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

Plaintiff, a Minnesota prisoner, sued several officials of the Minnesota Department of Corrections, alleging that they violated his constitutional rights by failing to protect him from an attack by a fellow inmate. The district court granted summary judgment for the officials. Defendant appealed the dismissal of his Eighth Amendment claims.   The Eighth Circuit affirmed. The court agreed with the district court that the evidence is insufficient to show that any of the defendant officials subjectively concluded that Plaintiff faced a substantial risk of serious harm and then failed to respond reasonably to it. The unrebutted evidence is that the two voting officials on the incompatibility committee considered incident reports and other relevant information but decided that the situation did not rise to the level of incompatibility—that is, they concluded that the evidence did not indicate a risk of serious bodily injury to an offender. This means that the officials did not draw the subjective inference that there existed a substantial risk of serious harm to Plaintiff. The officials predicted incorrectly, but they were not deliberately indifferent for the purposes of the Eighth Amendment. View "David Hodges v. Minnesota Dept. Corrections" on Justia Law

Plaintiff appealed the district court’s order upholding a decision by the Commissioner of the Social Security Administration denying her disability insurance benefits and supplemental security income. She argued that the Commissioner’s decision was not supported by substantial evidence. Plaintiff contends that the ALJ failed to sufficiently articulate his rationale for rejecting Plaintiff’s treating physician’s opinion, rendering the ALJ’s decision legally erroneous and unsupported by substantial evidence on the record as a whole.   The Eighth Circuit affirmed. The court held that ALJ was justified in finding the physician’s opinion unpersuasive. The opinion’s bare, formulaic conclusion presumptively warranted little evidentiary weight “because it was rendered on a check-box and fill-in-the-blank form.” The physician checked some boxes and left blank the short-answer section asking what objective medical findings supported his assessment. The ALJ also found the checkbox form “unsupported and highly inconsistent” with the record because the physician’s conservative treatment plan, other medical opinions, and Plaintiff’s own descriptions of her activities contradict the checkbox assessment. View "Vickie Nolen v. Kilolo Kijakazi" on Justia Law

A jury convicted Defendant of conspiracy to distribute 500 grams or more of methamphetamine with two prior serious drug felonies. The district court sentenced him to 324 months in prison. Defendant appealed, arguing that the district court erred in admitting Rule 404(b) testimony from a man who was not involved in the charged conspiracy but began selling meth with Defendant three months after the conspiracy ended.   The Eighth Circuit affirmed. The court explained that the government failed to give the notice required under Fed. R. Evid. 404(b)(3). But under a plain error standard of review, the error did not affect Defendant’s substantial rights. The evidence of his participation in the conspiracy was robust. And, as he concedes, many witnesses had already testified about his drug connections to California.   Further, Defendant argued the testimony, particularly about him exchanging guns for drugs, was unduly prejudicial because it “changed a non-violent, alleged conspiracy into a hyper-violent one.” However, the court held that the evidence, particularly with the court’s limiting instruction, was not unduly prejudicial. Moreover, four cooperating witnesses and co-conspirators testified that Defendant brought and shipped meth into Nebraska for redistribution. Their testimony was further corroborated by a package (intercepted by law enforcement) with about five pounds of meth; Postal Service records of packages sent; records of wire transfers sent to California; phone records; and records of drug sales kept by a cooperating witness. Accordingly, there was sufficient evidence to support the verdict. View "United States v. Enrique Abarca" on Justia Law

Lindenwood Female College (Lindenwood) asserted class action claims against its casualty insurer, Zurich American Insurance Company (Zurich), alleging a wrongful denial of coverage for COVID-19 business interruption at its Missouri and Illinois properties. The district court granted Zurich’s motion to dismiss, finding no plausible allegation of coverage.   The Eighth Circuit affirmed. The court concluded that Lindenwood’s argument fails to identify an ambiguity. The court explained that in its view, no lay person—no reasonable insured—could look at the policy as a whole and fail to appreciate that the state-specific endorsements are intended to apply in the respective states. The references to Louisiana and other states are not mere titles; they serve to establish the structure of the policy as a whole. And it would simply make no sense to define a contamination exclusion with express reference to viral contamination in the main body of the policy only to wholly eliminate that same exclusion nationwide in a later endorsement that references an individual state. View "Lindenwood Female College v. Zurich American Insurance Co." on Justia Law

The City of Carthage sued Union Pacific Railroad Co. for breach of contract, claiming UP failed to maintain several bridges. On summary judgment, the district court ruled that the City’s breach-of-contract claim was barred by the five-year statute of limitations. The City argues that the ten-year statute of limitations applies here because its claim seeks an equitable remedy.   The Eighth Circuit affirmed. The court explained that the City’s claim accrued in February 2013, at the latest. On February 15, 2013, the City wrote UP demanding the repair of the bridges—establishing that the City was on notice of a potentially actionable injury. The City waited until 2019—over five years later—to sue UP. The City’s claim is barred by the five-year statute of limitations. Further, here, UP did not engage in any affirmative act during the limitations period. Without more, a failure to act does not justify the continuing wrong rule. View "City of Carthage, Missouri v. Union Pacific Railroad Co." on Justia Law

Martinique Properties, LLC filed a complaint against Certain Underwriters at Lloyd’s, London (Underwriters), seeking to vacate an arbitration award. The district court dismissed the complaint for failure to state a claim for vacatur. Martinique Properties appealed. Martinique Properties argues that the appraisal award must be vacated because the appraisers “used figures and measurements which are contrary to the actual conditions of the Property” and failed to “consider certain buildings” and certain portions of a damaged roof when determining the appraisal award. These alleged errors, Martinique Properties argues, show that the appraisers were either “guilty of misconduct” or “so imperfectly executed” their powers that “a mutual, final, and definite award . . . was not made,” two of the four grounds for vacating an award under the FAA.   The Eighth Circuit affirmed. The court found that Martinique Properties has alleged only factual errors that challenge the merits of the appraisal award, and the court has no authority to reconsider the merits of an arbitration award, even when the parties allege that the award rests on factual errors. Accordingly, the appraisers’ use of certain figures and measurements in calculating the amount of loss here, and their alleged failure to consider particular buildings and portions of roof damage, even if incorrect, are not sufficient for vacatur under the FAA. View "Martinique Properties, LLC v. Certain Underwriters at Lloyd's of London" on Justia Law

Core and Main LP (“C&M”) supplies water, wastewater, storm drainage, and fire protection products and services to commercial and governmental customers. C&M acquired the assets of Minnesota Pipe and Equipment Company (“MPE”), which supplied the same products and services in areas of Minnesota and South Dakota. Defendant, one of the shareholders, was part of MPE’s management team. Defendant started work at Dakota Supply Group, Inc. (“DSG”), a C&M competitor. C&M brought a diversity action against Defendant and DSG, asserting breach of the Employment Agreement’s noncompete and confidentiality covenants, tortious interference, and related claims. The district court granted Defendants’ Rule 12(b)(6) motion to dismiss for failure to state a claim. The main issue on appeal is whether the court correctly concluded that the Noncompetition Agreement was a later agreement and, therefore, its Entire Agreement provision superseded the restrictive covenants.   The Eighth Circuit concluded that the breach of contract and tortious interference claims turn on fact-intensive issues that cannot be determined on the pleadings. Accordingly, the court reversed the dismissal of those claims and otherwise affirmed. The court explained that it agreed with C&M that it is at least plausible the two Agreements covered different subject matters, making Rule 12(b)(6) dismissal inappropriate. The Noncompetition Agreement restricting MPE shareholders from engaging or investing in a competing business was geographically broad, but its duration was precisely limited to a specific term for each restricted party. In addition, the court concluded that in the context of the multiple agreements that completed the Asset Purchase transaction, the term “prior or contemporaneous” in the Noncompetition Agreement’s Entire Agreement provision is ambiguous. View "Core and Main, LP v. Ron McCabe" on Justia Law

Defendant was convicted of one count of conspiracy to distribute 50 grams or more of methamphetamine or 5 grams or more of actual, pure methamphetamine, two counts of distribution of heroin, and one count of distribution of heroin and methamphetamine. On appeal, he challenged the district court’s denial of his motion for a new trial based on the introduction of a stipulation as to his codefendant’s prior conviction, its refusal to give his requested jury instructions, and the sufficiency of the evidence on the conspiracy count. He also challenged the district court’s calculation of his advisory sentencing guidelines range.   The Eighth Circuit affirmed. The court held that the district court did not abuse its discretion in allowing the stipulation to be introduced or in rejecting Defendant’s proposed jury instructions, and there was sufficient evidence to convict him of conspiracy to distribute. Thus, the district court did not abuse its discretion in denying Defendant’s motion for a new trial. Further, the court wrote that the district court did not clearly err in calculating the drug quantity involved in Defendant’s offense. The district court’s quantity determination was largely based on a customer’s and a confidential informant’s testimony. The district court found these witnesses to be credible, and the court found no reason to overturn that finding. View "United States v. Charleton Maxwell" on Justia Law

A U.S. Postal Service (USPS) vehicle allegedly ran over A.M.L.’s foot on July 18, 2018. A.M.L.’s mother sent a Claim for Damage, Injury or Death (Standard Form 95) to USPS in August 2018. A year later, A.M.L.’s attorney sent a demand letter that set forth A.M.L.’s medical expenses. After USPS denied liability, A.M.L. (by and through her parent) filed suit against the United States under the Federal Tort Claims Act (FTCA). The government moved to dismiss the suit for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1), arguing that A.M.L. had failed to exhaust her administrative remedies before bringing suit. The district court dismissed the suit, and A.M.L. appealed, arguing that her claims satisfied the FTCA’s presentment requirement.   The Eighth Circuit reversed and remanded. The court held that Sections 2672 and 2675(b) do not require that a claim set forth a single-dollar amount, but that it must express the maximum value of the asserted claim. Accordingly, the expression of a range complies with the statute’s requirements because it presents the maximum value of the claim. A.M.L.’s claim of “$250,000 to $275,000” thus presented a sum certain in compliance with the FTCA’s presentment requirement. View "A.M.L. v. United States" on Justia Law

Plaintiff appealed the district court’s grant of summary judgment to Defendant, Baptist Health, on her sex-discrimination, retaliation, hostile work environment, constructive-discharge, and negligent-retention claims. After the individual defendant was dismissed as a defendant, Baptist Health moved for summary judgment, and the district court granted its motion.   The Eighth Circuit affirmed. The court first explained that here, Plaintiff presented no evidence that Baptist Health intended to force her to quit. Rather, the record indicates that Baptist Health tried to retain Plaintiff by giving her paid administrative leave, offering to relocate her to a different location, and offering to transfer her to a new department. Thus, the district court did not err in granting summary judgment to Baptist Health on this claim.   Second, the court held that Plaintiff’s sex-discrimination and retaliation claims fail because she has not suffered an adverse employment action. Baptist Health offered for Plaintiff to keep her same job at any one of three locations or to transfer departments. The court wrote that Plaintiff has not shown that transferring to another department would produce a material employment disadvantage.   Third, the court found that the district court did not err in granting summary judgment to Baptist Health on this claim because there is no evidence that the alleged discrimination was based on sex. Finally, the court found that the evidence does not suggest that Baptist Health subjected her to any unreasonable risk of harm. View "Courtnay Bell v. Baptist Health" on Justia Law