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

Fidelity filed suit seeking a declaration that a title insurance policy did not cover mechanics' liens. Captiva filed counterclaims, which sought a declaration that the policy covered the mechanics' liens and which asserted claims against Fidelity for failing to diligently defend and resolve the mechanics' liens claims and for tortiously interfering with Captiva's relationship with the attorneys Fidelity had hired to defend Captiva. The Eighth Circuit held that the district court did not apply the correct legal standard in deciding that Title Insurance Policy Exclusion 3(a) did not apply to the mechanics' liens at issue in this case; Exclusion 3(a) can apply under Missouri law even if the insured did not engage in intentional misconduct or inequitable dealings; Captiva failed to show that the title was unmarketable on or before the effective date of the policy and thus failed to prove its claim that Fidelity breached the policy's unmarketability-of-title provision; and thus the court affirmed the dismissal of the tortious interference claim, vacated the judgment and remanded for further proceedings, and also vacated the order awarding attorneys' fees and costs. View "Captiva Lake Investments v. Fidelity National Title Insurance" on Justia Law

Fidelity filed suit seeking a declaration that a title insurance policy did not cover mechanics' liens. Captiva filed counterclaims, which sought a declaration that the policy covered the mechanics' liens and which asserted claims against Fidelity for failing to diligently defend and resolve the mechanics' liens claims and for tortiously interfering with Captiva's relationship with the attorneys Fidelity had hired to defend Captiva. The Eighth Circuit held that the district court did not apply the correct legal standard in deciding that Title Insurance Policy Exclusion 3(a) did not apply to the mechanics' liens at issue in this case; Exclusion 3(a) can apply under Missouri law even if the insured did not engage in intentional misconduct or inequitable dealings; Captiva failed to show that the title was unmarketable on or before the effective date of the policy and thus failed to prove its claim that Fidelity breached the policy's unmarketability-of-title provision; and thus the court affirmed the dismissal of the tortious interference claim, vacated the judgment and remanded for further proceedings, and also vacated the order awarding attorneys' fees and costs. View "Captiva Lake Investments v. Fidelity National Title Insurance" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence. The court held that the district court did not clearly err in concluding that the unconstitutional seizure and detention of defendant was not meaningfully connected to the plain-view seizure of the bag of methamphetamine. The court also agreed with the district court that defendant failed to establish that the officer's unconstitutional detention was at least a but-for cause of the officer's lawful plain-view seizure of methamphetamine in the engine compartment. View "United States v. Class" on Justia Law

The Eighth Circuit affirmed the district court's denial of habeas relief to defendant with respect to his Arkansas arson conviction. The court found that trial counsel's choice not to challenge a fire investigator's testimony regarding whether defendant was a suspect in a home fire investigation did not render counsel's performance deficient. In this case, the fire marshal did not testify that defendant caused the fire, but rather that he developed defendant as a suspect based on his investigation. The court explained that the testimony was not unfounded speculation nor did it improperly usurp the providence of the jury. Furthermore, even if counsel's performance were deficient, defendant failed to establish prejudice. View "Booth v. Kelley" on Justia Law

The Eighth Circuit affirmed the district court's denial of habeas relief to defendant with respect to his Arkansas arson conviction. The court found that trial counsel's choice not to challenge a fire investigator's testimony regarding whether defendant was a suspect in a home fire investigation did not render counsel's performance deficient. In this case, the fire marshal did not testify that defendant caused the fire, but rather that he developed defendant as a suspect based on his investigation. The court explained that the testimony was not unfounded speculation nor did it improperly usurp the providence of the jury. Furthermore, even if counsel's performance were deficient, defendant failed to establish prejudice. View "Booth v. Kelley" on Justia Law

The Eighth Circuit affirmed defendant's 188 month sentence after he pleaded guilty to one count of possession with intent to distribute cocaine base. The court declined to disturb the sentence on the mere absence of a separate statement by the district court denying defendant's request for a downward departure; the underlying controlled substance offenses under the Illinois statute was not overbroad; and defendant's two prior Illinois convictions categorically qualified as controlled substance offenses under USSG 4B1.1, 4B1.2. View "United States v. Jones" on Justia Law

The Eighth Circuit affirmed defendant's 188 month sentence after he pleaded guilty to one count of possession with intent to distribute cocaine base. The court declined to disturb the sentence on the mere absence of a separate statement by the district court denying defendant's request for a downward departure; the underlying controlled substance offenses under the Illinois statute was not overbroad; and defendant's two prior Illinois convictions categorically qualified as controlled substance offenses under USSG 4B1.1, 4B1.2. View "United States v. Jones" on Justia Law

Aerotek petitioned for review of the Board's decision affirming the ALJ's findings that Aerotek violated the National Labor Relations Act in not hiring the Salts and not considering them for hiring. A "salting" campaign is a campaign by which they actively try to organize and recruit for their union on non-union jobsites. The Eighth Circuit held that substantial evidence supported the Board's finding that anti-union animus contributed to Aerotek's actions. The court also held that the Board abused its discretion by determining that one of the Salts was disqualified from full backpay and instatement. Therefore, the court affirmed the Board's finding of a violation, but remanded in part for reconsideration of the remedy. View "Aerotek, Inc. v. NLRB" on Justia Law

Aerotek petitioned for review of the Board's decision affirming the ALJ's findings that Aerotek violated the National Labor Relations Act in not hiring the Salts and not considering them for hiring. A "salting" campaign is a campaign by which they actively try to organize and recruit for their union on non-union jobsites. The Eighth Circuit held that substantial evidence supported the Board's finding that anti-union animus contributed to Aerotek's actions. The court also held that the Board abused its discretion by determining that one of the Salts was disqualified from full backpay and instatement. Therefore, the court affirmed the Board's finding of a violation, but remanded in part for reconsideration of the remedy. View "Aerotek, Inc. v. NLRB" on Justia Law

Qwinstar and Pro Logistics entered into an agreement wherein Qwinstar would purchase Pro Logistics and employ its owner for a term of five years. Qwinstar fired the owner a few months after the sale and filed suit alleging that it did not receive the inventory it bargained for in the sale. The owner counterclaimed, alleging breach of the employment contract by not paying him for the full five-year term. The Eighth Circuit held that Qwinstar was unable to prove that the owner breached the contract and thus affirmed the district court's grant of summary judgment to the owner and Pro Logistics. The court held that summary judgment was inappropriate on the owner's counterclaim because the contract provisions were ambiguous and reasonably susceptible to more than one interpretation. Therefore, interpretation becomes a question of fact precluding summary judgment. View "Qwinstar Corp. v. Anthony" on Justia Law