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

Plaintiff filed suit against pharmaceutical companies, alleging that they were liable for substantial gambling and other financial losses that resulted from obsessive compulsive behavior, a side effect of taking a dopamine agonist called Mirapex for his Parkinson's disease. The Eighth Circuit affirmed the district court's grant of summary judgment dismissing all claims as barred by the applicable California statute of limitations. The court rejected plaintiff's contention that the statute should be tolled because he was insane when the cause of action accrued; rejected plaintiff's contention that each ingestion of the drug gave rise to a separate and distinct claim under the continuing violations doctrine; and held that the district court did not abuse its discretion in denying a motion to stay defendants' motion for summary judgment. View "Mancini v. Boehringer Ingelheim Pharmaceuticals" on Justia Law

Graco sought to set a jury verdict aside that found in favor of Rydex in its breach of contract claim against Graco. Graco renewed its motion for judgment as a matter of law and moved for a new trial. After the district court denied these motions, the district court further awarded $204,221.50 in attorneys' fees to Rydex.The Eighth Circuit affirmed and held that the jury's determinations, rather than the district court's findings as a matter of law, resolved the materiality issue. The court explained that these factual determinations were uniquely in the jury's purview and the court declined to upset it on appeal. The court also held that the jury instructions fairly and adequately presented the applicable law and there was no error in reducing the amount of attorneys' fees requested by plaintiff. View "Ryan Data Exchange, Ltd. v. Graco, Inc." on Justia Law

The receiver filed suit against Associated Bank, which provided banking services to some of the scammers' entities, accusing the bank of aiding and abetting the Ponzi scheme. The Eighth Circuit affirmed the district court's conclusion that there was insufficient evidence to reasonably infer the bank knew about and assisted the scammers' tortious conduct. The court held that a conclusion that the bank aided and abetted the Ponzi scheme could only be reached through considerable conjecture and speculation. In this case, the receiver failed to show that the bank had actual or constructive knowledge of the fraud or that it provided substantial assistance to the tortious conduct. View "Zayed v. Associated Bank, N.A." on Justia Law

The Eighth Circuit affirmed the district court's grant of Medtronic's motion to remand an employment contract dispute back to state court. Applying Minnesota law, the court held that plaintiff waived his right to remove the case to federal court because the employment contract he signed contained an enforceable forum selection clause. In this case, Medtronic alleged that plaintiff failed to repay the company pursuant to the Repayment Agreement. The court held that the Employee Agreement contained a clear and unequivocal forum selection clause that unambiguously encompassed the Repayment Agreement. View "Medtronic Sofamor Danek, Inc. v. Gannon" on Justia Law

The Eighth Circuit affirmed the district court's application of the concurrent sentence doctrine to petitioner and denial of 28 U.S.C. 2255 relief. The court held that sentencing petitioner as an armed career criminal on the firearm count had no impact on his advisory guidelines range for the drug trafficking charge, and his 220 month sentence was 40 months above the Armed Career Criminal Act's mandatory 180-month minimum. In this case, petitioner did not appeal his convictions and sentences for concurrent 220 month prison terms, and the district court did not err in denying the successive habeas motion under the concurrent sentence doctrine. Furthermore, the court noted that the collateral consequences petitioner claimed was more than highly speculative where they were entirely within his control to avoid. View "Eason v. United States" on Justia Law

Defendant was convicted of three counts relating to a conspiracy to distribute human growth hormone (HGH) for unauthorized purposes and to smuggle HGH into the United States. The Eighth Circuit affirmed the district court's decision to admit evidence of a 1998 conviction at trial and defendant's 40 month sentence. The court held that the district court did not abuse its discretion by admitting the 1998 conviction because it was used to prove intent and knowledge and was well supported by evidence; by applying a sophisticated means enhancement under USSG 2T3.1(b)(1); and by imposing a sentence above the advisory guidelines range and sufficiently explaining why defendant's understated criminal history justified an upward departure to 40 months. View "United States v. Patino" on Justia Law

Plaintiff filed a 42 U.S.C. 1983 action against defendants after William Collin Spradling was shot and killed during an investigation. Plaintiff's action was filed outside the Arkansas statute of limitations. The court affirmed the district court's judgment and held that the limitations period was not equitable tolled because the undisputed facts placed plaintiff on objective notice of the need to investigate the shooting. In this case, a witness had informed plaintiff outlining inconsistencies she believed existed in the file and plaintiff did not file suit until after the limitations period had expired. View "Spradling v. Hastings" on Justia Law

The Eighth Circuit vacated the district court's approval of a settlement agreement in a purported class action alleging that SC Data Center committed three violations of the Fair Credit Reporting Act. The court held that the district court erred by not assessing whether the class representative had standing before enforcing the settlement agreement. Therefore, the court remanded for the district court to address the standing issue. View "Schumacher v. SC Data Center, Inc." on Justia Law

The Estate appealed the district court's order denying its motion for reconsideration of an adverse grant of summary judgment. SPV cross-appealed the denial of its 28 U.S.C. 1927 and Federal Rule of Civil Procedure 26(g)(3) sanctions against the Estate's attorneys.The Eighth Circuit affirmed in part, holding that the district court did not abuse its discretion in considering the Estate's motion for reconsideration because the Estate sought to use its motion for reconsideration for the impermissible purpose of introducing new arguments it could have raised earlier and failed to support those arguments with any evidence even after receiving additional time for discovery. The court also held that the district court did not abuse its discretion in denying 28 U.S.C. 1927 sanctions. The court reversed in part, holding that the district court erred by denying the Estate's request for sanctions under Rule 26(g)(1) with respect to Attorney Kroll. However, the district court did not abuse its discretion denying sanctions against Attorney Donahoe. View "SPV-LS, LLC v. The Estate of Nancy Bergman" on Justia Law

The Eighth Circuit affirmed defendant's sentence after he pleaded guilty to domestic assault by an habitual offender. The court held that defendant's sentence was not procedurally unreasonable, because the district court sufficiently explained that its decision to depart upward because defendant's criminal history category substantially underrepresented the seriousness of his criminal history. Furthermore, there was no error, much less plain error, in the district court's comments lamenting the prevalence of domestic violence on the Standing Rock reservation and surmising that defendant may have committed other acts of domestic violence where such crimes often go unreported. Finally, defendant's sentence was not substantively unreasonable where the district court imposed a well-supported, fully explained USSG 4A1.3 upward departure and then varied slightly downward from the revised advisory guidelines. View "United States v. Charles Eagle Pipe" on Justia Law