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

Appellant, who had been on a medical leave of absence from appellee for nearly four months, sued appellee alleging violations of the Family and Medical Leave Act ("FMLA"), 29 U.S.C. 2612(a)(1), and the benefits-termination notice provisions of the Consolidated Omnibus Budget Reconciliation Act ("COBRA"), 29 U.S.C. 1166(a)(4)(A), when appellee fired him for job abandonment. Appellant appealed the district court's grant of summary judgment in favor of appellee on each of his claims. The court held that the district court properly granted summary judgment to appellee on appellant's interference claim under the FMLA where appellant failed to demonstrate any prejudice as a result of his firing on May 1, 2007. The court also held that the district court properly granted summary judgment to appellee on appellant's claim that appellee failed to provide him with notice of the termination of his benefits as required by COBRA where appellant failed to show that a genuine factual dispute existed regarding the means used by appellee to send the notice and where the undisputed facts showed that appellee used a notice method "reasonably calculated to reach" appellant.

Defendant appealed from the district court's grant of summary judgment in favor of plaintiff, compelling arbitration of a dispute related to healthcare benefits under an expired collective bargaining agreement. At issue was whether the district court erred in granting plaintiff's motion for summary judgment and issuing an order compelling the arbitration. The court reversed and held that the district court erred in granting summary judgment and compelling arbitration where both parties vigorously disputed issues of both law and fact, including whether the 1994 agreement was ambiguous and whether the summary plan descriptions constituted an intrinsic or extrinsic evidence of the parties' intent. The parties also point to various other extrinsic evidence and vehemently disagree as to whether the bargained for fully-paid health insurance premiums for life or just for the term of the agreement. Under these circumstances, the court held that the question of whether the right to fully-paid premiums vested under the 1994 agreement was best decided in the first instance by the district court and therefore, remanded for further proceedings.

Owatonna Clinic-Mayo Health System ("Clinic") sued its insurer, Medical Protective Company ("Medical Protective"), claiming that the company had breached its obligation to defend and indemnify the Clinic in a medical malpractice suit that had resulted in a judgment against it. At issue was whether the district court erred in ruling as a matter of law that the Clinic's notice to Medical Protective, of a potential claim against it, conformed to the insurance policy requirements and whether the Clinic's belief that it was at risk was objectively reasonable. Also at issue was whether the Clinic was entitled to pre-judgment interest. The court affirmed the judgment and held that the Clinic was deemed to have filed a timely notice with Medical Protective where the information that Medical Protective received would obviously alert a reasonable insurer to the likelihood of possible allegations of liability on the Clinic's part. The court also held that Medical Protective's challenge to the district court's finding, that the Clinic's belief that it was at risk was objectively reasonable, was meritless where the quoted policy language set an exceedingly low bar. The court further held that the district court did not err in awarding pre-judgment interest under Minn. Stat. 60A.0811, subd. 2(a) where the statute was unambiguous; and, in the alternative, if the statute was ambiguous, the court construed it against the insurer.

Plaintiff sought disability insurance benefits under the Social Security Act, alleging that migraine headaches, affective mood disorder, and mayofascial back pain left her unable to work. At issue was whether the administrative law judge's ("ALJ") decision was supported by substantial evidence and whether the ALJ properly weighed physicians' opinions in determining plaintiff's residual functional capacity. The court concluded that substantial evidence supported the ALJ's decision to discredit plaintiff's subjective complaints where none of her doctors reported functional or work related limitations due to her headaches and where there was no basis for her creditability. The court also held that the ALJ properly weighed the physicians' opinions in determining plaintiff's residual functional capacity.

Plaintiff filed a petition for equitable garnishment against State Farm Mutual Automobile Insurance Company ("State Farm") after she was injured at a crosswalk from a truck driver, the insured under State Farm's policies, who negligently struck and injured her. At issue was whether plaintiff could recover additional amounts from State Farm where State Farm's policy contained an "anti-stacking" clause and an "excess coverage" clause. The court reversed the district court's ruling that plaintiff could stack State Farm's liability limits in each of its four policies where Paragraph 3 of the policy did not create an ambiguity that permitted a court to ignore the unambiguous anti-stacking clause in Paragraph I. The court also remanded to the district court to decide whether a single insurer, having issued four policies to the owner of four vehicles who then negligently caused an accident while driving a non-owned vehicle, may enforce its anti-stacking clause after it satisfied the minimum Missouri's Motor Vehicle Financial Responsibility Law's, State. 303.010 et seq., coverage requirement.

Plaintiff, a urologic surgeon of 18 years, sued defendant seeking disability benefits under the terms of his disability insurance policy with defendant after he developed a degenerative ankle condition which prevented him from doing surgical procedures that required standing for more than an hour and a half. At issue was whether the district court erred in granting plaintiff's post-trial motion to correct the special verdict; in awarding prejudgment interest; and in denying defendant's post-trial motions for judgment as a matter of law, a new trial, and declaration of mistrial. The court held that the district court did not clearly abuse its discretion where its finding was supported by the jury's response to Question Six on the special verdict form and in amending the judgment, the district court was merely correcting a mistake that appeared on the face of the verdict; the district court erred in awarding prejudgment interest under Minnesota common law where it would be inequitable to award prejudgment interest when plaintiff prevented defendant from determining the amount of its potential liability by failing to provide the relevant financial information; the district court properly concluded that plaintiff's residual disability claim was not barred by the statute of limitations; the court need not decide whether the district court erred in submitting the residual disability benefits issue to the jury because defendant was estopped from making that argument under the invited error doctrine; and the district court did not err in denying defendant's motion for a mistrial based on a post-trial communication from a member of the jury concerning deliberations.