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

The Eighth Circuit held that an accidental death and dismemberment insurance policy does not qualify as a health plan under Maine law, Me. Rev. Stat. Ann. tit. 24-A, 4303. Therefore, Unum Life's decision to deny benefits is subject to a deferential abuse of discretion standard of review. In this case, substantial evidence supported Unum Life's conclusion that intoxication contributed to the insured's fall down the stairs, which resulted in her death. The court concluded the Unum Life did not abuse its discretion in denying benefits under the policy's intoxication exclusion. View "Williams v. Unum Life Insurance Company of America" on Justia Law

Plaintiff filed suit against State Farm and GEICO for liability coverage after she was injured on her husband's boat. In this case, plaintiff was seriously hurt when she was thrown from the boat.The Eighth Circuit affirmed the district court's grant of summary judgment concluding that the State Farm and GEICO household exclusions bar recovery here. Furthermore, the exclusions do not violate Minnesota law and public policy. The court rejected plaintiff's suggestion that the question of umbrella and boatowner's liability insurance coverage arising from spousal negligence creates a novel question of law that the court should certify to the Minnesota Supreme Court. The court explained that the caselaw plaintiff relies on does not hold that insurance policies must cover household members. Rather, Minnesota consistently enforces household exclusions when the controlling statutes do not prohibit such exclusions, nor do they require homeowner's policies to provide liability coverage for claims made by one resident of a household against another. View "Godfrey v. State Farm Fire and Casualty Co." on Justia Law

After Justin A. Stufflebean died after allegedly being denied necessary medication while incarcerated at the Buchanan County Jail and the Western Reception Diagnostic and Correctional Center, his parents filed 42 U.S.C. 1983 and wrongful death claims against defendants. The district court denied defendants' motions to dismiss and motions for summary judgment.The Eighth Circuit concluded that it has found no firmly rooted history of immunity for private medical services providers and the purposes of qualified immunity, on balance, do not favor extending immunity to these defendants because employees of large firms systematically organized to perform a major administrative task for profit are not entitled to assert the defense of qualified immunity. The court dismissed their appeal based on lack of jurisdiction. This holding similarly precludes immediate appellate review of ACH and Corizon's appeals. The court also concluded that Defendants Strong and Hovey, the supervisors of medical care, were not on notice of a pattern of constitutional violations and their failure to verify the accuracy of ACH's reporting is insufficient to create liability under section 1983; Defendant Gross was not deliberately indifferent to defendant and is entitled to qualified immunity; Gross was also entitled to official immunity on plaintiff's wrongful death claim; but the jail's booking officer, Defendant Nauman, was not entitled to official immunity where his inconclusive testimony on accessing defendant's prior records precludes summary judgment on this issue. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Davis v. Munger" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion for a sentence reduction under the First Step Act. The court has clarified that, while the district court may consider the 18 U.S.C. 3553(a) factors in exercising its First Step Act discretion, the Act does not require it to do so. The court concluded that the district court did not err in considering the impact on the Act of defendant's guidelines range. In this case, the entire sentencing record, including the prior motions for sentence reduction under guidelines amendments, supports the finding that defendant was responsible for 5.268 kilograms of crack cocaine and therefore the bottom of the amended range under the Act would remain 360 months. Finally, the court concluded that there was no error in failing to consider defendant's request for compassionate release where he failed to exhaust his administrative remedies. View "United States v. Milton" on Justia Law

Plaintiffs filed a putative class action alleging that Polaris failed to disclose heat defects and that this artificially inflated the price of their all-terrain vehicles. The Eighth Circuit affirmed the district court's denial of class certification, concluding that there was no error in determining that individualized questions predominated, a class action was not a superior method for litigating, and the putative class included members who lacked standing.In this case, plaintiffs' nationwide class action complaint alleges violations of the the Minnesota Consumer Fraud Act and thus rebuttal evidence is permitted; Polaris has evidence challenging how much each consumer-plaintiff relied on the alleged omissions; and this will require individualized findings on reliance and is likely to make for multiple mini-trials within the class action. The court also explained that, because the class has not been defined in such a way that anyone within it would have standing, the class cannot be certified. View "Johannessohn v. Polaris Industries Inc." on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress geolocation data from his cell phone and his Google email account. The court concluded that officers were entitled to rely on the magistrate's nexus finding, and thus the Leon good faith exception applies to the warrants. The court also rejected defendant's contention that his trial was spoiled by the cumulative effect of a few evidentiary rulings. The court explained that, even if all of this evidence was excluded, the core facts supporting the verdict remain. View "United States v. Barnes" on Justia Law

Ameren appeals an adverse judgment of the district court in a Clean Air Act (CAA) enforcement action brought by the United States, acting at the request of the EPA Administrator, arguing that the district court erroneously found it liable for not obtaining permits for projects at its Rush Island Energy Center and assessing liability under the applicable federal regulations. Ameren also contends that the district court ordered legally flawed injunctions at both Rush Island and at a different plant, Labadie Energy Center.The Eighth Circuit affirmed the district court's liability determination, holding that the district court did not err in holding that the Rush Island projects required permits through application of the actual-to-projected-actual applicability test under 40 C.F.R. 52.21(a)(2)(iv)(c), incorporated by reference in section 6.060(8)(A) of the Missouri state implementation plan (SIP). The court also held that the district court did not impermissibly shift the burden of proof to Ameren in proving the applicability of the demand-growth exclusion; the district court did not err in holding that to prove the applicability of the demand-growth exclusion, Ameren had to establish that demand on the unit increases; and the district court did not err in holding that no special standard of care evidence is required for the factfinder to be able to determine whether a reasonable power plant operator or owner would have expected the projects to cause a significant emissions increase. Furthermore, even assuming that the district court abused its discretion by admitting the expert testimony, any error would be harmless. However, the court reversed in part the remedial portion of the district court's order concerning the Labadie plant. Finally, the district court had jurisdiction to consider whether Ameren violated the express terms of its Title V permit. The court remanded for further proceedings. View "United States v. Ameren Missouri" on Justia Law

After Cameron Leftwich committed suicide in jail, his father filed suit alleging 42 U.S.C. 1983 claims against defendants for failure to provide adequate medical care and failure to train, as well as wrongful death claims under Minnesota law.The Eighth Circuit affirmed the district court's grant of summary judgment for defendants, concluding that plaintiff failed to show that any of the individual defendants (or any other relevant official) was deliberately indifferent to and subjectively aware of the risk of suicide. Therefore, there was no underlying constitutional violation and the individual defendants, as well as the city and the county, are entitled to summary judgment on the section 1983 claims. The court also concluded that the district court did not err in determining Defendants Wegner and Swanson had public official immunity for plaintiff's Minnesota wrongful death claims because they were performing discretionary duties. Furthermore, the county is entitled to vicarious official immunity. The court further concluded that the county is entitled to public entity or statutory immunity because the county's decision to have a mental health exam performed within 72 hours of incarceration is a policy making and not an operational government decision. Finally, the court concluded that the district court did not abuse its substantial discretion by denying plaintiff's motions to amend the scheduling order and file an amended complaint after the deadlines had passed. View "Leftwich v. County of Dakota" on Justia Law

Designworks filed suit alleging that defendants violated its copyright in the registered design of a two-story home. The district court granted summary judgment for defendants, concluding that defendants' home design was not a copy of the original Designworks home.The Eighth Circuit affirmed, concluding that the district court did not err in granting defendants' motion for summary judgment because the works were so dissimilar that reasonable minds could not differ as to the absence of substantial similarity in expression in the designs. The court explained that there was no direct evidence of copyright infringement and there was no evidence of a substantial similarity of expression in the designs. In this case, the district court's order emphasized how unreasonable Designworks' litigating position had been, from completely failing to address the "significant objective differences" between the designs to producing nothing more than speculative evidence that anyone associated with defendants had accessed the Designworks house. The court also affirmed the district court's award of attorneys' fees and costs to defendants. View "Designworks Homes, Inc. v. Thomson Sailors Homes, LLC" on Justia Law

Ascente filed suit against Digital River for Minnesota contract, fraud, and fraud-adjacent claims. Ascente's claims arose after it hired Digital River to build a customer-facing web portal and the portal fell below Ascente's expectations.The Eighth Circuit affirmed the district court's denial of Ascente's motion to amend its fraud and reckless-misrepresentation claims where amendment would be futile. The court concluded that there was no error in granting summary judgment on the contract claims where Ascente failed to raise a triable issue of fact regarding whether Digital River breached its purported duties. The court also concluded that there was no error in granting summary on the fraudulent inducement claim where Ascente failed to raise a triable issue of fact regarding its actual reliance. View "Ascente Business Consulting, LLC v. DR myCommerce" on Justia Law