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

Two insurance-related companies claim the name “AIG.” Agency is a family-owned insurance broker in Missouri. Agency allegedly began calling itself “AIG” around 1958. International is an insurance company incorporated in 1967. International first used the “AIG” mark sometime between 1968 and 1970. International obtained a federal trademark registration for “AIG” in 1981, which is still active. Agency sued International in 2017 over International’s use of “AIG.” Relevant here, Agency alleged common-law trademark infringement and unfair competition along with violation of the Lanham Act, 15 U.S.C. Section 1125. The district court agreed with International that Agency’s claims were barred by the doctrine of laches, so it granted summary judgment in favor of International and dismissed Agency’s claims. On appeal, Agency argues the district court erred in granting summary judgment because it weighed disputed facts in International’s favor.The Fifth Circuit reversed and remanded the district court’s grant of summary judgment in Plaintiff’s lawsuit for trademark infringement over International’s use of the “AIG” trademark. The court held that Plaintiff’s claims were barred by the doctrine of laches. The court reasoned that the district court abused its discretion by not applying for progressive encroachment and did not announce any test on which it relied for determining when a likelihood of confusion arose. It also did not meaningfully analyze the strength of International’s mark at the relevant times, whether Agency intended to confuse the public, the degree of care expected of potential customers, or the evidence of actual confusion. View "A.I.G. Agency, Inc. v. American International Group" on Justia Law

Plaintiff’s father died when a driver collided with a BNSF Railway Company (“BNSF”) train. Plaintiff filed a wrongful death suit in state court against BNSF, the train operator, and the driver. The driver’s widow filed a wrongful death suit against the City of Hayti (“City”) and the train operator in state court. Plaintiff and his sister filed a wrongful death suit against the City in state court, and a motion to consolidate that action with the driver's. Plaintiff moved to voluntarily dismiss this case without prejudice. BNSF opposed the motion, arguing improper forum shopping and prejudice to the defendants.   The state court granted Plaintiff’s motion to consolidate and the district court granted the motion for voluntary dismissal without prejudice. The district court concluded that a single action in state court “will best allow for efficient use of judicial resources that this Court cannot ignore.” BNSF appealed, arguing (i) the court erred when it “failed to address Plaintiff’s purpose in seeking to voluntarily dismiss, and (ii) abused its discretion in dismissing without prejudice.   The Eighth Circuit found no abuse of discretion and affirmed the district court’s ruling.  The court reasoned that Plaintiff’s memorandum supporting his motion for voluntary dismissal without prejudice set forth the proper standard; explained that two actions arising out of the same crash were pending in state court and were not removable; and argued that judicial economy and the interests of justice would be served by dismissing the case without prejudice so it can be consolidated with the state court cases. View "Ricky Tillman, Jr. v. BNSF Railway Company" on Justia Law

Petitioner was ordered removed and sought relief under the Convention Against Torture. Petitioner claimed he had a well-founded fear of persecution based on his membership in two social groups, his father’s immediate family and “young Guatemalan men who refuse to cooperate with gang members.” The Immigration Judge denied Petitioner relief and the Board of Immigration Appeals.The Eighth Circuit denied Petitioner's petition for relief. Petitioner's main claim was that the group his father belonged to which subjected him to likely persecution was not a "cognizable social group" at the time the Immigration Judge and Board of Immigration Appeals issued their opinions. However, subsequently, the group gained recognition.The Eighth Circuit determined that, notwithstanding any issues related to the group's recognition, Petitioner's application failed because he failed to establish a nexus between the persecution he allegedly suffered and either of his proposed social groups. Additionally, substantial evidence supports the determination that TojinPetitioner did not suffer past persecution. View "Diego Tojin-Tiu v. Merrick Garland" on Justia Law

After being pulled over, Defendant and his vehicle were searched, revealing a pistol and cocaine contained in various packaging materials. Defendant was charged with possession with intent to distribute, possession of a firearm in furtherance of a drug transaction, and being a felon in possession of a firearm. At trial, an expert testified for the government that the narcotics in question were "possessed with the intent to distribute." Defendant did not object at the time.Reviewing for plain error, the Eighth Circuit determined that the district court erred in admitting the expert's testimony, but affirmed Defendant's conviction. While the expert's testimony was prohibited opinion evidence, given the other evidence supporting the jury's verdict, the error did not affect Defendant's substantial rights. The court also held the evidence was sufficient to sustain the jury's verdict, rejecting Defendant's sufficiency challenge. View "United States v. Emanuel Cowley, Jr." on Justia Law

Sleep Number partnered with Defendants and through their partnership, Defendants’ inventions were adapted to create SleepIQ technology. After two years as employees, Defendants informed Sleep Number that they wished to pursue their own venture. The parties entered into a consulting agreement requiring Defendants to disclose and assign to Sleep Number the rights to inventions within a defined Product Development Scope (“PDS”).Sleep Number sued Defendants., asserting ownership of the inventions claimed in certain patent applications filed by UDP with the United States Patent and Trademark Office (“USPTO”). The district court granted Sleep Number’s motion for a preliminary injunction preventing the defendants from further prosecuting or amending the patent applications.   The Eighth Circuit affirmed the district court’s grant of Plaintiff’s motion for a preliminary injunction. The court held that the district court did not err in determining that Sleep Number had a fair chance of success on the merits of its claims; nor did the court err in concluding that Sleep Number has demonstrated a threat of irreparable harm in the absence of an injunction; further the remaining factors of the balance of the harms and public interest both weighed in favor of Sleep Number. The court reasoned that the plain meaning of the language in the consulting agreements clearly and unambiguously places the inventions described in the patent applications within the PDS. Finally, absent an injunction, Sleep Number faces a threat of harm if it cannot participate in the patent-prosecution process for the patent applications. View "Sleep Number Corporation v. Steven Young" on Justia Law

Defendants, Des Moines Police Department officers, lacking probable cause, took relatives of a stabbing victim to the station and held them for over three hours during which time the victim died. The district court denied qualified immunity, ruling for the family on their claims of illegal seizure and false arrest.   The Eighth Circuit affirmed the district court’s denial of qualified immunity. The court held both the duration and the nature of the seizure at issue exceeded the bounds of the Constitution.   The court reasoned that officers are entitled to qualified immunity unless (1) the evidence, viewed in the light most favorable to the plaintiffs, establishes a violation of a constitutional or statutory right, and (2) the right was clearly established at the time of the violation, such that a reasonable official would have known that his actions were unlawful.  Here, the officers seized the family against their will and without probable cause. There was no “reasonable ground” for the officers’ action.   The court concluded that there was no minimally-intrusive Terry stop and the detention was the most intrusive means of questioning survivors after a violent crime. Further, officers of the Des Moines Police Department were on notice that they could not detain someone for questioning against their will, even in a homicide investigation, absent probable cause.  The same evidence establishes the officers’ violation of sec. 1983 and the Fourth Amendment establishes a violation of the Iowa Constitution. View "Crysteal Davis v. Trevor Spear" on Justia Law

Plaintiff, a locomotive engineer, sued Kansas City Southern Railway Company (“KCSR”) for negligence after he sustained injuries in a railcar collision. The district court granted summary judgment to KCSR. Plaintiff argued that section 287.280.1, the civil-action provision, authorizes his civil action because KCSR failed to carry workers’ compensation insurance. KCSR responded that it is not liable because Plaintiff “was insured by his immediate . . . employer,” triggering the exemption from liability for statutory employers in section 287.040.3. According to Plaintiff, however, section 287.040.3 exempts KCSR from workers’ compensation liability only, not liability from civil actions.   The Eighth Circuit affirmed the district court’s grant of summary judgment in favor of KCSR. The court held that because Plaintiff was insured by his immediate employer, KCSR is not liable and is entitled to judgment as a matter of law. The court reasoned that Missouri’s workers’ compensation statute, Mo. Rev. Stat. Section 287.120.1, imposes liability on employers for workplace injuries. However, nowhere in section 287.040 does the text differentiate between workers’ compensation liability and civil liability. Accordingly, the court interpreted “liable as in this section provided” to mean “liable as an employer”; that is, liable as a statutory employer. Thus, KCSR’s potential liability, therefore, is liability “as in [section 287.040] provided,” so it enjoys the immunity from suit. View "Nathan Blanton v. KC Southern Railway Co." on Justia Law

A patron of RAJJ Entertainment successfully sued RAJJ and its owner, for negligence after being injured in the bar’s parking lot. Defendants’ insurance company, Great Lakes Insurance, sued for a declaration stating that it was not required to indemnify RAJJ and the owner for the damages award because the insurance policy excluded from coverage injuries that arose from physical altercations. The district court granted summary judgment to Great Lakes.The Eighth Circuit affirmed the district court’s summary judgment ruling in favor of Plaintiff. The court held that the clear language of the policy controls. The court reasoned that insurance companies are not required to indemnify the insured for injuries that are excluded by a policy. Generally, where a plaintiff’s negligence claim arises out of an assault or battery, the assault or battery exclusion bars coverage of the insured’s negligence claim.   Defendants claim that the exclusion does not apply because the underlying lawsuit “arose out of” their negligence—not any assault, battery, or physical altercation. The court reasoned that the policy language concerns how the bodily injury arose, not how the lawsuit arose. The concurrent-proximate-cause rule does not apply because RAJJ and the owner’s negligence is not a “covered cause.” Furthermore, even if RAJJ and the owner’s negligence were covered, that would not require Great Lakes to indemnify them because their negligence was not “truly independent and distinct” from the assault, battery, or physical altercation. View "Great Lakes Insurance SE v. Ray A. Perrin" on Justia Law

Plaintiffs, described as “political candidates, political associations, and individuals who engage in political activities relating to political elections and campaigns in Minnesota”, brought a case under 42 U.S.C. Section 1983 to assert a pre-enforcement First Amendment challenge to Minn. Stat. Section 211B.02. Plaintiffs sued four Minnesota county attorneys with the authority to criminally prosecute violations of 211B.02. Plaintiffs moved for a preliminary injunction to enjoin the county attorneys from enforcing 211B.02 pending the district court’s entry of final judgment. The district court denied the motion.   The Eighth Circuit affirmed the district court’s denial of Plaintiffs' motion for a preliminary injunction holding that Defendants had not enforced the statute and had not threatened to do so and were entitled to Eleventh Amendment immunity. The court reasoned that the record showed that after the motion-to-dismiss stage and in response to Plaintiffs’ preliminary-injunction motion, the four county attorneys filed substantially similar affidavits providing that they had “no present intention” to prosecute anyone for violating 211B.02. Further, because county officials’ affidavits all show that they have not enforced or threatened to enforce 211B.02 the Ex parte Young exception to Eleventh Immunity is inapplicable. View "Minnesota RFL Caucus v. Mike Freeman" on Justia Law

Plaintiff sued Defendant insurance company for mishandling his wife’s enrollment for supplemental life insurance and then declaring her ineligible for coverage after she died. The district court determined Defendant violated ERISA, finding Defendant breached its fiduciary duty to ensure its system of administration did not allow it to collect premiums until coverage was actually effective. Defendant appealed.The Eighth Circuit affirmed. Defendant maintained its fiduciary duty despite the fact that the deceased's employer collected premium payments before forwarding them to Defendant. The plan in question gave Defendant discretion to approve benefits, which under ERISA is sufficient to create a fiduciary duty. Defendant violated its fiduciary duty by failing to maintain an effective enrollment system. Under ERISA, a fiduciary must discharge its duties with reasonable care, skill, prudence and diligence. The court held that a reasonably prudent insurer would use a system that avoids the employer and insurer having different lists of eligible, enrolled participants. Defendant's billing system breached the fiduciary duty it owed to the deceased. Thus, the court affirmed the district court's granting of summary judgment to Plaintiff. View "Corey Skelton v. Reliance Standard Life Ins Co" on Justia Law