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

Defendant, the Director of Industry Operations for the Kansas City Field Division of the ATF, denied Harris News' application for a federal license to sell guns based on the ground that Harris News and co-owners willfully allowed a felon to possess firearms. The district court affirmed. The court, however, reversed the judgment of the district court, concluding that the ATF had no authority to deny the license application under 18 U.S.C. 923(d)(1)(C) because the ATF did not show that the Harris News officers and owners did anything to further the felon’s possession of firearms. View "Harris News Agency, Inc. v. Bowers" on Justia Law

Debtor appealed the bankruptcy court's decision finding that some, but not all, of her student loan obligations to NCT are nondischargeable. The court concluded that the bankruptcy court did not clearly err in its fact findings for the time period analyzed. In this case, the time period the bankruptcy court used was the most recent time period for which it had complete income and expense figures. Finally, the bankruptcy court did not abuse its discretion in denying debtor's motion to make additional findings and amended the judgment. Accordingly, the court affirmed the judgment. View "Conway v. National Collegiate Trust" on Justia Law

CMI filed suit against Bancorp, alleging breach of contract after Bancorp refused to cure or repurchase eleven loans. The district court granted summary judgment for CMI on eight of the eleven loans. Determining that Residential Funding Co. v. Terrace Mortg. Co. controls the court's analysis, the court held that the parties’ agreement granted the buyer sole discretion to determine whether a loan was defective and required the seller to repurchase if the buyer made such a determination, and the court should not inquire further by reviewing the validity of that determination. Even if CMI erroneously exercised its sole and exclusive discretion, Bancorp has presented no evidence that CMI exercised its discretion under the agreement in a manner intended to sabotage or evade the spirit of the agreement or to deny Bancorp the expected benefit of its bargain. Accordingly, the court concluded that the district court did not err in granting summary judgment on the Brown, Hansen, Maggio, and Perez loans. The court also concluded that the district court properly awarded CMI the repurchase price for the Brown and Bennett loans, as calculated using the formula set forth in the agreement. Finally, the court concluded that the district court did not err in granting summary judgment on the Curtis, Maggio, and Villares loans and rejected Bancorp's argument that there is a genuine issue of material fact regarding which party's negligent underwriting caused the loans to be defective. Accordingly, the court affirmed the judgment. View "CitiMortgage v. Chicago Bancorp." on Justia Law

Defendant pled guilty to conspiracy to distribute 500 grams or more of methamphetamine and conspiracy to launder money. On appeal, defendant challenged his sentence of 210 months imprisonment. The court concluded that the district court did not abuse its discretion by finding the immigration consequences insufficient to merit a downward departure or a variance from his Guidelines range; defendant has not offered sufficient evidence to rebut the presumption that his bottom-of-the-Guidelines sentence is reasonable; and the district court properly considered the 18 U.S.C. 3553(a) factors and did not give significant weight to improper or irrelevant evidence. Accordingly, the court affirmed the judgment. View "United States v. Meza-Lopez" on Justia Law

Plaintiff, an incarcerated state inmate, filed suit under 42 U.S.C. 1983, alleging deliberate indifference to her serious medical needs. Plaintiff alleged that defendants refused to provide hormone replacement therapy for her Gender Identity Disorder (GID).The district court granted summary judgment for defendants. The court concluded that the district court properly granted summary judgment where the district court found that plaintiff's claims against defendants in their official capacities are barred by sovereign immunity. The court agreed with the district court that plaintiff's claims against defendants in their individual capacities were barred by qualified immunity where the evidence, viewed in the light most favorable to plaintiff, did not establish an Eighth Amendment violation. In this case, numerous mental-health professionals have evaluated plaintiff, but none have diagnosed her with GID or concluded that GID treatment is appropriate. Plaintiff's disagreement with these diagnoses and treatment decisions is not actionable under section 1983. Accordingly, the court affirmed the judgment. View "Reid v. Griffin" on Justia Law

This appeal stems from a settlement agreement involving a patent infringement dispute between ACI Worldwide and JBTS. On appeal, ACI Worldwide challenged the district court's denial of its motion for partial summary judgment and grant of partial summary judgment to JBTS. The court concluded that even if case 231, standing alone, no longer arose under U.S. patent law after the district court deemed ACI Worldwide’s non-infringement and invalidity claims merged into case 245, the Federal Circuit still has exclusive appellate jurisdiction of this entire consolidated case composed in large part of federal patent claims. Although the court could transfer this case to the Federal Circuit, the court concluded that transfer is unnecessary because an appeal raising the same issues is already pending in the Federal Circuit. Accordingly, the court dismissed the case without prejudice for lack of appellate jurisdiction. View "Online Resources Corp. v. Joao Bock Transaction Sys." on Justia Law

Mechanics, members of the Union and employees of Metro, filed a declaratory judgment action, seeking a declaration under section 13(c) of the Urban Mass Transportation Act of 1964 (UMTA), 49 U.S.C. 5333, that Metro must establish a framework through which they could form a bargaining unit separate from the Union. The Union intervened and the district court granted the Union's motion to dismiss for failure to state a claim. The court concluded that the district court correctly determined that section 13(c) does not entitle mechanics to the relief they seek because Congress did not intend to provide a federal forum for disputes between unions and transit authorities; the language and structure of section 13(c) does not suggest that Congress intended to create a federal private cause of action; and the consistent theme in Section 13(c)’s legislative history was that “Congress intended that labor relations between transit workers and local governments would be controlled by state law[.]" Accordingly, the court affirmed the judgment. View "Stenger v. Bi-State Dev. Agency" on Justia Law

Plaintiffs, 19 workers employed by Degeller, filed a class action suit on behalf of themselves and similarly situated Deggeller employees. The court concluded that the district court erred in dismissing the breach of contract claim where the workers’ allegation that Deggeller failed to pay the prevailing wage stated a valid claim for breach of their employment contracts. The court also concluded that the district court erred in dismissing the workers' claim for statutory damages under 26 U.S.C. 7434 because they alleged that Deggeller intentionally filed fraudulent tax documents on their behalf. Accordingly, the court reversed the district court’s Rule 12(b)(6) dismissals of these claims and vacate its decision under 28 U.S.C. 1367(c)(3) not to exercise supplemental jurisdiction over the Arkansas minimum wage claim. View "Cuellar-Aguilar v. Deggeller Attractions, Inc." on Justia Law

Wolfe filed suit against Universal for a declaration of its rights under an insurance policy, as well as for breach of contract and vexatious refusal to pay. Universal counterclaimed for declaratory judgment in its favor. The district court granted Universal's motion for summary judgment. The court concluded that, under the plain language of the policy, the umbrella coverage is not available for the injuries alleged in the underlying complaint. Therefore, Universal is entitled to judgment as a matter of law that it is not under a duty to defend Wolfe from the underlying suit except to the extent such a duty may be provided for in the customer complaint defense provision, and consequently that Universal is not under a duty to indemnify Wolfe should there be an award of damages in the underlying suit. Because Wolfe's claims for breach of contract and vexatious refusal to pay rest on the success of its declaratory judgment action, the court need not address them, nor Universal's remaining arguments. Accordingly, the court affirmed the judgment. View "Wolfe Auto. Grp. v. Universal Underwriters Ins. Co." on Justia Law

The US filed suit on behalf of the USDA to enjoin dissolution of the Benton County Sewer District No. 1. A Voter Representative Group seeks to intervene. The district court denied the motion. The court affirmed, concluding that the Group does not have Article III standing. The court rejected the Group's claims that it has an interest in upholding the vote to dissolve the District and immediately dissolving the District; an interest in opposing the repayment of the revenue bond the District issued to the USDA; an interest in opposing the State’s claims under the Missouri law; and an interest in proposing on-site sewage treatment alternatives. View "United States v. Geranis" on Justia Law