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

Plaintiff Marnita Goddard was injured while riding on a trolley operated by the city of Deadwood, South Dakota. Invoking diversity jurisdiction, Goddard sued the city for negligence and the South Dakota Public Assurance Alliance (SDPAA) for uninsured motorist coverage. After Goddard settled with the city, the district court granted summary judgment in favor of SDPAA, concluding that Goddard was not covered under the uninsured motorist provision in the city's agreement with SDPAA. The Eighth Circuit Court of Appeals affirmed, holding that Goddard had not shown she was entitled to coverage under the uninsured motorist provision of the SDPAA agreement. View "Goddard v. S.D. Pub. Assurance Alliance" on Justia Law

Alpine Glass, Inc. appealed the district court's partial denial of Alpine's motion to consolidate 482 short-pay claims for arbitration against the Country Mutual Insurance Co. and five of its subsidiaries. The Eighth Circuit Court of Appeals dismissed Alpine's appeal for lack of appellate jurisdiction, holding (1) the Court lacked jurisdiction to hear the appeal under 28 U.S.C. 1291 because the district court's order was not a final order; and (2) the denial of a motion to consolidate arbitrations does not imperil a substantial public interest sufficient to warrant jurisdiction under the collateral order doctrine, and therefore, the order was not appealable under the collateral order doctrine. View "Alpine Glass, Inc. v. Country Mut. Ins. Co." on Justia Law

Contractor contracted to build a restaurant in Minnesota, promising to pay each subcontractor, upon receipt of payment from the owner, the amount to which the subcontractor was entitled. Appellant became the subcontractor for carpentry and drywall work. Upon completing its work, Appellant was not paid the full amount owed. After Contractor settled a dispute with the restaurant, it offered Appellant a smaller sum, claiming it was Appellant's pro rata share of the settlement proceeds. Appellant rejected the offer and sued Contractor and its Owner in state court. Owner and his wife subsequently filed a petition for Chapter 7 bankruptcy relief, with the debt to Appellant unsatisfied. Appellant commenced this adversary proceeding to have the debt declared nondischargeable. The bankruptcy appellate panel (BAP) determined that neither 11 U.S.C. 523(a)(4) nor 11 U.S.C. 523(a)(6) barred discharge of the debt. The Eighth Circuit Court of Appeals affirmed, holding (1) Owner was not a section 523(a)(4) fiduciary by reason of a Minnesota statute or Owner's Minnesota common law duties, nor did Contractor's use of its own property amount to embezzlement; and (2) the BAP did not err in finding no malicious injury, which resolved the section 523(a)(6) issue. View "Reshetar Sys., Inc. v. Thompson" on Justia Law

Art Etc., LLC sought a declaratory judgment that the sale of inventory purchased from Angel Gifts, Inc. and Donald Schmit would amount to copyright infringement in violation of the United States Copyright Act. Angel Gifts and Donald Schmit moved to stay the proceedings pending arbitration, invoking an arbitration provision in an agreement between the parties. The district court denied the motion. The Eighth Circuit Court of Appeals affirmed, holding (1) the parties intended for the arbitration provision to apply only under certain circumstances; and (2) Art. Etc.'s claims did not fall within the scope of the arbitration provision. Thus, arbitration in this case was not required. View "Art Etc. LLC v. Angel Gifts, Inc." on Justia Law

Patrick McGinness, driving a vehicle owned by his adult daughter, negligently struck and injured Marie DeMeo. DeMeo obtained a $350,000 state-court judgment against McGinness. McGinness's daughter's insurer, American Family Insurance Company, paid its $100,000 policy limit under an owner's liability policy that covered McGinness as a permitted driver. State Farm insured McGinness under four liability policies issued for the cars he owed. Each policy provided coverage to McGinness when operating a non-owned vehicle such as his daughter's. Invoking the policies' "anti-stacking" provisions, State Farm paid the per-person limit of one policy, $50,000. De Meo filed this action to recover an additional $150,000, the combined limits of the other three policies. The district court held that the anti-stacking provisions did not conflict with Missouri's Motor Vehicle Financial Responsibility Act (MVFRL) requirements, which mandate that motor vehicle owners and operates maintain minimum levels of financial responsibility for damages arising out of their ownership or use of a motor vehicle, and granted summary judgment in State Farm's favor. The Eighth Circuit Court of Appeals affirmed, holding that there was no basis to conclude that the MVFRL demands stacking when there are multiple policies. View "DeMeo v. State Farm Mutual Auto. Ins. Co." on Justia Law

Robert and Ethel Youngs' home and personal property were insured under a policy issued by Allstate Insurance Company. The policy provided that Allstate would "not cover any loss or occurrence in which any insured person has concealed or misrepresented any material fact or circumstance." After a fire broke out in the Youngs' garage, damaging or destroying many of its contents, AllState denied the Youngs' insurance claim, asserting that the Youngs misrepresented material facts regarding their losses. The Youngs filed suit against Allstate for breach of contract and vexatious refusal to pay. The district court granted summary judgment for Allstate. The Eighth Circuit Court of Appeals reversed, holding that there were genuine issues of fact for trial. View "Young v. Allstate Ins. Co. " on Justia Law

In this core adversary proceeding, a Chapter 7 bankruptcy Trustee appealed an order of the Bankruptcy Appellate Panel (BAP) denying his turnover action on the ground that an unjust enrichment claim exceeds the scope of 11 U.S.C. 542(a), a remedy limited to recovering property of the bankruptcy estate in the possession, custody, or control of a third party. The Eighth Circuit Court of Appeals affirmed, holding (1) the BAP correctly concluded that the Court's In re NWFX decisions did not recognize unjust enrichment as a basis for collecting a debt under section 542(a); and (2) thus, the Trustee's claim for unjust enrichment based upon a debt owed was beyond the scope of section 542(a). View "Lovald v. Falzerano" on Justia Law

This case involved a wire transfer from Plaintiff's bank account to Defendant's wife. Plaintiff claimed that Defendant, a former employee of Plaintiff, initiated the transfer unlawfully. Defendant moved for summary judgment, offering evidence of another explanation for the transfer. Plaintiff did not offer any evidence in response, and the district court entered summary judgment for Defendant. At issue on appeal was whether Defendant made the initial showing required by Fed. R. Civ. P. 56 that there was no genuine issue of material fact and that he was entitled to judgment as a matter of law, thereby shifting the burden to Plaintiff to present affirmative evidence showing that a genuine issue of material fact existed. The Eighth Circuit Court of Appeals affirmed, holding that Defendant made the required showing.

This declaratory judgment action concerned a controversy over the limits of an insurance policy issued by Insurer to Insured. A livestock company (Company) brought suit in Minnesota state court against Insured after Company's cattle in Insured's care died in unusually high numbers. Insured submitted the complaint in the underlying action to Insurer. Insurer refused to defend or indemnify Insured in the case brought by Company, basing its denial of coverage on an exclusion in the liability insurance policy for damage to property in the "care, custody, or control" of the insured. The Minnesota district court entered judgment against Insured. Insurer then commenced this action against Company and Insured in federal district court, seeking a declaratory judgment that the claims alleged in the underlying action were not covered under Insured's policy with Insurer and that Insurer therefore had no obligation to defend or indemnify Insured. The district court concluded that the claims were covered by the policy and granted Company and Insured's motion for summary judgment. The Eighth Circuit Court of Appeals reversed, holding that because Company's cattle were under Insured's care, custody, and control when they were damaged, the policy did not provide coverage for Company's claimed loss. Remanded.

Appellees entered into performance and stock agreements with their employer, appellant ONEOK, Inc. The agreements required Appellees to continue their employment for three years (performance period) in order to receive the full number of shares, but allowed pro rata payments if Appellees' employment terminated under certain conditions. After Appellees left ONEOK's employment before the earliest performance period ended, ONEOK denied Appellees' claims for pro rata payments under the agreements. Appellees sued ONEOK for breach of contract. The district court found for Appellees and awarded Appellees money damages equal to each of their pro rata shares under the agreements, and denied their request for attorney fees. The Eighth Circuit Court of Appeals reversed the denial of attorney fees, holding that the district court erred in determining Appellees were not entitled to attorney fees under the Nebraska Wage Payment and Collection Act (NWPCA). Remanded for a determination of the amount of the attorney fees award under the NWPCA.