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

Plaintiff, a pathologist, filed suit against Avera, alleging that Avera violated federal and state laws for terminating a Services Agreement. Plaintiff filed suit under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq.; the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; the Family Medical Leave Act (FMLA), 29 U.S.C. 2617 et seq.; and the South Dakota Human Relations Act (SDHRA), S.D. Codified Laws 20-13-1 et seq. The court affirmed the district court's grant of summary judgment dismissing all of plaintiff's claims because plaintiff was an independent contractor of St. Luke's Hospital under his Services Agreement and not an employee.View "Alexander v. Avera St. Luke's Hospital" on Justia Law

Plaintiff filed suit against JLLA for, inter alia, failure to pay him a commission on a deal that closed shortly after his departure. The district court sua sponte granted summary judgment for plaintiff and held that JLLA had wrongfully withheld commission payments. The district court awarded plaintiff the amount of the commission as well as statutory penalties for late payment under Minn. Stat. 181.03, 181.13, and attorney's fees and costs. The court concluded that the district court erred in awarding commission, wages, and statutory late payment penalties where JLLA did not owe plaintiff a commission payment at the time of termination because commission payments were subject to at least two conditions precedent that had not yet been fulfilled, and even if JLLA did eventually owe plaintiff a commission, any such amount would not have been owed until after termination, and therefore, Minn. Stat. 181.03 and 181.13 do not apply. Accordingly, the court reversed the judgment on these issues. Given the court's reversal of the underlying award, the court also vacated the later order awarding costs and attorney's fees.View "Karlen v. Jones Lang LaSalle Americas, Inc." on Justia Law

Annex, Stuart Lind, and Tom Janas filed suit challenging HHS' contraceptive mandate under the Religioous Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb-1(a). Lind, a controlling shareholder of Annex, opposed insurance coverage of contraceptives for Annex's employees. The district court denied Annex and Lind's motion for a preliminary injunction respecting the contraceptive mandate's enforcement. The court concluded that Janas lacks standing to appeal because he did not join the preliminary injunction motion which forms the basis of the appeal; the mandate does not apply to Annex because Annex has fewer than fifty full-time employees and has no government-imposed obligation to offer health insurance of any kind; the only alleged injury is that independent third parties - private health insurance companies not involved in this case - are unable to sell Annex a health insurance plan that excludes healthcare inconsistent with Lind's religious relief; and, ultimately, it is unclear whether Annex's alleged injury is caused by the government defendants and redressable by the federal courts. Accordingly, the court vacated the district court's denial and remanded for the district court to conduct more fact-finding to determine whether subject matter jurisdiction exists. View "Annex Medical, Inc., et al. v. Sebelius, et al." on Justia Law

Plaintiff filed suit against Malone and others after he was injured by a pipe saddle. The jury returned a verdict for Malone and plaintiff appealed, raising numerous issues on appeal. The court concluded that the district court did not abuse its discretion in refusing to give plaintiff's proffered instruction; the district court did not abuse its discretion by instructing the jury regarding OSHA regulations; the court rejected plaintiff's claim that the district court's comment regarding Instruction 15 was improper and prejudiced him such that he should receive a new trial; the district court did not abuse its discretion in allowing testimony regarding what procedures contractors other than Malone were using when working overhead on the same project; and the district court did not err in failing to grant plaintiff's motion for judgment as a matter of law as to Malone's third-party claim against Gilbert Project Services. The district court did not err in denying plaintiff's motion for judgment as a matter of law because reasonable minds could disagree as to whether Gilbert had a duty to plaintiff or Malone prior to or on the day of the accident. Accordingly, the court affirmed the judgment of the district court.View "Reed v. Malone's Mechanical, Inc., et al." on Justia Law

Two trustees of the Fund filed suit under section 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. 185(a), and section 515 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1145, to collect unpaid benefit contributions allegedly owed by Goebel. On appeal, the Trustees challenged the dismissal of the ERISA claim. The court read the Trust Agreement to unambiguously require that an employee is actually represented by the Union at the time the Fund claims delinquent contributions were owed on behalf of that employee. As it is undisputed that the Union did not "represent" the employees at the times in question, the Trustees failed to demonstrate the Fund was entitled to the contributions they seek under the terms of the Trust Agreement. Accordingly, the court affirmed the district court's grant of summary judgment to Goebel.View "Kern, et al. v. Goebel Fixture Co." on Justia Law

Plaintiffs filed suit against OEF and Hugo under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq., and Nebraska law, alleging sexual harassment and retaliation. Plaintiffs Davis and Duncan also sued Joe Ricketts, the CEO of OEF and owner of Hugo, for tortious interference with their expectation of continued employment. The court affirmed the district court's grant of summary judgment to Hugo and OEF because the court found that the undisputed facts in the record show that OEF and Hugo are not an integrated enterprise and because the court agreed with the district court that Ricketts, as CEO of OEF and acting on behalf of OEF, cannot be a third party interferer.View "Davis, et al. v. Ricketts, et al." on Justia Law

Plaintiffs, current or former "gang-time" employees at Tyson, filed a class action suit against Tyson for not paying wages due under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. 201 et seq., and the Iowa Wage Payment Collection Law, Iowa Code 91A.1 et seq. Plaintiffs claimed that Tyson's K-code time was insufficient to cover compensable pre- and post-production line activities. A jury returned a verdict for the class and Tyson appealed. The court concluded that the district court did not abuse its discretion in certifying the class; the court rejected Tyson's contention that the class should be decertified because evidence at trial showed that some class members did not work overtime and would receive no FLSA damages even if Tyson under-compensated their donning, doffing, and walking; the court concluded that Tyson exaggerated the authority for its contention; sufficient evidence existed to support a "reasonable inference" of classwide liability; and plaintiffs showed uncompensated overtime work by applying average donning, doffing, and walking times to employee timesheets. Accordingly, the court affirmed the judgment of the district court.View "Bouaphakeo, et al. v. Tyson Foods, Inc." on Justia Law

Plaintiffs filed suit against Tyson for not paying wages due under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. 201 et seq., and under Iowa law. The jury returned a verdict for Tyson and plaintiffs appealed. The court concluded that the district court did not err in letting the jury decide that donning, doffing, and walking were not "integral or indispensable to a principal activity;" because plaintiffs must prove their case on a classwide basis, the district court did not err in failing to give Reich v. IBP, Inc. and IBP, Inc. v. Alvarez preclusive effect; sufficient evidence existed that the disputed activities were not integral and indispensable classwide; sufficient evidence supported a finding that plaintiffs failed to prove damages for knife users; there was no error in allowing the jury to hear evidence on Tyson's good faith defense; plaintiffs failed to show an abuse of discretion in excluding documentary evidence; and summary judgment was appropriate that donning and doffing during the 35-minute meal period is not compensable. Accordingly, the court affirmed the judgment of the district court.View "Guyton, et al. v. Tyson Foods" on Justia Law

The Union appealed from the district court's order vacating an arbitration award. PSC argued that the plain language of the collective bargaining agreement (CBA) and the Standards of Conduct mandate that an employee found guilty of insubordination be discharged. PSC claimed that after the arbitrator found that the employee at issue in this case had been insubordinate, the arbitrator was required to uphold the employee's discharge. The court concluded that whether the employee's discharge was for just cause was a matter of contract interpretation that was within the arbitrator's authority. In this case, the arbitrator did not exceed his authority by concluding that PSC did not have just cause to discharge the employee and by reducing the penalty from discharge to suspension, because his award draws its essence from the CBA. The court reversed and remanded with directions that the arbitration award be reinstated.View "PSC Custom, LP v. United Steel, Paper, etc." on Justia Law

Plaintiff filed suit under the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A et seq., alleging that the County discriminated her based on her sex and her age when they terminated her employment. Plaintiff also claimed that the County retaliated against her after she took leave under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601. On appeal, plaintiff challenged the district court's grant of summary judgment on her MHRA discrimination claims. The court concluded that the County offered a non-discriminatory, legitimate justification for its conduct - plaintiff was terminated based on her repeated record-keeping errors - and plaintiff failed to show that the County's reasons for firing her was pretextual. Therefore, the court affirmed the district court's grant of summary judgment on plaintiff's sex discrimination claim. Further, plaintiff failed to present sufficient evidence to create a genuine issue of material fact as to her sex-plus age discrimination claim where her two male co-workers of comparable age did not engage in sufficiently similar misconduct or have a similar disciplinary history. Accordingly, the court affirmed the judgment of the district court.View "Doucette v. Morrison County, Minnesota" on Justia Law