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

Tremonti Perry, while incarcerated at Southeast Correctional Center, experienced a severe medical emergency that resulted in him being placed in a medically induced coma for a month. Several years after recovering, Perry filed a lawsuit under 42 U.S.C. § 1983 against the prison's warden, the Missouri Department of Corrections Director, and two medical-care contractors, alleging Eighth Amendment violations due to deliberate indifference to his medical needs. Perry admitted he did not use the prison’s administrative remedy, which required filing a complaint within fifteen days of the incident, but argued that his coma made it impossible to meet this requirement.The Defendants moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6), arguing that Perry had not exhausted his available remedies as required by the Prison Litigation Reform Act (PLRA). They acknowledged that the grievance process was unavailable to Perry during his coma and a reasonable period afterward but contended that Perry should have made a diligent effort to exhaust his claims once he recovered. The district court agreed with the Defendants and dismissed the complaint, concluding that Perry could have filed a grievance after his medical conditions resolved.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The appellate court determined that the prison’s administrative grievance process was unavailable to Perry due to his physical incapacity during the coma and the prison’s rules not allowing late filings. The court rejected the Defendants' arguments that Perry could have filed an untimely grievance or that the grievance deadline was perpetually renewed due to ongoing medical issues. The court also denied the Defendants' motion to supplement the record with new evidence. Consequently, the Eighth Circuit reversed the district court’s dismissal of Perry’s complaint and remanded the case for further proceedings. View "Perry v. Precythe" on Justia Law

Major Brands, Inc., a Missouri-licensed liquor distributor, had been the exclusive distributor of Jägermeister in Missouri since the 1970s. In 2018, Mast-Jägermeister US, Inc. (MJUS) terminated this relationship and appointed Southern Glazers Wine and Spirits, LLC (Southern Glazers) as the new distributor. Major Brands sued MJUS and Southern Glazers, alleging wrongful termination under Missouri franchise law, conspiracy to violate Missouri franchise law, and tortious interference with the franchise relationship.The case was initially brought in state court but was removed to the United States District Court for the Eastern District of Missouri. After dismissing additional defendants, the case proceeded to a jury trial. The jury awarded Major Brands $11.75 million, finding in its favor on five counts, including violation of Missouri franchise law and tortious interference. The district court denied the defendants' motions for judgment as a matter of law or a new trial and awarded attorney’s fees to Major Brands.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court had prejudicially erred in instructing the jury on the essential element of a "community of interest" under Missouri franchise law. The appellate court held that the jury instructions failed to require consideration of whether Major Brands made substantial investments that were not recoverable upon termination, which is necessary to establish a community of interest. Consequently, the Eighth Circuit reversed the district court’s decision, vacated the jury’s verdict and the award of attorney’s fees, and remanded the case for a new trial. View "Major Brands, Inc. v. Mast-Jagermeister US, Inc." on Justia Law

Strategic Energy Concepts, LLC (Strategic) partnered with Otoka Energy, LLC (Otoka) to develop a biomass power plant in California. The plant faced significant operational and financial issues, accumulating $19 million in debt. State Street Bank & Trust Company (State Street) agreed to invest $25 million to help the project, with Strategic transferring its shares in the plant's holding company to Otoka for a conditional payment of $1.1 million, contingent on the availability of funds from State Street's investment. The plant failed to meet operational deadlines and eventually shut down, leading Strategic to receive no payment.The United States District Court for the District of Minnesota dismissed some of Strategic's claims and granted summary judgment on the remaining claims, including breach of contract, tortious interference, and unjust enrichment. Strategic's motions to reopen discovery and for reconsideration were denied, prompting Otoka to dismiss its counterclaims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's summary judgment, finding no genuine issue of material fact. The court held that the conditions precedent for the $1.1 million payment were not met, as the funds from State Street were allocated to other obligations. Additionally, the court found no evidence of tortious interference by State Street, as it acted within its contractual rights and had justification for its actions. The unjust enrichment claim also failed, as there was no impropriety in State Street's conduct.The court also upheld the district court's denial of Strategic's motions to reopen discovery and for reconsideration, concluding that any new discovery would have been futile and that the summary judgment was based on facts existing at the time of the original decision. The judgment of the district court was affirmed. View "Strategic Energy Concepts, LLC v. Otoka Energy, LLC" on Justia Law

Sisters Nikki Mazzocchio and Angela Kraus filed a federal "public liability action" under the Price-Anderson Act (PAA) against several defendants, alleging that exposure to radioactive waste caused them to develop cancer. The waste had been handled by various entities over the years, including Mallinckrodt, Cotter Corporation, and Commonwealth Edison Company. The plaintiffs claimed negligence, negligence per se, strict liability, and civil conspiracy. The defendants moved to dismiss the complaint, arguing that federal law preempted the state-law claims because federal nuclear dosage regulations provide the exclusive standard of care in a public liability action. The district court denied the motions to dismiss, and the defendants appealed.The United States District Court for the Eastern District of Missouri denied the defendants' motions to dismiss, holding that the plaintiffs' state-law claims were not preempted by federal law. The court found that the plaintiffs had adequately pleaded their case under state tort law standards. The defendants then sought and were granted permission to appeal the decision.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court held that state tort law standards of care are not preempted by federal nuclear dosage regulations in a public liability action under the PAA. The court referenced the Supreme Court's decision in Silkwood v. Kerr-McGee Corp., which established that state tort law applies in cases involving nuclear incidents, despite the federal government's exclusive control over nuclear safety regulation. The court also noted that Congress, through the PAA's 1988 amendments, did not repudiate the role of state tort law in such cases. Therefore, the Eighth Circuit concluded that the district court correctly denied the defendants' motion to dismiss, allowing the plaintiffs' state-law claims to proceed. View "Mazzocchio v. Cotter Corporation" on Justia Law

The case involves Western Robidoux, Inc. (WRI), which filed for Chapter 11 bankruptcy while involved in federal litigation. Attorney Daniel Blegen, initially representing WRI and its controlling family members, moved to Spencer Fane LLP. The Chapter 7 Trustee, Jill Olsen, sought to employ Spencer Fane as special counsel for ongoing appeals in the federal litigation. Appellants TooBaRoo, LLC and InfoDeli, LLC, controlled by Breht Burri, opposed this, citing potential conflicts of interest and disproportionate legal fees.The United States Bankruptcy Court for the Western District of Missouri approved the employment of Spencer Fane as special counsel, finding no actual conflicts of interest and emphasizing procedural safeguards for potential future conflicts. The court noted Spencer Fane's expertise and cost-effectiveness. Appellants appealed this decision, arguing that the employment order was improper due to adverse interests and fee concerns.The United States Bankruptcy Appellate Panel for the Eighth Circuit reviewed the appeal. The panel first examined its jurisdiction, determining whether the bankruptcy court's order was final under 28 U.S.C. § 158(a)(1) or reviewable under 28 U.S.C. § 158(a)(3). The panel concluded that the order was not final, as the bankruptcy court retained ongoing responsibilities regarding Spencer Fane's employment and fee applications. Additionally, the panel found that delaying review would not prevent effective relief for the appellants, and a later reversal would not necessitate recommencement of the entire proceeding.The panel also declined to treat the appeal as an interlocutory appeal under 28 U.S.C. § 158(a)(3), agreeing with both parties that the criteria for such review were not met. Consequently, the appeal was dismissed for lack of jurisdiction. View "TooBaRoo, LLC v. Olsen" on Justia Law

Hannah Hekel received a letter from Hunter Warfield, Inc., a debt-collection agency hired by her landlord to collect past-due rent. The letter offered to forgive the debt in exchange for payment of about half of what she owed but included utility fees that may not have been collectible, failed to provide information on how to verify and dispute the debt on the front of the letter, and mentioned an interest rate that was allegedly too high. Hekel claimed these issues violated the Fair Debt Collection Practices Act and alleged harms including procedural injuries, emotional distress, and financial losses.The United States District Court for the District of Minnesota granted summary judgment in favor of Hunter Warfield on all claims. Although the agency mentioned standing as a defense, the district court did not address it.The United States Court of Appeals for the Eighth Circuit reviewed the case and focused on the issue of standing, which is a jurisdictional requirement. The court found that Hekel did not demonstrate a concrete injury. Allegations of statutory violations, informational injuries, risk of future harm, emotional distress, and financial losses were deemed insufficient or too conclusory to establish standing. The court emphasized that without a concrete injury, there is no standing, and without standing, the court lacks jurisdiction.The Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss for lack of jurisdiction. View "Hekel v. Hunter Warfield, Inc." on Justia Law

In 1983, an Arkansas rural electric distribution cooperative, Carroll Electric, entered into a lease agreement with the City of Berryville and constructed a telecommunications tower. In 1994, Carroll Electric subleased the tower to Northwest Arkansas RSA Limited Partnership, allowing them to install and maintain radio communications equipment. The sublease was renewed multiple times, and in 2011, a Second Amendment was added, extending the agreement for additional terms unless terminated with six months' notice. In 2015, Northwest Arkansas was dissolved, and Alltel Corporation became its successor. In 2022, Alltel notified Carroll Electric of its intent to terminate the agreement, effective October 2022.Carroll Electric filed a breach of contract lawsuit in Arkansas state court, alleging wrongful termination. Alltel removed the case to the Western District of Arkansas, citing diversity jurisdiction. The district court granted Alltel's motion to dismiss, concluding that the contract unambiguously allowed Alltel to terminate the agreement. The court also awarded attorney’s fees to Alltel as the prevailing party under Arkansas law.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that the contract provisions were unambiguous and did not conflict. The court held that Section 8(c) of the initial sublease allowed termination with six months' notice, while the Second Amendment dealt with automatic renewal, not termination. The court also upheld the award of attorney’s fees, finding no abuse of discretion by the district court. The judgment of the district court was affirmed. View "Carroll Electric Cooperative v. Alltel Corporation" on Justia Law

In 2022, NavSav Holdings, LLC, a Texas insurance company, acquired Universal Group, Ltd., a Nebraska insurance company. Following the acquisition, NavSav required Universal’s employees to sign noncompete and nonsolicitation covenants, which included Texas choice-of-law and forum-selection clauses. In June 2023, three employees—Austin Michael Beber, Cody Roach, and Jackie Damon—resigned from NavSav and joined a rival company, taking customers with them. NavSav claimed these customers were worth approximately $510,000 in annual premiums.Beber, Roach, and Damon filed lawsuits in Nebraska state court seeking declaratory and injunctive relief, arguing that Nebraska law should apply and the covenants were unenforceable. NavSav filed a lawsuit in Texas state court against the three employees and their new employer, seeking to enforce the covenants under Texas law. The Nebraska cases were removed to the United States District Court for the District of Nebraska, and the Texas case was removed to the United States District Court for the Eastern District of Texas. The Nebraska federal court issued antisuit and preliminary injunctions in favor of the employees, preventing NavSav from litigating in Texas and enforcing the covenants.The United States Court of Appeals for the Eighth Circuit reviewed the case. It vacated the antisuit injunctions for Roach and Damon, affirming only Beber’s antisuit injunction, as his Nebraska case was filed first. The court vacated all preliminary injunctions, finding that the district court erred in its analysis of irreparable harm, which should focus on the individual movants rather than state public policy. The court remanded Beber’s case for consideration of his request for declaratory relief and instructed the district court to evaluate the status of the Texas litigation for Roach and Damon’s cases to determine appropriate actions. The court dismissed NavSav’s appeal regarding the forum-selection clauses for lack of jurisdiction. View "Beber v. Navsav Holdings, LLC" on Justia Law

Officer Blayne Newton of the Kansas City, Missouri Police Department shot and killed Donnie Sanders during a traffic stop. Sanders’s children, Latetia Nunley and Zahleyiah Fielder, filed a lawsuit against Officer Newton under 42 U.S.C. § 1983, alleging a violation of Sanders’s Fourth Amendment right to be free from excessive force. Officer Newton sought summary judgment based on qualified immunity, which the district court denied, citing genuine issues of material fact. Officer Newton appealed the denial of qualified immunity.The United States District Court for the Western District of Missouri denied Officer Newton’s motion for summary judgment, finding that there were disputed facts essential to the analysis of the totality of the circumstances, including the nature of the threats made by Sanders and his level of compliance with commands. The court highlighted discrepancies between Officer Newton’s testimony and the forensic evidence from the autopsy, which suggested that Sanders was shot in a manner inconsistent with Newton’s account of Sanders pointing something at him.The United States Court of Appeals for the Eighth Circuit reviewed the case. Officer Newton argued that the district court erred in denying him qualified immunity and that the excessive-force claim was barred under the Eleventh Amendment. The appellate court dismissed the appeal for lack of jurisdiction, stating that it could not resolve genuine disputes of material fact in favor of the party seeking summary judgment. The court emphasized that the factual record was unsettled and disputed, preventing it from determining whether Newton’s actions were objectively reasonable or whether they violated clearly established law. The court concluded that the district court’s finding of a material factual dispute precluded it from granting qualified immunity at this stage. View "Nunley v. Newton" on Justia Law

Eric Poemoceah, an Oklahoma resident and member of the Comanche Nation, participated in a protest against the Dakota Access Pipeline at the Standing Rock Reservation in North Dakota. On February 22, 2017, while attempting to negotiate with law enforcement officers for the peaceful exit of elders from the protest site, Poemoceah was tackled and arrested by officers, including Benjamin Swenson. He sustained injuries, including a pelvic fracture, and was charged with obstruction of a government function, a charge that was later dismissed.The United States District Court for the District of North Dakota dismissed Poemoceah’s complaint with prejudice, granting the defendants' motions to dismiss. The court found that the defendants were entitled to qualified immunity on the First and Fourth Amendment claims and dismissed the remaining claims as inadequately pled. Poemoceah’s request for leave to amend his complaint was also denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Poemoceah plausibly alleged a Fourth Amendment excessive force claim against Swenson, as the facts suggested that Swenson's use of force was not objectively reasonable. However, the court affirmed the dismissal of Poemoceah’s deliberate indifference to medical needs claim, First Amendment retaliation claim, supervisory liability claims, Monell claim against Morton County, and the intentional infliction of emotional distress claim under North Dakota law. The court also found no abuse of discretion in the district court’s denial of Poemoceah’s motion to amend his complaint. The case was affirmed in part, reversed in part, and remanded for further proceedings on the Fourth Amendment claim against Swenson. View "Poemoceah v. Morton County" on Justia Law