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

The Eighth Circuit affirmed the district court's denial of plaintiff's motion for leave to amend and granted summary judgment dismissing plaintiff's sole claim remaining on remand -- that American Century breached the implied covenant of good faith and fair dealing by taking discretionary action to retaliate in violation of public policy. The court held that the Supreme Court of Missouri's decision in Bishop & Assocs., LLC, v. Ameren Corp., 520 S.W.3d 463 (Mo. banc. 2017), limits plaintiff's claim for breach of American Century's implied covenant of good faith and fair dealing to the "reasonable expectation" ground that was dismissed with prejudice in Kmak I. The court also held that the district court did not abuse its discretion in determining that plaintiff failed to show good cause to amend. View "Kmak v. American Century Co." on Justia Law

The Eighth Circuit affirmed summary judgment for tenant in a suit filed by landlord for breach of a terminated lease agreement and waste under Iowa law. The court held that, under section 26.01 of the lease agreement, the sole remedy was lease termination. Therefore, landlord could not recover the alleged contract damages. Furthermore, landlord's claim for waste failed because the parties expressly contracted for that liability in sections 6.06 and 26.01 of the lease. View "Davenport Chester, LLC v. Abrams Properties, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in an action filed by LNV against OSM to recover its share of sales proceeds from a promissory note. The court held that the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 (FIRREA), 12 U.S.C. 1821, barred the district court from exercising jurisdiction over OSM's counterclaim; post-receivership claims and claims arising after the claims-bar date were subject to exhaustion; OSM's alleged common-law defense for not paying LNV the net proceeds was ineffective because the contract addressed LNV's alleged prior material breach and OSM must comply with the contract; there was no right of setoff and thus BF-Negev breached the Bahia Agreement by withholding LNV's share of collections; and the court declined to exercise its discretion by reversing the district court's attorney fee award. View "LNV Corp. v. Outsource Services Management, LLC" on Justia Law

Plaintiff filed suit against defendants, alleging claims of breach of fiduciary duty, breach of contract, and negligence. The Eighth Circuit affirmed the district court's motion to dismiss the breach of contract and negligence claims because plaintiff failed to plead sufficient facts to state a plausible claim for breach of contract or negligence. In this case, the language of the policy was unambiguous in describing what the parties intended their contract to be—the policy itself and the written application for the policy. Because the loan forms plaintiff relied on to support the breach of contract claim were not part of the insurance policy, the claim failed. Likewise, the negligence claim failed because it relied on the loan forms being part of the insurance contract. View "Torti v. John Hancock Life Insurance Co." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for CIC on the Trust's claims for breach of contract, vexatious refusal, and declaratory judgment. The court held that the district court properly afforded the appraisal provision its plain meaning in determining it was unambiguous, enforceable, and did not abridge the Trust's rights under Missouri's vexatious refusal statute; the district court properly concluded CIC did not waive the appraisal provision; the Trust's contention that there was no basis for the district court to order appraisal of all covered damages, including replacement cost, was unfounded; the district court committed no error in finding the Trust's breach of contract claim failed as a matter of law; and the district court properly granted CIC summary judgment on the Trust's vexatious refusal claim. View "Olga Despotis Trust v. Cincinnati Insurance Co." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to JRMC in this breach of contract suit and the district court's subsequent award of $64,931.81 to JRMC. The court held that the documents executed in connection with defendant's employment at JRMC should be considered separately: the Recruitment Agreement and the Employment Agreement; defendant's obligation to pay the remaining debt under a promissory note was not excused by his allegations of fraud or breach of the duty of good faith, as well as breach of contract and personal injury; the terms of the note control and the note provided that defendant agreed to pay all costs and expenses incurred by JRMC in connection with the collection and enforcement of the note; and the district court did not abuse its discretion with respect to the award of attorney's fees. View "Johnson Regional Medical Center v. Halterman" on Justia Law

Bank of America filed suit against the Hanna Parties for breach of contract after they failed to pay a loan. The jury found that the Hanna Parties did not breach the contract and the district court entered judgment for them. On remand, the Hanna Parties advanced defenses of fraudulent inducement and fraudulent failure to disclose. The Eighth Circuit affirmed the district court's grant of the Bank's motion for summary judgment on those defenses because JB Hanna could not have reasonably relied on the Bank's allegedly fraudulent representations. In this case, the district court correctly rejected the defenses of fraudulent inducement and fraudulent failure to disclose as a matter of law. Furthermore, because there was insufficient evidence to support the fraud defenses, the setoff defense also failed. View "Bank of America v. JB Hanna, LLC" on Justia Law

Paris Limousine filed suit against Executive Coach, alleging that limousines it purchased from Executive Coach were in breach of warranty. The Eighth Circuit reversed the district court's dismissal of the complaint, holding that Paris Limousine brought its express warranty claim under Missouri law, which authorizes private enforcement actions for breaches of express warranties. The National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act), 15 U.S.C. 1381 et seq., and the Federal Motor Vehicle Safety Standards did not affect Executive Coach’s potential liability under Missouri law for breach of its express warranty. The court also held that Executive Coach had not met its burden to demonstrate that conflict preemption applied, and that Paris Limousine had alleged legally cognizable damages. View "Paris Limousine of OK, LLC v. Executive Coach Builders, Inc." on Justia Law

After Enerplus mistakenly overpaid mineral royalties to defendant and demanded repayment, defendant filed suit in tribal court. Enerplus then filed suit in federal court, seeking the return of the excess funds and a declaration that the tribal court lacked jurisdiction over the dispute. The Eighth Circuit affirmed the district court's decision to preliminarily enjoin defendant from proceeding with his case in tribal court. In this case, the contracting parties agreed that any disputes arising under the settlement agreement would be resolved in federal district court. Therefore, defendant could not bring suit arising from or related to the settlement agreement in the tribal court based on the forum selection clause. The court rejected defendant's bare assertion that Enerplus lacked standing to enforce the forum selection clause. View "Enerplus Resources (USA) Corp. v. Wilkinson" on Justia Law

The Eighth Circuit affirmed the district court's holding that an independent-contractor agreement's noncompete provision was unreasonable and therefore unenforceable. Without controlling precedent from the Iowa Supreme Court, the court predicted that the Iowa Supreme Court would hold that the enforceability of a noncompete provision was a question for the court. In this case, plaintiff developed his own customer base and received only minimal support from Ag Spectrum. The court explained that requiring plaintiff to forsake the customers that he brought to Ag Spectrum as an independent contractor was unreasonable in the circumstances, and plaintiff's business activity fostered fair competition in the marketplace, not unjust enrichment. View "Ag Spectrum Co. v. Elder" on Justia Law