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

InCompass filed suit against XO asserting a single claim of promissory estoppel based on a former XO employee's alleged oral promise to enter into a multi-year lease with InCompass. InCompass appealed the district court's grant of XO's motion to strike InCompass's jury trial demand. In light of InCompass's inconsistency as to the precise measure of damages that it sought, and in light of the undeniably equitable nature of the promissory estoppel claim as a whole, the court held that InCompass's claim was properly regarded as equitable rather than legal and, consequently, InCompass was not entitled to a jury trial on its claim of promissory estoppel. Accordingly, the court affirmed the judgment. View "InCompass IT, Inc., et al. v. XO Communications Servs., et al." on Justia Law

Plaintiff filed suit seeking interest on benefits she received under an Accidental Death and Dismemberment (ADD) insurance policy issued by Hartford. The parties disagreed on whether Tennessee law or Missouri law applied. Plaintiff did not dispute Hartford's argument that under Missouri law and the policy language, Hartford paid the benefit to her when it was payable. Accordingly, the court concluded that plaintiff was not entitled to interest under Missouri law. Assuming Tennessee law applied, the court relied on Performance Sys., Inc. v. First Am. Nat'l Bank, to conclude that the Tennessee Supreme Court would likely construe "due" in Tenn. Code Ann. 7-14-109(b) to mean the time of payment designated in the policy, not the date of loss. In this instance, Hartford paid the benefit to plaintiff within the time of payment designated in the policy and, therefore, plaintiff was not entitled to interest under subsection (b). Accordingly, the court affirmed the judgment. View "Williamson v. Hartford Life & Accident, etc." on Justia Law

Doe Run commenced a declaratory action seeking to enforce Lexington's contractual duty to defend Doe Run per its Commercial General Liability (CGL) policies in two underlying lawsuits (the Briley Lawsuit and the McSpadden Lawsuit). These underlying lawsuits sought damages arising out of Doe Run's operation of a five-hundred-acre waste pile (Leadwood Pile). The court concluded that the pollution exclusions in the CGL policies precluded a duty to defend Doe Run in the Briley Lawsuit. The court concluded, however, that the McSpadden Lawsuit included allegations and claims that were not unambiguously barred from coverage by the pollution exclusions in the policies. The McSpadden Lawsuit alleged that the distribution of toxic materials harmed plaintiffs, without specifying how that harm occurred. The McSpadden complaint also alleged that Doe Run caused bodily injury or property damage when it left the Leadwood Pile open and available for use by the public without posting warning signs. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Doe Run Resources Corp. v. Lexington Ins. Co." on Justia Law

Doe Run commenced a declaratory judgment action seeking to enforce Lexington's contractual duty to defend Doe Run per its Commercial General Liability (CGL) policies in an underlying lawsuit. The underlying lawsuit alleged environmental property damage resulting from Doe Run's mine and mill operations. The court affirmed the district court's conclusion that Lexington had no duty to defend because the policies' absolute pollution exclusions unambiguously barred coverage of all claims asserted in the underlying lawsuit. View "Doe Run Resources Corp. v. Lexington Ins. Co." on Justia Law

Affordable appealed the district court's grant of Fannie Mae's motion to dismiss, concluding that EFA had not acted as Fannie Mae's agent in originating the loan for a senior living complex that Affordable purchased and that the loan documents unambiguously authorized a prepayment penalty. The court affirmed the dismissal of Affordable's claims for negligent misrepresentation, breach of the covenant of good faith and fair dealing, and unjust enrichment. However, the court reversed the dismissal of Affordable's breach of contract claim where the agreement was ambiguous as to whether "condemnation award" included a sale in lieu of condemnation and remanded for further proceedings. View "Affordable Communities of MO v. Federal Nat'l. Mortgage Assoc." on Justia Law

This case involved the interpretation of two contractual provisions under Minnesota law: an indemnification clause in a contract between PDSI and Miller and an insurance contract between Harleysville and PDSI which extended insurance coverage to PDSI's indemnification of third parties for tort liability caused, in whole or in part, by PDSI or by those acting on its behalf. The court agreed with the district court's finding that a PDSI employee's suit fell squarely within the indemnity provision of the 1989 Agreement between PDSI and Miller. The court also agreed with the district court's interpretation of the insurance agreements as requiring Harleysville to cover Miller's settlement of the employee's claims. Further, the court concluded that the undisputed facts established as a matter of law that PDSI or those acting on its behalf at least partly caused the employee's bodily injury within the terms of the Harleysville policy. Accordingly, the court affirmed the judgment. View "Harleysville Ins. Co. v. Physical Distrib. Serv., et al" on Justia Law

In 2005, Curtis McGhee and another individual brought claims against the City alleging violations of civil rights sounding in malicious prosecution. The City sought coverage under insurance policies issued by CIC and Columbia. On appeal, the City and McGhee challenged the district court's order granting summary judgment to CIC and Columbia, on CIC's and Columbia's declaratory judgment claims concerning coverage under the various insurance policies. The court concluded that the district court correctly refused to consider and correctly denied additional discovery of extrinsic evidence. The court also concluded that the alleged malicious prosecution and resulting personal injuries occurred when the underlying charges were filed against McGhee in 1977. Therefore, the court affirmed the district court's judgment that the following policies did not afford coverage to the City for the malicious prosecution claims: the two excess liability policies issued by CIC; four of the special excess liability policies issued by Columbia; and the commercial umbrella liability policy issued by Columbia. As to the 1977-78 special excess liability policy issued by Columbia, the court reversed the district court's judgment regarding the applicability of the reasonable expectations doctrine. The court remanded for further proceedings. View "Chicago Ins. Co., et al v. City of Council Bluffs, et al" on Justia Law

After Lumbermens denied Smith Flooring's claim for loss of one of their buildings, Smith Flooring filed suit alleging breach of contract and sought a declaratory judgment as to the terms of the insurance policy. Lumbermens removed the case to the district court and counterclaimed for reformation of the insurance policy. The court held that the district court erred in finding that there were no issues common to the parties' legal and equitable claims; Smith Flooring had a Seventh Amendment right to a trial by jury on the common issue of what the terms of the intended contract were; the district court also erred in treating the jury's verdict as merely advisory under Rule 39 insofar as this issue was concerned; however, the district court's error did not necessitate reversal of its granting post-verdict judgment as a matter of law to Lumbermens. The court further held that the evidence in this case was not sufficient to support the jury's verdict in Smith Flooring's favor. Because there was no coverage for the building, it followed that Lumbermens did not breach its contract in denying Smith Flooring's proof of loss. With no breach, Lumbermens owed Smith Flooring no damages. The district court was correct to find that clear, cogent, and convincing evidence demonstrated that the policy did not accurately set forth the agreement between the parties and that the building at issue be excluded from coverage. Consequently, the district court did not err in reforming the policy. Accordingly, the court affirmed the judgment. View "Smith Flooring v. Pennsylvania Lumbermens Mutual Ins. Co." on Justia Law

Plaintiff appealed the district court's dismissal of his breach of contract and retaliation claim against Boston Scientific. Plaintiff filed for Chapter 7 bankruptcy and then Boston Scientific terminated his employment shortly after his filing. The court concluded that, because the guaranteed payments at issue, if due at all, were property of the bankruptcy estate, plaintiff lacked standing to assert his breach of contract claim. Plaintiff's argument that had Boston Scientific not terminated him, the payments he received under the Employment Agreement would have been future earnings also failed. Because plaintiff never requested leave to amend his complaint to include a retaliation claim, the district court could not be faulted for failing to allow him to do so. Accordingly, the court affirmed the judgment. View "Longaker v. Boston Scientific Corp., et al" on Justia Law

Clarinet sued Essex alleging that Essex wrongfully refused to pay Clarinet under a commercial general liability insurance policy. Clarinet sought payment for expenses for stabilizing and demolishing a building that it owned, in accordance with Clarinet's interpretation of the policy. Essex denied coverage and refused payment. The insurance policy contained several conditions and exclusions, including the owned property exclusion. The court held that the district court properly granted summary judgment to Essex and denied relief to Clarinet because the owned property exclusion barred coverage. View "Clarinet v. Essex Ins. Co." on Justia Law