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

A high-speed police chase initiated by a deputy from Pottawattamie County, Iowa, ended in a collision in Nebraska, injuring Kirstie Wade and her children. Wade sued Pottawattamie County in a Nebraska federal district court for damages. However, the district court dismissed the case, citing a lack of personal jurisdiction over the Iowa county.The case was then brought before the United States Court of Appeals for the Eighth Circuit. The court had to determine whether the Nebraska federal district court had personal jurisdiction over Pottawattamie County. Personal jurisdiction depends on both a forum state’s long-arm statute and general due-process principles. Nebraska’s long-arm statute authorizes “the exercise of personal jurisdiction consistent with the Constitution of the United States,” which means that the exercise of personal jurisdiction over Pottawattamie County must be “consistent with” due process.The court considered two types of jurisdiction: general and specific. General jurisdiction, which allows a court to hear any and all claims against a party, was ruled out as Pottawattamie County’s contacts with Nebraska were not continuous and systematic. However, the court found that specific jurisdiction, which covers only those claims arising out of or relating to a party’s contacts with the forum, was applicable. The court reasoned that the deputies had purposefully availed themselves of the benefits and protections of Nebraska’s laws by choosing to continue the chase across the border, and they could have reasonably anticipated being brought to court in Nebraska if something went wrong.The United States Court of Appeals for the Eighth Circuit reversed the district court's decision, ruling that the Nebraska federal district court did have personal jurisdiction over Pottawattamie County. The case was remanded for further proceedings. View "Wade v. Pottawattamie County" on Justia Law

Bader Farms, Inc. sued Monsanto Company and BASF Corporation, alleging that its peach orchards were damaged by dicamba drift between 2015 and 2019 due to the defendants' negligent design and failure to warn. The jury awarded $250 million in punitive damages against both Monsanto and BASF based on Monsanto’s acts in 2015-16, which the district court later reduced to $60 million. The defendants appealed the decision.The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision except for punitive damages, holding BASF and Monsanto liable as co-conspirators in a civil conspiracy. The court remanded the case to separately assess punitive damages against Monsanto and BASF. However, before the new trial, Monsanto settled with Bader Farms. The district court did not conduct a new trial and instead ruled that BASF could not be liable for any punitive damages, dismissing all claims against BASF.Bader Farms appealed, arguing that the district court ignored the appellate court’s mandate and its holding that BASF could be assessed punitive damages for its acts in furtherance of the conspiracy. The appellate court reviewed the district court’s interpretation of its mandate de novo and found that the district court did not comply with the appellate mandate. The appellate court held that BASF is vicariously liable for Monsanto’s actions and remanded the case for a trier of fact to apportion the punitive damages award. The court reversed the judgment and remanded with instructions to hold a new trial on the single issue of punitive damages. View "Bader Farms, Inc. v. BASF Corporation" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit reversed a district court's decision to impose sanctions on attorney Gregory Leyh and his law firm under Missouri Supreme Court Rule 55.03 and Federal Rule of Civil Procedure 11 for filing frivolous claims. The sanctions were requested by Martin Leigh, P.C., a party that Leyh had included in a series of lawsuits filed on behalf of Gwen Caranchini, who had defaulted on her home loan and was seeking to stop foreclosure proceedings.The district court had imposed sanctions after Leyh failed to respond to a warning letter and motion for sanctions served by Martin Leigh. On appeal, Leyh argued that the sanctions imposed were inappropriate because Martin Leigh had not complied with Rule 11(c)(2)'s safe harbor provision, which requires that a party be given an opportunity to withdraw or correct the offending document before a motion for sanctions is filed.The appellate court agreed with Leyh, finding that Martin Leigh had not adhered to the strict procedural requirements of Rule 11(c)(2). The court also noted that while Leyh's legal tactics were an abuse of the system, Martin Leigh had not pursued other possible avenues for sanctions, such as Rule 11(c)(3), 28 U.S.C. § 1927, or the court's inherent powers. The court thus reversed the sanctions and remanded the case to the district court with instructions to vacate the award. View "Martin Leigh PC v. Leyh" on Justia Law

Christine M. Nordgren's parental rights were terminated in a Minnesota state court. Instead of appealing this decision, she filed a federal lawsuit against the Minnesota Department of Human Services, Hennepin County, and various other parties involved in her case, alleging a range of constitutional, federal, and state claims. She sought multiple forms of damages, as well as attorney’s fees and costs. The district court dismissed all federal claims and declined to exercise jurisdiction over the state law claims. Nordgren then filed a motion to alter or amend the judgment, which the district court interpreted as a request to reconsider and amend her pleadings, and denied it. Nordgren appealed this decision.The Hennepin County defendants moved to dismiss Nordgren's appeal as untimely, arguing that she did not appeal the judgment in a timely manner and that the district court's order denying her motion for reconsideration was not separately appealable and did not extend the appeal period. The United States Court of Appeals for the Eighth Circuit agreed with the defendants, determining that Nordgren's motion did not qualify as an appealable motion under Rule 59(e), which is designed to correct manifest errors of law or fact or to present newly discovered evidence. As such, the appeal period began on the date the judgment was entered, and Nordgren's notice of appeal, filed beyond the 30-day appeal period, was untimely.Therefore, the Court of Appeals dismissed Nordgren's appeal for lack of jurisdiction. View "Nordgren v. Hennepin County" on Justia Law

The United States Court of Appeals for the Eighth Circuit affirmed a lower court's judgment in favor of a police officer who filed a lawsuit against the city of Omaha and the chief of police of the Omaha Police Department. Katherine Belcastro-Gonzalez had filed a complaint alleging sexual harassment by a coworker in 2010, and in 2017, she discovered that her complaint wasn't adequately investigated. She alleged that her subsequent applications for promotions were denied due to her complaints about sex discrimination. A jury found in favor of Belcastro-Gonzalez and awarded her $700,000 in damages. The lower court also awarded her attorney's fees.The city appealed, arguing first that the district court erred in denying its motion for summary judgment. The appeals court held that it could not review this decision after a trial on the merits. The city should have raised these issues in a post-trial motion for judgment as a matter of law. The city also argued that the district court erred in admitting evidence from proceedings before the Nebraska Employment Opportunity Commission. However, the appeals court found that the admission of this evidence was not an abuse of discretion. The city's last argument was against the size of the attorney’s fees award. The appeals court found that the lower court did not abuse its discretion in determining the amount of the fee, including fees incurred during the administrative proceedings. View "Belcastro-Gonzalez v. City of Omaha" on Justia Law

This case from the United States Court of Appeals for the Eighth Circuit involves a dispute between Midwest Medical Solutions, LLC and Exactech U.S., Inc. This is the second time the case has come before the court. The initial appeal by Midwest was regarding a summary judgment in favor of Exactech, which was based on the district court's interpretation of a non-compete clause in the parties' Sales Agreement. The Court of Appeals reversed the summary judgment, finding the clause unambiguous, and remanded the case for further proceedings.In the latest appeal, Exactech contends that the district court erred by denying its motion for leave to replead two counterclaims. Exactech had initially included these counterclaims in its pleadings but later removed them, believing they had been rendered moot by the district court's order interpreting the disputed contract language in Exactech's favor. Exactech attempted to reintroduce these counterclaims after the Court of Appeals reversed the summary judgment. The district court denied Exactech's motion to amend its pleadings, citing Exactech's lack of diligence in adhering to scheduling deadlines and the absence of changed circumstances that would justify its delay.The Court of Appeals affirmed the district court's decision. It found that the district court did not abuse its discretion in denying Exactech's motion to amend, as Exactech had failed to establish good cause for amending the scheduling order. The court noted that Exactech had voluntarily chosen not to replead these counterclaims in its amended pleadings, and that this decision could not be considered a changed circumstance. The court further noted that Exactech could have pleaded these counterclaims in the alternative, rather than omitting them entirely. View "Midwest Medical Solutions, LLC v. Exactech U.S., Inc." on Justia Law

In this case, James Scott filed a civil rights lawsuit against the City of Sherwood, Sherwood City Attorney Stephen Cobb, and Sherwood City Code Enforcement Officer Sheila Reynolds. Scott owned property in Sherwood, Arkansas, which he used for storage and a repair business. After Sherwood annexed his property, Scott faced numerous complaints, citations, and prosecutions over the use of his property.Scott filed a lawsuit in state court, which was dismissed on grounds of sovereign immunity. Later, he filed a nearly identical lawsuit in federal court. The defendants moved for dismissal, arguing that the doctrine of res judicata, which prevents issues that have been judicially decided from being re-litigated, applied to Scott's claims. The district court granted the motion, and Scott appealed.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that under Arkansas law, all the elements for claim preclusion, a type of res judicata, were satisfied. The court noted that Scott's lawsuit in state court was fully contested in good faith and resulted in a dismissal with prejudice, which constituted a final judgment. The state court had jurisdiction over the matter, and Scott's state and federal lawsuits involved the same civil rights claims and parties.Scott argued that the Arkansas court did not have jurisdiction and that it did not enter a valid final judgment. The appellate court rejected these arguments, explaining that under Arkansas law, sovereign immunity is treated like an affirmative defense, not a matter of subject-matter jurisdiction. The court also noted that the proper course of action for Scott to remedy an erroneous decision would be an appeal or a post-judgment motion, not another lawsuit. View "Scott v. City of Sherwood, Arkansas" on Justia Law

The case involves the Reporters Committee for Freedom of the Press, a nonprofit organization that sought to unseal court filings from federal criminal investigations. The District Court in Minnesota dismissed the application for lack of jurisdiction, and the case was appealed to the United States Court of Appeals for the Eighth Circuit.The Reporters Committee's application aimed to unseal electronic-surveillance filings, which were required to be filed under seal by a local rule. The District Court believed the request was too broad since the majority of the materials requested become unsealed after six months. The court suggested negotiations with the United States Attorney’s Office to reach a solution.The Reporters Committee subsequently filed an amended application, seeking an order directing the clerk of the court to presumptively unseal warrants and related documents after 180 days and to begin docketing the government’s applications for electronic surveillance regardless of whether a judge granted them. The Committee claimed these duties arose under the First Amendment and the common-law right of access to public records and documents.The District Court dismissed the application, concluding that the Committee lacked standing because all it had was a “generalized, abstract interest” in unsealing the records. This decision was affirmed by the Appeals Court, which held that the Committee failed to establish it suffered a “concrete” and “particularized” injury. It was also noted that the Committee did not sue anyone who could provide the relief it sought, hence there was a lack of adversity necessary for federal court adjudication. View "Reporters Comm. for Freedom of the Press v. United States" on Justia Law

The case involves Sanimax USA, LLC, who sued the City of South Saint Paul, Minnesota, under 42 U.S.C. § 1983, alleging that the city's zoning and odor ordinances violated the First Amendment and Equal Protection Clause. Sanimax contended that the city enacted these ordinances in retaliation for Sanimax challenging prior ordinances and that the ordinances unfairly singled out Sanimax. The district court granted the city's motion for summary judgment on all counts.Sanimax operates a rendering plant in South Saint Paul that processes animal carcasses and organic byproducts, emitting pungent, foul odors that have drawn numerous complaints from nearby residents and businesses. Sanimax was designated as a "Significant Odor Generator" by the city, and later challenged the constitutionality of the city's odor ordinance, alleging that it was unconstitutionally vague.The United States Court of Appeals For the Eighth Circuit affirmed the district court's decision. The Court found that Sanimax failed to show that the city's actions were a direct retaliation for Sanimax's prior lawsuits challenging the city's ordinances. Additionally, the Court rejected Sanimax's argument that it was unfairly singled out, finding that Sanimax was not similarly situated to other businesses due to the significantly higher number of odor complaints it generated. Lastly, the Court rejected Sanimax's argument that the city's odor ordinance was unconstitutionally vague, finding that the ordinance provided sufficient notice of the prohibited conduct and did not lend itself to arbitrary enforcement. View "Sanimax USA, LLC v. City of South St. Paul" on Justia Law

The case in question pertains to a dispute over the enforceability of dragnet clauses within mortgages used to secure loans funding Frank Welte’s farming operations. The Vera T. Welte Testamentary Trust, of which Frank Welte is the sole beneficiary, pledged its property as security for these loans, which were provided by Roger Rand, another Iowa farmer. The Trust's primary asset is 160 acres of farmland that were leased to Frank. Upon Rand's death, his estate initiated a foreclosure action against the Trust's farmland. The Trust subsequently filed for chapter 12 bankruptcy, which led to a stay of the foreclosure action against the Trust.The Estate filed a proof of claim and a motion to dismiss the Trust’s bankruptcy petition, alleging that the Trust was not a business trust as required by chapter 12. The Trust objected to the Estate’s proof of claim. The Iowa state court ruled that the dragnet clauses in the mortgage documents secured the loans made to Frank in excess of the face amount of the promissory notes.The United States Bankruptcy Court for the Northern District of Iowa, however, held that the dragnet clauses were not enforceable, thereby concluding that the Trust no longer owed a debt to the Estate. Following this, the United States District Court for the Northern District of Iowa gave preclusive effect to the judgment of the Iowa Court of Appeals concerning the enforceability of the clauses and the amounts owed thereunder.The Trust and the Estate both appealed the district court’s order. The United States Court of Appeals for the Eighth Circuit dismissed the appeal and cross-appeal due to lack of jurisdiction, as the district court's order was not final and required further proceedings in the bankruptcy court. View "The Security National Bank of Sioux City, IA v. Vera T. Welte Testamentary Trust" on Justia Law