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

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.

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.