Justia Civil Procedure Opinion Summaries

In this case before the United States Court of Appeals for the Eighth Circuit, Jet Midwest International Co., Ltd. (Jet Midwest International) sought attorneys’ fees and costs from Jet Midwest Group, LLC (JMG) and other defendants (collectively referred to as the Ohadi/Woolley defendants). The request was made in connection with a fraudulent transfer action filed under the Missouri Uniform Fraudulent Transfer Act (MUFTA), following a term loan agreement between Jet Midwest International and JMG which JMG failed to repay. The district court awarded attorneys’ fees and costs against the Ohadi/Woolley defendants, who were not parties to the term loan agreement, based on its finding that they conspired with JMG to violate the MUFTA.On appeal, the Eighth Circuit found that the district court erred in awarding attorneys’ fees and costs against the Ohadi/Woolley defendants based on the term loan agreement since they were not parties to that agreement. However, the court held that the district court's finding of "intentional misconduct" by the Ohadi/Woolley defendants in conspiring with JMG to violate the MUFTA could justify an attorneys’ fees award under the "special circumstances" exception to the American Rule (which generally requires each party to bear its own attorneys’ fees).The court vacated the award and remanded the case back to the district court to calculate a reasonable attorneys’ fee using the lodestar method (multiplying the number of hours reasonably expended by the reasonable hourly rates), and to determine the extent to which the claimed costs are recoverable under the relevant statute. The court's holding did not limit JMG’s ultimate responsibility for attorneys’ fees and costs under the term loan agreement. View "Jet Midwest International Co. v. Ohadi" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit reviewed the Board of Immigration Appeals (BIA) decision to deny Peter David Davis's appeal to reopen his case. Davis, a Liberian citizen, was admitted as an asylee to the United States in 2008. However, following multiple criminal convictions, his asylum status was terminated and removal proceedings were initiated. Davis conceded his removability but requested a waiver of inadmissibility for humanitarian purposes, which was denied. His appeal to the BIA was also unsuccessful.On appeal to the Court of Appeals, Davis argued that the BIA erred by not providing a reasoned explanation for its application of the motion-to-reopen standard. The Court of Appeals agreed, stating that the BIA's single sentence explanation did not meet the requirements for reasoned decision-making, as it did not explain how the elements of a motion to reopen applied to Davis's case. The Court held that the BIA's decision was an abuse of discretion as it was without rational explanation and failed to consider all factors presented by Davis. Consequently, the Court granted Davis's petition for review and remanded the case back to the BIA for further proceedings. However, the Court did not address Davis's other arguments regarding due process and competency as they were related to the request to submit new evidence, which would be considered upon remand. View "Davis v. Garland" on Justia Law

Contitech USA, Inc., a division of tire manufacturer Continental AG, contracted with a trucking company, McLaughlin Freight Services, Inc., and its owner, Dan McLaughlin, to deliver rubber between two of its facilities. The fee schedule included a base rate and a higher "rounder" rate, which required pre-approval from Contitech. Over three years, McLaughlin submitted 645 unapproved "rounder" bills to the third-party payments administrator, using fraudulent emails that purported to show pre-approval from Contitech. Contitech discovered the scheme and sued for fraud, unjust enrichment, and breach of contract.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that there was sufficient evidence for a reasonable jury to find for Contitech on the fraud and unjust-enrichment counts. The court rejected McLaughlin's argument that Contitech failed to prove proximate cause and damages, noting that under Iowa law, a defrauding defendant cannot claim that its misrepresentations did not cause any damages to the plaintiff. Furthermore, McLaughlin was contractually obligated not to charge rounder rates without pre-approval from Contitech. Thus, a reasonable jury could have found that the difference between the contractual base rate and the actual billed amount was the amount of money McLaughlin received, which in equity and good conscience belonged to Contitech.The court also affirmed the district court's decision to remit Contitech's unjust-enrichment award to $0 and to remit McLaughlin’s damages award to prevent double recovery. The court reasoned that while a party is entitled to proceed on various theories of recovery, it is not entitled to collect multiple awards for the same injury. Furthermore, the court held that the district court did not abuse its discretion in granting pre-judgment interest to Contitech, and that postjudgment interest is mandatory under 28 U.S.C. § 1961 and should be awarded regardless of whether the district court orders it. View "Contitech USA, Inc. v. McLaughlin Freight Services, Inc." on Justia Law

The United States Court of Appeals for the Eighth Circuit ruled in a case concerning a law in Iowa that penalized anyone who, while trespassing, knowingly placed or used a camera or surveillance device on the trespassed property. The law was challenged by five animal-welfare groups who argued that it unconstitutionally punished activity protected by the First Amendment. The lower court agreed with the plaintiffs, ruling that the law was unconstitutional on its face because it was not narrowly tailored to achieve the state's substantial interests. On appeal, the Eighth Circuit affirmed in part and reversed in part the lower court's decision. The appellate court found that the plaintiffs had standing to challenge the part of the law that penalized the use of cameras while trespassing (the "Use Provision"), but not the part penalizing the placement of cameras on trespassed property (the "Place Provision"). The court also disagreed with the lower court's conclusion that the law was unconstitutional, holding that it survived intermediate scrutiny against a facial challenge and was not unconstitutionally overbroad, as it did not prohibit a substantial amount of protected speech relative to its plainly legitimate sweep. The court remanded the case for further proceedings consistent with its opinion. View "Animal Legal Defense Fund v. Reynolds" on Justia Law

In this case, UMB Bank, N.A. (UMB) filed a complaint against Jessie Benton and her children, alleging that they violated the Racketeer Influenced and Corrupt Organizations Act (RICO) by committing acts of mail, wire, and bank fraud. The dispute arose from the management of a family trust, which included works of art, real estate, and personal effects. The beneficiaries of the trust accused UMB of mismanagement and sued UMB in a separate Missouri state court case. UMB then filed this federal case, arguing that the beneficiaries and their attorney engaged in fraudulent activities to force UMB to increase trust distributions or resign as trustee.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision to dismiss UMB's complaint for failure to state a civil RICO claim. The court agreed that UMB failed to sufficiently allege a pattern of racketeering activity. Although UMB might be able to prove that three communications to media outlets qualify as predicate acts of mail, wire, or bank fraud, these acts did not show a pattern of racketeering activity because they occurred within a few days and targeted a single victim (UMB). The court also affirmed the district court's denial of UMB's post-judgment motions for leave to amend the complaint, as the proposed amendment was both untimely and futile. View "UMB Bank v. Guerin" on Justia Law

In a case before the United States Court of Appeals For the Eighth Circuit, the plaintiffs, a group of patients, sued BJC Health System (BJC) alleging that BJC had violated their medical privacy rights under Missouri state law. Specifically, the plaintiffs claimed that when they accessed their electronic health records (EHRs) through BJC’s online patient portal, their protected health information was shared with third-party marketing services. BJC removed the case to federal court under the federal officer removal statute, arguing that they acted under the United States Department of Health and Human Services (HHS) when creating and operating the online patient portal. BJC's argument was rejected by the district court which ordered the case to be remanded back to Missouri state court. BJC appealed this decision.The United States Court of Appeals For the Eighth Circuit affirmed the decision of the district court to remand the case to the Missouri state court. The appellate court held that BJC, while receiving federal incentive payments from HHS for creating and operating the online patient portal, was not essentially performing a basic governmental task or duty. Therefore, BJC was not acting under a federal officer in terms of the federal officer removal statute. The court concluded that the creation and operation of an online patient portal was not a basic governmental task, and BJC was not a government contractor or functioning as a federal instrumentality. View "Doe v. BJC Health System" on Justia Law

Guatemalan citizens Miguel Pascual-Miguel and his daughter, Erika Gabriela Pascual-Miguel, sought review of the Board of Immigration Appeals' (BIA) decision affirming the denial of their asylum, withholding of removal, and protection under the Convention Against Torture requests by an immigration judge. They also sought review of the BIA’s denial of motions to reopen for ineffective assistance of counsel and Mendez Rojas class membership. The United States Court of Appeals for the Eighth Circuit denied the petition, affirming the BIA's decisions. The court held that the denial of asylum, withholding of removal, and CAT relief was supported by substantial evidence. Specifically, the court noted that the petitioners failed to show any evidence of persecutory motive related to their home in Guatemala being burned down, as they didn't know who did it or why. The court also held that the BIA's denial of the motions to reopen was not an abuse of discretion. The court noted that the attorney's misconduct did not prejudice the outcome of the removal proceedings and that the petitioners failed to demonstrate a nexus between the harm suffered and any protected ground, even if they were members of the Mendez Rojas class. View "Pascual-Miguel v. Garland" on Justia Law

The United States Court of Appeals for the Eighth Circuit reviewed a case where Deborah Lightner, a former employee of Catalent CTS (Kansas City), LLC, alleged age discrimination and retaliation under Missouri law. Lightner had received multiple promotions during her employment, but after several employees left citing her management style, her performance was rated poorly. After raising concerns about age discrimination in an email, Catalent removed the option of a performance improvement plan (PIP), offering only a demotion or severance. The district court granted summary judgment in favor of Catalent.Upon review, the Eighth Circuit affirmed the district court's decision on the age discrimination claim, as Lightner failed to show that Catalent's justifications were a pretext for discrimination. However, the court reversed the judgment on the retaliation claim. The court found that the timing of Catalent's removal of the PIP option within 48 hours of Lightner's complaint, combined with text messages from Catalent management, created a sufficient inference of retaliation. Here, the close temporal proximity was deemed sufficient to support a reasonable inference of a causal relationship. The case was remanded for further proceedings consistent with this opinion. View "Lightner v. Catalent CTS (Kansas City)" on Justia Law

The case before the United States Court of Appeals for the Eighth Circuit involved Allen Thomas Bloodworth, II, a business owner who operated two towing businesses in Kansas City. Bloodworth alleged that the Kansas City Board of Police Commissioners and fourteen officers of the Kansas City Police Department conspired to stop him from running his businesses and shut down his ability to conduct business in Kansas City. He brought 17 state and federal claims, including defamation, tortious interference with contract and business expectancy, intentional infliction of emotional distress, and negligent hiring, training, supervision, or retention. He also alleged Fourth Amendment violations for an unlawful warrant search and seizure of his residence and business, the shooting of his dog during the search, and the seizure of business records.The district court granted summary judgment in favor of the defendants. On appeal, the Eighth Circuit affirmed the ruling. The appellate court concluded that Bloodworth failed to link the specific conduct of individual defendants to the alleged constitutional violations, and his claims were based on general assertions mostly. It also ruled that Bloodworth failed to establish that the defendants' conduct was extreme and outrageous to support his claim for intentional infliction of emotional distress. The court further found that Bloodworth failed to establish a constitutional violation resulting from the official policy, unlawful practice, custom, or failure to properly train, retain, supervise, or discipline the police officers. Therefore, there was no basis for municipal liability against the Kansas City Board of Police Commissioners. View "Bloodworth v. Kansas City Board of Police Commissioners" on Justia Law

In this case, the United States Court of Appeals for the Eighth Circuit affirmed the decision of the United States District Court for the Southern District of Iowa to dismiss the lawsuit of Iowa-based livestock feed seller Hawkeye Gold, LLC against China National Materials Industry Import and Export Corporation, also known as Sinoma, for lack of personal jurisdiction. Hawkeye Gold sued Sinoma to recover an unpaid default judgment it obtained against Sinoma's now-defunct wholly owned United States subsidiary, Non-Metals, Inc., for breach of a contract to purchase livestock feed. After six years of litigation, the District Court dismissed the case because it did not have personal jurisdiction over Sinoma, a decision which Hawkeye Gold appealed. The Appeals Court, after reviewing the evidence, agreed with the District Court's conclusion that Sinoma had insufficient minimum contacts with Iowa to support personal jurisdiction. The Court also rejected Hawkeye Gold's argument that Sinoma was a party to the contract or that Non-Metals was the alter-ego of Sinoma. Furthermore, the Court affirmed the District Court's denial of Hawkeye Gold's request for sanctions against Sinoma for alleged discovery violations. View "Hawkeye Gold, LLC v. China National Materials" on Justia Law