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

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.