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

The Eighth Circuit affirmed the grant of summary judgment in favor of several creditors in this Chapter 11 debtor-in-possession case. The court held that the judgment allowed proofs of claim totaling over $5.2 million and there was no merit to debtor's several objections. In this case, the sale agreement was not executory; none of debtor's contractual defenses have merit because all of the challenged conduct occurred after debtor filed for bankruptcy; and the court rejected debtor's procedural arguments. View "Sears v. Sears" on Justia Law

Minn. Stat. 125A.06(d), by its plain language, does not impose a heightened standard that burdens school districts with an absolute obligation to guarantee that each blind student will use the Braille instruction provided to attain a specific level of proficiency. I.Z.M. filed suit against the District, alleging claims under the Individuals with Disabilities Education Act (IDEA) and non-IDEA claims for relief under Title II of the Americans with Disabilities Act (ADA), and Section 504 of the Rehabilitation Act. The Eighth Circuit affirmed the district court's grant of the District's motions for judgment on the administrative record on the IDEA claim and for summary judgment on the non-IDEA claims. In this case, the ALJ cited the state regulation and expressly concluded that the District took all reasonable steps to provide instructional materials in accessible formats in a timely manner. In regard to the non-IDEA claims, the district court used the correct standard and correctly concluded that I.Z.M. failed to present evidence of bad faith or gross misjudgment View "I.Z.M. v. Rosemount-Apple Valley-Eagan Public Schools" on Justia Law

Plaintiffs Lenny and Tracy Chapman filed suit against Hiland after an explosion seriously injured Lenny, alleging negligence and loss of consortium. Hiland then filed a third-party complaint against Missouri Basin and B&B, seeking indemnification. In this appeal, Missouri Basin challenged the district court's grant of summary judgment to plaintiffs and the district court's ruling on post-judgment motions. The Eighth Circuit held that honoring the Oklahoma choice-of-law provision in the Hiland Master Service Contract did not violate a fundamental public policy of North Dakota because it was not a motor carrier transportation contract under North Dakota law. The court also held that the district court did not abuse its discretion by granting plaintiffs' Fed. R. Civ. P. 59(e) motion where the district court clarified that by using the language "all amounts that have been paid or will be paid," Missouri Basin intended that it indemnify plaintiffs for the full amount of the settlement, including those amounts paid by Hiland's insurers. Furthermore, the district court did not abuse its discretion by denying Missouri Basin's Rule 59(e) motion. View "Chapman v. Missouri Basin Well Service" on Justia Law

Stine Seed filed suit against A&W and its principles, alleging contract claims related to A&W's failure to pay for corn and soybeen seed. The district court found in favor of Stine Seed on its implied-in-fact contract claim against Defendant Williams in the amount of $28,160, and found in favor of Williams and A&W on the remaining claims. The Eighth Circuit affirmed in part and held that the district court did not clearly err in finding that Williams did not sign the July Adjustment and in finding Williams' version of events credible; no implied-in-fact contract existed between Williams and Stine Seed with respect to the seed planted by J&A; and the district court did not err in finding Williams not liable for unjust enrichment. The court held, however, that the district court should have given A&W's admission that Alexander had apparent authority conclusive effect, and its finding that Alexander lacked authority to bind A&W to the Note was clear error. Therefore, the verdict in favor of A&W on Stine Seed's breach of contract claim must be reversed and remanded. View "Stine Seed Co. v. A & W Agribusiness, LLC" on Justia Law

The Eighth Circuit affirmed the district court's denial of defendant's motion to suppress evidence found in plain view during a warrantless search of his home. The court held that the officers were justified in conducting the protective sweep of defendant's residence before removing him from the porch in order to find other persons that might be inside. The court also held that the officers conducted the protective sweep in a constitutional manner because it lasted only two minutes and was confined to places large enough to hide a person. Because the protective sweep of defendant's residence passed constitutional muster, the fruits of that valid sweep were untainted. View "United States v. Alatorre" on Justia Law

The Eighth Circuit granted consolidated petitions for review of the Board's Final Rule, holding that the Board exceeded its authority by promulgating a rule defining "on-time performance" under the Passenger Rail Investment and Improvement Act of 2008, Pub. L. No. 110-432, 122 Stat. 4907, after the Act's delegation to another agency was invalidated. In this case, the Final Rule expressly bases its authority on the need to fill the vacuum created by the invalidation of the on-time performance rule announced by the FRA and Amtrak under section 207 of the Act; the gap-filling rationale does not allow one agency to assume the authority expressly delegated to another; Congress likely did not give the FRA/Amtrak and the Board separate authority to develop two potentially conflicting on-time performance rules; and on-time performance in section 213(a) means on-time performance as developed by the FRA and Amtrak under section 207(a). View "Union Pacific Railroad Co. v. STB" on Justia Law

The Eighth Circuit affirmed defendant's convictions for tax evasion, mail fraud, and wire fraud for conduct relating to the operation of three companies that he owned. The court held that the district court did not abuse its discretion by limiting defendant's cross-examination of a prosecution witness; the district court did not clearly err in determining that defendant's base offense level was 22 based on a tax loss of greater than $1,000,000; and the district court did not clearly err by applying and two-level adjustment under USSG 3C1.1 for obstruction of justice. Because the government concedes that it did not establish sufficient evidence to support the application of the USSG 2T1.1(b)(1) enhancement for failing to report income exceeding $10,000 from criminal activity, the court vacated the sentence and remanded for resentencing. View "United States v. Montanari" on Justia Law

The Eighth Circuit affirmed the district court's decision affirming the bankruptcy court's sustaining of debtors' objection to the proof of claim. The court held that 8 U.S.C. 502 does not preempt Arizona Revised Statute section 33-814, which sets a 90-day limit for commencing or continuing a civil action in Arizona state court. In this case, the 90-day limit had not expired before debtors filed their Chapter 11 petition. The court also held that, because creditor's state court action was dismissed shortly after the trustee's sale for failure to perfect service on defendants, it was not "maintained" within the meaning of Valley Nat'l Bank of Ariz. v. Kohlhase, 897 P.2d 738, 741 (Ariz. Ct. App. 1995). In Kohlhase, the court adopted an Arizona district court's holding that an action on the debt qualified as a deficiency action under A.R.S. section 33-814 even though the creditor filed the action before the trustee's sale and did not amend the complaint to allege a deficiency after the trustee's sale. View "Melikian Enterprises, LLLP v. McCormick" on Justia Law

The Eighth Circuit affirmed the district court's denial of the insurers' motion to dismiss, reversed and vacated the award of prejudgment interest, and affirmed the rejection of Simmons' claims for statutory damages and attorney fees. The court applied Arkansas law and held that the district court properly denied the insurers' motion to dismiss because Simmons's suit was timely. However, the district court's entry of judgment and prejudgment interest was not appropriate where Simmons' damages were not capable of exact determination until the jury spoke. Finally, the district court properly denied Simmons' request for statutory damages and attorney fees, because Simmons did not recover the statutory threshold of at least 80% of the amount it demanded in the suit. View "Simmons Foods, Inc. v. Industrial Risk Insurers" on Justia Law

The Eighth Circuit granting rehearing en banc and vacated the panel opinion.The court reversed the unregistered firearm conviction and remanded for further proceedings. The court held that the holding in United States v. Barr, 32 F.3d 1320 (8th Cir. 1994), as to the mens rea required for a conviction under the National Firearms Act was wholly inconsistent with Staples v. United States, 511 U.S. 600 (1994), and was therefore overruled. The court explained that by imposing strict criminal liability on owners of "quasi-suspect" guns—an undefined category that invites arbitrary application—Barr contravened the Supreme Court's view that Congress did not intend "to make outlaws of gun owners who were wholly ignorant of the offending characteristics of their weapons." Therefore, the court joined its sister circuits in holding that, in all cases in which a defendant is prosecuted under the National Firearms Act for unlawful possession of an unregistered firearm, the government must prove beyond a reasonable doubt that the defendant knew of the physical characteristics of the weapon bringing the weapon within the ambit of the Act. In this case, the jury instructions failed to sufficiently apprise the jury of the government's burden. View "United States v. White" on Justia Law