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

Sysco Minnesota filed suit against Local 120 under section 301 of the Labor Management Relations Act (LMRA) for violating their collective bargaining agreement (CBA). The Eighth Circuit held that Local 120 waived its right to the CBA's prescribed non-judicial grievance procedures, including arbitration. In this case, Local 120's failure to seek relief under the CBA’s prescribed grievance procedures in a timely manner caused the parties to complete all discovery and litigate the merits of Sysco Minnesota's breach claim. Furthermore, the district court did not err in finding that Local 120 violated the picket line clause in the CBA; Local 120 waived the right to engage in sympathy strikes; and the court was not persuaded that Local 120 did not authorize, participate in, or ratify the picket line. View "Sysco Minnesota, Inc. v. Teamsters Local 120" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the County on plaintiff's claim of interference with her rights under the Family Medical Leave Act (FMLA) and retaliation against her for asserting those rights. Plaintiff's claims arose when she was put on administrative leave following an investigation into her involvement in her husband's sexual abuse of their children. The court held that plaintiff failed to show any prejudice from the County's delay in acting on her FMLA request or its failure to give her notice of her FMLA rights. The court rejected the FMLA interference claim, holding that plaintiff was neither asked to nor required to complete work-related tasks while on leave. Rather, the activities plaintiff was asked to do related to the underlying child-protection investigation, her FMLA request, and her employment status.The court also held that the County was entitled to summary judgment on plaintiff's discrimination claim where the undisputed sequence of events does not demonstrate a causal link between her FMLA request and the Board's decision to proceed with a meeting regarding whether to terminate her employment. In this case, the Board's actions were based on the maltreatment determination. Finally, the court held that the district court did not err in declining to exercise supplemental jurisdiction over the state law claims, and the district court did not abuse its discretion in awarding costs to the County. View "Thompson v. Kanabec County" on Justia Law

The Eighth Circuit affirmed the district court's denial of plaintiff's motion for a new trial in an action seeking damages under the Federal Employers' Liability Act, and rejected his contention that the district court abused its discretion by refusing to provide the jury with a specific damages instruction. The court held that the district court did not abuse its discretion by refusing to give a specific instruction based on Eighth Circuit Manual of Model Instruction 15.70's optional list of damages because plaintiff's evidence was insufficient to support a claim of future damages.In this case, the district court's generic instructions permitted plaintiff to present his theory of the case—that BNSF breached a duty it owed to him causing his shoulder injury. Furthermore, the district court's instructions did not impact plaintiff's substantial rights. View "Hall v. BNSF Railway Co." on Justia Law

Marion Carter sued the Pulaski County Special School District for race discrimination under Arkansas state and federal laws. Carter taught at the Joe T. Robinson High School in the School District. She also coached the cheer and dance teams. In 2017, the school's principal recommended to the District Superintendent that Carter's cheer and dance duties not be renewed for the 2017-2018 school year, and that she be offered a teaching contract only. The principal cited: (1) lack of student participation in cheer and dance in the previous two years; (2) inappropriate cheer routines at sporting events; and (2) inappropriate behavior of cheerleaders during out-of-town travel. After a hearing, the District's School Board accepted the recommendation not to renew Carter's cheer and dance contract. The District filled the cheer position with an African-American woman, and eliminated all dance teams district-wide. The Eighth Circuit concurred with the district court's grant of summary judgment to the District on all claims. The Court found Carter's allegations were insufficient to defeat summary judgment. View "Carter v. Pulaski CO Special School Dist" on Justia Law

Plaintiff filed suit alleging that Dr. Pepper retaliated against him for complaining about racial discrimination at the company. The Eighth Circuit affirmed the district court's grant of summary judgment to Dr. Pepper, holding that, even if plaintiff made a prima facie case of retaliation, Dr. Pepper provided legitimate nondiscriminatory reasons for its actions based on plaintiff's performance under the McDonnell Douglas burden-shifting framework. In this case, Dr. Pepper alleged that plaintiff had an inability to adjust to new management expectations, an unwillingness to be coached, and a refusal to sit through his interim performance review. The court also held that plaintiff failed to create a jury issue on pretext. View "Couch v. American Bottling Co." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of Berkadia in an action brought by plaintiff, alleging that the employer terminated him in retaliation for actions protected by the False Claims Act (FCA) and Missouri law. The court held that defendant failed to establish direct evidence of retaliation. Although defendant produced evidence that Berkadia management did not implement, and were at times critical of, some of his suggestions regarding compliance with HUD regulations, there is also evidence that plaintiff's supervisors disapproved of other parts of his job performance. Therefore, he failed to prove that his termination was solely motivated by protected activity under the FCA.The court also held that, even assuming that his wrongful discharge claim was not waived, none of the HUD compliance issues plaintiff raised internally during his tenure amount to "serious misconduct" on the part of Berkadia or its employees. Therefore, plaintiff's wrongful-termination claim failed, because he failed to show that Berkadia's activity violated clearly mandated public policy. View "Sherman v. Berkadia Commercial Mortgage" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims of racial discrimination and retaliation, disability discrimination, whistleblower retaliation, and breach of fiduciary duty. The court held that plaintiff's discrimination claim failed because Mid Dakota offered a legitimate nondiscriminatory reason for its actions: his inability to get along with others; plaintiff's Title VII retaliation claims failed because he failed to show he was retaliated against for reporting racial slurs and racially charged comments; plaintiff's False Claims Act retaliation claim failed because there was no evidence, direct or otherwise, that his decision to report the allegedly fraudulent billing practices of a colleague caused—much less solely caused—Mid Dakota to force him out; and plaintiff's claim under the North Dakota Business Corporation Act failed because he was an at-will employee. View "Bharadwaj v. Mid Dakota Clinic" on Justia Law

The Eighth Circuit affirmed the district court's finding that plaintiff failed to allege a claim that a state prosecutor retaliated against him for seeking unpaid overtime compensation. The court held that plaintiff waived his First Amendment retaliation claim by failing to brief the issue; because plaintiff is not an employee under section 215(a)(3) of the Fair Labor Standards Act, the district court did not err in dismissing his claim; because plaintiff failed to point to any alteration or extinguishment of a right or legal status on appeal, he failed to state a due process claim; and because plaintiff failed to allege a conspiracy under 42 U.S.C. 1985(2), his sections 1985(3) and 1986 claims also failed. Finally, the court held that there was no error in dismissing plaintiff's state law claims and in denying him leave to file a third amended complaint. View "Liscomb v. Boyce" on Justia Law

The Eighth Circuit reversed the district court's grant of defendant's motion to dismiss plaintiff's action alleging a claim under the Americans with Disabilities Act (ADA). The court held that the district court erred by dismissing plaintiff's claim where plaintiff's allegations were sufficient to state a claim based on the statutory elements of the ADA. In this case, plaintiff has plausibly alleged that defendant refused to consider rehiring him because of his disability. The court also held that plaintiff's request for leave to amend was not futile and should have been granted. View "Cook v. George's, Inc." on Justia Law

Plaintiff, a former police officer, filed a 42 U.S.C. 1983 action against the city and the chief of police, alleging unlawful retaliation for exercising his First Amendment right to participate in a media interview, deprivation of his right to pretermination process, and violation of his rights under the North Dakota Constitution.The Eighth Circuit affirmed the district court's grant of defendants' motion for summary judgment. The court held that the district court properly granted summary judgment on the First Amendment claim where plaintiff failed to prove his speech as a public employee was protected by the First Amendment. In this case, the district court found that plaintiff was not speaking as a citizen in a local news interview; plaintiff's speech during the interview was not on a matter of public concern because his asserted desire was to clear the name of his Facebook alias, which was a purely private interest; and even assuming plaintiff was a citizen commenting on a matter of public concern, his speech at the interview was not First Amendment protected, because it created great disharmony in the workplace, interfered with plaintiff's ability to perform his duties, and impaired his working relationships with other employees. The court also held that plaintiff was not deprived of his right to due process, and declined to exercise supplemental jurisdiction over the state law claims. View "Nagel v. City of Jamestown" on Justia Law