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

Plaintiffs sought to establish a nationwide class of thousands of borrowers who allegedly paid inflated appraisal fees in connection with real estate transactions financed by Wells Fargo. Plaintiffs subsequently appealed the district court's dismissal of their claims contending that the appraisal practice of Wells Fargo and Rels unjustly enriched Rels and violated the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961 et seq.; the Real Estate Settlement Procedures Act of 1974 (RESPA), 12 U.S.C. 2601 et seq.; California's Unfair Competition Law (UCL), Cal. Bus. & Prof. Code 17200 et seq.; and Arizona's anti-racketeering statute (AZRAC), Ariz. Rev. Stat. 13-2314.04. Because plaintiffs did not plausibly allege a concrete financial loss caused by a RICO violation, the district court did not err in concluding that they lacked standing under RICO and AZRAC. In regards to the UCL claims, the court agreed with the district court that the complaint did not allege "lost money or property" where plaintiffs admitted that Wells Fargo charged them market rates for appraisal services as disclosed on the settlement. The court also rejected plaintiffs' claims under RESPA Section 8(a) and (b), as well as plaintiffs' assertion that the district court erred in dismissing their claims with prejudice rather than sua sponte allowing them leave to amend the complaint for the third time.

The United States sued defendants, alleging they engaged in a pattern or practice of sex discrimination in the rental of housing. After a jury found for defendants, the district court granted in part defendants' motion for costs and attorneys' fees under the Equal Access to Justice Act (EAJA), 28 U.S.C. 2412, and the government subsequently appealed. In this case, the government brought a single pattern or practice claim. The court held that the district court should have made a single determination about whether the government's suit, as a whole, was substantially justified. The district court improperly considered the case as consisting of ten individual victims' claims for separate assessment, rather than a single pattern or practice claim. Consequently, this error required reversal.

Debtors appealed from the Bankruptcy Court's Order Granting the Trustee's Motion for Approval of Compromise or Settlement of Controversy, relating to claims that they asserted against the Bank for lender liability and discrimination. Debtors also requested oral argument on appeal. The source of the dispute between the parties was a loan secured by debtors' property, which consisted of their residence and an adjacent commercial lot. The court held that the settlement proposed by the Trustee was within the range of reasonable compromises and the Bankruptcy Court did not err in approving it. The court also held that the facts and legal arguments were adequately represented in the briefs and record and that the decisional process would not be significantly aided by oral argument.

Debtor appealed the BAP's decision affirming a bankruptcy court order that her homestead was not exempt from the Bank's antecedent debts. The court agreed with the bankruptcy court and the BAP that the plain language of section 561.20 of the Iowa Code limited the "new homestead" exemption to cases where "a new homestead has been acquired with the proceeds of the old." Therefore, the court rejected debtor's contention that there was a conflict in the published bankruptcy court decisions and held that debtor was properly denied a new homestead exemption. The court also held that the bankruptcy court did not err in concluding that the homestead was not exempt from the Bank's antecedent debts under section 561.21(A) of the Iowa Code as construed by the Supreme Court of Iowa and in lifting the automatic stay in bankruptcy as to that property. Accordingly, the court affirmed the decision.

This case arose when plaintiff decided to develop some of the Indian trust land he owned on the Sisseton Wahpeton Reservation in a project planned with his cousin. The Bureau of Indian Affairs (BIA) subsequently denied a request by plaintiff and his wife to set aside the deed that conveyed the property to plaintiff and his cousin as joint tenants. After the district court affirmed the decision and dismissed plaintiff's action, plaintiff sought to alter the judgment and transfer their damage claims to the Court of Federal Claims (CFC). The court concluded that the district court did not abuse its discretion by denying the motion to alter the judgment to transfer the money damages claim to the CFC since plaintiff had withdrawn that claim several years before final judgment was entered. Accordingly, the judgment of the district court was affirmed.

This case arose when the Yankton Sioux Tribe requested that the Bureau of Indian Affairs (BIA) acquire 39 acres of land located in Charles Mix County in trust for the tribe pursuant to section 5 of the Indian Reorganization Act, 25 U.S.C. 465. The court held that the Secretary's decision to acquire the land was neither arbitrary nor capricious where the administrative record indicated that contrary to the county's assertions, the Secretary thoroughly considered all of the necessary factors when deciding to acquire the travel plaza in trust. Accordingly, the judgment was affirmed.

Plaintiff sued defendants in Missouri state court, on behalf of a putative class of similarly situated borrowers, alleging that defendants engaged in the unauthorized practice of law in violation of Mo. Rev. State 484.020 when they charged certain fees in the course of refinancing plaintiff's mortgage. Defendants moved the suit to federal court under the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d) and plaintiff subsequently appealed the district court's judgment. The court held that plaintiff failed to show that she was charged any fees, directly or indirectly, for legal work performed by non-lawyers. Therefore, plaintiff had not shown injury and did not have standing to bring her claim. In light of plaintiff's lack of standing, the district court should have dismissed for lack of jurisdiction rather than reaching the merits of the summary judgment motion. Accordingly, the judgment was affirmed in part, vacated in part, and remanded with instructions that the action be dismissed for lack of jurisdiction.

Best Buy sued various commercial landlords and the landlords' property manager, DDRC, alleging that DDRC impermissibly charged Best Buy for insurance-related costs under various lease agreements. The court held that the district court did not err in deciding that the landlords breached their various lease agreements by charging Best Buy for the First Dollar Program in an attempt to meet its insurance obligations under the leases. Based on the unambiguous language of the leases, the court found the landlords' interpretation of the leases to be unreasonable. Because the landlords breached the leases, the court found that the district court did not err in determining that the landlords breached their contracts with Best Buy. Therefore, the court affirmed the district court's order granting summary judgment to Best Buy on its breach of contract claims for 2005-2009. Because the court found that the district court erred in granting summary judgment to Best Buy, the court need not address the applicable pre-judgment interest rate until after the resolution of Best Buy's breach of contract claims for the 1999-2004 lease years. Finally, the district court did not abuse its discretion by dismissing Best Buy's remaining fraud claims with prejudice. Accordingly, the court affirmed in part, reversed in part, remanding for further proceedings.

Camelot brought this action against its tenant, AMC Showplace Theatres, seeking a declaration that section 3.4 of their lease was an option to renew if the parties agree on new, negotiated terms rather than an option to extend on the terms contained in their existing lease. The parties filed cross motions for summary judgment and the district court granted Camelot's motion. The court affirmed and held that the terms of the option period were not readily ascertainable and that section 3.4 was an option to renew that required new, negotiated terms.

In this consolidated appeal, three sets of landowners asserted claims against Arrington for breach of contract, promissory estoppel, and unjust enrichment relating to Arrington's failure to pay cash bonuses under oil and gas leases. The district court granted summary judgment to the landowners on the breach of contract claims and thereafter dismissed the landowners' other claims with prejudice on the landowners' motions. The court rejected the landowners' assertion that the lease agreements could be construed without considering the language of the bank drafts; the drafts' no-liability clause did not prevent enforcement of the lease agreements; Arrington entered into a binding contract with each respective landowner despite the drafts' no-liability clause; the lease approval language of the drafts was satisfied by Arrington's acceptance of the lease agreements in exchange for the signed bank drafts and as such, did not bar enforcement of the contracts; Arrington's admitted renunciation of the lease agreement for reasons unrelated to title precluded its defense to the enforceability of its contracts; Arrington's admission that it decided to dishonor all lease agreements in Phillips County for unrelated business reasons entitled the landowners to summary judgment; there was no genuine issue of material fact as to whether Arrington disapproved of the landowner's titles in good faith. Accordingly, the district court did not err in granting summary judgment on the breach of contract claims.