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

Plaintiffs Lenny and Tracy Chapman filed suit against Hiland after an explosion seriously injured Lenny, alleging negligence and loss of consortium. Hiland then filed a third-party complaint against Missouri Basin and B&B, seeking indemnification. In this appeal, Missouri Basin challenged the district court's grant of summary judgment to plaintiffs and the district court's ruling on post-judgment motions. The Eighth Circuit held that honoring the Oklahoma choice-of-law provision in the Hiland Master Service Contract did not violate a fundamental public policy of North Dakota because it was not a motor carrier transportation contract under North Dakota law. The court also held that the district court did not abuse its discretion by granting plaintiffs' Fed. R. Civ. P. 59(e) motion where the district court clarified that by using the language "all amounts that have been paid or will be paid," Missouri Basin intended that it indemnify plaintiffs for the full amount of the settlement, including those amounts paid by Hiland's insurers. Furthermore, the district court did not abuse its discretion by denying Missouri Basin's Rule 59(e) motion. View "Chapman v. Missouri Basin Well Service" on Justia Law

Stine Seed filed suit against A&W and its principles, alleging contract claims related to A&W's failure to pay for corn and soybeen seed. The district court found in favor of Stine Seed on its implied-in-fact contract claim against Defendant Williams in the amount of $28,160, and found in favor of Williams and A&W on the remaining claims. The Eighth Circuit affirmed in part and held that the district court did not clearly err in finding that Williams did not sign the July Adjustment and in finding Williams' version of events credible; no implied-in-fact contract existed between Williams and Stine Seed with respect to the seed planted by J&A; and the district court did not err in finding Williams not liable for unjust enrichment. The court held, however, that the district court should have given A&W's admission that Alexander had apparent authority conclusive effect, and its finding that Alexander lacked authority to bind A&W to the Note was clear error. Therefore, the verdict in favor of A&W on Stine Seed's breach of contract claim must be reversed and remanded. View "Stine Seed Co. v. A & W Agribusiness, LLC" on Justia Law

The Eighth Circuit affirmed the district court's order compelling arbitration and dismissing plaintiff's case without prejudice where he alleged violations of minimum wage laws, as well as fraud. In this case, plaintiff signed a Volunteer Release, Waiver and Indemnification Agreement when he volunteered as a concession worker for a fundraiser. The court held that the agreement was not unconscionable under Missouri law because the agreement was easy to understand, with no evidence that it was non-negotiable. Furthermore, the agreement did not lack consideration where the consideration was that plaintiff was giving up his right to sue in return for his opportunity to volunteer and DNCS's contribution to Washington University, something neither was legally bound to do. Finally, the underlying factual allegations were covered by the arbitration provision. View "Leonard v. Delaware North Companies Sport Service, Inc." on Justia Law

Plaintiff filed suit against his former employer, NCC, for breach of contract and alleging claims under the Nebraska Wage Payment and Collection Act. Applying Nebraska's two-part test to determine whether an agreement was voidable as a product of duress, the court held that there was, at least, a genuine issue of material fact as to whether the threat of termination would support a claim of duress. Therefore, the court remanded for a determination of this factual issue. The court also held that, considering all relevant circumstances then existing and viewing the facts in the light most favorable to plaintiff, the Term Sheet was unjust and thus voidable as a product of duress given the alleged pressure brought to bear on him to sign the Mutual Rescission and Term Sheet. Therefore, the district court erred by granting summary judgment for NCC on the breach of contract claim. Likewise, the district court erred in granting summary judgment for NCC on the state law claim. View "Gilkerson v. Nebraska Colocation Centers" on Justia Law

Class representatives challenged the district court's denial of their motion to enforce the settlement agreement in a securities settlement, and the district court's denial of a subsequent motion to alter or amend. The Eighth Circuit affirmed the district court's judgment and denied defendants' motion to dismiss. The court explained that this case continues to present a live controversy and the Stipulation explicitly granted that the district court would have continuing jurisdiction for the purposes of enforcing the agreement and addressing settlement administration matters. The court also held that the case was not prudentially moot where the district court has the ability to provide an effective remedy; the district court did not err in interpreting the Stipulation according to its unambiguous meaning and in holding that defendants complied with the Stipulation's payment obligations; and the district court did not err by holding that the meaning of the Stipulation was unambiguous as matter of law and, in doing so, the district court did not place a burden of proof on any party. View "Cromeans v. Morgan Keegan & Co." on Justia Law

Plaintiff filed suit against Scottsdale for coverage under a Business and Management Indemnity Policy. The Eighth Circuit affirmed the district court's grant of summary judgment to Scottsdale, holding that Food Market presented no evidence providing notice over seven months was "as soon as practicable." Where, as here, notice is a condition precedent to coverage, a showing of prejudice was not required. Finally, the district court properly found the policy unambiguous; Scottsdale expressly relied on the notice provision when denying coverage; and there was no waiver. View "Food Market Merchandising v. Scottsdale Indemnity" on Justia Law

Plaintiffs filed a class action against the Pegasus Pipeline's current owners and operators, Exxon, alleging that the company's operation of the pipeline was unreasonable and unsafe. The Eighth Circuit agreed with the district court's decision to decertify the class based on a lack of commonality of issues. In this case, the contract claims would require examination of how Exxon's operation of the pipeline affects plaintiffs, which varies depending on where individual class members' property was located, as well as many other factors. The Eighth Circuit also concluded that the evidence here was insufficient to raise a genuine issue of material fact as to whether there was unreasonable interference. The court explained that the question of unreasonable use of an easement was generally one of fact, dependent on the nature of the easement, the terms of the grant, and other relevant circumstances. Finally, the district court did not clearly abuse its discretion by denying plaintiffs' motion to alter or amend the judgment where the additional evidence at issue would not have produced a different result. Accordingly, the Eighth Circuit affirmed the judgment. View "Webb v. Exxon Mobil" on Justia Law

Hanzada, an Egyptian company that imports and exports beef, appealed the jury verdict and judgment against it on plaintiff's breach of contract claim. The district court relied on the Seventh Circuit's widely adopted Sadat v. Mertes rule that only the American nationality of the dual citizen should be recognized for purposes of 28 U.S.C. 1332(a). The court concluded that the district court properly found diversity jurisdiction because plaintiff was a U.S. citizen and his Egyptian citizenship did not defeat jurisdiction. The court also concluded that the district court properly exercised personal jurisdiction over Hanzada where there was sufficient minimum contacts with Missouri for the Missouri long-arm statute to authorize personal jurisdiction. Finally, the district court properly found the statute of frauds inapplicable in this case where, under Missouri law, an oral contract for an indefinite period of time does not violate the statute of frauds. Accordingly, the court affirmed the judgment. View "Aly v. Hanzada for Import & Export Co." on Justia Law

Omega filed suit against Mayo, alleging claims of fraud, negligent misrepresentation, breach of contract, and breach of the implied covenant of good faith and fair dealing. The parties had entered into an Exclusive Patent License Agreement in which Omega, a start-up company, agreed to, among other things, pursue Mayo's pending patent application. After the patent application was abandoned when the U.S. Patent and Trademark Office denied an elected group of claims as anticipated by prior art, Omega alleged damages because it relied on Mayo's pre-Agreement false representations. The court concluded that the Agreement and the patent application file squarely contradict Omega's general, conclusory allegation of reasonable reliance. Therefore, the district court properly dismissed these claims grounded in fraud for failure to state plausible claims of reasonable reliance. Accordingly, the court affirmed the judgment. View "OmegaGenesis Corp. v. Mayo Foundation" on Justia Law

The parties entered into a contract wherein John Lamoureux provided the necessary capital to MPSC, a start-up company, in exchange for a royalty fee every time the company used its patented service. After John died, his wife filed a breach of contract suit against MPSC for ceasing to make payments. The district court granted summary judgment to plaintiff, denying MPSC an at-will termination term. The court concluded that the express terms of the Investment Agreement compelled MPSC's continued performance. Because no principle of Minnesota state law or general contract law overrides the agreement's intent, the court affirmed the judgment. View "Lamoureux v. MPSC, Inc." on Justia Law