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

Loftness filed suit against defendants seeking a declaratory judgment that it had fulfilled its duties under the Non-Disclosure Agreement (NDA) and the May 2008 Agreement. Defendants asserted counterclaims against Loftness for, as relevant here, unjust enrichment and breach of two contracts. The court concluded that, instead of applying the test for the tort of misappropriation of trade secrets and confidential information, the district court should have interpreted and applied the terms of the NDA; the parties did not comprehensively brief or argue whether Loftness's actions in connection with the Brandt deal constituted a breach of the non-compete provision of the NDA; and the court remanded this counterclaim for further proceedings because it would be beneficial for the district court to consider the issue in the first instance. The court also concluded that the May 2008 Agreement was unenforceable under the statute of frauds; the court declined to read the NDA as a writing that extended the terms of the May 2008 Agreement; even if the court accepted defendant's position that the parties orally extended the May 2008 Agreement for seventeen years, such an extension was unenforceable under the statute of frauds because it could not be performed within one year; and there was no implied-in-fact contract. Accordingly, the court affirmed the grant of summary judgment on this counterclaim. Because the rights and the obligations of the parties were governed by the NDA and the May 2008 Agreement, the court affirmed the dismissal of the unjust enrichment counterclaim. View "Loftness Specialized Farm v. Twiestmeyer, et al." on Justia Law

This case concerned a dispute involving certain equipment Dakota purchased from the Kloster division of Tromley. On appeal, Tromley appealed the district court's denial of its motion to compel arbitration. Because the arbitration provision was not readily available and because Dakota did not have a reasonable opportunity to reject it, Tromley could not establish the necessary consent to bind Dakota to that provision. Further, the emails exchanged between Dakota and Tromley in June and July 2010 did not constitute an addendum to their agreement which successfully incorporated the arbitration agreement where the court could not say that the parties mutually assented to modify their agreement to include the provision. Accordingly, the court affirmed the judgment of the district court. View "Dakota Foundry, Inc. v. Tromley Industrial Holding" on Justia Law

Plaintiffs filed suit against defendant to recover on a promissory note. On appeal, plaintiffs challenged the district court's grant of summary judgment in favor of defendant. The court concluded that, construing the evidence most favorably to plaintiffs, a genuine issue of material fact existed as to whether the primary purpose of the loan was consumer or non-consumer in nature. The district court correctly declined to create a de minimus exception to the no notice rule. The court reversed and remanded. View "Crozier, et al. v. Wint" on Justia Law

Plaintiff filed suit against Farmers and American, insurance companies, for breach of contract and various state law violations, seeking recovery for additional loss. The court concluded that plaintiffs' claims for specific performance, unjust enrichment, and bad faith were expressly preempted by federal law; the court affirmed the district court's grant of Farmers' motion to dismiss plaintiffs' extracontractual claims because they were preempted under federal law; and the court affirmed the district court's grant of summary judgment to Farmers on the ground that plaintiffs failed to file a supplemental proof of loss, a strictly construed requirement, and thus did not satisfy the prerequisites for suing on their additional claims, rejecting plaintiffs' estoppel, duress, repudiation, and due process arguments. Further, the court affirmed the district court's grant of summary judgment for American, concluding that the American policy was supplemental and plaintiffs could not recover from American for flood damage because they had not exhausted their primary policy with Farmers. View "Gunter, et al. v. Farmers Ins. Co., et al." on Justia Law

Plaintiffs filed suit against Darwin alleging that the insurance company breached its duty to defend and its implied duties of good faith and fair dealing under the policy at issue. On appeal, plaintiffs challenged the district court's grant of summary judgment in favor of Darwin. The court concluded that Darwin owed no duty to defend plaintiffs because all of the claims at issue fell within the Customer Funds Exclusion; the district court's interpretation of the Customer Funds Exclusion did not violate the illusory coverage doctrine; and the reasonable expectations doctrine did not apply in this case. The court also concluded that the innocent insured doctrine did not obligate Darwin to defend plaintiffs and the district court did not err in granting summary judgment on plaintiffs' claim for breach of the implied contractual duties of good faith and fair dealing. Accordingly, the court affirmed the district court's judgment. View "Bethel, II, et al. v. Darwin Select Ins. Co." on Justia Law

The Market sought a declaration that its employment separation agreement with defendant was invalid because defendant had altered the agreement and fraudulently induced the president of the Market to sign it. Defendant counterclaimed to enforce the agreement. The court affirmed the district court's grant of summary judgment to the Market where defendant failed to fulfill a condition precedent - returning company property - and such failure meant that the Market had not duty to perform under the agreement. Alternatively, the district court did not abuse its discretion in striking defendant's pleadings based on defendant's deliberate and willful discovery abuses. The district court acted within its discretion to impose sanctions under Rule 37. View "St. Louis Produce Market v. Hughes" on Justia Law

Bruce Martin filed suit against CTB for negligent misrepresentation and breach of express warranty after the power sweeps it purchased from CTB did not work. The court concluded that it's decision in Dannix Painting, LLC v. Sherwin-Williams foreclosed Bruce Martin's argument that the district court erred in concluding that Missouri's economic loss doctrine precluded its negligent misrepresentation claim. Further, the court concluded that the district court did not err in granting summary judgment to CTB on Bruce Martin's breach of express warranty claim. Under Indiana law, the court agreed with the district court that Bruce Martin had alleged a defect in the design of the sweeps that was not covered by CTB's warranty against "defects in material and workmanship." Accordingly, the court affirmed the judgment of the district court. View "Bruce Martin Construction, Inc. v. CTB, Inc." on Justia Law

Dannix, a commercial painting contractor, filed suit against SWC alleging that SWC negligently misrepresented that a certain paint product SWC sold was appropriate for a particular painting project. The court concluded that the district court did not err in deciding that Missouri's economic loss doctrine precluded Dannix's negligent misrepresentation claim. The economic loss doctrine prohibited a commercial buyer of goods from seeking to recover in tort for economic losses that were contractual in nature. The court also concluded that the district court correctly dismissed Dannix's misrepresentation complaint where the complaint did not set forth any allegations of property damage to surfaces Dannix painted. Accordingly, the court affirmed the district court's dismissal of Dannix's complaint. View "Dannix Painting v. Sherwin-Williams Co." on Justia Law

This case concerned the 2011 NFL lockout. Active NFL players filed a class action suit (Brady suit) against the NFL, alleging violations of the federal antitrust laws and other claims. Retired NFL players also filed suit against the NFL and its teams, alleging antitrust violations (Eller I suit). After both actions were consolidated, the Brady suit was settled, the players re-designated the NFLPA as their collective bargaining agent, the NFL and NFLPA signed a new collective bargaining agreement (CBA) incorporating the settlement terms, the Brady plaintiffs dismissed their action, the lockout ended, and the 2011 NFL season commenced. Carl Eller and other retired NFL players (plaintiffs) then filed this class action (Eller II) against the NFLPA and others. The district court granted defendants' motion to dismiss and plaintiffs appealed, alleging claims for intentional interference with prospective economic advantage under Minnesota law. The court concluded that no reasonable jury could find that plaintiffs had a reasonable expectation of a prospective separate contractual relation with the NFL that would provide more than the increased benefits provided in the 2011 CBA. Even if plaintiffs alleged a reasonable expectation of prospective contractual relations or economic advantage with the NFL, plaintiffs failed to allege facts proving that defendants improperly or wrongfully interfered with these advantageous prospects. Accordingly, the court affirmed the judgment of the district court. View "Eller, et al. v. NFL Players Assoc., et al." on Justia Law

This case arose when DocMagic, provider of mortgage loan document preparation software, filed various claims against Lenders One, provider of mortgage products and services, stemming from the parties' service contract (Agreement), and Lenders One filed various counterclaims. Per the Agreement, Lenders One agreed to supply DocMagic with a list of all Lenders One's current members and refer, market, and promote DocMagic's products and services to the members. On appeal, the parties dispute the district court's award of attorneys' fees, expenses, and costs. As a preliminary matter, the court used de novo review in order to determine which litigant was the prevailing party and the court applied an abuse of discretion standard regarding the district court's award of fees and costs. On the merits, the court concluded that the district court did not err in designating Lenders One as the prevailing party where the district court considered the totality of the case and reasonably determined the prevailing party for purposes of the parties' contract. Accordingly, the court affirmed the district court's award of fees and costs. View "DocMagic, Inc. v. The Mortgage Partnership" on Justia Law