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

Ronald E. Byers owes the United States for unpaid income taxes, interest, and penalties. The government filed a suit to enforce its federal tax liens through the judicial sale of Ronald’s home, which he solely owns but shares with his wife, Deanna L. Byers. The Byerses agreed to the sale but argued that Deanna is entitled to half of the proceeds because the property is their marital homestead. The district court granted the government’s motion for summary judgment, ruling that Deanna lacked a property interest in the home and was not entitled to any sale proceeds.The United States District Court for the District of Minnesota found that Deanna did not have a property interest in the home under Minnesota law, which only provides a contingent interest that vests upon the owner's death. The court concluded that Deanna’s interest did not rise to the level of a property right requiring compensation under federal law. The court ordered that Ronald is liable for the tax debt, the government’s liens are valid, and the property can be sold with proceeds applied to Ronald’s tax liabilities.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that Minnesota’s homestead laws do not provide Deanna with a vested property interest in the home that would entitle her to compensation from the sale proceeds. The court distinguished this case from United States v. Rodgers, noting that Minnesota law does not afford the same level of property rights to a non-owner spouse as Texas law does. Therefore, the court upheld the summary judgment in favor of the government, allowing the sale of the property to satisfy Ronald’s tax debt. View "United States v. Byers" on Justia Law

Plaintiffs, E&I Global Energy Services, Inc. and E&C Global, LLC, sued Liberty Mutual Insurance Company for breach of contract and tort claims related to a construction project. The United States, through the Western Area Power Administration (WAPA), contracted with Isolux to build a substation, and Liberty issued performance and payment bonds for Isolux. After Isolux was terminated, Liberty hired E&C as the completion contractor, but E&I performed the work. Plaintiffs claimed Liberty failed to pay for the work completed.The United States District Court for the District of South Dakota granted summary judgment for Liberty on the unjust enrichment claim and ruled in Liberty's favor on all other claims after a bench trial. The court denied Plaintiffs' untimely request for a jury trial, excluded an expert witness report filed after the deadline, found no evidence of an assignment of rights between E&C and E&I, and ruled against Plaintiffs on their fraud, deceit, and negligent misrepresentation claims.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the jury trial request, as Plaintiffs failed to timely file the motion and did not justify the delay. The exclusion of the expert report was also upheld, as the district court properly applied the relevant factors and found the late report was neither substantially justified nor harmless. The court affirmed the district court's finding that there was no valid assignment of rights from E&C to E&I, meaning Liberty's promise to pay was to E&C, not E&I. The court also upheld the findings that Liberty did not have the intent to deceive or induce reliance, and that Bruce did not reasonably rely on Mattingly's statements. Finally, the court declined to address the unjust enrichment claim as Plaintiffs did not raise the argument below. The Eighth Circuit affirmed the district court's rulings in their entirety. View "E&I Global Energy Services v. Liberty Mutual Insurance Co." on Justia Law

WBI Energy Transmission, Inc. sought to build a natural gas pipeline through McKenzie County, North Dakota. After obtaining a certificate of public convenience and necessity from the Federal Energy Regulatory Commission, WBI attempted to acquire the necessary easements through voluntary sales. When one family refused to sell, WBI filed a federal condemnation action under the Natural Gas Act. After three years of negotiations, the parties agreed on the amount of just compensation for the easement, but the issue of attorney fees remained unresolved.The United States District Court for the District of North Dakota ruled that WBI was responsible for the family's attorney fees based on North Dakota law, which allows for such fees in condemnation proceedings. The district court relied on the precedent set by Petersburg School District of Nelson County v. Peterson.The United States Court of Appeals for the Eighth Circuit reviewed the case and determined that the availability of attorney fees depends on whether state or federal law governs the compensation due. The court concluded that federal law applies because WBI was exercising the federal eminent-domain power delegated under the Natural Gas Act. The court noted that the Fifth Amendment's requirement for just compensation does not include attorney fees unless explicitly provided by statute. The Natural Gas Act does not mention attorney fees, and thus, the default rule under the Fifth Amendment applies. Consequently, the court vacated the district court's award of attorney fees, holding that WBI is not obligated to pay the family's attorney fees. View "WBI Energy Transmission, Inc. v. 189.9 rods in Twsp. 149" on Justia Law

Cedar Hills Investment Co., L.L.C. leased part of the ground under the Battlefield Mall in Springfield, Missouri, to Battlefield Mall LLC. Cedar Hills suspected that Battlefield was improperly deducting certain costs from revenue-sharing payments owed under the lease. Cedar Hills sued Battlefield, and the district court found that Battlefield had improperly deducted capital expenditures and some administrative costs from shared revenue. The court approved the deduction of security costs and other administrative costs but held that Battlefield failed to state charges to subtenants for deducted costs separately as required by the lease. Cedar Hills was awarded approximately $3.5 million in damages.The United States District Court for the Western District of Missouri held a bench trial and ruled in favor of Cedar Hills on several points, including the improper deduction of capital expenditures and the failure to separately state charges. However, the court also found that Battlefield's deduction of security costs was permissible.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's findings regarding the improper deduction of capital expenditures and the failure to separately state charges. However, the appellate court found that the district court misidentified which administrative costs were deductible and miscalculated Cedar Hills's damages. The Eighth Circuit held that Battlefield's deduction of capital expenditures breached the lease, and the failure to separately state charges also breached the lease. The court affirmed the district court's finding that security costs were common area maintenance costs. The case was remanded for further proceedings to correctly identify deductible administrative costs and recalculate damages. The appellate court granted the parties' joint motion to supplement the record. View "Cedar Hills Investment Co. v. Battlefield Mall, LLC" on Justia Law

McKenzie County, North Dakota, sued the United States and the Department of the Interior, claiming ownership of mineral royalties under certain lands. The County argued that previous litigation had settled the matter in its favor. The United States contended that the prior litigation involved different lands and that the County’s claim was untimely. The district court ruled in favor of the County, and the United States appealed.The United States District Court for the District of North Dakota had previously granted judgment for the County, concluding that the 1930’s Condemnation Judgments and a 1991 Judgment quieted title to the disputed minerals in favor of the County. The district court held that the County’s claim was not barred by the Quiet Title Act’s statute of limitations and that the All Writs Act and Rule 70 empowered it to enforce its prior judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court’s decision. The Eighth Circuit held that the All Writs Act could not be used to circumvent the Quiet Title Act’s requirements. The court determined that the 1991 Judgment did not include the tracts listed in the 2019 Complaint and that the County’s claim under the Quiet Title Act was untimely. The court concluded that the County knew or should have known of the United States’ adverse claim to the mineral royalties by December 2003, thus triggering the Quiet Title Act’s 12-year statute of limitations. The Eighth Circuit instructed the district court to enter judgment in favor of the United States. View "McKenzie County, ND v. United States" on Justia Law

Vernon Holland was fatally injured by a rewinder machine at his workplace. Robert Cearley, Jr., representing Holland’s estate, filed a wrongful death lawsuit against Bobst Group North America, Inc. (Bobst NA), the company responsible for delivering and installing the rewinder. The lawsuit sought damages based on several tort claims.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of Bobst NA. The court ruled that Arkansas’s statute of repose, which limits the time frame for bringing claims related to construction or design defects, barred Cearley’s claims. Cearley appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court examined whether Bobst NA was protected under Arkansas Code § 16-56-112(b)(1), which is a statute of repose for claims arising from personal injury or wrongful death caused by construction defects. The court concluded that Bobst NA’s involvement in the delivery, installation, integration, and commissioning of the rewinder constituted the construction of an improvement to real property. The court also determined that the rewinder was an improvement to real property because it was affixed to the plant, furthered the purpose of the realty, and was designed for long-term use.As the lawsuit was filed more than four years after the installation of the rewinder, the court held that the claims were barred by the statute of repose. Consequently, the Eighth Circuit affirmed the district court’s judgment in favor of Bobst NA. View "Cearley v. Bobst Group North America Inc." on Justia Law

CEZ Prior, LLC ("CEZ") entered into a purchase agreement with 755 N Prior Ave., LLC ("Prior") to buy a property for $26 million. The agreement required Prior to cooperate in obtaining tenant estoppel certificates. Errors in square footage measurements led to rent discrepancies, prompting an amendment to reduce the purchase price to $15.1 million and the cash required at closing to $3.8 million. CEZ later requested to delay closing due to financial issues, but Prior did not agree. Prior sent estoppel certificates that did not address rate increases, and CEZ proposed edits that Prior rejected. CEZ demanded satisfactory certificates on the closing date, but Prior terminated the agreement, alleging CEZ failed to tender cash.CEZ sued Prior for breach of contract in Minnesota state court and sought to enjoin the termination. Prior removed the case to federal court and counterclaimed for breach of contract. The district court stayed the matter and later denied CEZ's motion for a preliminary injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court's denial of the preliminary injunction. The court found that CEZ was unlikely to succeed on the merits of its breach of contract claim, as Prior had reasonably cooperated in obtaining the estoppel certificates. The balance of harms favored Prior, given CEZ's insufficient evidence of its ability to pay. The public interest did not favor CEZ due to its low probability of success on the merits.The court also addressed CEZ's argument under Minnesota law, finding that the district court's stay order was not an injunction and did not extend statutory deadlines. Consequently, CEZ was not entitled to additional time to close under Minnesota statutes. The Eighth Circuit affirmed the district court's judgment. View "CEZ Prior, LLC v. 755 N Prior Ave. LLC" on Justia Law

The City of Hillsboro, Missouri, enacted ordinances prohibiting new private wells within city limits and requiring residences to connect to the city water system. The Antoinette Ogilvy Trust, owning a 156-acre property within Hillsboro, claimed these ordinances constituted an uncompensated regulatory taking under the Fifth and Fourteenth Amendments. The trustees, William Becker and Darcy Lynch, argued that the regulations made developing the property financially unfeasible due to the high costs of connecting to the city water system.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the City, rejecting the trustees' claims. The court found that the regulations did not constitute a per se taking, as they did not involve a physical invasion of the property or deprive it of all economic value. The court also determined that the regulations did not fail the Penn Central balancing test for regulatory takings.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the regulations did not mandate a permanent physical invasion of the property, as the trustees were not compelled to build structures or dedicate land to the City. The court also found that the property retained substantial value, thus not constituting a taking under Lucas v. South Carolina Coastal Council. Additionally, the court declined to consider the trustees' exaction claim, as it was not sufficiently raised in the lower court.Under the Penn Central test, the court concluded that the economic impact on the trustees was not significant enough to constitute a taking, and the regulations did not interfere with reasonable investment-backed expectations. The character of the governmental action was deemed a legitimate exercise of the City's police powers to prevent water contamination and protect the aquifer. Therefore, the court affirmed the district court's summary judgment in favor of the City. View "Becker v. City of Hillsboro" on Justia Law

The case involves William Phillip Jackson, who owes unpaid federal taxes to the United States. Following a jury trial and post-trial proceedings, the United States District Court for the Western District of Missouri entered a judgment against Jackson for $2,396,800.47 and ordered the foreclosure and sale of four properties owned by Jackson and his wife. Jackson filed multiple motions to amend or vacate the sale, which were denied, and his appeals to the Eighth Circuit Court of Appeals were unsuccessful. Jackson then filed for Chapter 13 bankruptcy relief, but the United States proceeded with evictions and seized personal property before being notified of the bankruptcy filing.The United States Bankruptcy Court for the Western District of Missouri heard Jackson's motion for contempt and turnover of property and the United States' motion to lift the automatic stay nunc pro tunc. The bankruptcy court denied Jackson's motion and granted the United States' motion, annulling the automatic stay retroactively to the date of Jackson's bankruptcy filing. Jackson appealed this decision but did not seek a stay of the order pending appeal. While the appeal was pending, the United States sold the properties at auction, and the district court confirmed the sales and approved the disbursement of proceeds.The United States Bankruptcy Appellate Panel for the Eighth Circuit reviewed the case and determined that the appeal was constitutionally moot. The court held that since the properties had been sold and Jackson did not obtain a stay pending appeal, there was no effective relief that could be granted. Consequently, the appeal of the bankruptcy court's order annulling the stay and denying Jackson's motion for contempt and turnover was dismissed for lack of jurisdiction. View "Jackson v. United States" on Justia Law

Covenant Construction Services, LLC was the prime contractor on a federal construction project for a U.S. Department of Veterans Affairs facility in Iowa City, Iowa. Covenant subcontracted with Calacci Construction Company, Inc. to supply carpentry labor and materials. Calacci had a collective bargaining agreement (CBA) with two regional unions, requiring it to pay fringe-benefit contributions to the Five Rivers Carpenters Health and Welfare Fund and Education Trust Fund (the Funds). Despite multiple demands, Calacci failed to remit the required contributions.The Funds filed a lawsuit under the Miller Act to collect the unpaid contributions, liquidated damages, interest, costs, and attorneys' fees from Covenant and its surety, North American Specialty Insurance Company. The United States District Court for the Southern District of Iowa granted summary judgment in favor of the Funds, concluding that the Funds had standing to sue and that the Miller Act notice was properly served and timely.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the Funds sufficiently complied with the Miller Act's notice requirements by sending the notice to Covenant's attorney, who confirmed receipt. The court also held that the notice was timely as it was filed within 90 days of the last day of labor on the project. Additionally, the court upheld the award of liquidated damages and attorneys' fees, finding that the CBA obligated Calacci to pay these amounts and that Covenant, as the prime contractor, was liable for the amounts due under the payment bond.The Eighth Circuit concluded that the Funds were entitled to recover the unpaid contributions, liquidated damages, and attorneys' fees from Covenant and its surety, affirming the district court's judgment. View "Five Rivers Carpenters v. Covenant Construction Services" on Justia Law