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

WPX Energy, a non-Indian oil and gas company, obtained rights-of-way from the Bureau of Indian Affairs to access land owned by members of the Three Affiliated Tribes on the Fort Berthold Reservation. The Fettigs, tribal members and landowners, consented to the grants and also entered into side letter agreements with WPX Energy, imposing conditions such as prohibiting smoking and hunting, and specifying fines for violations. In 2020, the Fettigs filed suit in the Three Affiliated Tribes District Court, alleging WPX Energy violated the no-smoking provision. WPX Energy argued that the tribal court lacked jurisdiction, as it is a non-Indian entity, but the tribal district court, through Judge Jones, found it had jurisdiction under the Montana consensual relationship exception. The Fettigs also pursued an administrative claim with the Bureau, which was denied on the basis that the side letter agreements were not incorporated into the grants.WPX Energy sought a preliminary injunction in the United States District Court for the District of North Dakota, claiming the tribal court lacked jurisdiction. The district court granted the injunction, but the United States Court of Appeals for the Eighth Circuit previously vacated it, requiring exhaustion of tribal remedies. After the Three Affiliated Tribes Supreme Court affirmed tribal jurisdiction, WPX Energy again sought relief in federal court, which again granted a preliminary injunction. Judge Jones appealed this second grant.On review, the United States Court of Appeals for the Eighth Circuit held that the tribal court had jurisdiction under the first Montana exception because the dispute arose from a commercial relationship created by the side letter agreements, which were independently negotiated and not governed by federal law. The court also found that normal litigation costs did not constitute irreparable harm. The Eighth Circuit vacated the preliminary injunction and remanded for further proceedings. View "WPX Energy Williston, LLC v. Jones" on Justia Law

Sonia Breslow purchased a $250,000 watch from Jacob & Company, which was shipped from New York to the Iron Horse Golf Club in Montana. The Club repackaged the shipment and sent it via Federal Express (FedEx) “priority overnight” to a UPS store in Arizona. The shipping label did not declare a value for the package. Video evidence showed that after FedEx took possession, the yellow bag containing two boxes was no longer secured by a zip tie, and at the Scottsdale facility, an employee removed one box from the bag. Ultimately, FedEx delivered the bag to the UPS store, but the watch was missing. Sonia filed an insurance claim, and Pennsylvania Insurance paid the Breslows the purchase price, then sued FedEx as their subrogee.Pennsylvania Insurance initially brought claims for negligence, conversion, unjust enrichment, breach of contract, and civil theft in Nebraska state court. FedEx removed the case to the United States District Court for the District of Nebraska. The district court ruled that the Airline Deregulation Act preempted the claims for negligence, unjust enrichment, and civil theft, dismissed the conversion claim for lack of evidence, and found breach of contract but limited FedEx’s liability under the shipping contract to $100. The case proceeded to a bench trial, where the court found the breach and upheld the liability limit, entering judgment for Pennsylvania Insurance in the amount of $100.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s rulings. The court held that the Airline Deregulation Act preempts state-law claims relating to FedEx’s package handling and transportation services. It found no error in the district court’s dismissal of the conversion claim and upheld the liability limit of $100, concluding that the Club had adequate notice and opportunity to purchase greater coverage. The court also affirmed that Pennsylvania Insurance had standing as subrogee and that FedEx breached the contract. View "Pennsylvania Insurance Co. v. Federal Express Corp." on Justia Law

A municipal corporation operating a large regional commuter rail system in the Chicago area provided rail service on lines owned by a freight rail company. For decades, this service was conducted under a series of agreements, but in 2019, the freight rail company announced it would cease operating the commuter trains. Following litigation, the freight company obtained a declaratory judgment that it had no ongoing obligation to provide such service. While the commuter rail operator began transitioning to run the service itself, the parties failed to reach agreement on compensation for continued use of the lines. With no long-term agreement in place and negotiations at an impasse, the commuter rail operator applied to the federal Surface Transportation Board for terminal trackage rights, which would allow it to use the lines despite the lack of agreement.The Surface Transportation Board granted the application, finding the lines to be terminal facilities for a reasonable distance from the terminal, and that the use would be practicable, in the public interest, and not substantially impair the freight carrier’s operations. The Board did not set compensation or use conditions at that time but pledged to do so retroactively if the parties could not agree. The freight rail company sought review of this decision in the United States Court of Appeals for the Eighth Circuit.The Eighth Circuit held that the Board acted within its statutory authority in granting terminal trackage rights to the commuter operator, including over the full extent of the lines at issue, and properly concluded the public interest was served. However, the court found that the Board erred by granting immediate rights without first ensuring that compensation was paid or adequately secured, as required by statute. The court vacated the Board’s order and remanded for further proceedings, allowing time for the parties to address compensation. View "Union Pacific Railroad Company v. STB" on Justia Law

After purchasing a trucking company through an asset purchase agreement, Jim Daws Trucking, LLC (JDT) alleged that the sellers—James and Lana Daws, Daws, Inc., and other affiliated entities—violated the APA’s noncompete provision by engaging in competing trucking operations. The APA included a $12 million purchase price, with $4.5 million allocated to goodwill, and a five-year noncompete clause barring the sellers from participating in trucking nationwide. After the relationship between Jim Daws and JDT deteriorated, Jim Daws left JDT and communicated with former employees about starting new trucking ventures, allegedly causing JDT to lose significant personnel and drivers.The United States District Court for the District of Nebraska granted a temporary restraining order, then a preliminary injunction, prohibiting Jim Daws and associates from engaging in trucking or advising new trucking companies nationwide, except for operating certain pre-existing businesses. The district court determined that the noncompete provision was valid and enforceable under Nebraska law, that JDT was likely to prevail on its breach of contract claim, and that irreparable harm existed due to loss of goodwill. The district court also ordered Jim Daws to release $500,000 in funds from an account used for JDT’s operations and set a $480,000 bond based on potential lost revenue.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of the preliminary injunction, the order to release funds, and the bond amount. The appellate court affirmed the district court’s decisions, holding that the noncompete provision was reasonable in scope and duration given the sale of goodwill and the nature of the trucking business. The court found no clear error in the district court’s factual findings, no abuse of discretion in ordering the release of funds as injunctive relief, and no abuse of discretion in setting the amount of the bond. View "Jim Daws Trucking, LLC v. Daws, Inc." on Justia Law

Two individuals, both former members of several Missouri limited liability companies operating as a commercial insurance brokerage, entered into contracts with their company containing Missouri choice-of-law and forum-selection clauses, as well as customer non-solicitation covenants. The agreements required members to follow certain operating agreements, which included a provision allowing termination of membership interests upon 30 days’ notice. Despite this, both individuals resigned “effective immediately” and began working for a competitor. The company sued them in federal court in Missouri to enforce the contractual terms, while the former members filed lawsuits in California state court seeking to void the agreements.The United States District Court for the Western District of Missouri granted summary judgment for the company on the enforceability of the Missouri forum-selection and choice-of-law clauses, finding the individuals breached the forum-selection clauses by suing in California. The court also found the customer non-solicitation covenants enforceable to the extent the company sought to enforce them. However, it granted summary judgment to the former members on claims that they breached the notice provision and related fiduciary duties, and on certain other contract and tort claims. The court awarded the company attorneys’ fees for the Missouri litigation but only nominal damages for the forum-selection clause breaches, declining to award fees incurred in the California actions.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings on the enforceability of the choice-of-law and forum-selection clauses, as well as the customer non-solicitation covenants. It reversed the findings on the notice provision and fiduciary duty, holding these were breached, and directed entry of judgment for the company on those claims. The court vacated the nominal damages for the forum-selection clause breaches, instructing the district court to determine actual damages, and affirmed the attorneys’ fee awards to the company. The case was remanded for further proceedings consistent with these holdings. View "West Series of Lockton Companies, LLC v. Kaufman" on Justia Law

In 2018, BAPTKO, Inc., wholly owned by Robert Kupper, agreed to sell two car dealerships in North Dakota to Foundation Automotive Corp. The agreement included provisions regarding inventory management prior to closing, contingent earnout payments based on dealership performance, and an attorney’s fees clause for prevailing parties in disputes. Foundation Automotive Corp. later assigned its interests to two LLCs connected to each dealership. After the sale, relations deteriorated: the LLCs sued Kupper and related entities for breach of non-compete and tortious interference, while BAPTKO counterclaimed for unpaid earnout payments, asserting the performance targets had been met.The United States District Court for the District of North Dakota consolidated the actions. It granted partial summary judgment for the Kupper parties, holding that the Foundation parties were obligated to make the earnout payments. The district court denied summary judgment on the amount of damages, finding factual disputes. The Foundation parties conceded nonpayment but argued they were excused due to BAPTKO’s alleged prior breaches, particularly regarding inventory management. The district court rejected this argument, determining that any such breaches did not excuse performance but might affect the damages offset. At trial, the jury found BAPTKO had not breached the agreement. The district court also awarded attorney’s fees to BAPTKO, including amounts spent defending Kupper personally, and denied the Foundation parties’ post-trial motions.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s rulings. The appellate court held that the district court properly granted partial summary judgment, concluding that no reasonable jury could find BAPTKO’s alleged breaches defeated the object of the agreement. The appellate court also held that limitations on expert testimony and jury instructions were not abuses of discretion, and that the attorney’s fee award, including amounts for Kupper’s defense, was supported by the agreement and not an abuse of discretion. View "FA ND Chev, LLC v. BAPTKO, Inc." on Justia Law

The dispute centers on mineral rights to a property in McKenzie County, North Dakota. In 1938, the county acquired the property from Ellen Stole through foreclosure. In 1948, the county leased mineral rights—the “County Lease”—to Thomas Dorough, granting extraction rights in exchange for royalties. Hans Stole, Ellen’s son, redeemed the property in 1951, terminating the county’s ownership, and in 1954 ratified the County Lease as it pertained to his interest. There has been continuous mineral production since 1957. The Rolfsruds acquired the property in 2002 and entered new leases in 2007 and 2019—the latter (“Rolfsrud Lease”) granting higher royalties and naming Davis Exploration as lessee. Continental Resources operated under both leases, ultimately paying royalties at the lower County Lease rate. The Rolfsruds, joined by Davis Exploration, sued Continental and Petro-Hunt, asserting the Rolfsrud Lease controlled the property and raising several claims, including breach, quiet title, and declaratory relief.The United States District Court for the District of North Dakota granted summary judgment to the defendants. The court relied on Ulrich v. Amerada Petroleum Corporation and Holbeck v. Hull from the North Dakota Supreme Court, finding the County Lease had priority. The court determined the Rolfsrud Lease was a “top lease” and quieted title in favor of Petro-Hunt’s interest under the County Lease.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. It held the County Lease became voidable—not void—upon redemption, and Hans’s ratification was valid as to the property he owned. The court further held continuous production under the County Lease sustained its force, despite no Pugh clause or lack of production on the specific property. The Eighth Circuit affirmed the district court’s judgment, holding the County Lease controls the subject property and the Rolfsrud Lease is a top lease. View "Rolfsrud v. Continental Resources, Inc." on Justia Law

Matthew Goforth, through MG Management Co., LLC, entered a dealer agreement with Sears Authorized Home Stores that included a broad non-compete provision, extending restrictions to his spouse, Malinda Goforth. After Matt decided not to renew the agreement, Sears suspected the Goforths would open a competing business and initiated arbitration, seeking to enforce the non-compete. The Goforths opposed enforcement, asserting the provision was unreasonable. The arbitrator initially denied emergency injunctive relief but later, upon learning that Matt and Malinda were opening Goforth Home & Lawn, granted interim relief enforcing the non-compete and added Malinda and her company as parties. A final arbitration award enforced the non-compete, but an appellate arbitrator later held the provision unenforceable while affirming attorneys’ fees to Sears. Subsequently, the Goforths initiated a second arbitration alleging antitrust violations, but the arbitrator determined their antitrust claims were compulsory counterclaims that should have been brought in the first arbitration.Following Sears’s bankruptcy, the Goforths brought an action in the United States District Court for the Western District of Missouri against Sears’s owners, Transform Holdco, LLC and affiliates, asserting the same antitrust claims. Transform moved for summary judgment, arguing the claims were compulsory counterclaims barred by their failure to raise them in the initial arbitration. The district court agreed, holding the claims accrued upon Sears’s initiation of the first arbitration and were thus subject to compulsory counterclaim rules. The court granted summary judgment for Transform and did not address alternative grounds or the Goforths’ partial summary judgment motion.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the Goforths’ antitrust claims accrued when Sears initiated the first arbitration, making them compulsory counterclaims under Federal Rule of Civil Procedure 13. The court also held that Malinda and her company were bound by the agreement’s arbitration provision. View "Goforth v. Transform Holdco, LLC" on Justia Law

A technology company developed a healthcare revenue management software platform and, in 2014, licensed a white-labeled version to a bank. The bank branded this software as its own and used it to provide services to its customers. The licensing agreement gave the bank access to confidential software and data, while prohibiting reverse engineering, copying, or creating derivative works. In 2018, the bank began developing its own software that performed similar functions. The technology company later noticed a decline in users of its platform and suspected the bank had breached the contract by reverse engineering and copying its software. The company then sought a preliminary injunction to stop the bank from using its new platform and from misusing the information gained through the contract.The United States District Court for the Western District of Missouri reviewed the request for a preliminary injunction. The district court found that the technology company failed to show that it would suffer irreparable harm absent injunctive relief, ruling that any potential financial losses could be compensated with money damages and that claims of reputational harm were too speculative. The court also determined that the contract’s clause permitting injunctive relief was not, by itself, sufficient to require an injunction.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that the district court did not clearly err in finding the alleged harms compensable with money damages or too speculative, nor did it abuse its discretion by giving limited weight to the contract’s injunctive relief provision. The court emphasized that failure to demonstrate likely irreparable harm is, by itself, a sufficient ground to deny a preliminary injunction. Accordingly, the denial of the preliminary injunction was affirmed. View "RMS v. Commerce Bank" on Justia Law

A dairy operator in Northeast Missouri leased thousands of acres of adjacent forage land from a landowner to grow feed for its cattle and manage waste under regulatory requirements. The lease included provisions for renewal at a market rental rate and an agreement for the eventual sale of the leased and surrounding acreage to the dairy, with fair market value to be established by appraisal if necessary. The dairy alleged that the landowner breached the lease by unilaterally raising rent, demanding an unfavorable addendum, and refusing to complete the agreed land sales, while the landowner asserted that the dairy breached by not signing the addendum and threatened eviction.The United States District Court for the Eastern District of Missouri granted the dairy’s request for injunctive relief, enjoining the landowner from evicting or otherwise interfering with the dairy’s possession of the leased land. The landowner appealed, arguing lack of adequate notice and opportunity to be heard, as well as contesting the enforceability of the lease and the propriety of the injunction.The United States Court of Appeals for the Eighth Circuit first determined it had jurisdiction, treating the lower court order as a preliminary injunction rather than a temporary restraining order, based on its duration and effect. The appellate court held that the landowner waived or forfeited its due process objections by not raising them below. On the merits, the court found the dairy had a fair chance of prevailing on its contract claims, including the enforceability of the land-sale provision and compliance with notice requirements. The court further concluded that the dairy faced irreparable harm due to threatened loss of unique land, that the balance of harms favored the dairy, and that the public interest did not weigh against the injunction. The Eighth Circuit affirmed the district court’s issuance of the preliminary injunction. View "La Belle Dairy, LLC v. Sharpe Holdings, Inc." on Justia Law