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

Plaintiffs, successors in title to land located in Arkansas, brought a declaratory judgment action in Arkansas state court against AgriBank, FCB, seeking to quiet title to oil and gas rights that AgriBank held in Plaintiffs' land. AgriBank removed the case to federal district court. The district court granted AgriBank's motion to dismiss, identifying two bases on which to do so: (1) that a regulation promulgated by the Farm Credit Administration (FCA) specifically approved the sort of ownership interests held by AgriBank that Plaintiffs now attacked; and (2) that the challenge to AgriBank's oil and gas rights was based on a repealed act of Congress. The Eighth Circuit Court of Appeals affirmed, holding that the district court correctly dismissed the case under its first rationale, as the reservations at issue enjoyed the FCA's approval. View "Nixon v. AgriBank, FCB" on Justia Law

Chapter 11 Debtor, an LLC, held certain parcels of undeveloped land that were included within property-owners' improvement districts (the Districts) formed in accordance with Arkansas law. After Debtor entered into bankruptcy, secured creditor National Bank of Arkansas (the Bank) filed a motion with the bankruptcy court seeking a ruling that a proposed state court action against the Districts would not violate the automatic stay. The bankruptcy court determined (1) the automatic stay applied to the Bank's proposed action and that relief from the stay was unwarranted, and (2) the Bank's motion was barred by laches. The bankruptcy appellate panel (BAP) affirmed. The Eighth Circuit Court of Appeals reversed, holding (1) the automatic stay did not apply to the Bank's proposed action against the Districts because the Districts were neither property of the Debtor nor debtors themselves, the Bank's action would only impact the value of the estate in some undetermined and indirect manner, and the action would not divest the Debtor of its property; and (2) the doctrine of laches did not apply in this situation because there was no showing of detrimental reliance by the Debtor upon the Bank's failure to raise this particular challenge in a more timely fashion. View "Nat'l Bank of Ark. v. Panther Mtn. Land Dev. " on Justia Law

Homeowners filed this lawsuit in Minnesota state court against Lender seeking legal and equitable relief from Lender's foreclosure and sale of their home. Lender removed the case to federal court and subsequently moved to dismiss the complaint for failure to state a claim, or, alternately, for summary judgment. The district court dismissed the suit, holding (1) the United States Department of the Treasury's Home Affordable Mortgage Program preempted Homeowners' state-law claims; and (2) Homeowners did not plead the claims with sufficient particularity. The Eighth Circuit Court of Appeals affirmed, holding that, in regard to the majority of Homeowners' claims, Homeowners failed to state a claim upon which relief could be granted.

After JPMorgan Chase Bank (Chase) initiated foreclosure proceedings on Appellants' home and subsequently bought the property at a sheriff's sale, Appellants filed suit against Chase, doing business as Washington Mutual, seeking damages under theories of promissory estoppel and negligence. The district court dismissed the claims. Appellants subsequently filed a second suit against Chase and Washington Mutual, alleging causes of action relating to purported misrepresentations and alleged failure to disclose information and Chase's alleged failure to provide adequate notice of the sheriff's sale and to respond to two qualified written requests in violation of the Real Estate Settlement Practices Act (RESPA). The district court dismissed all claims against Washington Mutual without prejudice and all claims against Chase with prejudice. The Eighth Circuit Court of Appeals affirmed, holding (1) other than their claim under RESPA, the claims set forth in Appellants' complaint were barred by the doctrine of res judicata; and (2) as for the RESPA claims, Appellants failed to show how the complaint could be amended to survive a motion to dismiss.

Debtor appealed an order of the bankruptcy court sustaining the chapter 7 trustee's objection to debtor's claimed homestead exemption. The court concluded that the bankruptcy court identified debts debtor incurred prior to October 2007, when the property at issue became his homestead. Debtor had not challenged that finding on appeal. Pursuant to Iowa Code 561.21(1), therefore, the house could be sold to satisfy those debts, notwithstanding debtor's claimed homestead exemption. Accordingly, the court affirmed the order.

Debtor borrowed from Arvest to purchase a newly-constructed home, executing a promissory note and mortgage. After debtor filed a voluntary petition for Chapter 13 bankruptcy relief, Arvest then purchased the mortgaged property at a foreclosure sale for substantially less than what debtor owed on the promissory note and filed this adversary proceeding, seeking a judgment declaring the mortgage debt nondischargeable under 11 U.S.C. 523(a)(2) and (4). At trial, the bankruptcy court directed a verdict for debtor on the section 523(a)(2) claim but concluded that $65,000 of the remaining debt was nondischargeable under section 523(a)(4) because debtor held that amount of settlement proceedings in a fiduciary capacity created by section 4-58-105(b)(2) of the Arkansas Code. The BAP reversed and Arvest appealed. The court agreed with the BAP that the statute did not create the requisite fiduciary relationship, and that debtor was not guilty of embezzlement within the meaning of section 523(a)(4), affirming the judgment.

Plaintiff filed suit in Minnesota state court against her mortgage lender, seeking legal and equitable relief from the lender's foreclosure and sale of her home. The court held that, because there was no dispute as to whether the foreclosure was actually postponed, Minn. Stat. 580.07, subdiv. 1 was inapplicable. The court also held that the Minnesota Credit Agreement Statute (MCAS), Minn. Stat. 513.33, subdiv. 2, prohibited the enforcement of an oral promise to postpone a foreclosure sale and that the lender was entitled to summary judgment on plaintiff's promissory estoppel claim. Finally, the court held that plaintiff did not raise a genuine question of material fact as to whether she detrimentally relied on the lender's promise. Accordingly, the court affirmed the district court's grant of summary judgment on Counts I-V.

Debtor appealed an order of the bankruptcy court granting relief from the automatic stay to Bank of the West. At issue was whether the bankruptcy court properly granted relief from the automatic stay to Bank of the West to exercise its rights under state law with respect to real property that it purchased at a foreclosure sale. The court affirmed the decision of the bankruptcy court where Bank of the West was a "party in interest" under Bankruptcy Code 362(d) and where the bankruptcy court acted within its discretion when it granted relief from the stay to Bank of the West for "cause."

This case involved the property rights to coal bed methane gas (CBM) produced from certain lands located in Sebastian County, Arkansas. The original holder of fee simple absolute title to the lands (Grantor) conveyed surface and coal rights in 1965 via an instrument the parties referred to as the Garland Deed. Coal Owner acquired those rights effective April 30, 2010. However, three years before the grant of the coal rights, in 1962, Grantor had conveyed an undivided one-half interest in all oil, gas, and other mineral rights except coal via an instrument known as the Wheeler Deed. In 1976, Grantor conveyed its second undivided one-half interest via an instrument known as the Texas & Pacific Deed. Gas Owners were the successors-in-interest to the rights Grantor conveyed in the Wheeler and Texas & Pacific Deeds. EnerVest entered into various oil and gas leases and contracts with Coal Owner and Gas Owners to produce CBM from the lands and initiated this interpleader action seeking a ruling as to whether Coal Owner or Gas Owners were entitled to the CBM royalties. The parties moved for summary judgment on a stipulated record that included the Wheeler, Garland, and Texas & Pacific Deeds. The court affirmed the district court's holding that Gas Owners were entitled to the CBM royalties where the plain language of the deeds broadly conveyed to Gas Owners all rights to oil, gas, and other mineral resources.

Debtor appealed an order of the Bankruptcy Court directing that a third party receive a portion of a check made payable jointly to the third party and debtor for rent of debtor's property. At issue was whether the third party had a right to funds for rent of debtor's property when the rent check was made payable jointly to debtor and the third party. The court held that the third party had an interest in the funds by virtue of a contract between the parties and, therefore, the third party was entitled to the portions of the funds that the bankruptcy court required debtor to remit to him.