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

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

Plaintiff filed suit against her former employer, Metro, alleging that her supervisor had sexually harassed her in violation of Title VII, 42 U.S.C. 2000e et seq. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of Metro. The court concluded that the supervisor's alleged conduct was not so severe or pervasive as to alter the terms and conditions of plaintiff's employment and, therefore, affirmed the district court's grant of summary judgment on plaintiff's hostile work environment claim. The court concluded, however, that plaintiff presented genuine issues of fact as to whether the supervisor was motivated by sex and whether he intentionally and proximately caused her termination. Accordingly, the court reversed the district court's grant of summary judgment on this quid pro quo harassment claim. View "McMiller v. Metro" on Justia Law

Plaintiff filed suit against her supervisor, individually and in her official capacity as an employee of the Arkansas Department of Human Services, alleging that the supervisor violated the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., and the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq. Plaintiff also alleged claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and claims against the Department under the Rehabilitation Act, 29 U.S.C. 701 et seq. The court concluded that plaintiff's FMLA claims failed because she was not an eligible employee under the FLMA and she had been employed for less than 12 months; plaintiff's FLSA claim failed because she did not plead adequately that the supervisor violated the statute; because plaintiff could not perform the essential functions of her position, with or without reasonable accommodation, she failed to create a genuine issue for trial on a claim of discrimination under the ADA; and there was no genuine issue for trial on plaintiff's claim of unlawful retaliation. Accordingly, the court affirmed the district court's dismissal of the FMLA and FLSA claims and the district court's grant of summary judgment on the ADA and Rehabilitation Act claims. View "Hill v. Walker" on Justia Law

Branden Mueller filed a complaint against BCI with the DOE alleging that BCI had terminated him after he complained about not being paid prevailing wages as required by the American Recovery and Reinvestment Act (ARRA), Pub. L. No. 111-5, 123 Stat. 115. BCI subsequently petitioned for review of the Secretary's order reinstating Mueller with back pay. The court concluded that BCI was deprived of its due process rights because it was never afforded a hearing and because the post-deprivation procedures available under section 1553 of the ARRA did not provide an opportunity for BCI to confront and cross examine adverse witnesses. Therefore, the court granted the petition and vacated the order. View "Business Communications v. U.S. Dept. of Education, et al." on Justia Law

Plaintiff filed suit against Riceland, alleging retaliatory discharge after being a witness in an internal investigation into a complaint about a manager. A jury subsequently awarded plaintiff approximately $60,000 in compensatory damages and back pay in regards to his 42 U.S.C. 1981 claim. The court concluded that the district court properly denied Riceland's motion for judgment where the evidence was sufficient for the jury to find retaliation; the district court properly dismissed plaintiff's Title VII claim where, even if plaintiff had properly preserved this claim on appeal, the claim was untimely; it was not necessary to address the district court's grant of summary judgment on plaintiff's state law claim because the state statute would not entitle plaintiff to any additional relief beyond his section 1981 claim; the district court did not abuse its discretion in denying plaintiff's motion for a new trial on punitive damages; and the district court did not abuse its discretion by denying plaintiff's request for reinstatement. Accordingly, the court affirmed the judgment of the district court. View "Sayger v. Riceland Foods, Inc." on Justia Law

Reyco appealed from the district court's grant of summary judgment for the Union and the district court's denial of its motion for summary judgment and request to vacate the arbitrator's award. At issue was Article XII, section 3 of the collective bargaining agreement (CBA) between Reyco and the Union. In this case, the arbitrator recognized that the crux of the issue was whether the use of the word "may" was discretionary or mandatory when referring to exceptions to be made to a holiday pay policy. The arbitrator, relying on parol evidence, concluded that the word "may" indicated the company held "some discretion" and that the language of the contract did not make granting the exception mandatory. The court concluded, however, that there was no ambiguity in the contract language at issue. The arbitrator was not construing an ambiguous contract term, but rather was imposing a new obligation upon Reyco. Therefore, the arbitrator's interpretation altered the plain language of the contract as written. Accordingly, the court vacated the district court's order and opinion granting summary judgment for the Union and confirming the arbitration award, and directed the court to grant Reyco's motion for summary judgment, vacating the arbitrator's award. View "Reyco Granning LLC v. IBT, Local No. 245" on Justia Law

Plaintiff filed suit against her former supervisor and employer, the Department, for statutory and constitutional violations. The court concluded that it had jurisdiction over the supervisor's appeal where the supervisor challenged the sufficiency of plaintiff's pleadings to state 42 U.S.C. 1983, Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., interference and retaliation claims. The court also concluded that plaintiff failed to state a section 1983 claim for gender discrimination where her conclusory assertion that she was discharged under circumstances similarly situated men were not imported legal language couched as factual allegations and failed to raise a right to relief above the speculative level. Accordingly, the district court erred in denying the supervisor's motion to dismiss the claim. Further, the district court erred in denying the supervisor's motion to dismiss the FMLA entitlement claim and the FMLA discrimination claim. The court remanded for the district court to consider whether to allow plaintiff to amend her pleadings. Finally, the court, declining to exercise pendant jurisdiction, did not have jurisdiction to hear the Department's appeal. View "Hager v. Arkansas Dept. of Health, et al." on Justia Law

The Market sought a declaration that its employment separation agreement with defendant was invalid because defendant had altered the agreement and fraudulently induced the president of the Market to sign it. Defendant counterclaimed to enforce the agreement. The court affirmed the district court's grant of summary judgment to the Market where defendant failed to fulfill a condition precedent - returning company property - and such failure meant that the Market had not duty to perform under the agreement. Alternatively, the district court did not abuse its discretion in striking defendant's pleadings based on defendant's deliberate and willful discovery abuses. The district court acted within its discretion to impose sanctions under Rule 37. View "St. Louis Produce Market v. Hughes" on Justia Law

Plaintiffs filed suit against their former employer and others under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. After the district court adopted the magistrate judge's recommended dispositions, plaintiffs appealed. The court concluded that plaintiffs have failed to set forth sufficient evidence to show that they were due more in benefits and penalties than the amount that the district court determined that they were owed; the district court did not abuse its discretion in denying their requests for nonmonetary relief or in determining the reasonable attorney's fees and costs; and, therefore, the court affirmed the judgment of the district court. View "McDowell, et al. v. Price, et al." on Justia Law

This case concerned the 2011 NFL lockout. Active NFL players filed a class action suit (Brady suit) against the NFL, alleging violations of the federal antitrust laws and other claims. Retired NFL players also filed suit against the NFL and its teams, alleging antitrust violations (Eller I suit). After both actions were consolidated, the Brady suit was settled, the players re-designated the NFLPA as their collective bargaining agent, the NFL and NFLPA signed a new collective bargaining agreement (CBA) incorporating the settlement terms, the Brady plaintiffs dismissed their action, the lockout ended, and the 2011 NFL season commenced. Carl Eller and other retired NFL players (plaintiffs) then filed this class action (Eller II) against the NFLPA and others. The district court granted defendants' motion to dismiss and plaintiffs appealed, alleging claims for intentional interference with prospective economic advantage under Minnesota law. The court concluded that no reasonable jury could find that plaintiffs had a reasonable expectation of a prospective separate contractual relation with the NFL that would provide more than the increased benefits provided in the 2011 CBA. Even if plaintiffs alleged a reasonable expectation of prospective contractual relations or economic advantage with the NFL, plaintiffs failed to allege facts proving that defendants improperly or wrongfully interfered with these advantageous prospects. Accordingly, the court affirmed the judgment of the district court. View "Eller, et al. v. NFL Players Assoc., et al." on Justia Law