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

Plaintiff filed suit under Titles I and V of the Americans With Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq., against his employer and various state employees, alleging that defendants retaliated against him in response to a prior discrimination suit that he had filed against them. The court dismissed the appeal for lack of jurisdiction because sovereign immunity barred plaintiff's claims for money damages against defendants. View "Lors v. Dean, et al." on Justia Law

Plaintiffs filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001-1461, alleging that defendants violated ERISA when defendants, realizing that they had paid plaintiffs excess retirement benefits, reduced plaintiffs' monthly benefit payments and recouped overpayments through withholding. The court concluded that Count One of the complaint was time-barred; the court rejected plaintiffs' argument that defendants had no authority to either correct or recoup the benefit overpayments where the 2002 plan booklet contained broad language granting defendants such action; because the PPNPF was a defined-benefit plan, plaintiffs could not recover individualized relief in a section 1132(a)(2) claim; and plaintiffs' claim for equitable estoppel under section 1132(a)(3)(B) failed where this claim mirrored Count One's section 1132(a)(1)(B) claim. Accordingly, the court affirmed the district court's grant of summary judgment for defendants. View "Pilger, et al. v. Sweeney, et al." on Justia Law

This appeal stemmed from a dispute between the Union and Carlisle over the arbitrability of a grievance concerning disability benefits. The district court granted summary judgment in favor of Carlisle and denied the Union's cross-motion for summary judgment. The court concluded that Carlisle's claim for declaratory judgment was barred by the doctrine of res judicata where there was no basis for the district court to conclude that the Union acquiesced in the splitting of Carlisle's claims. Therefore, the Union did not waive its right to rely on the doctrine of res judicata. Accordingly, the court vacated the order and remanded with directions to dismiss Carlisle's action View "Carlisle Power Trans. Products v. United Steel, etc." on Justia Law

Plaintiff, a truck driver for Red Racks, which was operated by DAV, filed suit under section 306 of the Safe, Accountable, Flexible, Efficient Transportation Equity Act (SAFETEA-LU) Technical Corrections Act (TCA), Pub. L. 110-244, Title III, section 306, 122 Stat. 1572, 1620, claiming that he was a "covered" employee eligible for overtime. The court affirmed the judgment, concluding that the district court properly determined that a Fair Labor Standards Act (FLSA), 29 U.S.C. 207(a)(1), covered employee under the TCA was one driving a vehicle with a gross motor vehicle weight rating of 10,000 pounds or less. The district court also correctly determined that plaintiff was not a covered employee, where the trucks he drove actually weighed less than 10,000 pounds, and properly granted summary judgment to DAV and denied partial summary judgment to plaintiff. View "McCall v. Disabled American Veterans, et al." on Justia Law

Plaintiffs filed suit against the Cafe and its owner and manager for willfully violating the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. 201 et seq. On appeal, defendants challenged the district court's denial of their motion for judgment as a matter of law, arguing that plaintiffs, as aliens without work authorization, lacked standing to sue. The court affirmed the judgment, concluding that the FLSA did not allow employers to exploit any employee's immigration status or to profit from hiring unauthorized aliens in violation of federal law. View "Lucas, et al. v. Jerusalem Cafe, LLC, et al" on Justia Law

Plaintiff filed suit against the OHA after she was terminated. At issue on appeal was whether plaintiff's appeal must be dismissed for failure to order the necessary portions of a trial transcript. Plaintiff ordered the portion of the trial transcript that contained her testimony and the remaining portions of the transcript were not transcribed and were not available. The court could not properly review the issues in the case based on the record plaintiff provided and, therefore, the court did not address the merits of plaintiff's First Amendment retaliation claim. Accordingly, the court granted the OHA's motion to dismiss plaintiff's appeal based on Federal Rule of Appellate Procedure 10(b). View "Kelly v. Omaha Housing Authority, et al." on Justia Law

Plaintiff sued her former employer alleging violations of her rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The employer believed that plaintiff suffered from a serious health condition and placed her on involuntary FMLA leave. After plaintiff submitted certifications of her fitness to return to work, the employer informed her that she had exhausted her FMLA leave and terminated her employment. The court affirmed the district court's grant of the employer's motion to dismiss where the statute entitled plaintiff to a certain amount of leave and her employer did not interfere with that entitlement. Further, the court concluded that plaintiff had no right to FMLA benefits where she admitted that she never suffered a serious health condition within the meaning of the Act. The court rejected defendant's claim of equitable estoppel where she did not establish a submissible case of detrimental reliance; and the employer's mistaken belief that plaintiff suffered a serious health condition could not entitle her to FMLA benefits. View "Walker v. Trinity Marine Products, et al." on Justia Law

Plaintiffs filed suit against their former employer alleging retaliatory termination after plaintiffs filed grievances against their supervisor. A jury found that the employer did retaliate against plaintiffs and awarded backpay and damages for emotional distress to each plaintiff. Both parties appealed. The court concluded that the evidence of discriminatory animus was sufficient to submit plaintiffs' retaliation claims to the jury; the employer's proffered non-discriminatory explanation for the terminations failed to address the discriminatory motivation; and the employer's argument that the discriminatory motivation was cured was unavailing. Accordingly, the district court properly denied the employer's motion for judgment as a matter of law on the retaliation claims. The court agreed with the district court's decision to instruct the jury that it could award damages for emotional distress; the district court did not clearly abuse its discretion in denying the employer's motion for new trial or remittitur; and the court affirmed the district court's decision to refuse an instruction on punitive damages. Accordingly, the court affirmed the judgment. View "Bennett, et al. v. Riceland Foods, Inc." on Justia Law

Plaintiff, injured on an oil and gas rig, filed suit against various third parties - including TESCO and TESCO employee Jeffrey Anderson - after recovering workers' compensation benefits from his employer, DeSoto. SWE was the owner/operator of the oil and gas well. The court concluded that the SWE contract did not establish that the common law duty of care Anderson owed plaintiff extended to preventing unforeseen injuries caused by DeSoto's failure to follow SWE's safety rules; Anderson and TESCO had no duty to foresee that injury to a DeSoto employee would occur because other DeSoto employees not under defendants' control had failed to exercise their duty of care; ordinary care did not require Anderson to foresee that his encouraging word would cause a DeSoto driller to do something he had not already decided, indeed, been ordered to do; and the amount of encouragement Anderson gave the DeSoto driller was insubstantial. Finally, the district court did not abuse its discretion in striking an expert report submitted by plaintiff and in denying the motion to amend. Accordingly, the court affirmed the judgment. View "Williams v. Chartis Casualty Co. et al." on Justia Law

The Union filed a grievance on behalf of a nurse terminated by the Hospital, alleging that the Hospital lacked "just cause" to terminate. The court concluded that the arbitrator did not exceed his authority by awarding reinstatement and back-pay; the manner in which the collective bargaining agreement (CBA) expired had no effect on the arbitrator's authority; the circumstances of the Union's decertification and the CBA's expiration were known to, and expressly considered by the arbitrator in making his award; and there was no basis to conclude that the arbitrator's exercise of his remedial authority failed to "draw its essence" from the CBA. Accordingly, the court affirmed the district court's grant of summary judgment confirming the arbitration award. View "Midwest Division - LSH, LLC v. Nurses United For Improved Patient Care" on Justia Law