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

Ascente filed suit against Digital River for Minnesota contract, fraud, and fraud-adjacent claims. Ascente's claims arose after it hired Digital River to build a customer-facing web portal and the portal fell below Ascente's expectations.The Eighth Circuit affirmed the district court's denial of Ascente's motion to amend its fraud and reckless-misrepresentation claims where amendment would be futile. The court concluded that there was no error in granting summary judgment on the contract claims where Ascente failed to raise a triable issue of fact regarding whether Digital River breached its purported duties. The court also concluded that there was no error in granting summary on the fraudulent inducement claim where Ascente failed to raise a triable issue of fact regarding its actual reliance. View "Ascente Business Consulting, LLC v. DR myCommerce" on Justia Law

The Eighth Circuit affirmed the district court's award of $283,609.15 in attorneys' fees to Manning in this action arising out of a contract dispute between Kinder, a general contractor, and Manning, a subcontractor.The court concluded that the district court properly applied Arkansas state law to decide the matter because the issue of attorneys' fees is a procedural matter governed by Arkansas law. The court also concluded that the subcontract's silence as to Manning's ability to recover attorneys' fees as the prevailing party does not operate as a waiver of its right to recover such fees under Ark. Code Ann.16-22-308. The court further concluded that because the requested attorneys' fees were incurred by Manning, Manning's recovery of such attorneys' fees is not prohibited under Ark. Code Ann. 23-79-208. View "Randy Kinder Excavating, Inc. v. JA Manning Construction Company, Inc." on Justia Law

CRST filed suit alleging that Swift wrongfully recruited and hired long-haul truck drivers who were "under contract" with CRST. Ruling on post-verdict motions, the district court upheld the intentional interference with contracts award, vacated the unjust enrichment award because it was predicated on a theory of damages rejected in the court's summary judgment rulings, and remitted the punitive damages to $3 million.The Eighth Circuit reversed the district court's post-verdict order upholding the intentional interference verdict because it relied upon CRST's theory of liability that the court rejected in CRST Expedited, Inc. v. TransAm Trucking, Inc., 960 F.3d 499 (8th Cir. 2020). The court explained that the proper focus is on intentionally and improperly causing the employee to violate his or her covenant not to compete, not merely on the hiring of a competitor's at-will employee to further the actor's legitimate competitive interests. After careful review of the record, the court concluded that it must reverse with instructions to dismiss because, for multiple reasons, CRST failed to prove its interference with contract claim and therefore its claim for unjust enrichment as well. The court affirmed the amended judgment in favor of Swift on CRST's unjust enrichment claim. View "CRST Expedited, Inc. v. Swift Transportation Co." on Justia Law

The Eighth Circuit affirmed the district court's order granting summary judgment to Agrifund on the conversion claim Agrifund brought against Heartland. The court concluded that Heartland failed to exercise reasonable commercial standards of fair dealing, and Heartland does not qualify as a holder in due course. In this case, it would have taken minimal effort for Heartland to confirm, whether with the borrowers or with Agrifund, that Agrifund had been fully recompensed before accepting the payment at issue.The court also concluded that the Subrogation Agreement did not bind Heartland to the terms of the Note; the 14% contractual interest rate does not apply to the damages award; and the district court properly awarded pre-judgment interest at the rate required by Iowa law and post-judgment interest at the federal rate. Finally, the court concluded that Heartland is not liable for attorney fees as set forth in the Note, and there is no abuse of discretion in the district court's decision to deny Agrifund's request for attorney fees. Accordingly, the court affirmed the district court's award of damages and attorney fees. View "Agrifund, LLC v. Heartland Co-op" on Justia Law

Plaintiffs, two couples who entered into multiple timeshare contracts with Wyndham, filed suit against Wyndham, alleging various improper trade practices under Missouri law. Wyndham counterclaimed for breach of contract. Plaintiffs' claims were dismissed and the district court granted summary judgment in favor of Wyndham on its counterclaim.The Eighth Circuit affirmed, concluding that the notice of appeal confers appellate jurisdiction over the district court's grant of summary judgment. On the merits, the court concluded that plaintiffs ratified their contracts with Wyndham and thus cannot assert duress as a defense. Furthermore, even assuming that the couples did not ratify their contracts and waive the duress defense, the facts show that neither couple was prevented from exercising their free will. Finally, the court concluded that none of Wyndham's alleged misrepresentations rise to the level of fraudulent misrepresentation. View "Kohlbeck v. Wyndham Vacation Resorts, Inc." on Justia Law

Pepsi previously granted Mahaska exclusive rights to distribute bottles and cans of certain Pepsi products in identified territories. Pepsi also granted Mahaska limited rights to distribute fountain syrup products in identified territories. The claims and counterclaims in this case arose out of these agreements. After a jury trial, the jury returned a split verdict. The jury awarded Mahaska a total of $2,956,540.10 in damages and Pepsi a total of $24,000 in damages. Pepsi filed a motion for a new trial asserting a number of claims, including that Mahaska's closing arguments were improper and prejudicial. The district court denied Pepsi's motion and Pepsi appeals only the closing argument issue.The Eighth Circuit affirmed, concluding that the comments Pepsi challenges, either alone or together, did not so infect the trial with the type of impropriety that would make a new trial appropriate. In this case, the court grouped Pepsi's claimed improper statements into a five categories: (1) statements regarding Mahaska's survival; (2) statements referencing Pepsi's size; (3) statements allegedly encouraging local bias; (4) statements denigrating Pepsi's defenses and counterclaims and its witnesses' credibility; and (5) statements related to punishment, sending signals, or malice. The court explained that, while portions of Mahaska's closing argument were hyperbolic and other portions perhaps approached the line for permissible argument, Pepsi's failure to object during or after the closing argument is some indication that the multitude of statements deemed improper weeks after the jury returned its verdict were not viewed by Pepsi's counsel as prejudicial or improper when they were made in context before the jury. Furthermore, the statements raised by Pepsi on appeal were based on evidence presented during trial or reasonable inferences that could be drawn from the evidence. View "Mahaska Bottling Co. v. Pepsico, Inc." on Justia Law

This appeal arose out of a construction dispute between Timber Ridge and Quality Structures. After a bench trial, the district court awarded Timber Ridge $22,500 in damages and Quality Structures an amount in excess of $5 million in damages.The Eighth Circuit affirmed, concluding that the district court did not clearly err in determining that Quality Structures substantially complied with the contractual predicates for payment for the extra excavation work. Furthermore, the district court did not clearly err in finding Quality Structures proved damages related to Timber Ridge's failure to pay for the additional excavation work. The court affirmed the district court's award of other damages to Quality Structures with one exception regarding site lighting. Finally, the court concluded that the district court did not err in awarding defendant attorneys' fees under the Missouri Prompt Payment Act. View "Timber Ridge Escapes, LLC v. Quality Structures of Arkansas, LLC" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of PepsiCo in an action brought by Northern, alleging that PepsiCo failed to protect Northern's interests under their exclusive bottling contracts. Applying New York common law, the court concluded that it is evident PepsiCo did not owe a duty to prevent transshipping under the express terms of the bottling contracts, and thus Northern's breach claim fails as a matter of law. The court also concluded that Northern cannot rely on an implied duty to create obligations that are not expressly included in the bottling contracts, and that duty cannot provide a basis for Northern's breach of contract claim.Furthermore, because the bottling agreement is unambiguous and fails to confer a contractual duty on PepsiCo to prevent transshipping, and given Northern's inability to establish that PepsiCo owed a duty to prevent transshipment of products into Northern's territories, there is no genuine dispute of material fact and Northern's breach of contract claim was properly disposed of on summary judgment. Finally, the court agreed with the district court that no genuine dispute of material fact exists as to Northern's tortious interference claim. View "Northern Bottling Co., Inc. v. PepsiCo, Inc." on Justia Law

The Eighth Circuit affirmed the district court's dismissal of an action brought by Smart against the County, based on the forum-selection clause in the parties' contract. The district court determined that the clause precluded Smart from suing the County in federal court and dismissed the case.The court explained that the ordinary understanding of "Arkansas courts" refers to courts that are constituted under the Arkansas state government, not any court that happens to be within Arkansas's borders. Furthermore, the word "pertinent" does not alter the meaning of "Arkansas courts," as Smart suggests. In this case, both the forum-selection clause and the anti-removal provision in the contract are clear, and they obviate the need to resort to the rule against surplusage. View "Smart Communications Collier Inc. v. Pope County Sheriff's Office" on Justia Law

In this dispute over waste-removal services, the Eighth Circuit reversed the district court's dismissal with prejudice of Pietoso's complaint against Republic Services and Allied Services. The court could not conclude at this stage that Pietoso's invoice payments manifested its consent to paying Optional Reason increases. Therefore, it cannot yet be decided that defendants did not breach the Agreement by imposing Optional Reason increases without Pietoso's consent. Therefore, the district court erred in concluding otherwise and in deciding that Pietoso's allegations failed to state a claim for breach of contract. The court remanded for further proceedings. View "Pietoso, Inc. v. Republic Services, Inc." on Justia Law