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

Travelex filed suit against defendant to enforce an alleged agreement restricting her ability to compete with Travelex by soliciting business from certain customers. The district court granted partial summary judgment in favor of defendant, determining that the purported agreement was unenforceable.The Eighth Circuit reversed and remanded, holding that summary judgment was not warranted. In this case, the district court concluded that the agreement was unenforceable because the 2008 agreement became a nullity when Travelex was acquired by Cover-More and defendant refused to sign a new agreement as a condition of continued employment and was terminated. The court held that defendant's refusal to sign the new agreement nullified the prior agreement. The court also held that defendant's alternative argument, that under New York law restrictive covenants may not be enforced when an employee is dismissed without cause, does not apply because the non-solicitation agreement is not unreasonable as a matter of law. View "Travelex Insurance Services, Inc. v. Barty" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Air Evac in an action brought by plaintiff, alleging unpaid overtime wages in violation of the Fair Labor Standards Act (FLSA).The court agreed with the district court that Air Evac is a "carrier by air," and thus plaintiff's job as a flight paramedic was exempt from the FLSA's overtime requirements. In this case, Air Evac is not equitably estopped from asserting that the position is exempt, and thus the district court did not abuse its discretion in concluding that plaintiff's reliance on a letter to argue to the contrary was unreasonable because Air Evac had otherwise clearly and consistently communicated its overtime policy to plaintiff. Furthermore, the air-carrier exemption applies because Air Evac is a common carrier where Air Evac is willing to provide transportation services for hire to all within its definable segment and it does not discriminate within its segment. View "Riegelsberger v. Air Evac EMS, Inc." on Justia Law

FEI, Crop Venture's successor-in-interest, filed suit alleging that the individual defendants took proprietary information they developed at Crop Ventures after they left the company and co-founded Farmobile (the corporate defendant). Specifically, FEI alleges that the individual defendants' behavior constituted a breach of explicit or implicit contracts with the company; defendants were obligated to assign to their employer the ownership rights of products they worked to develop; the individual defendants breached their duty of loyalty to their employer; and the individual defendants misappropriated trade secrets. The district court denied in full FEI's motion, and granted in part and denied in part Farmobile's motion.The Eighth Circuit affirmed and held that because no contract bound the parties during Defendant Nuss' term of employment, Nuss was not in breach of an explicit contract; FEI has not shown that any of the individual defendants was similarly "specifically directed" during their product-development process, so no implied contracts were created under the hired-to-invent doctrine; FEI failed to show the individual defendants breached their duty of loyalty to their employer; FEI cannot maintain a trade secret claim under the Nebraska Trade Secrets Act (NTSA) or the federal Defend Trade Secrets Act (DTSA); and the remaining claims are unpersuasive. View "Farmers Edge Inc. v. Farmobile, LLC" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of BNSF in an action brought by plaintiff, alleging a claim of retaliation for engaging in protected activity under the Federal Railroad Safety Act (FRSA).The court held that, in order to make a prima facie case of unlawful retaliation under the FRSA, an employee must show, by a preponderance of the evidence: (i) he engaged in a protected activity; (ii) the rail carrier knew or suspected, actually or constructively, that he engaged in the protected activity; (iii) he suffered an adverse action; and (iv) the circumstances raise an inference that the protected activity was a contributing factor in the adverse action. Furthermore, the contributing factor that an employee must prove is intentional retaliation prompted by the employee engaging in protected activity. In this case, the court held that the record as a whole could not lead a rational trier of fact to find that plaintiff's injury report prompted BNSF to intentionally retaliate against him. View "Neylon v. BNSF Railway Co." on Justia Law

The Eighth Circuit reversed the district court's dismissal of the union's claims against Trane concerning an arbitration award. In this case, the June Award indicated that the arbitrator did not intend for it to be final because he explicitly retained jurisdiction "until the terms of the award are met." When a dispute did arise regarding damages, the arbitrator resolved that dispute in the September Award and then expressly stated that he was "no longer retaining jurisdiction in this matter." Therefore, the express relinquishment of jurisdiction in the September Award indicated that the arbitrator intended the September Award to be final and did not contemplate further disputes regarding the award.The court held that the union is not time-barred from seeking to vacate the arbitration award because the text of the June Award indicates that it was not the final award. The court stated that the September Award is the final award and the union filed its claim to vacate within 90 days of it. Therefore, the union's claim was timely and the district court erred in concluding otherwise. The court remanded for further proceedings. View "International Union v. Trane U.S. Inc." on Justia Law

Plaintiff filed suit alleging a sex discrimination claim for a failure to promote against the County of Wright and the Wright County Sheriff's Department under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA).The Eighth Circuit affirmed the district court's grant of summary judgment to the County, holding that plaintiff failed to present evidence that one of the reasons for the chief deputy's actions in not promoting plaintiff was gender animus; plaintiff failed to argue that the interview notes show that the other panelists' negative impressions of her were pretextual, or that the chief deputy was somehow responsible for their negative impressions; and plaintiff failed to point to any evidence of gender animus from the other panelists. The court also held that the district court did not err by concluding that plaintiff failed to raise a genuine issue of material fact as to her cat's-paw theory. View "Pribyl v. County of Wright" on Justia Law

This appeal stemmed from a collective bargaining agreement (CBA) dispute between the parties where an arbitrator resolved the dispute in favor of the union. The Eighth Circuit held that because the arbitrator was arguably construing or applying the contract and acting within the scope of his authority, there is no basis for vacating the arbitrator's finding that Exide violated the CBA.The court also held that the district court correctly determined that it did not have jurisdiction over Exide's claim that the arbitrator's decision that unilaterally changing Family Medical Leave Act leave administrators was a material, substantial and significant change in the employees' terms and conditions of employment in violation of Section 8 of the National Labor Relations Act. Rather, Congress has empowered the NLRB to resolve unfair-labor-practice claims in the first instance. Furthermore, the cases cited by the parties do not expand the court's original jurisdiction. View "Exide Technologies v. International Brotherhood of Electrical Workers" on Justia Law

Plaintiff filed suit under Title VII against Midwest after it allegedly withdrew his job offer after learning that he was gay. The Eighth Circuit reversed the district court's dismissal based on Williamson v. A.G. Edwards & Sons, Inc., 876 F.2d 69, 70 (8th Cir. 1989), and remanded for further proceedings in light of the Supreme Court's decision in Bostock v. Clayton Cty., 590 U.S. ___, Nos. 17-1618, 17-1623, 18-107, slip op. at 4 (June 15, 2020), which held that it "defies" Title VII for "an employer to discriminate against employees for being homosexual or transgender," because to do so, it "must intentionally discriminate against individual men and women in part because of sex." View "Horton v. Midwest Geriatric Management" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Koss in an action brought by plaintiff, a former employee, alleging that Koss terminated her employment in retaliation for her complaints about pay discrimination based on sex in violation of the Equal Pay Act (EPA).The court held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact as to pretext. In this case, plaintiff failed to present sufficient evidence as to the question of whether there was no basis in fact for Koss's proffered reason for her termination: there was lack of work at the project. The court also held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact on the question of whether a retaliatory reason more likely motivated the manager's decision to terminate her. View "Yearns v. Koss Construction Co." on Justia Law

Plaintiff filed suit against the railroad under the Missouri Human Rights Act (MHRA) and the Family and Medical Leave Act (FMLA), alleging that the railroad discriminated against her on the basis of her gender and her use of FMLA leave when it terminated her. The railroad maintains that plaintiff was terminated as part of a reduction in force (RIF) without discriminatory intent.The Eighth Circuit affirmed the district court's grant of summary judgment to the railroad, holding that the affidavits that the district court relied on were not sham affidavits; plaintiff failed to present any evidence to create a genuine dispute of material fact that her gender was a contributing factor in her termination; the RIF was legitimate and plaintiff failed to demonstrate evidence showing that her gender was a contributing factor in her termination; and thus the district court properly granted the railroad summary judgment on plaintiff's MHRA gender-discrimination claim. Because plaintiff does not offer any direct evidence that the railroad terminated her in the RIF for exercising her FMLA rights, the court analyzed her claim under the McDonnell Douglas burden-shifting framework. In this case, the railroad proffered a legitimate, nondiscriminatory reason for terminating plaintiff and she failed to show that the stated reason was a pretext for FMLA discrimination. View "Button v. Dakota, Minnesota & Eastern Railroad Corp." on Justia Law