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

Appellants appealed the Commissioner's determination that the USDA's Conservation Program (CRP) payments that appellants received were taxable as income from self-employment. The court entered judgment in favor of appellants, holding that the 2006 and 2007 CRP payments at issue were consideration paid by the government for use and occupancy of appellants' property. Consequently, they constituted rentals from real estate fully within the meaning of 26 U.S.C. 1402(a)(1). The court reversed and remanded.View "Morehouse v. Commissioner of IRS" on Justia Law

Plaintiff filed suit against Reliance and the Plan, under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., claiming that Reliance abused its discretion in denying long-term disability benefits. The district court granted summary judgment to plaintiff. The court concluded that Reliance's interpretation of the Plan is reasonable. The loss-of-license provision states that the loss of a license for any reason is insufficient in and of itself to entitle a claim to benefits. In this case, plaintiff's diagnosis of diabetes mellitus was not enough by itself to justify benefits. Reliance's interpretation merely requires that the claimant show that the injury or sickness itself renders him unable to perform his occupation. Further, Reliance's determination that plaintiff was not totally disabled was supported by substantial evidence and its denial of benefits was reasonable. Accordingly, the court reversed the judgment of the district court.View "Hampton v. Reliance Standard Life Ins. Co." on Justia Law

Plaintiff filed suit against BNSF, alleging that BNSF violated the anti-retaliation mandate in the Federal Rail Safety Act (FRSA), 49 U.S.C. 20109(a), when BNSF terminated him. The district court granted summary judgment dismissing plaintiff's claim. The court concluded that plaintiff's FRSA claim failed because he failed to present a prima facie case of unlawful discrimination where plaintiff's protected activity was completely unrelated to the fouling-the-tracks incident that led to his discharge. BNSF submitted clear and convincing evidence that it would have discharged plaintiff whether or not he had made unrelated reports that were activity protected by the FRSA. Accordingly, the court affirmed the judgment of the district court.View "Kuduk v. BNSF Railway Co." on Justia Law

Plaintiff filed suit against Associated Underwriters after she was terminated, alleging claims under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The district court dismissed both claims. The court concluded that plaintiff presented sufficient evidence to allow a reasonable jury to conclude that there was a direct correlation between employee age and the termination decision - that it was the but-for cause of plaintiff's termination. Therefore, the court reversed the district court's dismissal of the ADEA claim. The court concluded, however, that the district court properly dismissed the ADA claim where there is no evidence that Associated Underwriters terminated her employment on the basis of disability. Therefore, the court affirmed as to this claim.View "Tramp v. Associated Underwriters, Inc." on Justia Law

Hudson filed suit seeking a declaratory judgment that the Hired and Non-Owned Auto Liability endorsement to an insurance policy's Commercial General Liability Coverage Form provides no coverage to any defendant in the underlying lawsuit. The district court granted summary judgment to defendants. Hudson appealed. Defendants cross-appealed an earlier ruling that Hudson is not collaterally estopped to contest coverage by the state court judgment. In appeal No. 13-1688, the court concluded that Hudson is entitled to summary judgment on the coverage issue where, at the time of the accident, defendant Tyler Roush was not acting in the course of defendant Brash Tygr's business within the meaning of the Policy's Hired and Non-Owned Auto Liability endorsement. In appeal No. 13-1742, the court affirmed the judgment and dismissed the cross-appeal, concluding that defendants' cross-appeal is an alternative argument in support of the district court's decision. On the merits, the district court correctly ruled that defendants are not entitled to summary judgment on the basis of collateral estoppel.View "Hudson Specialty Ins. Co. v. Tygr, LLC, et al." on Justia Law

Stonebridge appealed the district court's judgment in favor of Trip Mate, holding that Stonebridge breached an implied amendment to the parties' Managing General Agent Agreement that was incorporated into the Termination Agreement they executed in 2009. The court reversed the district court's judgment in favor of Trip Mate and remanded with instructions to dismiss the case. The court concluded that the district court's comments to the parties regarding their course of dealings were too vague and ambiguous to provide the parties with actual notice that the court amended the pleadings to include the implied amendment theory. The parties did not have actual notice of the implied amendment issue or an adequate opportunity to cure the suprise of this issue being added to the case. View "Trip Mate, Inc. v. Stonebridge Casualty Ins., et al." on Justia Law

In 1989, Wheatley plaintiffs filed suit against the District alleging on-going violations of the Voting Rights Act, 42 U.S.C. 1971 et seq., and the Fourteenth Amendment. In 1990, the district court confirmed a settlement between the parties. In 2012, the District filed a motion to modify or terminate the settlement decree, seeking an order permitting the District to relocate the middle school grades from the Wheatley campus to the Palestine campus. The district court granted the motion and the Wheatley plaintiffs appealed. The court concluded that the district court properly applied the standards for modifying a consent decree when changed circumstances have caused it to be unjust under Rufo v. Inmates of the Suffolk County Jail. In this case, the district court did not abuse its discretion in approving the modification, which was directly related to the evidence of changed circumstances the District presented. Further, it is apparent from the face of the consent decree that many of its eleven contractual commitments were premised on continued use of two school campuses and, therefore, these provisions were effectively terminated. Other provisions in the decree do not require functioning schools in both communities. The district court did not intend that its order terminate the entire consent decree, and the court so construed its order. Accordingly, the court affirmed the district court's order.View "Smith, et al. v. Palestine-Wheatley Sch. Dist, et al." on Justia Law

Defendant appealed his conviction for charges related to his activity in the mortgage lending and related businesses. The court concluded that the district court did not abuse its wide discretion in refusing to sever his case from his codefendant's case and even if it did, defendant failed to show clear prejudice; the district court was within its discretion to exclude the possibly confusing and certainly cumulative evidence from a civil suit and any possible error in refusing to admit the evidence was harmless; the district court did not abuse its discretion in allowing the government to use the common phrase - "Robbing Peter to pay Paul" - and defendant could not establish prejudice by use of the words; the district court did not err in its restitution calculation; and the court rejected defendant's claim of cumulative error. Accordingly, the court affirmed the judgment of the district court.View "United States v. Kramer" on Justia Law

Debtor filed for bankruptcy under Chapter 7 and the bankruptcy court refused to apply collateral estoppel to a state judgment, finding all the debt dischargeable. The district court reversed, finding all the debt nondischargeable, but remanded the attorney-fee debt. Debtor appealed. The court dismissed the appeal for lack of jurisdiction under 28 U.S.C. 158(d) because the district court's order was not final. In this case, the district court remanded to the bankruptcy court to determine whether the operating agreement connects the attorney fees to the nondischargeable fiduciary debt, delay does not harm the aggrieved party, and a later reversal would not require a new proceeding.View "Clear Sky Properties, LLC, et al. v. Roussel" on Justia Law

Plaintiff filed suit against XTO, an oil and natural gas producer, for damages caused by vibrations from drilling operations. The jury returned a verdict for plaintiff and XTO moved for a new trial. The district court denied the motion and XTO appealed. The court concluded that, even assuming the jury's fracking and earthquake discussions included any extraneous matters under Federal Rule of Evidence 606(b)(2)(A), XTO has not shown a reasonable possibility that the discussions prejudiced it or altered the verdict. Therefore, the district court did not abuse its discretion in denying XTO's motion for a new trial. Further, the district court did not abuse its discretion in declining to subpoena the jury foreman under Moore v. Am. Family Mut. Ins. Co. Accordingly, the court affirmed the judgment.View "Hiser v. XTO Energy, Inc." on Justia Law