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

Charles James, a home designer, claimed that real estate agents infringed his copyrights by including floorplans of his homes in resale listings. James designed a home with a triangular atrium and stairs, built six homes using the design, and registered copyrights for the designs. In 2010, agent Susan Horak listed one of these homes for resale, creating a floorplan by hand for the listing. In 2017, agent Jackie Bulgin listed another of James's homes, using a similar floorplan. James discovered these listings in 2017 and alleged that the floorplans could be used to build homes, potentially infringing his copyrights.The United States District Court for the Western District of Missouri granted summary judgment to the real estate agents, concluding that their use of the floorplans was fair use. The court also initially ruled in favor of the agents under § 120(a) of the Copyright Act, but this decision was reversed by the United States Court of Appeals for the Eighth Circuit, which remanded the case for further consideration of the fair use defense.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's summary judgment in favor of the agents. The court held that the agents' use of the floorplans was fair use, considering the purpose and character of the use, the nature of the copyrighted work, the amount and substantiality of the portion used, and the effect on the market for the original work. The court found that the agents' use was transformative, had an informational purpose, and did not harm the market for James's designs. The court also rejected Designworks's request for further discovery on the fair use issue, concluding that the district court did not abuse its discretion in denying the motion. The court affirmed the district court's judgments. View "Designworks Homes, Inc. v. Columbia House of Brokers Realty, Inc." on Justia Law

An employee, Brandon Smith, was fired by Kansas City Southern Railway Company (KCSR) in 2018. His union, the International Association of Sheet Metal, Air, Rail, and Transportation Workers, Transportation Division (SMART-TD), challenged the dismissal under the collective-bargaining agreement (CBA) and the Railway Labor Act (RLA). The dispute went to arbitration, and in 2022, the National Railroad Adjustment Board (Board) overturned Smith's discharge, ordering his reinstatement with full benefits and back pay without deductions for outside earnings.The district court enforced the arbitration award, rejecting KCSR's argument that the award was ambiguous and required clarification. The court ordered KCSR to provide Smith with back pay without deductions and vacation benefits, and also awarded attorney fees to SMART-TD. KCSR appealed, arguing that the district court lacked jurisdiction and should have remanded the case to the Board for interpretation of the ambiguous award.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court erred in enforcing the award without remanding it to the Board for clarification, particularly regarding the vacation benefits, which were not explicitly addressed in the award. The court noted that the district court overstepped by interpreting the CBA, which is outside its jurisdiction under the RLA. The court also acknowledged that the Board had since clarified the back pay issue, rendering that part of the dispute moot.The Eighth Circuit reversed and vacated the district court's judgments, including the award of attorney fees, and remanded the case for further proceedings consistent with its opinion. The court emphasized the need for the Board to interpret any ambiguities in the arbitration award. View "Assoc.of Sheet Metal Workers v. K.C. Southern Railway" on Justia Law

Air Force Staff Sergeant Cameron Beck was killed in a collision with a car driven by Blanca Mitchell, a civilian government employee, on Whiteman Air Force Base. Beck was on active duty and driving home for lunch when the accident occurred. Mitchell pleaded guilty to careless and imprudent driving. Beck’s wife and son received benefits from the Department of Veterans Affairs and the Department of Defense. They filed a wrongful death claim, which the Air Force denied, but allowed them to pursue the claim in federal court under the Federal Tort Claims Act (FTCA).The United States District Court for the Western District of Missouri dismissed the case for lack of subject matter jurisdiction, citing the Feres doctrine, which grants the government immunity for injuries arising out of activities incident to military service. The court concluded that Beck’s death was incident to his service because he was on active duty and on-base at the time of the accident. The court also denied the plaintiffs' requests for additional discovery and to file supplemental suggestions.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court agreed that the Feres doctrine applied, as Beck was on active duty, on-base, and subject to recall at the time of the accident. The court also found that the district court did not abuse its discretion in denying additional discovery, as the facts necessary to resolve the jurisdictional inquiry were undisputed and the additional facts sought were not material to the determination of whether Feres applied. The judgment of the district court was affirmed. View "Beck v. United States" on Justia Law

Robert Gallagher borrowed money from Santander Consumer USA to purchase a car. After making the final payment via electronic funds transfer, Santander, following its standard practice, waited 15 days before sending the car title. Missouri law requires lienholders to release their lien within five business days after receiving full payment, including electronic funds transfers, or pay liquidated damages. Gallagher filed a lawsuit in Missouri state court on behalf of a potential class of borrowers affected by Santander's 15-day policy.The case was removed to the United States District Court for the Eastern District of Missouri, which granted summary judgment in favor of Santander. Gallagher appealed the decision, seeking to reverse the summary judgment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on whether Gallagher had standing to bring the case in federal court, specifically whether he had suffered an injury-in-fact. The court determined that Gallagher had not identified a concrete harm resulting from the delay in receiving the car title. The court noted that a statutory violation alone is insufficient for standing; there must be a concrete harm related to the violation. Gallagher did not demonstrate any monetary harm, such as a failed sale or impaired credit rating, nor did he show any ongoing injury to his property rights.The Eighth Circuit concluded that Gallagher lacked standing because he did not suffer a concrete injury. As a result, the court vacated the district court's judgment and instructed the district court to remand the case to state court. View "Gallagher v. Santander Consumer USA, Inc." on Justia Law

Jennifer Harmon’s son, N.J., died by suicide while residing at the Bruce Normile Juvenile Justice Center (BNJJC) under the care of the Second Judicial Circuit of Missouri. Harmon filed a lawsuit seeking damages for her son’s death, including various 42 U.S.C. § 1983 and state wrongful death claims against the Second Circuit, several named defendants from both the Second Circuit and BNJJC, Preferred Family Healthcare (PFH), and several named defendants from PFH. All defendants filed motions to dismiss for failure to state a claim.The United States District Court for the Eastern District of Missouri granted the Second Circuit and Government Defendants’ motion to dismiss. The court found that the claims against the Second Circuit were barred by the Eleventh Amendment, the § 1983 claims against the Government Defendants were barred by qualified immunity, and the state tort claims against the Government Defendants were barred by official immunity. Harmon appealed these immunity judgments.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s dismissal of Harmon’s claims against the Second Circuit, holding that the Second Circuit is not a “person” amenable to suit under § 1983 and is entitled to Eleventh Amendment immunity, which Missouri has not waived. The court also affirmed the dismissal of Harmon’s § 1983 claims against the Government Defendants, concluding that the Government Defendants were entitled to qualified immunity because Harmon failed to show that any constitutional violation was clearly established. Lastly, the court affirmed the dismissal of Harmon’s state tort claims against the Government Defendants, holding that the Government Defendants were entitled to official immunity under Missouri law because Harmon failed to plead both the existence of a department-mandated policy and a breach of that policy. View "Harmon v. Second Judicial Circuit of the State of Missouri" on Justia Law

Kujali Strawther was stopped by a South Dakota Highway Patrol officer for speeding. During the stop, the officer claimed to smell burnt marijuana emanating from the vehicle. Strawther admitted to having smoked marijuana in the vehicle while in California. A search of the vehicle revealed over two pounds of raw marijuana and a firearm. Strawther was subsequently arrested and charged with possessing a firearm after being convicted of a felony.In the United States District Court for the District of South Dakota, Strawther filed a motion to suppress the evidence found during the search, arguing that the traffic stop and subsequent search were unlawful. The district court denied the motion, finding that the traffic stop was justified based on the officer's observation of speeding and that the search was lawful due to the smell of marijuana providing probable cause.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, holding that the initial traffic stop was constitutionally sound based on the officer's credible testimony that Strawther was speeding. The court also found that the officer did not unreasonably prolong the stop and that the smell of burnt marijuana provided probable cause for the search. The court concluded that the district court did not err in denying Strawther's motion to suppress the evidence. View "United States v. Strawther" on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely for payments going back five years under Kansas’s statute of limitations. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, interpreting the policy against Kansas City Life. The conversion claim was dismissed. A jury awarded over $5 million in damages, which was reduced to $908,075 due to the statute of limitations. Both parties appealed.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s class certification, finding that common questions of law and fact predominated. The court also upheld the application of Kansas law for both the conversion claim and the statute of limitations. The court agreed with the district court’s interpretation of the insurance policy, concluding that the cost of insurance should not include profits and expenses. The court found that the jury’s damages award was supported by reasonable evidence and did not warrant an increase.The Eighth Circuit affirmed the district court’s judgment, including the class certification, the application of Kansas law, the partial summary judgment in favor of Meek, and the damages award. View "Meek v. Kansas City Life Ins. Company" on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely under Kansas’s five-year statute of limitations for breach-of-contract claims. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, concluding that the policy's cost-of-insurance provision was ambiguous and should be construed against Kansas City Life. The jury awarded over $5 million in damages, which was reduced to $908,075 under the statute of limitations. Both parties appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the cost-of-insurance provision in the policy did not include profits and expenses, as these were not listed factors. The court also upheld the class certification, finding that common questions of law and fact predominated over individual issues. Additionally, the court agreed with the district court's application of Kansas law for the conversion claim and the statute of limitations for the breach-of-contract claim. The court found that the jury's damages award was supported by sufficient evidence and did not warrant an increase. View "Meek v. Kansas City Life Ins. Company" on Justia Law

The City of Hillsboro, Missouri, enacted ordinances prohibiting new private wells within city limits and requiring residences to connect to the city water system. The Antoinette Ogilvy Trust, owning a 156-acre property within Hillsboro, claimed these ordinances constituted an uncompensated regulatory taking under the Fifth and Fourteenth Amendments. The trustees, William Becker and Darcy Lynch, argued that the regulations made developing the property financially unfeasible due to the high costs of connecting to the city water system.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the City, rejecting the trustees' claims. The court found that the regulations did not constitute a per se taking, as they did not involve a physical invasion of the property or deprive it of all economic value. The court also determined that the regulations did not fail the Penn Central balancing test for regulatory takings.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that the regulations did not mandate a permanent physical invasion of the property, as the trustees were not compelled to build structures or dedicate land to the City. The court also found that the property retained substantial value, thus not constituting a taking under Lucas v. South Carolina Coastal Council. Additionally, the court declined to consider the trustees' exaction claim, as it was not sufficiently raised in the lower court.Under the Penn Central test, the court concluded that the economic impact on the trustees was not significant enough to constitute a taking, and the regulations did not interfere with reasonable investment-backed expectations. The character of the governmental action was deemed a legitimate exercise of the City's police powers to prevent water contamination and protect the aquifer. Therefore, the court affirmed the district court's summary judgment in favor of the City. View "Becker v. City of Hillsboro" on Justia Law

George Harper, Jr. was indicted for being a felon in possession of ammunition following a shooting incident in Davenport, Iowa. After two unsuccessful suppression motions, he pled guilty. At sentencing, the district court applied the attempted murder cross-reference and sentenced Harper to 67 months’ imprisonment. Harper appealed the application of the cross-reference and the denial of one of his suppression motions.The United States District Court for the Southern District of Iowa denied Harper’s motion to suppress A.H.’s eyewitness identification, concluding that A.H. knew Harper before the incident and that his reluctance to identify Harper initially was due to fear of involvement in a police investigation. The court also found that Detective Reeves’s thumb placement on Harper’s photograph was not impermissibly suggestive. Harper pled guilty but preserved his right to appeal the denial of his motion to suppress and the district court’s sentence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the identification procedure did not create a substantial likelihood of irreparable misidentification, as A.H. knew Harper and identified him from surveillance footage before the photo array. The court also found that the district court did not err in applying the attempted murder cross-reference, as Harper fired multiple rounds at X.B., demonstrating an intent to kill or callous disregard for human life. The Eighth Circuit affirmed the district court’s judgment. View "United States v. Harper" on Justia Law