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

Plaintiff filed suit against defendants, alleging, inter alia, a state-law defamation claim arising out of a fact-finding meeting concerning a workplace dispute. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of defendants. The court held that because plaintiff failed to follow Rule 15's procedures and nothing in the district court's order or the record suggested that leave to amend the complaint was granted, the federal claims were not withdrawn from the second amended complaint and remained before the district court until those claims were dismissed by the court in its order. The court construed plaintiff's purported dismissal as a declaration that he was abandoning all claims except the defamation and breach of union constitution claims and would present no further evidence or argument supporting those abandoned claims. Therefore, the claims were merely abandoned for purposes of argument, not removed from the second amended complaint. The court also concluded that the district court properly exercised supplemental jurisdiction over plaintiff's state-law defamation claim. On the merits, the district court's grant of summary judgment was improper because plaintiff satisfied all elements of his defamation claim for summary judgment purposes and the vice president of the union's statements were not privileged. Accordingly, the court reversed and remanded. View "Thomas v. United Steelworkers Local 1938, et al." on Justia Law

Plaintiff appealed the district court's entry of summary judgment in favor of Open Harvest on plaintiff's claim alleging a violation of section 510 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1140. Because plaintiff has not identified direct evidence of a specific intent to interfere with her ERISA benefits, the court must analyze her claim under the McDonnell Douglas burden-shifting framework. In this case, Open Harvest articulated a legitimate, non-discriminatory justification for its failure to pay the August policy premium. Under the McDonnell Douglas framework, the burden shifted back to plaintiff to show a genuine dispute whether Open Harvest's justification was pretextual. Plaintiff failed to show a genuine dispute whether Open Harvest terminated her employment with a specific intent to interfere with her ERISA benefits. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Open Harvest. View "Barnhardt v. Open Harvest Cooperative" on Justia Law

Plaintiffs, African American officers who worked in a state penitentiary, filed suit under 41 U.S.C. 1981 and 1983 against supervisors for race based harassment and retaliation. On appeal, the officers challenged the district court's dismissal of their claims against Lieutenants Stoner, Haney, and Runge and against Sergeants Miles and Furby. The court concluded that the evidence revealed acts, comments, and inaction by Sergeant Miles sufficient to make out prima facie harassment claims against him, which must be reinstated and remanded; there was insufficient evidence of harassment by the other supervisors and therefore the claims against Lieutenant Stoner, Runge, and Haney, and Sergeant Furby were affirmed; the retaliation claims by supervisors were affirmed; and Sergeant Miles has not shown that he was entitled to qualified immunity on the officers' harassment claims, nor have Lieutenants Stoner and Haney shown they were entitled to qualified immunity on the retaliation claims of Officer Ellis. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Ellis, et al. v. Houston, et al." on Justia Law

Plaintiff and other union members filed suit against US Foods and the Union for breach of duty of fair representation in a hybrid action under section 301 of the Labor Management Relations Act, 29 U.S.C. 1985. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of the Union. The court affirmed, concluding that plaintiff's claim was time-barred because the claim accrued when plaintiff filed a charge against the Union with the NLRB. Plaintiff's claim accrued on that date when he should reasonably have known of the Union's alleged breach. View "Becker, et al. v. Int'l Brotherhood of Teamsters Local 120" on Justia Law

Maverick petitioned for review of the ARB's affirmance of an ALJ's finding that Maverick was liable for taking retaliatory action against an employee in violation of the Surface Transportation Assistance Act (STAA), 49 U.S.C. 31105. The court applied Chevron deference in regards to the agency's interpretation that the limitations period in the STAA began to run when the employee received notice of the employer's adverse action; the court also agreed with the ARB that the ALJ's finding that the employee received such notice within 180 days of filing his claim was supported by substantial evidence; and, therefore, the ARB's determination that the employee timely filed his claim was not contrary to law. The court also concluded that all of the facts found by the ALJ, including those pertaining to the retaliation claim, were supported by substantial evidence. Finally, the ALJ's decision not to reduce the back pay award on the basis that the employee failed to mitigate damages by voluntarily leaving his position was not contrary to law and the court found no abuse of discretion in the ALJ's award of compensatory damages for the employee's emotional distress. Accordingly, the court denied the petition for review. View "Maverick Transp., LLC v. U.S. Dept. of Labor" on Justia Law

After BIVI discharged an employee for falsifying work records, the Union grieved the discharge. BIVI and the Union submitted the dispute to arbitration, the arbitrator ordered that the employee be reinstated without back pay, and BIVI commenced this action to vacate the arbitration award. The district court granted summary judgment to the Union and BIVI appealed. The court concluded that the arbitrator's award drew its essence from the collective bargaining agreement (CBA) where BIVI's Article VIII, Section 3(d) argument was waived and where the arbitrator conducted a straightforward balancing of the management rights and just cause provisions. The court also concluded that BIVI has not made the factual and legal showing that would be required for the court to invoke the narrow public policy exemption and vacate an arbitration award that fully acknowledged the employee's misconduct, denied her back pay as a result of that misconduct, but reinstated her to her former position. Accordingly, the court affirmed the judgment of the district court. View "Boehringer Ingelheim Vetmedica v. UFCW" on Justia Law

Plaintiff filed suit under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and Arkansas state law, alleging various claims against her former employers. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of the employers on her claims of sex discrimination, hostile work environment, constructive discharge, and retaliation. The court concluded that plaintiff did not produce sufficient evidence to demonstrate that she suffered an adverse employment action and that she received different treatment because of her sex; considering the totality of the circumstances, plaintiff failed to establish that an incident related to a workplace disagreement permeated the workplace and thus had not established a prima facie case of hostile work environment; plaintiff failed to establish a case of constructive discharge where, inter alia, the record reflected that the employers sought to retain her as an employee; and plaintiff failed to establish a case of retaliation. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the employers on plaintiff's claims. View "Rester v. Media, et al." on Justia Law

Plaintiff filed suit against ARI, alleging that a golf cart accident had caused his debilitating back pain. The court concluded that the district court did not err in admitting an expert's testimony under the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc.; under Arkansas law, the jury could rely upon lay testimony to conclude that plaintiff was asymptomatic prior to the accident and upon the expert's testimony to conclude that plaintiff's lack of symptoms prior to the accident tended to exclude potential causes of his symptoms; where the parties agreed that the district court abused its discretion in partially remitting the jury's damages award, the district court did not err in denying the motion for a new trial; and the district court did not err in its remittitur of damages. Accordingly, the court affirmed the judgment of the district court. View "Tedder v. American Railcar Industries" on Justia Law

Plaintiffs represented four security guards that filed suit against the Commission for unlawful termination. After the Commission chose to reinstate the guards, it issued checks for back pay to the guards but did not put plaintiffs' names on the checks. Plaintiffs moved to establish an attorneys' lien against the Commission and the district court denied the motion. Determining that the court had jurisdiction under the collateral order doctrine, the court concluded that the district court erred in using equitable discretion to deny the attorneys' lien under Minn. Stat. 481.13 where the statutory requirements for the lien were met. Equitable principles did not trump the lien. Accordingly, plaintiffs were entitled to an attorneys' lien and the court reversed and remanded. View "Schermer, et al. v. Municipal Building Commission, et al." on Justia Law

Plaintiff filed suit against CRST in state court alleging that CRST negligently failed to maintain his workers' compensation insurance coverage. CRST removed the case to federal court and the district court granted summary judgment to CRST. The court affirmed the district court's holding that plaintiff's action was barred by the applicable Missouri statute of limitations. View "Brown v. CRST Malone" on Justia Law