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

Marcus Todd, a state employee in Minnesota, alleged that a union violated his First and Fourteenth Amendment rights by deducting union dues from his paycheck without his consent. Todd joined the American Federation of State, County, and Municipal Employees in 2014 and authorized dues deductions. In 2018, a new authorization card was allegedly signed electronically with Todd's name, which he claims was forged. After the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, Todd attempted to resign from the union and stop dues deductions, but the union continued until May 2021, citing an annual opt-out period.The United States District Court for the District of Minnesota dismissed Todd's federal claims, stating that he voluntarily agreed to the dues deductions before Janus and was contractually bound to the opt-out period. The court also found that the union did not act under color of state law regarding the alleged forgery and dismissed Todd's claims for prospective relief as moot. The court declined to exercise jurisdiction over Todd's state law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Todd's claims failed due to the lack of state action, as the union's actions were based on private agreements, not state statutes. The court referenced Hoekman v. Education Minnesota and Burns v. School Service Employees Union Local 284, which established that private agreements for dues deductions do not constitute state action. The court also found that the alleged forgery did not establish state action, as it was a private misuse of state law. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Todd v. AFSCME" on Justia Law

An employee, Brandon Smith, was fired by Kansas City Southern Railway Company (KCSR) in 2018. His union, the International Association of Sheet Metal, Air, Rail, and Transportation Workers, Transportation Division (SMART-TD), challenged the dismissal under the collective-bargaining agreement (CBA) and the Railway Labor Act (RLA). The dispute went to arbitration, and in 2022, the National Railroad Adjustment Board (Board) overturned Smith's discharge, ordering his reinstatement with full benefits and back pay without deductions for outside earnings.The district court enforced the arbitration award, rejecting KCSR's argument that the award was ambiguous and required clarification. The court ordered KCSR to provide Smith with back pay without deductions and vacation benefits, and also awarded attorney fees to SMART-TD. KCSR appealed, arguing that the district court lacked jurisdiction and should have remanded the case to the Board for interpretation of the ambiguous award.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court erred in enforcing the award without remanding it to the Board for clarification, particularly regarding the vacation benefits, which were not explicitly addressed in the award. The court noted that the district court overstepped by interpreting the CBA, which is outside its jurisdiction under the RLA. The court also acknowledged that the Board had since clarified the back pay issue, rendering that part of the dispute moot.The Eighth Circuit reversed and vacated the district court's judgments, including the award of attorney fees, and remanded the case for further proceedings consistent with its opinion. The court emphasized the need for the Board to interpret any ambiguities in the arbitration award. View "Assoc.of Sheet Metal Workers v. K.C. Southern Railway" on Justia Law

Dr. Tara Gustilo, an Asian American obstetrician-gynecologist of Filipino descent, was demoted from her position as Chair of the OBGYN Department at Hennepin Healthcare System, Inc. (HHS) in April 2021. Following her demotion, she filed charges with the Equal Employment Opportunity Commission (EEOC) and subsequently sued HHS, alleging race discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA), as well as a First Amendment retaliation claim under 42 U.S.C. § 1983.The United States District Court for the District of Minnesota granted summary judgment in favor of HHS, finding no genuine dispute of material fact regarding the race discrimination, retaliation, and First Amendment claims. The court concluded that Dr. Gustilo failed to establish a prima facie case of race discrimination and that there was no evidence she opposed an unlawful employment practice. Additionally, the court found no material fact dispute regarding whether the HHS Board considered her Facebook posts in its decision to demote her.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court reversed the district court's grant of summary judgment on the First Amendment retaliation claim, finding that there was a material fact dispute regarding whether the HHS Board ratified the MEC's decision and the basis for it, which included consideration of Dr. Gustilo's Facebook posts. The court remanded the case for further proceedings to determine if the posts were protected speech and to apply the Pickering balancing test.The court declined to review the district court's summary judgment rulings on the Title VII and MHRA claims at this time, as they are now interlocutory. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Gustilo v. Hennepin Healthcare System, Inc." on Justia Law

Estella Morris, an employee of the Central Arkansas Veterans Healthcare System (CAVHS), filed civil-rights claims against her employer, alleging racial discrimination and retaliation. Morris, who is black, claimed she was denied a promotion to Chief of Social Work Service in favor of a white colleague, Anne Wright, despite having veteran preference. Morris also alleged that her pay upgrade request was sabotaged by her supervisor, Michael Ballard, in retaliation for her previous discrimination complaints.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of CAVHS. The court found that Morris had established a prima facie case of race discrimination but concluded that CAVHS had provided a legitimate, nondiscriminatory reason for promoting Wright—her more favorable references. The court held that Morris failed to show that this reason was a pretext for racial discrimination. Regarding the retaliation claim, the court found no evidence that Ballard's actions were causally linked to Morris's protected activities or that the person who denied the pay upgrade was aware of her discrimination complaints.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision de novo. The appellate court affirmed the summary judgment, agreeing that Morris did not demonstrate a causal connection between her race and the promotion decision. The court also found that Morris failed to show that Ballard's alleged sabotage of her pay upgrade request was linked to her protected activities. The court concluded that no reasonable jury could find that CAVHS's actions were motivated by racial discrimination or retaliation. View "Morris v. Department of Veterans Affairs" on Justia Law

Daniel’la Deering, an in-house lawyer for Lockheed Martin, was terminated and subsequently sued the company for discrimination and retaliation. While her discrimination claim was dismissed at the summary judgment stage, her retaliation claim was set to go to trial. However, during the litigation, Deering misled Lockheed Martin and the district court about her employment status and income. She falsely claimed to be employed by nVent and did not disclose her higher-paying job elsewhere, even submitting false information in a deposition, declaration, and settlement letters.The United States District Court for the District of Minnesota, presided over by Judge David S. Doty, found that Deering’s actions constituted intentional, willful, and bad-faith misconduct. Lockheed Martin discovered the deception shortly before the trial, leading to an emergency motion for sanctions. The district court dismissed Deering’s case with prejudice and awarded Lockheed Martin $93,193 in attorney fees. Deering’s motions for a continuance and reconsideration were also denied by the district court.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court did not abuse its discretion in dismissing the case due to Deering’s prolonged and intentional deception. The court emphasized that dismissal was appropriate given the severity and duration of the misconduct. Additionally, the appellate court found no abuse of discretion in the district court’s denial of Deering’s motions for a continuance and reconsideration. However, the appellate court dismissed Deering’s appeal regarding the attorney fee award due to a premature notice of appeal. View "Deering v. Lockheed Martin Corp." on Justia Law

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

Erica Barrett and other employees of O’Reilly Automotive, Inc. alleged that the company’s 401(k) plan managers breached their fiduciary duty by imposing high recordkeeping expenses and inflated expense ratios on the plan, resulting in less money for the participants. They claimed that these high costs were due to either incompetence or laziness on the part of the plan managers.The United States District Court for the Western District of Missouri dismissed the complaint. The court found that the plaintiffs failed to provide meaningful benchmarks to support their claim that the plan’s fees were excessive. Specifically, the court noted that the plaintiffs did not adequately compare the costs of O’Reilly’s plan with those of similar plans offering the same services.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court affirmed the district court’s decision, agreeing that the plaintiffs did not provide meaningful benchmarks to show that the plan’s fees were excessive. The court emphasized that the plaintiffs’ comparisons were flawed because they did not account for the different services included in the fees of the comparator plans. Additionally, the court found that aggregate data from the Investment Company Institute was insufficient to establish a plausible claim of mismanagement. The court also dismissed the failure-to-monitor claim against O’Reilly and its board of directors, as it was derivative of the primary claim. Finally, the court held that the district court did not abuse its discretion in dismissing the complaint with prejudice, as the plaintiffs did not formally request leave to amend their complaint. View "Barrett v. O'Reilly Automotive, Inc." on Justia Law

Raymond Black, a skilled mechanic at Swift Pork Company, was responsible for operating and fixing the loin-puller machine. He frequently took FMLA leave to care for his wife, who had severe cardiovascular disease. After returning to work from a bout of pneumonia, Black was reassigned to a different task, which led to a dispute with his supervisor. Black requested vacation time, which was denied, and then opted for FMLA leave to care for his sick wife. He was subsequently fired after a meeting with the human-resources director and plant manager.The United States District Court for the Southern District of Iowa granted summary judgment in favor of Swift Pork Company on both of Black's FMLA claims—interference and discrimination. Black then appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that there was sufficient evidence to create a jury question on whether Black's FMLA leave was medically necessary and whether Swift interfered with his FMLA rights by not crediting his absences and firing him. Therefore, the court reversed the summary judgment on the interference claim and remanded it for further proceedings.However, the court affirmed the summary judgment on the discrimination claim. The court concluded that there was no evidence that Swift fired Black because he took FMLA leave, especially given his extensive history of taking FMLA leave without repercussions. Negative comments from supervisors who did not make the termination decision were insufficient to establish a discriminatory motive.In summary, the Eighth Circuit reversed and remanded the interference claim but affirmed the dismissal of the discrimination claim. View "Black v. Swift Pork Company" on Justia Law

Mychal Byrd was injured in an automobile accident caused by an unknown motorist and subsequently died from his injuries. Byrd's medical expenses, totaling $474,218.24, were covered by the Gilster-Mary Lee Corporation Group Health Benefit Plan, a self-funded plan subject to ERISA. Byrd had an automobile insurance policy with Nationwide Insurance Company, which provided $50,000 in uninsured-motorist coverage. After Byrd's death, his family sued Nationwide in state court to collect the insurance proceeds. The Plan intervened, removed the case to federal court, and claimed an equitable right to the insurance proceeds.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the Plan, determining that the Plan was entitled to the insurance proceeds under the plan document. The plaintiffs, initially proceeding pro se, did not respond to the motion for summary judgment. After obtaining counsel, they moved for reconsideration, which the district court denied. The plaintiffs then appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the district court lacked subject-matter jurisdiction. The appellate court determined that the plaintiffs' claim did not fall within the scope of ERISA's civil enforcement provisions because the plaintiffs were neither plan participants nor beneficiaries. Consequently, the claim was not completely preempted by ERISA, and the federal court did not have jurisdiction. The Eighth Circuit vacated the district court's judgment and remanded the case with instructions to return it to Missouri state court. View "Kellum v. Gilster-Mary Lee Corporation Group Health Benefit" on Justia Law

Covenant Construction Services, LLC was the prime contractor on a federal construction project for a U.S. Department of Veterans Affairs facility in Iowa City, Iowa. Covenant subcontracted with Calacci Construction Company, Inc. to supply carpentry labor and materials. Calacci had a collective bargaining agreement (CBA) with two regional unions, requiring it to pay fringe-benefit contributions to the Five Rivers Carpenters Health and Welfare Fund and Education Trust Fund (the Funds). Despite multiple demands, Calacci failed to remit the required contributions.The Funds filed a lawsuit under the Miller Act to collect the unpaid contributions, liquidated damages, interest, costs, and attorneys' fees from Covenant and its surety, North American Specialty Insurance Company. The United States District Court for the Southern District of Iowa granted summary judgment in favor of the Funds, concluding that the Funds had standing to sue and that the Miller Act notice was properly served and timely.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the Funds sufficiently complied with the Miller Act's notice requirements by sending the notice to Covenant's attorney, who confirmed receipt. The court also held that the notice was timely as it was filed within 90 days of the last day of labor on the project. Additionally, the court upheld the award of liquidated damages and attorneys' fees, finding that the CBA obligated Calacci to pay these amounts and that Covenant, as the prime contractor, was liable for the amounts due under the payment bond.The Eighth Circuit concluded that the Funds were entitled to recover the unpaid contributions, liquidated damages, and attorneys' fees from Covenant and its surety, affirming the district court's judgment. View "Five Rivers Carpenters v. Covenant Construction Services" on Justia Law