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

Plaintiff filed suit against Mid-Continent, alleging that Mid-Continent breached the insurance contract by denying coverage to plaintiff in an underlying lawsuit arising from a subcontractor's faulty workmanship during construction of a home. The court affirmed the district court's dismissal of the claim because faulty workmanship on the home was not an "occurrence" within the meaning of the policy under Essex Ins. Co. v. Holder. The district court did not err by denying plaintiff leave to amend because plaintiff seeks to extend coverage to subcontractor negligence through a claim of estoppel. Under Arkansas law, the doctrine of waiver of estoppel cannot be given the effect of enlarging or extending the coverage as defined in the contract. View "J-McDaniel Construction Co v. Mid-Continent Casualty Co., et al." on Justia Law

Defendant appealed his conviction of five counts of subscribing to false tax returns and one count of endeavoring to obstruct the administration of the internal revenue laws. The court concluded that a rational jury could convict defendant of subscribing to a false return even if he also under-reported his expenses and deductions. The court also concluded that a rational jury could find that defendant's actions were an attempt to obstruct or impede the IRS's administration of the tax code so that he could secure a financial gain. Accordingly, the court affirmed the judgment of the district court. View "United States v. Mathews" on Justia Law

Grandoe filed suit against Gander Mountain after Gander Mountain reneged on its oral commitment to purchase $3.05 million worth of winter gloves from Grandoe. After the jury awarded judgment in favor of Grandoe, Gander Mountain moved for judgment as a matter of law or for a new trial, claiming that two written documents rendered the oral agreement void. Grandoe filed an unopposed motion for prejudgment interest. The court concluded that the district court did not commit reversible error in declining to rule on the legal effect of the Vendor Buying Agreement because any error on the district court's part was invited by Gander Mountain; the district court did not err in concluding that the Resource Allowance Contract did not render evidence of the oral agreement inadmissible; a reasonable jury could have found that the parties orally agreed to the sale of $3.05 million worth of gloves and that no written contract voided that oral agreement; and the district court did not clearly err in awarding Grandoe prejudgment interest. Accordingly, the court affirmed the district court's denial of Gander Mountain's motion for judgment as a matter of law or for a new trial, and affirmed its grant of prejudgment interest to Grandoe. View "The Grandoe Corp. v. Gander Mountain Co." on Justia Law

Defendant appealed the denial of his motion to suppress after pleading guilty to distributing and possessing with intent to distribute a controlled substance, and to aiding and abetting that offense. A state trooper pulled over behind defendant's broken-down car and initially approached him to offer assistance. The court concluded that a reasonable person in defendant's position would have understood that a state trooper had legitimate reasons to monitor the situation without seizing the motorist; once defendant identified himself as the driver and admitted that he did not have a driver's license, the trooper had probable cause to issue defendant a citation for a traffic violation and was thus entitled to detain defendant; the trooper had reasonable, articulable suspicion sufficient to justify an investigatory stop, including a dog sniff, where, among other things, defendant was unable to identify his passengers and knew one of them only as "Homie," and the trooper was unable to match the name and date of birth that defendant provided to the law enforcement database; once this reasonable suspicion was developed, the trooper did not effect an unreasonable seizure by detaining defendant until another officer arrived with the drug-detection dog; and because defendant's hour-long detention before the dog-sniff was due to the remote location, not any lack of diligence or unnecessary delay by law enforcement, the court concluded that it was reasonable under the circumstances. The district court did not violate defendant's rights under the Fifth and Sixth Amendments by considering records of the drug-detection dog's field performance in camera without disclosing the records to him where evidence of the dog's training and certification was sufficient to establish the dog's reliability and thereby demonstrate probable cause. Accordingly, the court affirmed the judgment of the district court. View "United States v. Salgado" on Justia Law

Plaintiff appealed the denial of his application for disability insurance benefits and supplemental security income (SSI) benefits. The court concluded that the ALJ did not err in concluding that plaintiff did not have a severe impairment that met the criteria of listing 12.04 (Affective Disorders); substantial evidence supported the ALJ's conclusion that plaintiff did not meet all the criteria for the listed impairment; the ALJ's determination of plaintiff's residual functional capacity (RFC) was supported by substantial evidence, and the ALJ did not err in declining to give a nurse practitioner's assessment controlling weight; and the hypothetical posed by the ALJ to the vocational expert was not defective. Accordingly, the court affirmed the denial of benefits. View "Blackburn v. Colvin" on Justia Law

Petitioner, convicted of first degree murder and sentenced to life imprisonment, appealed the district court's denial of his petition for habeas relief. Assuming without deciding that Cuyler v. Sullivan applied to conflict of interest not arising out of multiple representation, the court held that petitioner failed to demonstrate that he was entitled to relief where trial counsel's conflict of interest did not adversely affect his performance. Petitioner also failed to demonstrate that appellate counsel was ineffective by failing to press arguments outside the scope of remand. Accordingly, the court affirmed the judgment of the district court. View "Williams v. Ludwick" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of Encompass in this insurance coverage dispute. Plaintiff's home was damaged from a broken drain pipe in the basement shower stall and she sought to recover repair costs for the damage. The court concluded that Encompass failed to satisfy its burden of proving the applicability of the policy's exclusion and the district court erred when it determined as a matter of law that the water damage resulted from seepage. Further, the district court erred when it determined the "seepage or leakage" exclusion for mold remediation barred all of plaintiff's claims. Accordingly, the court reversed and remanded for further proceedings. View "Syfco v. Encompass Indemnity Co." on Justia Law

Plaintiffs challenged the constitutionality of Minnesota's Family Child Care Providers Representation Act, Minn. Stat. 179A.06 and 179A.52. Plaintiffs, operators of child-care businesses in their homes, argued that the exclusive representation and the fair share fee provisions of the Act violate their First Amendment rights. The court dissolved the injunction pending appeal and affirmed the district court's dismissal because plaintiffs' claims are unripe for review where an election is not currently scheduled, no organization is trying to obtain certification through a card check program, no organization has filed a petition for an election, and plaintiffs have not shown any significant practical harm from awaiting a petition. View "Parrish, et al. v. Governor Mark Dayton, et al." on Justia Law

Debtor filed for Chapter 7 bankruptcy and his former business associate, David Heide, challenged certain debts debtor owed to Heide as nondischargeable. The court reversed the BAP and reinstated the bankruptcy court's judgment that the debt was non dischargeable under 11 U.S.C. 523(a)(2)(A) because debtor obtained and lost more than $300,000 in loans by false representation. View "Heide v. Juve" on Justia Law

Defendant appealed his sentence after pleading guilty to conspiracy to distribute methamphetamine. The court concluded that the Government did not breach the plea agreement by introducing additional evidence to establish defendant's role under U.S.S.G. 3B1.1(a) because the plea agreement contained no provision limiting the scope of relevant conduct or defining defendant's role in the offense and because the Government unequivocally stood by its stipulation to a base offense level of 36. Accordingly, the court affirmed the district court's judgment. View "United States v. Noriega" on Justia Law