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

The case involves Charles and Lisa Kass, parents of Brody Kass, who sued the Western Dubuque Community School District (the District) alleging that the District violated the Individuals with Disabilities Education Act (IDEA) and other statutes when it developed Brody’s individualized education program (IEP) for the 2020–21 school year. Brody has epilepsy, autism, attention deficit/hyperactivity disorder, severe vision impairment, and intellectual disabilities. Despite Brody having enough credits to graduate, his IEP Team determined he had unmet transitional needs and should remain in school. The District proposed that Brody would not enroll in general education courses in the traditional classroom setting. Instead, Brody would spend a half-day focusing on developing his reading and math skills through individualized and practical training. The Kasses objected to the proposed IEP and filed a complaint with the Iowa Department of Education.The administrative law judge (ALJ) ruled in favor of the District on all claims, concluding the District did not violate Brody’s right to a free appropriate public education (FAPE) in the 2018–19 or 2019–20 school years. The ALJ also determined neither the draft IEP nor its development violated any procedural or substantive provisions of the IDEA. The Kasses brought this action in federal district court, alleging violations of the IDEA, the Americans with Disabilities Act (ADA), and the Rehabilitation Act. The district court affirmed the ALJ’s decision on the IDEA claims and dismissed the other claims as subsumed under the IDEA claims.The United States Court of Appeals For the Eighth Circuit affirmed the district court's decision. The court held that compensatory education may be available beyond a student’s twenty-first birthday. The court also concluded that the District complied with the IDEA’s procedural requirements in drafting the May 2020 IEP. The court found that the May 2020 IEP’s specific and measurable goals were reasonably calculated to enable Brody to progress in light of his circumstances, and thus met the IDEA’s requirements. View "Kass v. Western Dubuque Community School District" on Justia Law

The case involves a group of grocery store owner-operators and their related company, Anchor Mobile Food Markets, Inc. (AMFM), who sued Onex Partners IV, Onex Corporation, Anthony Munk, and Matthew Ross (collectively, Onex) for violations of Missouri common law and the Racketeer Influenced and Corrupt Organizations Act (RICO). The owner-operators had invested in the discount grocery chain Save-A-Lot and its independent licensee program, which turned out to be a disastrous investment. They alleged that Onex, which had acquired Save-A-Lot, had fraudulently induced them into the investment.The United States District Court for the Eastern District of Missouri had granted summary judgment to Onex. The court found that the owner-operators had signed multiple contractual releases and anti-reliance disclaimers before opening their stores, which barred their claims. The owner-operators and AMFM argued that these releases and disclaimers were fraudulently induced.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that the owner-operators failed to raise a genuine dispute of material fact that they were fraudulently induced to enter the releases. The court also found that the releases were valid and barred the owner-operators' claims. The court further found that AMFM's claims against Onex failed, as neither Save-A-Lot nor Onex had contracted with AMFM. Finally, the court affirmed the district court's denial of the owner-operators and AMFM's request for leave to amend their complaint. View "SBFO Operator No. 3, LLC v. Onex Corporation" on Justia Law

KOKO Development, LLC, a real estate developer, contracted with Phillips & Jordan, Inc., DW Excavating, Inc., and Thomas Dean & Hoskins, Inc. (TD&H) to develop a 180-acre tract of land in North Dakota. However, the project faced numerous issues, leading KOKO to sue the defendants for breach of contract and negligence. KOKO did not disclose any expert witnesses before the trial, leading the district court to rule that none of its witnesses could give expert testimony. Consequently, the district court granted the defendants' motion for summary judgment, finding that without expert witnesses, KOKO could not establish its claims.The district court's decision was based on the complexity of the issues involved in the case, which required expert testimony. The court found that KOKO's negligence and breach of contract claims required complex infrastructure and engineering analysis, which was beyond the common knowledge or lay comprehension. KOKO appealed the decision, arguing that the district court erred in finding that it did not properly disclose witnesses providing expert testimony and that expert testimony was necessary for the case.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court found that KOKO did not identify the witnesses that would provide expert testimony and did not meet the requirements of Rule 26(a)(2). The court also agreed with the district court that the negligence and breach of contract claims required expert testimony due to the complexity of the issues in the case. The court concluded that the district court did not abuse its discretion by excluding the three witnesses' expert testimony and requiring expert testimony for the negligence and breach of contract claims. View "KOKO Development, LLC v. Phillips & Jordan, Inc." on Justia Law

A high-speed police chase initiated by a deputy from Pottawattamie County, Iowa, ended in a collision in Nebraska, injuring Kirstie Wade and her children. Wade sued Pottawattamie County in a Nebraska federal district court for damages. However, the district court dismissed the case, citing a lack of personal jurisdiction over the Iowa county.The case was then brought before the United States Court of Appeals for the Eighth Circuit. The court had to determine whether the Nebraska federal district court had personal jurisdiction over Pottawattamie County. Personal jurisdiction depends on both a forum state’s long-arm statute and general due-process principles. Nebraska’s long-arm statute authorizes “the exercise of personal jurisdiction consistent with the Constitution of the United States,” which means that the exercise of personal jurisdiction over Pottawattamie County must be “consistent with” due process.The court considered two types of jurisdiction: general and specific. General jurisdiction, which allows a court to hear any and all claims against a party, was ruled out as Pottawattamie County’s contacts with Nebraska were not continuous and systematic. However, the court found that specific jurisdiction, which covers only those claims arising out of or relating to a party’s contacts with the forum, was applicable. The court reasoned that the deputies had purposefully availed themselves of the benefits and protections of Nebraska’s laws by choosing to continue the chase across the border, and they could have reasonably anticipated being brought to court in Nebraska if something went wrong.The United States Court of Appeals for the Eighth Circuit reversed the district court's decision, ruling that the Nebraska federal district court did have personal jurisdiction over Pottawattamie County. The case was remanded for further proceedings. View "Wade v. Pottawattamie County" on Justia Law

The case revolves around an incident involving Corey Fisherman, an inmate at Minnesota’s maximum-security prison, and David Launderville, a prison guard. Fisherman was being transferred to a more restrictive area after a shank was found in his cell. During the transfer process, Fisherman initially refused to undergo a strip search, leading to the intervention of the A-Team, a group of guards trained to handle noncompliant inmates, which included Launderville. After the search, Fisherman objected to kneeling and placing his hands through a small opening in his cell door. Once he complied, he was handcuffed. Fisherman alleges that Launderville kneed him six times, three times each in the face and body, while another guard kneeled on his legs. Launderville, however, claims he struck Fisherman twice in the leg because he was resisting.The case was initially heard in the United States District Court for the District of Minnesota. The magistrate judge identified a potential jury issue: whether Launderville struck a restrained inmate six times in the face and body or a partially unrestrained one just twice in the leg. The district court adopted the report and recommendation, leading to an appeal to the United States Court of Appeals for the Eighth Circuit.The Court of Appeals affirmed the district court's decision, denying Launderville's claim of qualified immunity. The court found that a reasonable jury could conclude that the repeated blows to Fisherman's head and body were "malicious and sadistic." The court also determined that the law was clearly established that repeatedly striking a fully restrained inmate violates the Eighth Amendment. Therefore, the court concluded that every reasonable official in Launderville's position would have understood that kneeing a restrained inmate several times in the face and body violated that right. View "Fisherman v. Launderville" on Justia Law

Meyer, Borgman & Johnson, Inc. (MBJ), a structural engineering firm, sought research tax credits for expenses incurred in creating designs for building projects. MBJ claimed approximately $190,000 in tax credits for the years ending September 30, 2010, 2011, and 2013. The Commissioner of Internal Revenue denied these credits.The United States Tax Court affirmed the Commissioner's decision, ruling that MBJ's research was "funded" within the meaning of 26 U.S.C. § 41(d)(4)(H), and therefore, MBJ did not qualify for the credits. The Tax Court's decision was based on a summary judgment.The United States Court of Appeals for the Eighth Circuit reviewed the Tax Court's decision de novo. MBJ argued that the Tax Court erred because its right to payment was contingent on the success of its research, and its contracts had inspection, acceptance, and quality assurance provisions. MBJ claimed that its payments were contingent on the success of its research because it was required to create a design that met all the owner's requirements, complied with all pertinent codes and regulations, and was sufficiently detailed for a contractor to successfully construct it.However, the Court of Appeals disagreed with MBJ's arguments. It found that MBJ's contracts did not expressly or by clear implication make payment contingent on the success of MBJ’s research. The court distinguished between "successful performance"—meeting detailed, barometers of success—and "proper performance"—providing deliverables pursuant to a general professional standard of care and promising work free from negligence, error, or defects. The court found that MBJ's contracts fell into the latter category.The Court of Appeals affirmed the Tax Court's ruling that MBJ’s research did not merit the research tax credit. View "Meyer, Borgman & Johnson, Inc. v. CIR" on Justia Law

Sergio Rosas-Martinez, who had been living in the United States since he was nine years old, was arrested in 2019 for possessing illegal drugs. Following his conviction, the Department of Homeland Security initiated removal proceedings. Rosas-Martinez applied for deferral of removal under the Convention Against Torture (CAT), arguing that if he returned to Mexico, the Sinaloa Cartel would kill or capture him because he lost their drugs when police arrested him. An immigration judge granted his CAT application, but the Board of Immigration Appeals reversed the decision. Rosas-Martinez then filed a motion for reconsideration with the Board, which was also denied.The Board of Immigration Appeals reversed the immigration judge's decision to grant Rosas-Martinez's CAT application. The Board found clear error in the immigration judge's predictive findings and legal error in the application of the law. The Board used the factual findings to show that the immigration judge clearly erred in predicting that Rosas-Martinez would be tortured if he returned to Mexico. The Board also justified its decision that the Mexican government would not acquiesce to or be directly involved in any torture of Rosas-Martinez, citing evidence of Mexico's recent efforts to purge corruption from its ranks.Rosas-Martinez then petitioned the United States Court of Appeals for the Eighth Circuit to review the Board's reversal of the immigration judge's decision and its denial of his motion for reconsideration. The court denied both petitions for review, holding that the Board correctly applied its standard of review and refrained from independent fact finding. The court also found that the Board provided sufficient justification for its determination that the immigration judge erred in predicting that Rosas-Martinez would be tortured if he returned to Mexico and that the Mexican government would acquiesce to or be directly involved in his torture. View "Sergio Rosas-Martinez v. Garland" on Justia Law

Bader Farms, Inc. sued Monsanto Company and BASF Corporation, alleging that its peach orchards were damaged by dicamba drift between 2015 and 2019 due to the defendants' negligent design and failure to warn. The jury awarded $250 million in punitive damages against both Monsanto and BASF based on Monsanto’s acts in 2015-16, which the district court later reduced to $60 million. The defendants appealed the decision.The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision except for punitive damages, holding BASF and Monsanto liable as co-conspirators in a civil conspiracy. The court remanded the case to separately assess punitive damages against Monsanto and BASF. However, before the new trial, Monsanto settled with Bader Farms. The district court did not conduct a new trial and instead ruled that BASF could not be liable for any punitive damages, dismissing all claims against BASF.Bader Farms appealed, arguing that the district court ignored the appellate court’s mandate and its holding that BASF could be assessed punitive damages for its acts in furtherance of the conspiracy. The appellate court reviewed the district court’s interpretation of its mandate de novo and found that the district court did not comply with the appellate mandate. The appellate court held that BASF is vicariously liable for Monsanto’s actions and remanded the case for a trier of fact to apportion the punitive damages award. The court reversed the judgment and remanded with instructions to hold a new trial on the single issue of punitive damages. View "Bader Farms, Inc. v. BASF Corporation" on Justia Law

In 2011, James Buchl and Doren Chatinover, electrical engineers with experience in oil fields, entered into an oral contract with Gascoyne Materials Handling & Recycling to work as project managers for a division of Gascoyne. After five years, Gascoyne stopped making monthly payments under the contract, leading the plaintiffs to end the relationship and file a lawsuit. The plaintiffs' initial complaint alleged eleven causes of action, including fraud and deceit, which were dismissed by the district court. The case proceeded to a bench trial on the remaining claims for breach of contract and conversion, and on Gascoyne’s counterclaims.The district court found that Gascoyne had underpaid the plaintiffs by $822,199 and entered judgment in their favor for that amount, plus prejudgment and post-judgment interest. The court dismissed Gascoyne’s counterclaims. Gascoyne filed a post-trial motion to alter or amend, raising the issues now presented on appeal. The district court modified the award of post-judgment interest but otherwise denied the motion.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed all but $14,650 of the award of contract damages and the award of costs, reversed the grant of prejudgment interest, and remanded for entry of an amended judgment. The court found that the district court had not made a clear error in calculating the profits due to the plaintiffs, except for failing to include $29,300 in expenses for a particular project, which would reduce the plaintiffs' share of the profits by $14,650. The court also held that the plaintiffs' contract damages were not certain and were not capable of being made certain by calculation, so the district court erred in awarding prejudgment interest. View "Buchl v. Gascoyne Materials" on Justia Law

In 2021, Hugo Escudero was investigated as a suspected wholesale cocaine dealer based on information provided by a confidential informant. The informant claimed that Escudero and his brother were selling large amounts of cocaine and used a runner, M.G., to deliver the drugs. Law enforcement officers corroborated this information through surveillance and obtained a GPS tracking warrant for Escudero's vehicle. This led to additional search warrants for Escudero's apartment and music studio. In September 2021, officers arrested Escudero and M.G. when they arrived with a kilogram of cocaine for a controlled buy.Escudero was indicted and filed a motion to suppress the evidence obtained from the tracking and search warrants. A federal magistrate judge recommended denying Escudero's motions to suppress, and the district court adopted this recommendation. During the trial, Escudero posted a message on M.G.'s Facebook page, which the court admitted into evidence as it was "probative of the consciousness of guilt" and not unfairly prejudicial. The jury found Escudero guilty of possessing five or more kilograms of cocaine with intent to distribute, and he was sentenced to 216 months of imprisonment.On appeal, Escudero challenged the legitimacy of the tracking warrant, the admission of his Facebook message, and the sufficiency of evidence for his guilty verdict. The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that the Leon good-faith exception to the exclusionary rule applied to the tracking warrant, the district court did not abuse its discretion in admitting Escudero's Facebook message and witness list comment, and the evidence was sufficient to convict Escudero of possession. View "United States v. Escudero" on Justia Law