple had over 1,600 cattle, exceeding the 300 animal unit limit, making Buffington the eligible applicant. Temple's permits were awarded to Buffington, and Temple's appeals to the OST executive committee and the Bureau of Indian Affairs (BIA) were unsuccessful. Temple continued to graze his cattle on the land allocated to Buffington, leading to multiple trespass notices and eventual impoundment of his cattle by the BIA.Temple filed a lawsuit in the District of South Dakota in August 2015, seeking a temporary restraining order (TRO) and contesting the permit allocation. The district court denied the TRO and dismissed Temple's permit allocation claims, requiring him to exhaust administrative remedies. Temple's due process claims regarding the impoundment of his cattle proceeded, but the district court found that the written notices of trespass provided to Temple were sufficient and did not violate his due process rights. Temple's motion to continue the trial was also denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Temple was provided due process through the written notices of trespass and had ample opportunity to contest the trespass determinations. The court also affirmed the dismissal of Temple's permit allocation claims for failure to exhaust tribal remedies, as he did not appeal the tribal court's decision. Lastly, the court found no abuse of discretion in the district court's denial of Temple's motion to continue the trial. The judgment of the district court was affirmed. View "Curtis Temple v. Roberts" on Justia Law

Iowa enacted Senate File 2340, which criminalizes the presence of aliens who have illegally reentered the United States within its boundaries. The Act mandates that aliens violating it must return to the country they reentered from and prohibits judges from abating state prosecutions due to pending or possible federal determinations of the alien’s immigration status. The United States sought a preliminary injunction against the enforcement of the Act, which the district court granted. Iowa appealed the decision.The United States District Court for the Southern District of Iowa ruled that the United States had standing to sue and could state a cause of action to enjoin the Act. The court found that the United States established a likelihood of success on the merits, showing that federal immigration law preempts the Act under both conflict and field preemption. The court also found that irreparable harm would occur if the Act went into effect and that the balance of equities and public interest favored granting the injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion, examining factual findings for clear error and legal conclusions de novo. The appellate court affirmed the district court’s decision, holding that the United States had standing and an equitable cause of action to enjoin the Act. The court found that the Act likely conflicts with federal immigration law, as it obstructs the discretion of federal officials and creates a parallel enforcement scheme. The court also agreed that the United States demonstrated irreparable harm and that the balance of equities and public interest favored the injunction. The preliminary injunction against the enforcement of the Act was affirmed. View "United States v. State of Iowa" on Justia Law

CEZ Prior, LLC ("CEZ") entered into a purchase agreement with 755 N Prior Ave., LLC ("Prior") to buy a property for $26 million. The agreement required Prior to cooperate in obtaining tenant estoppel certificates. Errors in square footage measurements led to rent discrepancies, prompting an amendment to reduce the purchase price to $15.1 million and the cash required at closing to $3.8 million. CEZ later requested to delay closing due to financial issues, but Prior did not agree. Prior sent estoppel certificates that did not address rate increases, and CEZ proposed edits that Prior rejected. CEZ demanded satisfactory certificates on the closing date, but Prior terminated the agreement, alleging CEZ failed to tender cash.CEZ sued Prior for breach of contract in Minnesota state court and sought to enjoin the termination. Prior removed the case to federal court and counterclaimed for breach of contract. The district court stayed the matter and later denied CEZ's motion for a preliminary injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court's denial of the preliminary injunction. The court found that CEZ was unlikely to succeed on the merits of its breach of contract claim, as Prior had reasonably cooperated in obtaining the estoppel certificates. The balance of harms favored Prior, given CEZ's insufficient evidence of its ability to pay. The public interest did not favor CEZ due to its low probability of success on the merits.The court also addressed CEZ's argument under Minnesota law, finding that the district court's stay order was not an injunction and did not extend statutory deadlines. Consequently, CEZ was not entitled to additional time to close under Minnesota statutes. The Eighth Circuit affirmed the district court's judgment. View "CEZ Prior, LLC v. 755 N Prior Ave. LLC" on Justia Law

John Doe filed a putative class action against SSM Health Care Corporation in Missouri state court, alleging that SSM shared private health information with third-party marketing services without authorization, violating Missouri law. Doe claimed that SSM's MyChart patient portal transmitted personal health data to third-party websites like Facebook. The lawsuit included nine state law claims, such as violations of the Missouri Wiretap Statute and the Computer Tampering Act.SSM removed the case to federal court, citing the federal officer removal statute and the Class Action Fairness Act (CAFA). Doe moved to remand the case to state court. The United States District Court for the Eastern District of Missouri rejected SSM's arguments, ruling that SSM was not "acting under" a federal officer and that Doe's proposed class was limited to Missouri citizens, thus lacking the minimal diversity required under CAFA. The district court remanded the case to state court.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that SSM did not meet the criteria for federal officer removal because it was not acting under the direction of a federal officer. The court also held that the proposed class was limited to Missouri citizens, which destroyed the minimal diversity necessary for CAFA jurisdiction. Consequently, the Eighth Circuit affirmed the district court's remand order. View "Doe v. SSM Health Care Corporation" on Justia Law

Monsanto Company, Pharmacia, LLC, and Solutia, Inc. (collectively, "Monsanto") filed a lawsuit in St. Louis County Circuit Court in Missouri against Magnetek, Inc., General Electric Co. ("GE"), Paramount Global, KYOCERA AVX Components Corporation, Cornell Dubilier Electronics, Inc., and The Gillette Company LLC (collectively, "Defendants"). Monsanto alleged that it continues to incur substantial costs to defend against PCB lawsuits that should be borne by Defendants and sought to enforce written agreements obligating Defendants to defend, indemnify, and hold Monsanto harmless in all currently pending and future PCB lawsuits.GE removed the action to federal court, asserting jurisdiction under the federal officer removal statute, 28 U.S.C. § 1442(a)(1). The United States District Court for the Eastern District of Missouri granted Monsanto’s motion to remand, finding that GE's removal was untimely. GE appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the parties had waived Missouri Supreme Court Rule 54.13(c)’s personal service provision and expressly agreed that January 31, 2023, was the effective date for service of process. The court determined that the 30-day removal period began on the agreed effective date of service, not when GE signed the acknowledgment and waiver of service of process or when Monsanto filed the document. Consequently, GE's notice of removal was filed within the 30-day period, making the removal timely.The Eighth Circuit vacated the district court’s order of remand and remanded the case for further proceedings consistent with its opinion. The court declined to address whether GE satisfies the government contractor requirement of 28 U.S.C. § 1442(a)(1), as this issue was not addressed by the district court. View "Monsanto Company v. General Electric Co." on Justia Law

F.B. and M.B. filed a lawsuit on behalf of themselves and their minor child, L.B., under Section 504 of the Rehabilitation Act, alleging that Our Lady of Lourdes Parish and School failed to comply with procedural standards and requirements mandated by the Act's implementing regulations. L.B. had ADHD and reduced vision, and her parents claimed that the school initially provided necessary accommodations but later failed to do so after a change in school administration. This led to L.B. receiving failing grades and eventually being expelled from the school.The United States District Court for the Eastern District of Missouri dismissed the case, holding that Section 504 does not create a private right of action for claims based solely on an alleged failure to comply with procedural standards and requirements of the implementing regulations. The plaintiffs appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the plaintiffs lacked Article III standing to bring their claims. The court found that the plaintiffs' alleged injury, L.B.'s expulsion, was not fairly traceable to the school's failure to comply with the procedural regulations of Section 504. Additionally, the court determined that the relief sought by the plaintiffs would not redress their alleged injury. Consequently, the Eighth Circuit vacated the district court's judgment and remanded the case with instructions to dismiss for lack of jurisdiction. View "F.B. v. Our Lady of Lourdes Parish and School" on Justia Law

Charles James, a home designer, claimed that real estate agents infringed his copyrights by including floorplans of his homes in resale listings. James designed a home with a triangular atrium and stairs, built six homes using the design, and registered copyrights for the designs. In 2010, agent Susan Horak listed one of these homes for resale, creating a floorplan by hand for the listing. In 2017, agent Jackie Bulgin listed another of James's homes, using a similar floorplan. James discovered these listings in 2017 and alleged that the floorplans could be used to build homes, potentially infringing his copyrights.The United States District Court for the Western District of Missouri granted summary judgment to the real estate agents, concluding that their use of the floorplans was fair use. The court also initially ruled in favor of the agents under § 120(a) of the Copyright Act, but this decision was reversed by the United States Court of Appeals for the Eighth Circuit, which remanded the case for further consideration of the fair use defense.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's summary judgment in favor of the agents. The court held that the agents' use of the floorplans was fair use, considering the purpose and character of the use, the nature of the copyrighted work, the amount and substantiality of the portion used, and the effect on the market for the original work. The court found that the agents' use was transformative, had an informational purpose, and did not harm the market for James's designs. The court also rejected Designworks's request for further discovery on the fair use issue, concluding that the district court did not abuse its discretion in denying the motion. The court affirmed the district court's judgments. View "Designworks Homes, Inc. v. Columbia House of Brokers Realty, Inc." on Justia Law

Robert Gallagher borrowed money from Santander Consumer USA to purchase a car. After making the final payment via electronic funds transfer, Santander, following its standard practice, waited 15 days before sending the car title. Missouri law requires lienholders to release their lien within five business days after receiving full payment, including electronic funds transfers, or pay liquidated damages. Gallagher filed a lawsuit in Missouri state court on behalf of a potential class of borrowers affected by Santander's 15-day policy.The case was removed to the United States District Court for the Eastern District of Missouri, which granted summary judgment in favor of Santander. Gallagher appealed the decision, seeking to reverse the summary judgment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on whether Gallagher had standing to bring the case in federal court, specifically whether he had suffered an injury-in-fact. The court determined that Gallagher had not identified a concrete harm resulting from the delay in receiving the car title. The court noted that a statutory violation alone is insufficient for standing; there must be a concrete harm related to the violation. Gallagher did not demonstrate any monetary harm, such as a failed sale or impaired credit rating, nor did he show any ongoing injury to his property rights.The Eighth Circuit concluded that Gallagher lacked standing because he did not suffer a concrete injury. As a result, the court vacated the district court's judgment and instructed the district court to remand the case to state court. View "Gallagher v. Santander Consumer USA, Inc." on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely for payments going back five years under Kansas’s statute of limitations. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, interpreting the policy against Kansas City Life. The conversion claim was dismissed. A jury awarded over $5 million in damages, which was reduced to $908,075 due to the statute of limitations. Both parties appealed.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s class certification, finding that common questions of law and fact predominated. The court also upheld the application of Kansas law for both the conversion claim and the statute of limitations. The court agreed with the district court’s interpretation of the insurance policy, concluding that the cost of insurance should not include profits and expenses. The court found that the jury’s damages award was supported by reasonable evidence and did not warrant an increase.The Eighth Circuit affirmed the district court’s judgment, including the class certification, the application of Kansas law, the partial summary judgment in favor of Meek, and the damages award. View "Meek v. Kansas City Life Ins. Company" on Justia Law