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

Plaintiff sued her former employer for retaliation in violation of the Family Medical Leave Act, 29 U.S.C. 2615(a)(2). The district court granted the employer's motion for judgment as a matter of law. Because the employer did not offer a non-discriminatory reason for its alleged act, the proper inquiry for the district court was whether plaintiff's evidence was sufficient to establish a prima facie case. Because plaintiff failed to provide any other evidence linking her termination to her use of FMLA leave, a reasonable jury would not have a legally sufficient evidentiary basis to find for her on that issue. Therefore, the employer was entitled to judgment as a matter of law.

The Chapter 7 Trustee appealed from the Bankruptcy Court's judgment in favor of debtor's parents on a fraudulent transfer action, holding that debtor could not fraudulently transfer property that would have been exempt. Because the court concluded that the Bankruptcy Court erred in applying Minnesota fraudulent transfer law to the count seeking relief under section 548(a)(1)(B) of the Bankruptcy Code, the court reversed and remanded for further findings.

This case arose out of a dispute between plaintiff and her ex-husband over the education and custody of their three minor children. Plaintiff sued City Defendants, alleging that they unlawfully impeded her access to the children. Plaintiff sued the School District Defendants, asserting that they unlawfully denied her access to the children and their education records. The district court dismissed plaintiff's claims against the City Defendants for failure to state a claim and granted summary judgment for the School District Defendants. The court held that the fact that plaintiff lived in a different state did not suffice to convert the loss of a single three-hour visit into a deprivation of a fundamental right for purposes of substantive due process and, even if plaintiff could show a deprivation, the City Defendants' alleged conduct would not shock the conscience. The court also held that plaintiff failed to state a procedural due process claim against the City Defendants, given the relatively minimal deprivation alleged in this case, where the post-deprivation procedures were adequate to protect her rights to be heard at a meaningful time and in a meaningful manner. The court further held that plaintiff had no fundamental liberty interest in contacting her children at their schools and the court agreed with the district court that an attendance clerk's one-time refusal to tell plaintiff why one of the children had been absent from school, a coach's referral of plaintiff to her ex-husband for information about the children's swimming activities, and the school's refusal to send plaintiff all of the school's projects she requested did not amount to a deprivation of a fundamental liberty interest. Given the limited nature of any infringement of plaintiff's protected liberty interest, the procedures at issue were sufficient to protect plaintiff's right to procedural due process. The court finally held that plaintiff's right, as a non-custodial parent, under state law and her role in the children's lives vary significantly from the rights and role afforded to the ex-husband or to a typical married parent. Therefore, the court affirmed the grant of summary judgment to defendants with respect to her equal protection claims. Accordingly, the judgment of the district court was affirmed.

Planned Parenthood brought this equitable action against the Governor and Attorney General of South Dakota in their official capacities, seeking to enjoin enforcement of revisions enacted in 2005 to the South Dakota law on informed consent to abortion. The court held that because Planned Parenthood Minn., N.D., S.D. v. Rounds upheld the human being advisory against a facial challenge, the district court did not err in doing the same in this case. The court also held that the district court erred in holding the relationship advisories unconstitutional where they could be constitutionally applied to a "large fraction" of the women to whom they were relevant. The court further held that the district court did not err in granting Planned Parenthood summary judgment as to the suicide advisory where it violated due process and doctors' First Amendment right to be free from compelled speech that was untruthful, misleading, or irrelevant. The court finally held that the district court did not err in upholding the risk advisory where Planned Parenthood had not shown that the risk advisory would cause confusion in any case, let alone the quantum of cases required to sustain a facial challenge.

Appellee sued the Commissioner of the Social Security Administration (SSA), seeking review of the SSA's denial of benefits to her daughter. At issue was whether a child conceived through artificial insemination more than a year after her father's death qualified for benefits under the Social Security Act, 42 U.S.C. 402, 416. The Commissioner interpreted the Act to provide that a natural child of the decedent was not entitled to benefits unless she had inheritance rights under state law or could satisfy certain additional statutory requirements. The court held that the Commissioner's interpretation was, at a minimum, reasonable and entitled to deference, and that the relevant state law did not entitle the applicant in this case to benefits. Therefore, the court reversed the district court's judgments.

The Minch Family sued the Estate of the Norbys in diversity, seeking injunctive relief and damages for flooding of the Minch Family's property, allegedly caused by a field dike built on the Norbys' land. At issue was whether the district court erred in concluding that the Minch Family's claims were time-barred and whether the magistrate judge abused its discretion by denying the Minch Family's motion to amend its complaint to allege a claim for punitive damages and the Minch Family's motion to amend the scheduling order. The court held that the Minch Family had failed to meet its burden of showing that the applicable two year-statute of limitations should be tolled and its claims were untimely. The court held that because it had affirmed the district court's dismissal of the Minch Family's claims as time-barred, the issue of punitive damages was moot. The court further held that because the Minch Family's motion only related to its claim for punitive damages, the court need not address the issue of whether the magistrate judge abused its discretion in denying its motion to amend the court's scheduling order. Accordingly, the court affirmed the judgment of the district court.

Appellee filed a petition to return his 22-month-old daughter to Mexico pursuant to the Hague Convention on the Civil Aspects of Child Abduction (Convention), implemented by the International Child Abduction Remedies Act (ICARA), 42 U.S.C. 11601 et seq. Appellant, the estranged wife of appellee and mother of the child, opposed the petition. The district court subsequently entered an order granting the petition and appellant appealed, arguing that the district court erred in denying her motion for a continuance and in excluding the testimony of two witnesses. The court held that, given the underlying circumstances and the professed goal of expediency in Convention proceedings, the court agreed that the district court did not abuse its discretion in denying the motion for continuance. The court also held that the district court did not abuse its discretion in excluding testimony of the witnesses where the testimony would have been cumulative or not relevant.

Appellant, the named beneficiary of an accident benefits plan that her husband obtained through his employer, brought suit under ERISA, 29 U.S.C. 1001 et seq., alleging that the plan administrator, Metropolitan Life Insurance (Metlife), abused its discretion in determining that her husband was intoxicated at the time of the accident and denying coverage. At issue was whether the district court properly granted summary judgment to Metlife because Metlife's interpretation of the relevant policies was arbitrary and capricious and not supported by substantial evidence. The court held that Metlife did not abuse its discretion as plan administrator when it denied benefits based on the general exclusion for intoxication that appeared in the certificate of insurance. The court also held that the toxicology report, which concluded that the husband's blood alcohol level was above the state limit, constituted evidence that a reasonable mind might accept as adequate to support a conclusion and therefore, satisfied the substantial evidence standard. The court also held that because it agreed with the district court's conclusion that the denial of benefits was justified in light of the intoxication conclusion, it need not address Metlife's assertion that the husband's death was not accidental because it was reasonably foreseeable or, alternatively, the result of intentional self-inflicted injury. Accordingly, summary judgment was affirmed.

Debtor reopened his Chapter 13 bankruptcy proceedings and thereafter, moved the bankruptcy court to hold in contempt his former spouse and her subrogee, West Virginia's Department of Health and Human Resources, Bureau of Child Support Enforcement (BCSE), for violating the terms of debtor's confirmed Chapter 13 repayment plan by seeking income-withholding orders against him for child and spousal support arrears. The bankruptcy court refused to hold the former spouse or BCSE in contempt but did reduce the income withholding. On appeal, the Bankruptcy Appellate Panel (BAP) reversed and reinstated the income withholdings. Debtor timely appealed. The court held that 11 U.S.C. 1327(a) did not apply to this case because the bankruptcy court confirmed debtor's plan and the plan explicitly limited the former spouse's privilege to return to family court for the sole purpose of litigating child support interest. Although the Bankruptcy Code provided that, to be confirmed, a plan must provide for the full payment of accrued interest on child support and spousal support, 11 U.S.C. 101(14A), a confirmed plan was given res judicata effect even when it violated the Code. As for debtor's claim for post-petition child and spousal support, and interests thereon, the BAP correctly ruled that these claims were beyond the purview of the plan and the bankruptcy court's jurisdiction. Therefore, the BCSE income-withholding order could exceed the monthly payment schedule provided in debtor's plan. The court further held that the former spouse's recovery of post-petition spousal and child support was permitted because they were post-petition domestic support obligations for which the Bankruptcy Code allowed no proof of claim. Accordingly, the court affirmed in part and reversed in part, remanding for further proceedings.

Plaintiff brought this suit under ERISA, 29 U.S.C. 1001-1461, and the FMLA, 29 U.S.C. 2601-2654, against the state, the Iowa Department of Administrative Services (DAS), and two officials of the DAS. At issue was whether the district court properly granted defendants' motions to dismiss the complaint on the ground that the Eleventh Amendment barred plaintiff's FMLA claims against all of the defendants. The court held that the state's waiver of its state court immunity in FMLA cases had no bearing on the state's immunity from suit in federal court. Therefore, the state had not waived its Eleventh Amendment immunity and summary judgment was affirmed.