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

Plaintiff filed suit against Sun Life, alleging that Sun Life improperly denied him long-term disability benefits under a disability plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The court concluded that it was reasonable for Sun Life to conclude that plaintiff's vitamin A supplements constituted a "medical treatment." The court held that Sun Life did not abuse its discretion in denying plaintiff's claim for benefits under the Plan, in light of an ordinary understanding of what constitutes a "medical treatment" and the purpose of the Pre-Existing Condition clause. Accordingly, the court reversed the district court's entry of summary judgment to plaintiff and remanded for entry of summary judgment to Sun Life. View "Kutten v. Sun Life Assurance Co." on Justia Law

Defendant appealed his convictions stemming from his involvement in a Ponzi scheme known as the "British Lending Program" (BLP). The court concluded that the government satisfied the particularity requirement for the search warrant given the ubiquity of the BLP within defendant's law office; even if the executing officers failed to leave a copy of Attachment A of the warrant at the scene of the search, any error would have been isolated inadvertence rather than indicative of a pattern of recurring negligence; and defendant failed to show any prejudice from a violation of Federal Rule of Criminal Procedure 41(f)(1)(C). The court rejected defendant's remaining arguments and affirmed the district court's motion to suppress. The court rejected defendant's arguments relating to the authority of the AUSAs in this case to prosecute him; defendant's Brady claims; defendant's claims of other errors committed during trial; and defendant's claims of sentencing errors. Accordingly, the court affirmed the judgment of the district court. View "United States v. Sigillito" on Justia Law

Defendant appealed his sentence after pleading guilty to one count of being a felon in possession of a firearm. The court affirmed defendant's conviction as an armed career criminal where the district court did not err in holding that defendant's prior Missouri convictions for first-degree assault and first-degree robbery were separate predicate offenses under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e)(1). View "United States v. Humphrey" on Justia Law

Plaintiffs Williams and Porter filed suit against law enforcement officers, alleging claims arising from a traffic stop. The court concluded reasonable suspicion that Williams was operating a vehicle while intoxicated justified the officer's investigatory stop of the vehicle; Officer Forck's mistaken perception that the driver, rather than the passenger, in a double-parked vehicle was consuming alcohol was objectively reasonable; an objectively reasonable concern for officer safety or suspicion of danger existed in this instance; the officers permissibly drew their weapons, handcuffed plaintiffs and performed a protective sweep of the vehicle; detaining plaintiffs for about 30 minutes was not an unreasonable amount of time; and, therefore, the officers were entitled to qualified immunity on the Fourth Amendment claims. The court rejected plaintiffs' contention that the district court judge lacked authority to adjudicate this matter due to her status as a senior district court judge. Accordingly, the court affirmed the judgment of the district court. View "Williams, et al. v. Decker, et al." on Justia Law

Plaintiff filed suit to collect fringe benefits owed to union employee benefit funds by a plumbing company under 29 U.S.C. 1145. The court concluded that O'Laughlin did not unequivocally express an intent to terminate its participation in the collective bargaining agreement (CBA) for two reasons. First, under the circumstances, the court's examination of O'Loughlin's conduct was paramount to the court's consideration of the two letters it sent to the Union. Here, O'Laughlin manifested an intent to abide and be bound by the terms of the CBA by continuing to make fringe benefit contributions on behalf of its employees throughout the 2011 calendar year. Second, the two letters O'Laughlin sent to the Union were ineffective to express an unequivocal intent to terminate participation in the CBA in any event. Accordingly, the court reversed the district court's determination that O'Laughlin unequivocally terminated its participation in the CBA and remanded for further proceedings. View "Twin City Pipe Trades Service v. O'Laughlin Plumbing & Heating" on Justia Law

Starr Indemnity filed suit seeking a determination of their rights and obligations under Continental Cement's insurance policies after the Mark Twain, a cement barge owned by Continental Cement, sank in the Mississippi River. Continental Cement counterclaimed for breach of contract and vexatious refusal to pay under Missouri law. Determining that Continental Cement did not waive its appeal, the court concluded that the district court did not err by applying the federal doctrine of utmost good faith, a judicially established federal admiralty rule, instead of Missouri state law; Continental Cement waived its appeal of the denial of its motion for judgment as a matter of law on Starr Indemnity's utmost good faith defense; and, apart from the issue of waiver, the district court did not abuse its discretion in submitting the utmost good faith instruction. Accordingly, the court affirmed the judgment of the district court. View "New York Marine & General Ins., et al. v. Continental Cement Co., et al." on Justia Law

Plaintiff filed suit against her former employer, CSG, under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., alleging claims of gender discrimination and retaliation. The court concluded that, assuming without deciding, that plaintiff established a prima facie case of gender discrimination, CSG offered a legitimate, non-discriminatory justification for terminating her employment where CSG identified substantial performance-related problems; plaintiff failed to prove there was pretext for the gender discrimination; and, therefore, the court affirmed the district court's grant of summary judgment on plaintiff's discrimination claim. Likewise, plaintiff failed to demonstrate that CSG's legitimate, nondiscriminatory reason for terminating her employment was pretextual. Accordingly, the district court properly granted summary judgment on plaintiff's retaliation claim as well. View "Fiero v. CSG Systems, Inc." on Justia Law

Plaintiff filed suit against Cory Snethen, the Jaycees, and Carico Farms (collectively, "defendants") and others, alleging common law negligence claims and wrongful death actions after her husband died from a motorcycle collision with a pickup. The court concluded that the district court properly dismissed negligence claims against defendants where the court predicted that the Nebraska Supreme Court would find defendants had no duty to control traffic on the highway at the time of plaintiff's husband's death. The court rejected plaintiff's remaining claims of error and affirmed the district court's dismissal of plaintiff's claims against defendants. View "Packard v. Falls City Area Jaycees, et al." on Justia Law

BVS filed suit against CDW over a dispute regarding BVS's contract with CDW for a computer storage area network (SAN). The court agreed with the district court's finding that BVS's original purchase order constituted an offer and that CDW accepted that offer when it sent a purchase order to Arrow. The court concluded, however, that the district court erred when it ruled, as a matter of law, that the Invoice - sent after offer and acceptance had already created a contract - integrated the contract with respect to terms not included in either BVS's offer or CDW's acceptance. Accordingly, the court reversed the district court's grant of summary judgment and remanded for further proceedings. View "BVS, Inc. v. CDW Direct, LLC" on Justia Law

Defendant appealed the denial of his motion to dismiss after pleading guilty to distributing child pornography, in violation of 18 U.S.C. 2252A(a)(2)(A) and 2256(8)(C). Defendant transmitted an image to his eleven-year-old half-sister's Facebook page depicting an adult male and an adult female engaged in sexual intercourse where the eleven-year-old's face was superimposed over the woman's face. The court concluded that the government has a compelling interest in protecting innocent minors from the significant harms associated with morphed images and there was no less restrictive means for the government effectively to protect the minor child from the exploitation and psychological harm resulting from the distribution of the morphed image than to prohibit defendant from disseminating it. Accordingly, the court concluded that sections 2252A(a)(2)(A) and 2256(8)(C) are constitutional as applied to defendant's conduct. The court affirmed the district court's denial of defendant's motion to dismiss. View "United States v. Anderson" on Justia Law