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

After the death of Dana Kleinsteuber, her husband, Charles Kleinsteuber, sought accidental death and dismemberment (AD&D) benefits under an ERISA-governed insurance plan administered and insured by Metropolitan Life Insurance Company (MetLife). Dana Kleinsteuber, who suffered from end-stage renal disease (ESRD) due to a long history of an eating disorder, was using home dialysis as treatment. On the day of her death, she apparently failed to properly close her chest port after a dialysis session, resulting in severe blood loss and subsequent cardiac arrest. Emergency responders stopped the bleeding, but she died shortly after.MetLife initially denied the claim on the basis that Dana’s death resulted from natural causes related to her ESRD, and that an exclusion in the plan applied for losses caused or contributed to by illness or its treatment. Following an extensive administrative appeal submitted by Mr. Kleinsteuber, which included evidence from Dana’s doctor and other records, MetLife reconsidered and acknowledged the death was accidental. However, it maintained the exclusion applied because the death was caused or contributed to by the treatment for her ESRD. After Mr. Kleinsteuber exhausted his administrative remedies, he filed suit in the United States District Court for the District of Minnesota. The district court granted summary judgment for MetLife, finding the exclusion applicable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that MetLife provided a full and fair review and that its conflict of interest deserved little weight. The court interpreted the plan exclusion de novo, finding that the ordinary meaning of “caused or contributed to” included Dana’s death under these circumstances. Applying an abuse-of-discretion standard to MetLife’s ultimate decision, the court found substantial evidence supported the denial. As a result, the Eighth Circuit affirmed the district court’s judgment, upholding MetLife’s denial of benefits. View "Kleinsteuber v. Metropolitan Life Ins. Co." on Justia Law

General Electric Company (GE) was assessed withdrawal liability by the Boilermaker-Blacksmith National Pension Trust (the Fund) under the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), which amended the Employee Retirement Income Security Act (ERISA). The Fund claimed that GE partially withdrew from the plan based on a 70% decline in contribution base units (CBUs) and the closure of a manufacturing facility in Chattanooga, resulting in liability assessments totaling over $227 million. GE disputed these assessments, arguing that it qualified for the “building and construction industry” (BCI) exception, which exempts certain employers from withdrawal liability if substantially all their covered employees perform work in the building and construction industry.An arbitrator considered the dispute and found in favor of GE, concluding that it met the requirements for the BCI exception. Both parties sought review in the United States District Court for the Western District of Missouri, which affirmed the arbitrator’s decision. The district court determined that the statutory language was ambiguous regarding how to count employees for the purpose of the BCI exemption and adopted GE’s cumulative headcount method rather than the Fund’s preferred monthly headcount method.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s legal conclusions de novo and examined the ambiguity in the statutory language. The Court held that, of the two methods presented, the cumulative headcount approach advanced by GE was more consistent with the purpose and legislative intent of the statute, which was designed to accommodate the fluctuating nature of employment in the building and construction industry. The Court affirmed the district court’s judgment, holding that GE qualified for the building and construction industry exemption and was not liable for withdrawal assessments. View "General Electric Company v. Boilermaker-Blacksmith National Pension Trust" on Justia Law

Angela Kendall was employed as a production operator by a manufacturing company that required physical tasks such as standing for up to 12 hours, lifting, bending, and reaching. In 2021, after suffering from back pain and being diagnosed with muscle spasms and potential sciatica, Kendall received a temporary workplace accommodation allowing her to sit occasionally during her shifts. Over time, her medical restrictions increased, including limitations on standing, bending, lifting, and other physical activities. After exhausting her leave and with no foreseeable return to unrestricted work, her employment was terminated.Kendall filed discrimination charges, alleging her employer failed to accommodate her disability and retaliated in violation of the Americans with Disabilities Act (ADA), and discriminated based on sex in violation of Title VII. The United States District Court for the Eastern District of Missouri granted summary judgment to the employer on all claims, finding that Kendall was not qualified for her position because she could not perform its essential functions, even with reasonable accommodation, and that there was no evidence of adverse employment action based on retaliation or sex.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that standing for extended periods, lifting, bending, and other physical tasks were essential functions of the production operator position, as evidenced by the job description and employer’s expectations. Kendall’s medical restrictions prevented her from performing these essential duties, and allowing her to sit as needed was not a reasonable permanent accommodation. The court also found that Kendall failed to establish a prima facie case of sex discrimination because she was not qualified for her position at the time of termination. Accordingly, the Eighth Circuit affirmed the district court’s judgment in favor of the employer. View "Kendall v. Zoltek Corporation" on Justia Law

Edward Beard, a participant in an employer-sponsored ERISA plan administered by Lincoln National Life Insurance Company, died after suffering a fall and subsequent subdural hematoma. Mr. Beard had stage IV pancreatic cancer and was taking a blood thinner due to an increased risk of blood clots. The fall occurred while he was rushing to the bathroom, and although an initial hospital visit revealed no issues, he was found unresponsive the following day and died after a second hospital visit revealed a large subdural hematoma. His wife, Tina Beard, filed a claim for accidental death and dismemberment (AD&D) benefits, asserting that his death resulted from an accidental injury.The United States District Court for the Southern District of Iowa reviewed the administrative record after Lincoln Life denied the claim. Lincoln Life concluded that Mr. Beard’s death was not solely the result of an accidental injury and invoked a plan exclusion since his blood thinner, used to treat his cancer-related clotting risk, contributed to his death. The district court granted judgment in favor of Lincoln Life, finding its interpretation of the plan reasonable and supported by substantial evidence, including medical reports indicating the blood thinner contributed to the fatal outcome.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the plan administrator’s decision for abuse of discretion, as the plan granted Lincoln Life discretionary authority to interpret its terms. The appellate court found that Lincoln Life’s interpretation of the plan terms and application of the exclusion were reasonable and supported by substantial evidence. The court held that Mrs. Beard failed to prove the loss resulted solely from an accident, and that Lincoln Life established the plan exclusion applied because the blood thinner contributed to Mr. Beard’s death. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "Beard v. Lincoln Nat'l Life Ins. Co." on Justia Law

Jason Schmit, a truck driver for Trimac Transportation, Inc., was diagnosed with Parkinson’s disease in 2018. Following his diagnosis, Trimac provided informal accommodations, allowing Schmit to perform tasks that avoided climbing, pulling hoses, or making certain connections, and adjusting his work schedule to end earlier in the day. In 2021, after a new terminal manager was hired, Schmit was asked to formalize his accommodation requests, which Trimac largely approved. However, Schmit encountered difficulties, including changes in internal shop procedures that affected his ability to perform required tasks, disputes about hauling heavy loads, and disciplinary actions for job violations. Schmit complained to Human Resources about alleged harassment and difficulties related to his disability, but Trimac concluded its policies were being properly enforced. In August 2021, following a dispute, Schmit left work and Trimac treated his departure as a resignation. Schmit later applied for and received Social Security disability benefits, representing that his condition made it impossible for him to work.The United States District Court for the District of South Dakota dismissed Schmit’s state law claims for failure to exhaust administrative remedies and granted summary judgment to Trimac on the remaining claims. The district court found genuine disputes existed regarding whether Schmit resigned or was fired and whether there was discriminatory intent, but determined that Schmit’s statements to the Social Security Administration prevented him from showing that he was a “qualified individual” under the ADA.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that Schmit failed to adequately explain the contradiction between his representations to the Social Security Administration and his litigation position, barring his ADA claim. The court also concluded that Schmit failed to establish a hostile work environment, retaliation, or wrongful termination under South Dakota law. The judgment of the district court was affirmed. View "Schmit v. Trimac Transportation, Inc." on Justia Law

After being employed by the City of St. Louis as a corrections officer for over two decades, the plaintiff was transferred to a clerk typist position in the City’s towing division following an injury. In her new role, she uncovered and reported numerous instances of apparent misconduct and fraud involving the unlawful sale or transfer of vehicles by employees at the tow lot. She conveyed her concerns to various city officials, including her supervisors, the mayor’s office, and the comptroller’s office, and ultimately disclosed the information to the media. Following these disclosures, she experienced workplace retaliation and was ultimately terminated by the Director of the Department of Streets the day after a news story, which included information she had provided, was broadcast.The United States District Court for the Eastern District of Missouri dismissed the First Amendment claim against the City but allowed the First Amendment retaliation claim against the Director, in his individual capacity, to proceed to trial. The jury found in favor of the plaintiff, concluding that her protected speech was a motivating factor in her termination, and awarded compensatory and punitive damages. The district court denied the Director’s post-trial motions for judgment as a matter of law and for a new trial.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the Director failed to preserve his qualified immunity defense for appeal and found that there was sufficient evidence for the jury to find that the plaintiff’s protected speech motivated her termination. The court further determined that the district court did not abuse its discretion in admitting contested evidence or in denying a new trial, and that there was enough evidence for punitive damages. The Eighth Circuit affirmed the district court’s judgment. View "Woods v. City of St. Louis, Missouri" on Justia Law

The plaintiff, a Hawaii resident, entered into a National Employment Agreement with Cardiovascular Systems, Inc. (CSI), a Minnesota-based medical device company, to serve as District Sales Manager for Hawaii. The agreement required him to complete mandatory training in Minnesota before he could work fully in Hawaii. He attended training in Minnesota for a total of twelve days over two visits during early 2023 and participated in remote meetings from Hawaii. Shortly after completing training, CSI terminated his employment. The plaintiff alleged that his termination was in retaliation for reporting illegal conduct in violation of federal law, while CSI claimed it was due to his conduct. Subsequently, Abbott Laboratories, Inc. acquired CSI.The plaintiff first filed a complaint in Minnesota state court against Abbott Laboratories, Inc. (ALI) under the Minnesota Whistleblower Act (MWA). ALI removed the case to federal court and moved to dismiss the complaint. After an unsuccessful attempt to amend his complaint, the plaintiff voluntarily dismissed the action and refiled a nearly identical complaint, later amending it to add CSI as a defendant and a claim under the Hawaii Whistleblowers’ Protection Act (HWPA). The defendants again moved to dismiss, and the plaintiff sought to further amend the complaint to add more details and another defendant.The United States District Court for the District of Minnesota granted the motion to dismiss, holding that the plaintiff did not qualify as an “employee” under the MWA because he neither performed “services for hire” nor maintained ongoing physical presence in Minnesota, and that he had waived his HWPA claim by agreeing to a Minnesota choice-of-law provision in his employment contract. The Eighth Circuit Court of Appeals affirmed, concluding that the district court correctly applied Minnesota law, enforced the choice-of-law provision, and properly denied leave to amend as futile. View "Ghosh v. Abbott Laboratories" on Justia Law

Midwest Division-RMC, LLC operates a hospital in Kansas City, Missouri, and has had collective bargaining relationships with two unions: the Service Employees International Union HCII (SEIU) and the National Nurses Organizing Committee (NNOC). In June 2021, employees in the SEIU bargaining unit voted to decertify SEIU as their representative, but SEIU’s objections to the election were still pending before the National Labor Relations Board (NLRB). Midwest stopped recognizing SEIU and ceased processing grievances, taking actions that included halting dues deductions and denying SEIU access to the facility. Separately, after an unrelated grievance meeting in September 2021, NNOC’s labor representative was denied participation by Midwest.SEIU and NNOC filed unfair labor practice charges with the NLRB. An Administrative Law Judge found Midwest violated the National Labor Relations Act (NLRA) by withdrawing recognition from SEIU before the election was certified and by preventing the NNOC representative from attending the grievance meeting. The NLRB affirmed these findings and ordered Midwest to remedy both violations, but denied SEIU’s request for a notice reading remedy. Midwest sought review of these orders, the NLRB sought enforcement, and SEIU also petitioned for review regarding the remedy.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Midwest did not automatically violate the NLRA by withdrawing recognition from SEIU after the vote but before certification; instead, Midwest acted at its peril, and when the NLRB ultimately certified the decertification, Midwest’s actions did not violate the Act. The court reversed the NLRB’s order regarding SEIU and remanded with instructions to dismiss those claims. However, the court enforced the NLRB’s order regarding the NNOC grievance, finding that the collective bargaining agreement did not clearly limit the number of union representatives at the grievance meeting. View "Midwest Division-RMC, LLC v. NLRB" on Justia Law

During the COVID-19 pandemic, a county employer required its employees to either be fully vaccinated or undergo weekly COVID-19 testing. Employees could test at county facilities during work hours or use at-home test kits and count that time as work. Two employees objected to these requirements on religious grounds. One employee, Borgheiinck, asserted that mandatory vaccines and testing conflicted with her Christian beliefs about bodily autonomy. She was initially given unpaid leave as an accommodation, but the county later revoked this, citing undue hardship, and ultimately terminated her after not responding to her proposals for alternative work arrangements. The other employee, Colson, also objected on religious grounds. She was granted an exemption from nasal swab testing and allowed to use saliva tests, which she found intrusive and non-private, but she was not terminated.The United States District Court for the District of Minnesota dismissed all claims, including those under Title VII. The plaintiffs sought leave to file a motion for reconsideration based on new legal precedent, but the court denied this request. The plaintiffs appealed the dismissal of their Title VII claims and the denial of reconsideration.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. It held that Borgheiinck’s complaint did not sufficiently connect her religious beliefs to an objection to the testing policy, as required to state a plausible claim under Title VII. For Colson, the court held that she had not plausibly alleged that she suffered any adverse employment action, such as termination or unpaid testing time, since the county’s policy allowed testing during compensated time. The Eighth Circuit affirmed the district court’s dismissal of the Title VII claims and its denial of leave to seek reconsideration. View "Colson v. Hennepin County" on Justia Law

Donald Stephens was employed as an operator for United States Environmental Services, LLC, a position that required him to maintain a valid commercial driver's license (CDL). During a Saturday shift, Stephens refused to perform tasks typically assigned to technicians and raised several safety concerns, including inadequate equipment and staff. He also disclosed a heart condition to his supervisor. As a result, he was required to undergo a medical examination, which led to a 45-day medical hold on his CDL. Although he was medically cleared to perform non-driving work, USES denied his request for reassignment and recommended he seek short-term disability. After the hold was lifted and he was cleared to drive, Stephens resigned, claiming discomfort with his treatment by USES. Stephens filed suit in the United States District Court for the Eastern District of Arkansas, alleging disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Arkansas Civil Rights Act, as well as violations of the Fair Labor Standards Act (FLSA). The district court dismissed the FLSA claim and granted summary judgment to USES on the remaining claims. The court held that Stephens did not have a disability as defined by the ADA because his heart condition did not substantially limit a major life activity, and that USES did not regard him as disabled. The court also found that Stephens had not engaged in protected activity necessary to support a retaliation claim. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment ruling de novo. The appellate court affirmed the district court’s judgment, holding that Stephens did not demonstrate a substantial limitation of a major life activity and did not establish that he engaged in protected activity under the ADA. The Eighth Circuit also declined to consider an argument Stephens raised for the first time on appeal. View "Stephens v. U.S. Environmental Services LLC" on Justia Law