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

Plaintiffs, Germain and GM Enterprises, filed suit against defendants, HCH and Metropolitan, alleging breach of contract claims related to an option to purchase based on the assignment of a lease agreement. The district court dismissed the complaint because plaintiffs were precluded from bringing the action where a state court already had decided the issue underlying the claims alleged in their federal complaint. As a preliminary matter, the court held that the Rooker-Feldman doctrine does not bar plaintiffs' claims where their complaint alleged injuries caused by breach of contract and related to torts. Turning to section 13 of the Restatement (Second) of Judgments, the court believed that the Arkansas Supreme Court would hold that the state-court judgment in this case was sufficiently firm to be considered final for purposes of issue preclusion; based on the state court's conclusion and the terms of the subordination agreement, Germain was not entitled to specific performance of the option and dismissal of the federal declaratory-judgment action was appropriate; and the district court did not abuse its discretion in awarding attorneys' fees to defendants. The court affirmed the judgment of the district court. View "Germain Real Estate v. HCH Toyota" on Justia Law

Hutterites disavow individual property ownership for a communal lifestyle. The Hutterian Church has three conferences. South Dakota’s Hutterville Colony belonged to the Schmiedeleut Conference. Hutterville’s nonprofit corporation operates a communal farm, conducts business, and owns all property. In 1983, when the Colony formed, Kleinsasser led Schmiedeleut Conference. Several ministers repudiated Kleinsasser’s leadership in 1992 and followed Wipf. Colonies following Wipf ratified a new constitution. Kleinsasser’s colonies did not. Each group claimed that it was the true Schmiedeleut. Waldner, Hutterville’s ecclesiastical leader, its corporation’s president, and a director, was loyal to Kleinsasser. The complaint alleges that through “sham” corporate meetings in 2008-2009, Wipf faction members were elected to replace Waldner faction officers and directors. Each faction conducted business in the name of the company. In 2009 a state trial court determined that Wipf faction members were the duly elected directors and officers. Waldner and Kleinsasser excommunicated Wipf faction members. State courts rejected a challenge to the excommunication, reasoning that control of the corporation could not be determined without addressing religious questions. In a second state action, the supreme court reversed appointment of a receiver, concluding that even corporate dissolution is beyond secular jurisdiction. As the factions were contesting the receiver’s accounting, the Waldners filed suit under RICO, as individuals and in their “official” capacities as purported directors and officers, claiming that attorneys worked with the Wipf faction to “wrest control” of Hutterville, and that the receiver was part of the plan. The district court dismissed, reasoning that official capacity standing required knowing who truly controls Hutterville, which involves religious disputes; individual claims for property damages claims were dismissed based on the renunciation of individual property. The Eighth Circuit affirmed. View "Hutterville Hutterian Brethren, Inc. v. Sveen" on Justia Law

In 1990, Magee was hired as a professor at Hamline University School of Law. She became tenured in 1994. In 2009, Magee was charged with felony state tax violations. While her case was pending, Hamline placed her on a leave of absence and relieved her of teaching responsibilities. In 2011, a jury found Magee guilty of four misdemeanor counts of failure to file state tax returns. The convictions were upheld on appeal. After the dean initiated her termination, a faculty committee voted in favor of discharge. Magee was terminated on July 21, 2011. Magee filed suit under 42 U.S.C. 1983. The district court dismissed. The Eighth Circuit affirmed. In 2013, Magee served a second lawsuit, alleging violation of 42 U.S.C. 1981, which “offers relief when racial discrimination blocks the creation of a contractual relationship, as well as when racial discrimination impairs an existing contractual relationship,” The district court dismissed. The Eighth Circuit affirmed, holding that because Magee’s section 1983 claim in Magee I and the section 1981 claim “arise out of the same transaction or series of transactions,” the section 1981 claim should have been raised in Magee I and was barred by the doctrine of res judicata.. View "Magee v. Hamline Univ." on Justia Law

Howard allegedly rear-ended Gumby's vehicle, Gumby sued Howard and his employer, UPS. Contending that Gumby’s health might have contributed to the accident, UPS requested information including medical records and the identity of anyone with knowledge concerning this defense. Gumby provided the names of one physician and one hospital from which he had received pre-accident care. Gumby died a year later. Comstock, Gumby’s daughter and estate administrator, was substituted as plaintiff. A year after discovery began, Comstock produced documents revealing more medical providers, but did not produce all requested information. The court ordered Comstock to complete production by September 28. She failed to do so. In December 2012, Comstock provided UPS with over 3,000 pages of documents. Some were duplicates, but new documents showed that Gumby had vision problems; suffered dizziness, paranoia, and hallucinations while driving; had been instructed not to drive at night; and had been hospitalized hours before the accident. Comstock had called law enforcement that night, worried because Gumby, had left Pennsylvania to drive to Arkansas. UPS had already deposed Gumby and family members. The district court noted further misconduct concerning expert test results. The court found “extreme prejudice” and sanctioned Comstock under FRCP37(b)(2) by dismissal. The Eighth Circuit affirmed. View "Comstock v. UPS Ground Freight, Inc." on Justia Law

The Arkansas DHS regulates child care facility licensing and administers the USDA Child Care Food Program. Sparkman day care facility provided disability services funded by DHS and participated in the Program through DHS. The Program prohibits placement of disqualified individuals in a position of authority, 7 C.F.R. 226.6(c)(3)(ii)(B). DHS Policy states that violations can result in exclusion of a provider from further funding. DHS alleged that Sparkman placed a disqualified individual, Whitaker, in a position of authority. Sparkman believed that racial animus motivated DHS to place Whitaker on the disqualification list, but did not raise an equal protection claim at the hearing. Before the hearing was complete, the ALJ resigned, stating "as an African American male I cannot continue to work in a[n] office where racism and harassment continue to exist." Another ALJ, a Caucasian present as an observer, upheld DHS's termination of funding. With state appeals pending, Sparkman filed a federal complaint. The district court stayed proceedings. Following state court remand, DHS appointed a private attorney to serve as hearing officer; Sparkman agreed to the selection. Sparkman again made no equal protection or due process claims. The hearing officer decided in DHS's favor. Sparkman’s state court appeal alleged ex parte communications between DHS and the hearing officer. The state courts upheld the decision. The federal court concluded that claim preclusion barred Sparkman's due process and equal protection claims. The Eight Circuit affirmed, holding that the claims could have been brought during the state administrative proceeding and judicial review. View "Sparkman Learning Ctr. v. Ark. Dep't. Human Servs." on Justia Law

DeCoteau was convicted of gross sexual imposition in 1996. His 2012 habeas petition had six claims. The district court dismissed, finding four claims time-barred, one procedurally barred, and the other without merit, but granted a certificate of appealability as to whether the Antiterrorism and Effective Death Penalty Act limitations period applies on a claim-by-claim basis. The Eighth Circuit affirmed. AEDPA’s one-year limitations period applies to “an application” for habeas corpus, running from the latest of: the date on which judgment became final by conclusion of direct review or expiration of the time for seeking review; the date on which the impediment to filing an application created by state action in violation of the Constitution or laws of the United States is removed; the date on which a newly-recognized constitutional right was initially recognized by the Supreme Court and made retroactively applicable to cases on collateral review; or the date on which the factual predicate of the claim could have been discovered through the exercise of due diligence, 28 U.S.C. 2244(d)(1)(A)-(D). The court rejected DeCoteau’s argument that the word “application” focuses on the date of the latest claim within the entire application, allowing review of all claims if one is timely. View "DeCoteau v. Schweitzer" on Justia Law

EEOC sued CRST in its own name, under Title VII, 42 U.S.C. 2000e, alleging that CRST subjected Starke and 270 similarly situated female employees to a hostile work environment, in its Driver Training Program. For two years, EEOC failed to identify the women comprising the putative class; the court ordered EEOC to make all class members available for deposition or risk a discovery sanction. EEOC filed updated lists of allegedly aggrieved individuals, but failed to make all of them available for deposition before the deadline. The court barred EEOC from pursuing relief for any individual not made available for deposition before the deadline. EEOC then listed 155 individuals for whom it was still pursuing relief and 99 individuals, allegedly sexually harassed, but for whom EEOC was not pursuing relief based on the order. Following remand, the court dismissed, but for one claim, which settled for $50,000, and awarded CRST $92,842.21 in costs, $4,004,371.65 in attorneys' fees, and $463,071.25 in out-of-pocket expenses. The Eighth Circuit held that CRST is not entitled to attorneys' fees for claims dismissed based on EEOC's failure to satisfy pre-suit obligations and a purported pattern-or-practice claim. On remand, the court must individually assess each claim for which it granted summary judgment on the merits and explain why it deems each to be frivolous, unreasonable, or groundless. View "Equal Emp't Opportunity Comm'n v. CRST Van Expedited, Inc." on Justia Law

Plaintiffs filed suit against Heinkel and Pepperl in Iowa state court, seeking damages based on a products-liability theory. On appeal, Heinkel and Pepperl challenged the district court's grant of plaintiffs' motion to dismiss without prejudice and the district court's failure to condition the dismissal on the payment of fees and costs. The court concluded that the district court did not abuse its discretion by granting plaintiffs' motion to dismiss without prejudice where the grant of voluntary dismissal did not result in a waste of judicial time and effort because the case had not progressed very far. Further, in these circumstances, the district court did not abuse its discretion by granting the voluntary dismissal without awarding fees and costs. Accordingly, the court affirmed the judgment of the district court.View "Mullen v. Pepperl & Fuchs, Inc." on Justia Law

Plaintiffs filed suit against defendants alleging that defendants breached a contract for legal services, seeking compensatory and punitive damages. The district court granted defendants' motion to transfer the legal malpractice suit to the District of Nebraska. The district court subsequently denied plaintiffs' motion to retransfer and concluded that plaintiffs' claims were time-barred. Plaintiffs appealed. The court concluded that, because the malpractice occurred exclusively in the District of Nebraska, there was no error in concluding that the Southern District of Iowa was an improper venue. Further, this issue is governed by the Nebraska, the transferee forum, choice-of-law principles. Accordingly, the court affirmed the district court's judgment applying Nebraska's legal malpractice statute of limitations in ruling that plaintiffs' claim was time-barred.View "Steen v. Murray" on Justia Law

Plaintiff filed suit against XTO, an oil and natural gas producer, for damages caused by vibrations from drilling operations. The jury returned a verdict for plaintiff and XTO moved for a new trial. The district court denied the motion and XTO appealed. The court concluded that, even assuming the jury's fracking and earthquake discussions included any extraneous matters under Federal Rule of Evidence 606(b)(2)(A), XTO has not shown a reasonable possibility that the discussions prejudiced it or altered the verdict. Therefore, the district court did not abuse its discretion in denying XTO's motion for a new trial. Further, the district court did not abuse its discretion in declining to subpoena the jury foreman under Moore v. Am. Family Mut. Ins. Co. Accordingly, the court affirmed the judgment.View "Hiser v. XTO Energy, Inc." on Justia Law