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

After defendant denied plaintiff's claim for long-term disability benefits (LTD benefits), where plaintiff suffered from fibromyalgia, plaintiff filed a complaint against defendant pursuant to ERISA, 29 U.S.C. 1000 et seq. At issue was whether the district court properly granted summary judgment in plaintiff's favor finding that defendant had abused its discretion in denying benefits to plaintiff. The court held that the district court improperly determined that defendant abused its discretion when it ultimately denied the LTD benefits claim. Based on the record, there was more than a scintilla of evidence supporting defendant's conclusion that plaintiff's condition did not render him "disabled" under the policy's any occupation definition and defendant's decision was supported by substantial evidence, where a reasonable person could have reached a similar decision. The court also held that the fact that defendant operated under a structural conflict of interest, as both plan administrator and insurer, did not warrant a finding that defendant abused its discretion in denying plaintiff's claim. Accordingly, the court reversed summary judgment and remanded for further proceedings.

Appellant sued his employer alleging race discrimination and retaliation for opposing race discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. At issue was whether the district court properly granted summary judgment and dismissed the complaint. As a preliminary matter, the court held that the district court did not abuse its discretion in excluding certain affidavits and in concluding that discovery concerning the settlement agreement was not warranted. The court held that the district court properly granted summary judgment on both failure-to-promote claims where the employer did in fact promote appellant in 2007. The court also held that the district court properly granted summary judgment on the hostile work environment based on race claim where the incidents that appellant had alleged were not sufficiently severe or pervasive to establish a hostile work environment.

Appellant sued his former employer claiming under Missouri law that the employer subjected him to malicious prosecution and false arrest for his alleged theft of certain checks. A issue was whether the district court properly granted summary judgment to the employer, concluding, inter alia, that appellant failed to create a genuine issue of fact as to the lack of probable cause for the theft prosecution, an essential element of malicious prosecution and false arrest under Missouri law. The court held that the district court did not err in concluding that the Missouri court's probable cause determination at appellant's preliminary hearing constituted prima facie evidence of the employer's probable cause which appellant had failed to rebut. Therefore, the court declined to address the district court's alternative holding that the underlying prosecution did not terminate in appellant's favor. The court also held that the district court correctly granted summary judgment in the employer's favor on appellant's claim for false arrest where the arrest was supported by probable cause and was justified per se under Missouri law and could not form the basis of a false arrest claim.

Plaintiff appealed from the district court's grant of summary judgment in favor of defendant on his claims that defendant committed employment discrimination, in violation of the Uniformed Services Employment and Reemployment Rights Act (USERRA), 38 U.S.C. 4301, et seq. Plaintiff claimed that his military service was a motivating factor in defendant's decision to discharge him and that defendant terminated him without cause. The court held that plaintiff failed to present sufficient evidence to allow a reasonable jury to find that defendant was hostile to his membership in the uniformed services; that the timing of plaintiff's termination failed to support his argument that his membership in the uniform services was a motivating factor in defendant's decision; and that defendant's reason for termination have not varied. Therefore, the court concluded that the district court properly granted summary judgment in favor of defendant on this claim. The court also held that defendant's decision to discharge plaintiff was not arbitrary and there was no evidence to suggest that defendant tried to evade the statute and that plaintiff had notice that his conduct would constitute cause for discharge. Therefore, the court also affirmed summary judgment on this claim.

A former employee of Schwan's Home Service (Schwan) filed a charge with the EEOC alleging gender discrimination while she was employed at Schwan. Schwan subsequently appealed the district court's order enforcing an administrative subpoena issued by the EEOC while investigating the charges. The court held that because the EEOC's investigation into the former employee's charge of individual gender discrimination revealed potential systematic gender discrimination, the EEOC had the authority to subpoena information relevant to systemic gender discrimination even absent a valid systemic charge by the former employee. Accordingly, the court affirmed the district court's order enforcing the administrative subpoena.

Plaintiff appealed the district court's grant of summary judgment dismissing claims of wrongful termination against her former employer, its president and chief executive officer, and its principal owner (collectively, defendants). At issue was whether plaintiff's claim of wrongful termination violated Iowa public policy. The court held that, in these circumstances, the district court correctly concluded that plaintiff's discharge did not undermine clearly defined public policy as a matter of law where plaintiff was discharged based on an at-will employment contract and where there was no false reimbursement claim submitted and no acts of fraud occurring on the part of defendants. Accordingly, the judgment of the district court was affirmed and the court denied as moot plaintiff's motion to strike portions of defendants' briefs.

This appeal stemmed from an action filed by nine professional football players and one prospective football player (Players) against the National Football League and its 32 separately-owned clubs (NFL or League). On March 11, 2011, a collective bargaining agreement between the League and a union representing professional football players expired and the League made known that if a new agreement was not reached before the expiration date, then it would implement a lockout of players, during which athletes would not be paid or permitted to use club facilities. The Players, aware of the League's strategy, opted to terminate the union's status as their collective bargaining agent as of 4:00 p.m. on March 11, just before the agreement expired. Later that day, the Players filed an action in the district court alleging that the lockout planned by the League would constitute a group boycott and price-fixing agreement that would violate Section 1 of the Sherman Antitrust Act, 15 U.S.C. 1, and alleging other violations of the antitrust laws and state common law. The League proceeded with its planned lockout on March 12, 2011 and the Players moved for a preliminary injunction in the district court, urging the court to enjoin the lockout as an unlawful group boycott that was causing irreparable harm to the Players. The district court granted a preliminary injunction and the League appealed. The court held that the injunction did not conform to provisions of the Norris-LaGuardia Act (Act), 29 U.S.C. 101 et seq., where Section 4(a) of the Act deprived a federal court of power to issue an injunction prohibiting a party to a labor dispute from implementing a lockout of its employees. Therefore, the court vacated the district court's order and declined to reach the other points raised by the League on appeal.

Appellees brought this declaratory judgment action seeking a determination that there was no coverage for an accident involving a company car driven by Daniel Brandt and injuring Donald Bunch. At issue was whether liability coverage extended to Brandt and whether Donald Bunch was entitled to uninsured and underinsured motorist coverage because the policy at issue was ambiguous. The court concluded that the Bunches conceded that Brandt did not have express or implied permission from his employer to drive the car and that Patricia Bunch lacked the authority to give Brandt permission to use the vehicle as either a named insured or as a second permitee. Therefore, the district court did not err in concluding that liability coverage did not extend to Brandt. The court also concluded that there was no indication that the term "vehicle" was ambiguous or that a person reading the policy would not understand that the vehicle referred to in the exclusion would have included the car involved in the accident. Therefore, the district court did not err in determining that Donald Bunch did not qualify for uninsured or underinsured motorist coverage.

Plaintiff brought this suit under ERISA, 29 U.S.C. 1001-1461, and the FMLA, 29 U.S.C. 2601-2654, against the state, the Iowa Department of Administrative Services (DAS), and two officials of the DAS. At issue was whether the district court properly granted defendants' motions to dismiss the complaint on the ground that the Eleventh Amendment barred plaintiff's FMLA claims against all of the defendants. The court held that the state's waiver of its state court immunity in FMLA cases had no bearing on the state's immunity from suit in federal court. Therefore, the state had not waived its Eleventh Amendment immunity and summary judgment was affirmed.

Monarch Fire Protection District of St. Louis County (Monarch) appealed several adverse rulings in favor of Freedom Consulting & Auditing Services, Inc. (Freedom), Freedom's owner, and a Freedom employee. The International Association of Firefighters Local 2665 (Firefighters Union), representing Monarch employees, requested an independent audit of Monarch's self-funded group health plan because union representatives believed that Monarch's board of directors had illegally approved a non-covered medical procedure for a plan member. Monarch hired Freedom to conduct the audit and Monarch subsequently sued Freedom, alleging that protected health information (PHI) had been improperly disclosed to Firefighters Union attorneys in violation of the Business Associate Agreement (BIA) between Monarch and Firefighters Union. Monarch subsequently appealed the district court's dismissal of its conversion claim and underlying claim for punitive damages, the district court's decision that the BAA's indemnity clause did not entitle Monarch to attorneys' fees and costs, and that the district court's denial of its motion for sanctions. The court held that Monarch could not show that Freedom deprived it of the right to possession, which it must do to establish conversion under Missouri law. The court also held that Freedom was not contractually obligated to pay the attorneys' fees and costs that Monarch incurred in the litigation and that Monarch could not survive summary judgment on its claim that the indemnity clause entitled it to attorneys' fees. The court further held that the district court did not abuse its discretion by declining to impose a sanction on the Freedom employee when the case did not proceed to trial because nothing in the record suggested that the district court based its ruling on a legal error or a clearly erroneous assessment of the evidence. Accordingly, the court affirmed the judgment of the district court.