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

Choice filed suit against BancorpSouth for lost funds and BancorpSouth counterclaimed for attorney's fees. The court concluded that the loss of funds from Choice's account falls on Choice because there was no genuine dispute of fact as to whether BanCorpSouth's security procedures - which included password protection, daily transfer limits, device authentication, and dual control - were commercially reasonable; BancorpSouth met its burden of establishing that it accepted the payment order at issue in good faith; and BanCorpSouth complied with procedures or Choice's instructions. The court also concluded that the portion of the indemnification provision relating to attorney's fees was not inconsistent with Article 4A of the UCC and that BancorpSouth may seek attorney's fees from Choice under this provision. Accordingly, the court affirmed the district court's grant of summary judgment to BancorpSouth, reversed the district court's dismissal of BancorpSouth's counterclaim on the pleadings, and remanded for further proceedings. View "Choice Escrow and Land Title v. BancorpSouth Bank" on Justia Law

This dispute arose from the lease of a commercial building from CRG to Smucker. The lease provided that, after its initial term, it would automatically renew unless Smucker provided written notice of its intent to terminate the lease 180 days prior to the end of the current term. When the termination notice to CRG arrive after the deadline, CRG refused to accept the notice and filed suit against Smucker. The court concluded that it would be unconscionable to hold Smucker to the renewal because Smucker had substantially performed its lease obligations. The court concluded that the district court erred in failing to treat the cancellation provision in this case as an option to terminate. The court also concluded that there was insufficient evidence to conclude as a matter of law that enforcing the terms of the lease against Smucker would cause Smucker such hardship as to make literal enforcement of the option unconscionable. Accordingly, the court reversed and remanded for further proceedings. View "Commercial Resource Group, LLC v. The J.M. Smucker Co." on Justia Law

Plaintiffs filed suit seeking a declaratory judgment quieting title to an interest in the Bakken formation that Phillip Armstrong purchased from Berco. Armstrong also filed suit against Encore for breaching a Letter Offer and for trespassing on, and converting the oil and gas attributable to, Armstrong's interest. Berco counterclaimed. The court affirmed the dismissal of Armstrong's quiet-title claim, based on the district court's conclusion that the Purchase Agreement and Assignment, taken together, conveyed to Armstrong a wellbore-only assignment; Armstrong's trespass claim was properly dismissed because Armstrong did not assert that Encore interfered with his use of the two wellbores; Armstrong's conversion claim was properly dismissed because Armstrong has an interest in only the Thompson and Yttredahl wellbores, the equipment associated with those wellbores, and the production through those two wellbores; the breach of contract claim was properly dismissed because Armstrong had no leasehold interest to transfer and thus could not comply with the Letter Offer; and the district court correctly ruled that Armstrong's unilateral alteration of Exhibit A before recording it rendered the recorded Assignment null and void. Accordingly, the court affirmed the judgment of the district court. View "Armstrong, et al. v. Berco Resources, LLC, et al." on Justia Law

BLB, an aviation company, brought contract claims against Jet Linx and others, and Jet Linx counterclaimed. The court concluded that Jet Linx's tender of a check and BLB's act of depositing the check did not amount to an accord and satisfaction; the district court did not clearly err by finding that BLB did not agree to the terms of the August 2008 letter at issue and, as a result, the district court did not err by rejecting Jet Linx's defense of accord and satisfaction; the court affirmed the district court's judgment for BLB with respect to its claim for unpaid lease payments under the dry lease agreement (DLA) and the award of $141,400 to BLB; the court affirmed the district court's judgment for BLB on its claim that Jet Linx breached the management services agreement (MSA) by "marking up" the cost of maintenance; the court reversed and remanded the district court's judgment with regard to Jet Linx's failure to maintain the maintenance records and part tags where it was error to choose diminution in values as the appropriate measure of BLB's damages; and the court affirmed the district court's judgment in favor of Jet Linx on its counterclaim for breach of the MSA and the award of damages to Jet Linx. View "BLB Aviation South Carolina v. Jet Linx Aviation, LLC, et al." on Justia Law

Farm Credit had a security interest in corn delivered to Cargill and filed suit against Cargill in replevin for the corn. The district court concluded that Farm Credit's security interest under the Food Security Act (FSA) of 1985, 7 U.S.C. 1631(e), entitled it to proceeds from the corn delivered to Cargill. The court concluded that Cargill did not dispute that Farm Credit complied with the FSA. To the extent that the U.C.C. governs priority disputes as a foundation for the FSA, Cargill's argument failed because U.C.C. 9-404 does not apply in this case. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Farm Credit. View "Farm Credit Serv. v. Cargill, Inc." on Justia Law

In 2011, plaintiffs filed suit against the Bank for breach of contract, negligence, and conversion after plaintiffs gave physical possession of gold coins and proof sets to a predecessor of the Bank, as collateral to secure a line of credit in the 1980's, and the Bank stated conclusively in 2009 that it no longer possessed the coins. The court affirmed the district court's grant of summary judgment to the Bank, holding that the suit was time-barred by Missouri's ten-year statute of limitations. Whether plaintiffs could or could not have continued to borrow on the allegedly ongoing line of credit did not change the fact that reasonable persons had to have known, prior to January 2001, that their creditor's non-responsiveness and inability to locate the collateral suggested that an injury and substantial damages may have occurred. View "Mahanna, et al. v. U.S. Bank Nat'l Assoc." on Justia Law

Plaintiffs filed suit against the Bank seeking to void a mortgage foreclosure sale of their home. Plaintiffs alleged that the Bank represented orally that it would postpone the foreclosure sale, but then proceeded to foreclose anyway. The court concluded that plaintiffs' claim of negligent misrepresentation was barred by the Minnesota Credit Agreement Status, Minn. Stat. 513.33, where any party asserting the existence of a credit agreement must comply with the writing and signature requirements of section 513.33. The court concluded that the complaint alleged a claim of promissory estoppel, rather than equitable estoppel, and was barred by the Minnesota Credit Agreement Statute. Accordingly, the court affirmed the district court's grant of the Bank's motion to dismiss. View "Bracewell, et al. v. U.S. Bank Nat'l Assoc." on Justia Law

The Union sought to set aside an arbitration award that ruled in favor of the MADA and several member car dealerships. At issue was the transition between the 2006 collective bargaining agreement (CBA) and the 2010 CBA and its impact on above-scale time allowances for hybrid car warranty and recall work. The district court granted defendants' motion to dismiss under Rule 12(b)(6). The court agreed with the district court and found that the arbitrator was "warranted" in determining the CBA's plain language to be "silent or ambiguous with respect to the disputed issue - how the above-scale time allowances could be legitimately terminated." With MADA's attorney's unrebutted testimony and the letters documenting other dealerships' similar conduct to help the parties' past practice with respect to the ambiguous CBA language at issue, the court concluded that the arbitration award drew its essence from the CBA. Therefore, the court found no basis to vacate the arbitration award. The court affirmed the district court's order granting MADA's motion to dismiss with prejudice. View "Garage Maintenance, etc. v. Greater Metropolitan, etc., et al." on Justia Law

Sara Lee and the Unions entered into a collective bargaining agreement (CBA), and an outsourcing agreement which permitted Sara Lee to outsource covered functions to a contract company. After Sara Lee did outsource one of the covered functions and the contract company hired Sara Lee's displaced employees, Sara Lee refused to require the contract company to adhere to the CBA for its remaining terms. The Unions argued that Sara Lee breached the outsourcing agreement. The court concluded that Sara Lee was entitled to judgment as a matter of law where the Unions failed to establish a genuine dispute of material fact as to whether Sara Lee subsequently changed subcontractors. The court found it unnecessary to address the extension agreement's impact on the old CBA's term or to reconcile this tangle of agreements, because the proposition that Sara Lee never subsequently changed subcontractors provided a clear basis upon which to affirm. Accordingly, the court affirmed the judgment of the district court. View "Allied Sales Drivers, et al. v. Sara Lee Bakery Group, et al." on Justia Law

Block appealed a district court order denying its motion for a preliminary injunction requiring defendant to comply with post-termination covenants in a Puerto Rican franchise agreement. The district court denied the preliminary injunction, concluding that Block had not demonstrated that it would suffer irreparable harm if the court did not issue an injunction. The court vacated and remanded, concluding that the district court failed to make specific findings and explain its ruling. Even if the record permitted the court to infer why the district court concluded that Block's initial showing of irreparable injury was inadequate, without adequate Rule 52(a) findings and reasons, the court could not evaluate whether summary denial of Block's motion without an evidentiary hearing was an abuse of discretion, when other procedural alternatives were clearly available. The court declined to direct the district court to enter the requested injunction on remand. View "H&R Block Tax Services, LLC v. Acevedo-Lopez" on Justia Law