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

In this case, the parties disagreed about the nature of their dissolution agreement after one of them experienced a change in circumstances. Patriot Coal and Heritage Coal sought declaratory relief under 28 U.S.C. 2201 and Fed. R. Civ. P. 57, and requested a declaration that Peabody Holding's obligations with respect to the healthcare benefits owed to the Assumed Retirees would not be affected by modification of the benefits of retirees of Heritage or Eastern Associated under 11 U.S.C. 1114. The bankruptcy court denied relief and Patriot and Heritage appealed. While Heritage's rejection of its collective bargaining agreement relieved it of its contractual obligation to pay benefits, it still has a statutory obligation to pay those same benefits, at least until all of the steps of section 1114 are complied with. Therefore, the bankruptcy appellate panel (BAP) held that upon rejection of the "me too" agreement under section 1113, absent modification under section 1114, Heritage was still required to comply with the terms of the individual employer plan and provide its retirees those plan defined benefits; neither Heritage or United Mine Workers of America requested a modification; Peabody Holding's obligation under the liabilities assumption agreement remains undisturbed upon grant of the sections 1113 and 1114 motion; and Peabody Holding's remaining arguments lacked merit. Accordingly, the BAP reversed the decision of the bankruptcy court. View "Patriot Coal Corp., et al. v. Peabody Holding Co., et al." on Justia Law

Plaintiff appealed the bankruptcy court's finding that her student loan obligations to NCT and its loan servicer were nondischargeable. The bankruptcy appellate panel (BAP) concluded that the record revealed that plaintiff's past, present, and reasonably reliable future resources were not sufficient to meet all of the monthly payment obligations to NCT while maintaining a minimum standard of living. Accordingly, the BAP concluded on de novo review that excepting all of the obligations to NCT from discharge would be an undue hardship on plaintiff and, therefore, the BAP reversed and remanded for further proceedings. View "Conway v. National Collegiate Trust, et al." on Justia Law

In these consolidated cases, the court addressed the Board's finding that RELCO unlawfully discharged eight workers for engaging in protected labor activity and RELCO's subsequent challenge to the Board's composition. The court concluded that substantial evidence supported the Board's labor law conclusions. The court also concluded that it lacked authority to decide RELCO's challenge to the recess appointments where RELCO's challenge was barred by 29 U.S.C. 160(e)'s jurisdictional exhaustion requirement. Accordingly, the court granted the Board's application for enforcement and denied RELCO's petitions for review. View "NLRB v. RELCO Locomotive" on Justia Law

Appellants, owners and/or managers of Big Drive Cattle, LLC, appealed the district court's dismissal of their counterclaims against Farm Credit. Big Drive executed various promissory notes and loan agreements with Farm Credit. Farm Credit subsequently filed suit against appellants to enforce appellants' guarantees. Appellants filed counterclaims against Farm Credit for negligence, negligent misrepresentations, and breach of the duty of good faith and fair dealing. The court concluded that appellants could not rely on the loan agreements, the notes, the guarantees, or any other contracts for the source of the legal duty of accurate reporting they alleged Farm Credit owed to them; appellants' allegations that Farm Credit ignored an "express directive" to remove a particular employee from Big Drive's line of credit was not relevant to their amended counterclaims; and appellants failed to state a claim for negligence where appellants have not plead any plausible duty requiring Farm Credit to provide appellants with accurate reports on the loan collateral, negligent misrepresentation where appellants did not plead the element of intent, and breach of the duty of good faith and fair dealing where appellants failed to plead sufficient specific facts to establish damages arising from Farm Credit's breach. Accordingly, the court affirmed the judgment of the district court. View "Page, et al. v. Farm Credit Services, etc., et al." on Justia Law

Plaintiffs filed suit against defendants alleging claims under, inter alia, the Truth in Lending Act (TILA), as amended by the Home Ownership Equity Protection Act, 15 U.S.C. 1602 et seq. Defendants are persons and entities involved in the transactions related to the financing of an addition to a house on plaintiffs' property. The court recently joined the Ninth and Tenth Circuits in holding that notice was not sufficient to exercise the right of rescission. In this instance, the court concluded that the district court erred in finding that plaintiffs' notice was sufficient to exercise the right of rescission under section 1635 of TILA. Therefore, plaintiffs' right of rescission expired upon the sale of the property. Accordingly, the court reversed the district court's finding that plaintiffs' notice was sufficient to exercise the TILA statutory right of rescission. The court affirmed, however, the district court's grant of summary judgment, the dismissal of plaintiffs' claims, and the dismissal of the Hartmans as parties to the case. View "Hartman, et al. v. Smith, et al." on Justia Law

Plaintiff filed suit under the Federal Tort Claims Act (FTCA), 28 U.S.C. 2671 et seq., alleging that the VA negligently withheld benefits. Determining that the court had jurisdiction under 28 U.S.C. 1291, the court concluded that resolving plaintiff's claim would require the district court to determine whether the VA acted negligently in the benefits determination. Therefore, the district court lacked jurisdiction under 38 U.S.C. 511(a) and the district court properly dismissed the case. Accordingly, the court affirmed the judgment of the district court. View "Jones v. United States" on Justia Law

Defendant appealed his conviction for food-stamp fraud by giving cash back on a purchase with a USDA Electronics Benefit Transfer (EBT) food-stamp card. The court concluded that it was unnecessary to decide whether admitting Exhibit 7, a translated transcript of selected portions of a recording from the device the confidential informant wore during the sting operation, into evidence without having the original translator testify regarding its content violated the Confrontation Clause because any alleged error was harmless beyond a reasonable doubt; the district court did not violate Federal Rule of Evidence 106 in excluding Exhibit 7; the linguist's use of a pseudonym did not deny defendant the opportunity to effectively conduct cross-examination and no Confrontation Clause violation occurred; and there was sufficient evidence to support the jury's verdict as to Count II. Accordingly, the court affirmed the judgment of the district court. View "United States v. Mohamed" on Justia Law

Plaintiffs filed suit against the city alleging that the city's zoning scheme violated the First and Fourteenth Amendments. The court concluded that the zoning ordinances at issue were content-neutral, time, place and manner regulations subject to intermediate scrutiny; the zoning scheme was narrowly tailored to serve a substantial government interest; and there were reasonable alternative avenues in which plaintiffs could operate an adult entertainment business despite the zoning ordinances. Accordingly, the zoning ordinances did not violate plaintiffs' constitutional rights and the court affirmed the judgment of the district court. View "Peterson, et al. v. City of Florence" on Justia Law

Defendant conditionally pleaded guilty to two counts of possessing child pornography and subsequently appealed the district court's rulings. The court concluded that defendant's Fourth Amendment rights were not violated where a reporting requirement, standing alone, did not transform an Internet service provider, such as AOL, into a government agent whenever it chooses to scan files sent on its network for child pornography; defendant did not demonstrate a contested issue of fact that warranted a hearing; and the district court did not abuse its discretion in granting the motion to quash the subpoena duces tecum that he served on AOL where the subpoena requests were not sufficiently specific. View "United States v. Stevenson" on Justia Law

Defendant pleaded guilty to possession with intent to distribute marijuana and possession of a firearm in furtherance of a drug trafficking offense. On appeal, defendant challenged the district court's denial of his motion to suppress evidence seized from the search of his residence and his statements arising from the search. The court affirmed the conviction, concluding that law enforcement satisfied the triggering conditions of the anticipatory warrant by maintaining direct visual surveillance of a confidential informant's vehicle entering and leaving defendant's residence where the driveway leading up to the house was part of the residence. View "United States v. Donnell" on Justia Law