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

Plaintiff sued her former employer alleging violations of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The district court found in favor of plaintiff and awarded back pay, front pay, and liquidated damages. The court rejected defendant's challenges to the district court's finding of liability. Even if defendants did not waive the affirmative defense of failure to mitigate damages, the court agreed with the district court's alternative holding that plaintiff's efforts to secure other employment were reasonable. The court vacated the award of front pay as overly speculative but affirmed the district court's judgment in all other respects. View "Dollar v. Smithway Motor Xpress, et al" on Justia Law

Plaintiffs, individually and as parents and next friends of C.S., A.S., and J.S., brought suit against the County under 42 U.S.C. 1983 for violations of their procedural due process rights stemming from their child-protection case. Plaintiffs' complaint related to the notice and hearing requirement of an emergency protective custody hearing. The court concluded that the County lacked any policymaking authority regarding the handling and scheduling of the EPC hearing and formal hearing. Plaintiffs' complaint essentially alleged that Minnesota law, and the state court judge's application of that law - not an independent County policy - caused the procedural due process violations. The County could not be liable to plaintiffs under section 1983 for the violation of their procedural due process rights based on the allegations contained in the complaint. Accordingly, the court affirmed the judgment. View "Slaven, et al v. Engstrom, et al" on Justia Law

Plaintiff, an employee of Cargill, sued under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., asserting FMLA entitlement and retaliation claims. The district court granted Cargill's motion for summary judgment on both claims. The court held that plaintiff had provided insufficient evidence for a reasonable jury to find that she gave Cargill adequate notice under the FMLA; plaintiff's notice requirement was not excused on the basis of extraordinary circumstances; and there were no genuine issues of material fact as to her failure to satisfy her notice obligation under the FMLA and therefore, the district court did not err in dismissing plaintiff's entitlement claim. Further, plaintiff failed to make a prima facie case for FMLA retaliation and the district court did not err in dismissing this claim. View "Bosley v. Cargill Meat Solutions Corp." on Justia Law

Decedent, father of plaintiffs, died without naming a beneficiary of his Unum life insurance. Plaintiffs sued Unum, asserting a breach of the policy and an Employee Retirement Income Security Act, 29 U.S.C. 1002 et seq., violation. The district court concluded that they lacked standing and dismissed the suit. The court concluded that the estate's decision not to appeal precluded the children from having a reasonable or colorable claim to benefits. Because plaintiffs could not become entitled to benefits, the court held that the district court properly dismissed the case. View "A.J., et al v. UNUM, et al" on Justia Law

Kathleen Marez sued her former employer, Saint-Gobain Containers, Inc. for unlawful termination. Marez claimed that Saint-Gobain retaliated against her in violation of the family Medical Leave Act (FMLA) and that Saint-Gobain committed gender discrimination in violation of the Missouri Human Rights Act (MHRA). A jury returned a verdict in Marez's favor on the FMLA claim and in Saint-Gobain's favor on the gender discrimination claim. The district court awarded Marez liquidated damages and part of her requested attorneys' fees. The Eighth Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the jury's verdict in Marez's favor; (2) the district court did not abuse its discretion in awarding liquidated damages, as Saint-Gobain was liable for employment discrimination under the cat's-paw theory of liability, and liquidated damages may be awarded in eligible FMLA cases premised on cat's-paw liability; and (3) the district court did not abuse its discretion in its award of attorneys' fees. View "Marez v. Saint-Gobain Containers, Inc." on Justia Law

Appellant appealed the district court's grant of summary judgment in favor of her employer, G4S Youth Services, LLC, and her supervisor, Todd Speight (Appellees), on Appellant's claims that they terminated her employment based on her race, age, and use of family medical leave. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant did not create a genuine issue of material fact as to whether G4S's legitimate, non-discriminatory reason for terminating her employment was merely a pretext for intentional race of age discrimination, the district court did not err in granting summary judgment in favor of Appellees on Appellant's race and age discrimination claims; and (2) because Appellant failed to raise a genuine issue of fact as to whether G4S retaliated against her for exercising her FMLA rights, the district court did not err in granting summary judgment on Appellant's Family and Medical Leave Act claims. View "Bone v. G4S Youth Servs., LLC" on Justia Law

The Governor and Attorney General of South Dakota, along with two intervening crisis pregnancy centers and two of their personnel appealed the district court's permanent injunction barring enforcement of a South Dakota statute requiring the disclosure to patients seeking abortions of an "increased risk of suicide ideation and suicide" and the underlying grant of summary judgment in favor of Planned Parenthood of Minnesota, North Dakota, South Dakota and its medical director Dr. Carol Ball. The district court found that this advisory would unduly burden abortion rights and would violate physicians' First Amendment right to be free from compelled speech. The Eighth Circuit Court of Appeals reversed, holding that on its face, the suicide advisory presented neither an undue burden on abortion rights nor a violation of physicians' free speech rights. View "Planned Parenthood Minn, N.D., S.D. v. Rounds" on Justia Law

Plaintiff filed a lawsuit against Comcast claiming that the company interfered with his ability to request an excused absence under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601-54, and that his termination from employment was based on the interference, as well as retaliation of his prior FMLA absences. Plaintiff lost his employment with Comcast when he failed to show up for work on three consecutive shifts and failed to notify his department of his absences or to request leave under the FMLA. Plaintiff's unilateral determination that he was fired did not excuse him from his responsibility to return Comcast's phonecalls or otherwise confirm his employment status before he stopped showing up to work or calling in to request additional FMLA leave. Plaintiff had many opportunities to correct his misperception that he had been terminated before missing three consecutive work shifts. Therefore, the court held that the record did not support plaintiff's claim of interference against Comcast and the court affirmed the judgment.

Plaintiff sued his employer, alleging that his termination was the result of interference with and retaliation for his exercise of his rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., and racial discrimination in violation of 42 U.S.C. 1981. The district court granted summary judgment for the employer and plaintiff appealed. The court affirmed the judgment because plaintiff failed to raise a genuine issue of material fact that the employer's actions were a pretext for discrimination. Plaintiff's testimony that the racially hostile environment had abated since his first lawsuit was settled in his numerous uses of FMLA leave without negative consequences supported the employer's non-discriminatory and non-retaliatory justification for plaintiff's termination.

Petitioner appealed the district court's dismissal of her petition seeking half the proceeds of the sale of stock that was ordered forfeited in her ex-husband's conviction for mail fraud and money laundering in connection with the Thomas Petters Ponzi scheme. The court concluded that petitioner did not allege a legal interest in the stock proceeds sufficient to confer standing, and that, even if she did, her petition failed on the merits. Accordingly, the court affirmed the judgment.