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

American Family appealed the district court's order denying its motion for judgment as a matter of law or, in the alternative, for a new trial and awarding defendant attorney's fees pursuant to section 91A.8 of the Iowa Wage Payment Collection Law (IWPCL). The court concluded that the district court did not abuse its discretion in granting defendant's Rule 15(b)(2) motion to amend the pleadings to add the IWPCL claim because the claim was tried with American Family's implied consent and the amendment did not result in prejudice to American Family. The district court did not abuse its discretion in awarding attorney's fees to defendant under the IWPCL. Any error in giving jury Instruction 13A was harmless in light of the subsequently given Instruction No. 14. Accordingly, the court affirmed the judgment of the district court. View "American Family Mutual Ins. Co. v. Hollander" on Justia Law

Heubel and Raymond appealed the district court's grant of summary judgment in favor of Universal on Heubal's claim for coverage under a Universal insurance policy. The district court held that Heubel's breach of a cooperation clause in the Universal policy absolved Universal of the duty to defend or provide coverage for a products liability lawsuit against Heubel. Because no reservation of rights or conflict of interest entitled Heubel to select its own counsel while continuing to enjoy the coverage benefits of the Universal policy, Heubel breached the policy by refusing to allow Universal to control the defense. Because nothing in the Universal policy or the Raymond indemnification program precluded a third-party indemnification claim by Universal against Raymond in the Harris suit, Universal suffered substantial prejudice from Heubel's refusal to allow Universal to control the defense. As a result, Universal was justified in denying coverage based on Heubel's breach of the cooperation clause. Accordingly, the court affirmed the judgment. View "Heubel Materials Handling Co. v. Universal Underwriters Ins. Co." on Justia Law

Hallmark sued its former employee, defendant, for a breach of the parties' separation agreement and won a jury verdict of $860,000 on its breach of contract claim. Defendant appealed, arguing that the district court erred in delivering an adverse inference instruction to the jury and the award on Hallmark's breach of contract claim was excessive. In light of the overwhelming evidence of bad faith and prejudice before the district court, the court concluded that its failure to issue explicit findings before delivering the otherwise warranted adverse inference instruction was harmless error which did not prejudice defendant. By awarding Hallmark more than its $735,000 severance payment, the jury award placed Hallmark in a better position than it would find itself had defendant not breached the agreement. Accordingly, the jury's award of the $125,000 payment was improper and the court vacated and remanded for the district court to reduce the fee award appropriately. View "Hallmark Cards v. Murley" on Justia Law

Plaintiffs sued Wells Fargo for fraudulent misrepresentation and promissory estoppel after Wells Fargo initiated foreclosure when plaintiffs stopped paying on their mortgage loan. The court held that plaintiffs have not stated a plausible claim for fraudulent misrepresentation regarding the modification of their home loan and therefore, the district court did not err in dismissing plaintiffs' claims under Rules 12(b)(6) and 9(b). The court also held that plaintiffs have not stated a plausible claim for promissory estoppel and the district court did not err in dismissing their claim. View "Freitas, et al v. Wells Fargo Home Mortgage, Inc." on Justia Law

General Mills sued Five Star for breach of contract and breach of warranties after the meatballs General Mills purchased from Five Star contained beef that was recalled. The district court granted summary judgment to General Mills on the breach-of-contract claim and to Five Star on the breach-of-warranty claims. The parties cross-appealed. The court concluded that the press release that General Mills relied upon to recall the meatballs constituted hearsay. However, the press release set out findings from an investigation pursuant to authority granted by law and was therefore admissible. The court also concluded that sufficient admissible evidence supported the conclusion that the meat was procured in violation of regulations and that it was adulterated. Therefore, the district court properly granted summary judgment to General Mills on the breach-of-contract claim. The court further concluded that the district court properly analyzed the breach-of-contract and breach-of-warranties claims separately. The court dismissed General Mills' cross-appeal as moot and affirmed the award of attorneys fees to General Mills. View "General Mills Operations, LLC v. Five Star Custom Foods, Ltd." on Justia Law

A railroad employee sued his employer, DM&E, after he was injured while working as the employee-in-charge of a construction site. DM&E then brought a third-party complaint against Corman, contending that Corman was required to indemnify and defend it against the employee's Federal Employers' Liability Act (FELA), 45 U.S.C. 51-60, claim pursuant to a contract between the parties. Nothing in the Contract Work Agreement (CWA) indicated that it extended to claims which were unrelated to Corman's common-law negligence. The indemnity clause in the CWA did not mention the FELA. Therefore, the court held that DM&E had not shown any issues of material fact existed and therefore no negligence could be attributed to Corman. The court also held that the indemnification provision in the CWA did not trigger the insured contract exception to the general exclusion provision contained in the Lexington Insurance policy, and, as a result, no obligation existed based on the terms of the policy. View "Dakota, MN & Eastern R. R. v. R. J. Corman R. R. Construction" on Justia Law

DFA, a Kansas cooperative, sued Bassett, an international commodities broker and a Canadian corporation, for failure to pay. The district court dismissed the suit for lack of personal jurisdiction. Bassett did not transact business within Missouri; sent no product there or ordered none from Missouri; did not advertise there; no Bassett employee ever entered Missouri; and Bassett's communications with DFA's Missouri headquarters did not alone amount to the transaction of business. Therefore, Bassett did not transact business in Missouri and was not within the reach of Missouri's long-arm statute. Even if Bassett had transacted business in Missouri, the district court could not constitutionally exercise jurisdiction over Bassett. Accordingly, the court affirmed the judgment. View "Dairy Farmers of America v. Bassett & Walker International" on Justia Law

Super Wings sued defendant for failing to pay on a promissory note and defendant asserted that he did not have to pay because Super Wings had breached an agreement it had with defendant's company, JLI. JLI intervened. The district court ruled that Super Wings had fulfilled its contractual obligations to JLI, that defendant was liable for failing to pay on his note, and that JLI's claim against Super Wings should be dismissed. The court affirmed, concluding that there was substantial evidence supporting the district court's finding that Super Wings had released JLI's property as required by the December 2008 agreement. Since the district court did not err in entering judgment for Super Wings against defendant and in dismissing JLI's claim, the court affirmed the judgment. View "Super Wings Int'l v. J Lloyd Int'l, Inc." on Justia Law

Plaintiff appealed from the district court's dismissal of his declaratory judgment, contract, unjust-enrichment, tort, and shareholder claims. Applying a choice-of-law analysis, the district court dismissed the contract and unjust-enrichment claims as barred by a Delaware statue of limitations and dismissed the tort and declaratory judgment claims as derivative of the contract claims. The district court dismissed the shareholder claims as insufficiently pleaded. The court held that plaintiff's pleadings were minimally sufficient to present plausible shareholder claims. Therefore, the court reversed as to the shareholder claims but affirmed in all other respects. View "Whitney v. The Guys, Inc., et al" on Justia Law

Retro Television Network appealed the district court's dismissal of its claims against appellees, Luken and Retro Television, under Rule 12(b)(6). In 2005, Equity entered into an intellectual property agreement (IPA) with Retro Television Network. Retro Television Network subsequently sued appellees seeking royalty payments and an accounting under the IPA. Because Retro Television Network failed to allege any facts that would make Luken liable for Equity's obligations under the IPA, the district court properly dismissed its claims against Luken. The court also held that the district court did not abuse its discretion in awarding attorneys' fees. View "Retro Television Network, Inc. v. Luken Communications LLC, et al" on Justia Law