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

Thomas Hipp was driving a semi-tractor and trailer on a two-lane road when the trailer collided with a vehicle driven by Amy Soczynski. Amy died as a result of the collision and this appeal concerns the subsequent insurance coverage dispute. The court affirmed the district court's determination that a bobtail policy issued by Hipp's Trucking provided coverage for damages arising out of the collision and that the bobtail policy provided $1 million in coverage.View "Occidental Fire & Casualty Co. v. Soczynski" on Justia Law

Plaintiff appealed the denial of his application for Social Security disability and supplemental security income benefits. The court concluded that the ALJ's failure to explicitly refer to SSR 96-9p was an arguable deficiency in opinion writing that had no practical effect on the decision and therefore was not a sufficient reason to set aside the ALJ's decision; the ALJ posed a hypothetical that accurately reflected his residual functioning capacity (RFC) finding, questioned the vocational expert (VE) about any apparent inconsistencies with the relevant DOT job descriptions, explained his decision to credit the VE's testimony, and, therefore, the ALJ complied with SSR 00-4p; and substantial evidence supported the ALJ's finding that a sufficient number of jobs existed in the national and local economies that a person with plaintiff's RFC could perform, based on the VE's testimony. Accordingly, the court affirmed the judgment of the district court.View "Welsh v. Colvin" on Justia Law

Defendants Bennett, Jennifer, and Clayton were found guilty of several counts stemming from two fraudulent schemes. Bennett and Clayton appealed their convictions and sentences, and Jennifer appealed her convictions. Clayton died while this appeal was pending. The court vacated Clayton's convictions and remanded his case with instructions to dismiss the indictment as it pertains to him because the criminal proceedings against Clayton abated ab initio. The court concluded that the district court did not err in denying Bennett's motion to dismiss the mail-fraud and mail-fraud-conspiracy counts on the ground that they are barred by the statute of limitations; the district court did not err in denying Bennett's motion for a judgment of acquittal on the mail-fraud charge because the Government presented sufficient evidence to support the jury's verdict; the facts found by the district court did not alter the statutory maximum or minimum sentence that Bennett faced and, therefore, the court rejected Bennett's Alleyne claim; Clayton's death does not necessitate reversal of Bennett's convictions and sentences; and the district court did not err in denying Jennifer's motion to sever her trial from the other defendants.View "United States v. Bennett" on Justia Law

Plaintiff filed suit against Malone and others after he was injured by a pipe saddle. The jury returned a verdict for Malone and plaintiff appealed, raising numerous issues on appeal. The court concluded that the district court did not abuse its discretion in refusing to give plaintiff's proffered instruction; the district court did not abuse its discretion by instructing the jury regarding OSHA regulations; the court rejected plaintiff's claim that the district court's comment regarding Instruction 15 was improper and prejudiced him such that he should receive a new trial; the district court did not abuse its discretion in allowing testimony regarding what procedures contractors other than Malone were using when working overhead on the same project; and the district court did not err in failing to grant plaintiff's motion for judgment as a matter of law as to Malone's third-party claim against Gilbert Project Services. The district court did not err in denying plaintiff's motion for judgment as a matter of law because reasonable minds could disagree as to whether Gilbert had a duty to plaintiff or Malone prior to or on the day of the accident. Accordingly, the court affirmed the judgment of the district court.View "Reed v. Malone's Mechanical, Inc., et al." on Justia Law

Relator filed a qui tam action against Planned Parenthood, alleging that it violated the False Claims Act (FCA), 31 U.S.C. 3729-3733, and the Iowa False Claims Act (IFCA), Iowa Code Ann. 685.1-.7, by submitting false or fraudulent claims for Medicaid reimbursement. The district court dismissed the complaint under Rule 9(b). The court concluded that relator has pled sufficiently particularized facts to support her allegations that Planned Parenthood violated the FCA by filing claims for (1) unnecessary quantities of birth control pills, (2) birth control pills dispensed without examinations or without or prior to a physician's order, (3) abortion-related services, and (4) the full amount of services that had already been paid, in whole or in part. The court affirmed the dismissal of relator's claim that Planned Parenthood violated the FCA by instructing patients who experienced abortion-related complications to give false information to medical professionals at other hospitals, causing those medical professionals to unknowingly file claims for services performed in connection with abortions. Because relator failed to provide a factual basis for her knowledge of these alleged false claims, the court was unable to infer that false claims were submitted. Further, the court affirmed the dismissal of relator's upcoding claim. The court's holding with respect to the Rule 9(b) issue, however, should not be read as in any way expressing a view on Planned Parenthood's Rule 12(b)(6) arguments.View "Thayer v. Planned Parenthood" on Justia Law

Plaintiff filed suit against Sammy Hagar after he published an autobiography in which he alleged that plaintiff had extorted him by claiming she was pregnant with his child. The district court granted summary judgment for Hagar on all of plaintiff's claims. Applying Iowa law, the court concluded that the district court erred by granting summary judgment on the libel per se claim where Hagar's statements are defamatory as a matter of law, plaintiff has shown the existence of a fact issue regarding whether the challenged statements were "of and concerning" her, and the evidence was sufficient to submit the question of substantial truth to the jury. The court also concluded that the district court erred in granting summary judgment on the false light invasion of privacy claim where questions of fact exist as to whether the challenged statements were sufficiently publicized. The court agreed with the district court's ruling that, with respect to evidence of emotional distress, plaintiff put forth conclusory statements; the court reversed the district court's grant of summary judgment on the breach-of-contract claim where a jury must decide the ultimate issue of breach; and the district court did not err in granting summary judgment on plaintiff's claim for breach of the covenant of good faith and fair dealing because Hagar's statement's did not deprive plaintiff of the benefits under a negotiated agreement between the parties.View "Doe v. Hagar" on Justia Law

This case involved a scenario in which a creditor holds a third mortgage that is secured only by the debtor's principal residence, but the value of the creditor's interest in the home is zero, because the value of the residence is insufficient to make whole the holders of the first and second mortgages. The bankruptcy court confirmed a Chapter 13 plan that reclassified the third-mortgage creditor's claim as unsecured and provided for avoidance of the creditor's lien upon discharge. The district court affirmed. The court agreed with other circuits that when considering the rights of creditors who hold homestead liens, the dividing line drawn by 11 U.S.C. 1322(b)(2) runs between the lienholder whose security interest in the homestead property has some value, and the lienholder whose security interest is valueless. Section 1322(b)(2) protects a creditor's right in a mortgage lien only where the debtor's residence retains enough value - after accounting for other encumbrances that have priority over the lien - so that the lien is at least partially secured under 11 U.S.C. 506(a). Accordingly, the court affirmed the judgment of the district court.View "MN Housing Finance Agency v. Schmidt, et al." on Justia Law

U.S. Bank appealed the district court's denial of its motion to intervene in a suit between a homeowner and her insurer, State Farm. The court concluded that the district court reasonably determined that the bank was too late in attempting to intervene. Accordingly, the court affirmed the judgment of the district court.View "U.S. Bank v. State Farm Fire & Casualty Co." on Justia Law

Two trustees of the Fund filed suit under section 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. 185(a), and section 515 of the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1145, to collect unpaid benefit contributions allegedly owed by Goebel. On appeal, the Trustees challenged the dismissal of the ERISA claim. The court read the Trust Agreement to unambiguously require that an employee is actually represented by the Union at the time the Fund claims delinquent contributions were owed on behalf of that employee. As it is undisputed that the Union did not "represent" the employees at the times in question, the Trustees failed to demonstrate the Fund was entitled to the contributions they seek under the terms of the Trust Agreement. Accordingly, the court affirmed the district court's grant of summary judgment to Goebel.View "Kern, et al. v. Goebel Fixture Co." on Justia Law

SHF acquired the vestiges of Sholom Rubashkin's bankrupt Agriprocessors, now rebranded Agri Star. Debtor, Nevel, is owned by Rubashkin's brother. At issue on appeal was whether SHF has any rights to a well located on land owned by Nevel. The bankruptcy court concluded that SHF did not and the district court affirmed. SHF appealed and Nevel moved to dismiss the appeal based on the so-called "equitable mootness" doctrine. The court concluded that the district court did not err in concluding that SHF had no rights to the well. The bankruptcy court correctly found that SHF never acquired any rights to the well because Agriprocessors' trustee was deemed to have rejected the contract as a matter of law. Accordingly, the court affirmed the district court's judgment and denied the motion to dismiss.View "Agri Star Meat & Poultry, et al. v. Nevel Properties Corp." on Justia Law