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

Three retirement-plan participants field suit against WashU for breach of its fiduciary duties under the Employee Retirement Income Security Act (ERISA). The district court dismissed the complaint for failure to state a claim.The court held that plaintiffs sufficiently alleged that fees were too high and that WashU should have negotiated a better deal. The court held that a failure of effort or competence is enough to state a claim for breach of the duty of prudence. In this case, two inferences of mismanagement are plausible from the WashU's failure to offer more institutional shares. However, the court held that plaintiffs' claims that WashU had several underperforming investments in the plan for too long was properly dismissed, because the allegations failed to establish a meaningful benchmark for evaluating the challenged options. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Davis v. Washington University in St. Louis" on Justia Law

After the district court granted petitioner partial habeas relief, both petitioner and the state appealed. The Eighth Circuit agreed with the district court that petitioner's guilt-and-penalty ineffective-assistance claims were procedurally defaulted. However, the court held that no procedural default was triggered in the initial Arkansas Rule of Criminal Procedure 37 proceedings. In this case, habeas relief cannot be granted on petitioner's guilt-and-penalty ineffective-assistance claims because he cannot establish cause for the default and actual prejudice as a result of the alleged violation of federal law, or demonstrate that failure to consider the claims will result in a fundamental miscarriage of justice.The court also held that the district court did not err in denying petitioner a hearing for his jury-pool ineffective-assistance claim where petitioner received a constitutionally adequate jury and he was not prejudiced. Finally, the court held that petitioner's McCoy-type claim is procedurally defaulted and the court rejected his request for a hearing. Accordingly, the court affirmed in part and reversed in part. View "Thomas v. Payne" on Justia Law

Plaintiff filed suit against Silverstar, alleging that it intentionally misrepresented the condition of the used Ferrari it sold him. A jury awarded plaintiff $20,201 in compensatory and incidental damages and $5.8 million in punitive damages on his claims for fraud, breach of express warranty, and deceptive trade practices under Arkansas law. The district court subsequently denied Silverstar's renewed motion for judgment as a matter of law but partially granted its motion to alter or amend the judgment, reducing the jury's punitive damages award to $500,000.The Eighth Circuit affirmed, holding that the evidence was sufficient to establish justifiable reliance on Silverstar's misrepresentations about the conditions of the car; the district court did not err in denying Silverstar's renewed motion for judgment as a matter of law on plaintiff's fraud claim where an "as is" clause does not bar an action by the vendee based on claims of fraud or misrepresentation; and the court need not address whether Silverstar should have been granted judgment as a matter of law on plaintiff's other claims for breach of warranty and deceptive trade practices, because Arkansas law allows a successful fraud plaintiff to recover compensatory, incidental, and punitive damages. The court also held that the district court did not err in reducing the punitive damages award, because the award was grossly excessive and in violation of the due process clause. View "Adeli v. Silverstar Automotive" on Justia Law

The Eighth Circuit affirmed the district court's findings of fact and conclusions of law in this trademark infringement case over the word mark "Lawn Managers." In this case, the licensing agreement was the result of a divorce and provided that husband and wife would, in effect, operate parallel, almost identical companies using the same name and similar equipment and vehicles but in different zip codes.The court agreed with the district court that Progressive has not met its high burden of proving that Lawn Managers abandoned its mark through naked licensing. Therefore, the district court properly found that wife could reasonably rely on husband's own quality control efforts and thus met the duty of control as licensor. The court held that the terms of the licensing agreement, combined with the couple's successful operation of the Lawn Managers business for over 17 years and the lack of any evidence of quality deviations at Progressive, were sufficient to support the district court's finding of reasonable reliance. Furthermore, the court held that the district court was within its discretion to conclude that the Lawn Managers mailer did not support Progressive's unclean hands defense. Finally, the district court did not clearly err in its damages award. View "Lawn Managers, Inc. v. Progressive Lawn Managers, Inc." on Justia Law

Plaintiff, his three children, and Stop Child Protection Services from Legally Kidnapping filed suit against the county, DCSS, nine county officials, and three officials. Plaintiffs' constitutional, federal, and state law claims stemmed from a Child in Need of Protection of Services (CHIPS) proceeding by DCSS.The Eighth Circuit affirmed the district court's grant of defendants' motion to dismiss, holding that plaintiffs lacked standing to challenge the facial constitutionality of three Minnesota child welfare statutes; plaintiff was not entitled to monetary damages under 42 U.S.C. 1983, because he failed to establish a due process violation, an equal protection claim, and municipal liability and conspiracy; and the children are also not entitled to damages under section 1983. The court also held that, even if the complaint was sufficiently pled and established a constitutional violation, defendants would be entitled to qualified immunity. Furthermore, the court held that no conduct by the individual defendants, as alleged in the amended complaint, rose to the level of maliciousness required to deny official immunity under Minnesota law. Finally, plaintiffs are not entitled to declaratory relief. View "Mitchell v. Dakota County Social Services" on Justia Law

Petitioner sought a petition for habeas relief under 28 U.S.C. 2254 and concurrently sought a stay of execution. The district court entered an order granting the motion for stay of execution on the basis that it required more time to consider the merits of petitioner's claims.The Eighth Circuit questioned the applicability of the authorities the district court relied on to enter a stay solely on the basis of time constraints that purportedly prevented even a preliminary consideration of the merits of the two issues petitioner has raised to determine whether he has a significant likelihood of succeeding on either of them. Accordingly, the court vacated the stay of execution and remanded with instructions to dismiss the petition for habeas corpus relief, because the court saw no possibility of success on the merits of either of petitioner's competency claim and actual innocence claim. View "Barton v. Warden Stange" on Justia Law

The Eighth Circuit reversed the district court's dismissal of plaintiffs' complaint alleging three defamation counts against defendants. The defamatory statements at issue stemmed from the parties' failed business relationship in the sport of darts.The court held that the pleaded actual damages are sufficient to satisfy the $75,000 amount-in-controversy requirement. In this case, the complaint does not limit its request for damages to a precise monetary amount, but pleaded in excess of $60,000. On the merits, the court held, under Missouri law, that defendants' three statements are capable of defamatory meaning and the opinion privilege does not render these statements nonactionable at this stage. In light of the totality of the circumstances and context in which these statements were made, the court held that a reasonable factfinder could conclude that these statements at a minimum imply an assertion of objective fact. Therefore, the district court erred in concluding that the complaint failed to state a claim for defamation and in dismissing the action. The court remanded for further proceedings. View "Turntine v. Peterson" on Justia Law

The Eighth Circuit affirmed defendant's sentence imposed after he pleaded guilty to illegally possessing a gun. The court held that defendant's sentence was substantively reasonable; the district court did not err by varying upward from the recommended sentence; and the district court considered the 18 U.S.C. 3553(a) factors including defendant's criminal history and his age. Therefore, the district court did not abuse its discretion in sentencing defendant. View "United States v. Donahue" on Justia Law

The Bankruptcy Appellate Panel affirmed the bankruptcy court's orders granting the trustee's second motion to compromise controversy, denying an agreed motion to seal, and denying debtor's motion to seal. The orders relate to the trustee's settlement of debtor's sexual assault claim against the Marianist Province.The panel held that the bankruptcy court did not err by determining that debtor's sexual assault claim was part of debtor's Missouri bankruptcy estate, because the bankruptcy estate was the entity that held the contingent reversionary interest in the claim. The panel also held that the bankruptcy court did not err in approving a proposed settlement, and that the bankruptcy court did not abuse its discretion in denying the motions to seal. View "Boisaubin v. Blackwell" on Justia Law

After an ATF agent shot and killed Myron Pollard during an undercover operation, Pollard's mother and personal representative of his estate filed suit against the United States under the Federal Tort Claims Act (FTCA) and the agent under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971). The district court held in favor of the United States and the jury returned a verdict in favor of the agent.The Eighth Circuit affirmed the district court's judgment on the FTCA claim, holding that the district court did not abuse its discretion in deciding not to draw a negative inference from deleted data against the United States. In this case, the district court's finding that the ATF did not act in bad faith in destroying the original records of the shooting is supported by evidence, and plaintiff proffered no evidence to support an inference that the original recordings were intentionally destroyed to suppress the truth or to contradict any of the government's evidence. The court also held that, in light of the facts, the district court properly determined that the agent reasonably believed deadly force was necessary to protect himself and the other agents from the vehicle and that he had acted reasonably by firing his service weapon. The court held that the FTCA judgment barred plaintiff's Bivens action and remanded to the district court with directions to vacate the judgment for the agent on the Bivens claim and to dismiss the claim. View "White v. United States" on Justia Law