Articles Posted in US Court of Appeals for the Eighth Circuit

by
CMI, a purchaser and reseller of mortgage loans, filed suit against Platinum, an originator and seller of mortgage loans, alleging that Platinum breached a contract by failing to repurchase seven allegedly defective loans after CitiMortgage demanded repurchase by sending multiple notices to Platinum for each loan. The Eighth Circuit reversed and held that CMI adequately and substantially complied with the contract, which neither specified a form of notice nor indicated that the prescription of a time for cure had to be contained within the notice. Accordingly, the court remanded for further proceedings. View "CitiMortgage, Inc. v. Platinum Home Mortgage, Corp." on Justia Law

by
The District filed suit alleging that an UV System installed at one of its treatment facilities had consistently failed to function in any working capacity. The Eighth Circuit affirmed the district court's grant of summary judgment dismissing the District's claims. The court held that the breach of warranty claim was properly dismissed because the District failed to present expert testimony to establish that the UV System's ongoing operational issues were caused by equipment defects. Furthermore, the express warranty provided that the District's exclusive remedy was replacement of the defective parts, but the District did not allow Evoqua, the UV System vendor, to repair or replace the warranty items. Finally, the district court did not err by dismissing the District's claim against Travelers, the project's contractor, under its Performance and Maintenance Bond. View "Iowa Great Lakes Sanitary District v. Travelers Casualty and Surety Co." on Justia Law

by
The Eighth Circuit affirmed the district court's grant of summary judgment for Employers in an action brought by Employers, seeking a declaratory judgment to clarify whether Hartford had a duty to pay half of the expenses related to an underlying workers' compensation claim. The court held that Hartford's purported cancellation of an insurance policy, after a workers' compensation claim had arisen, was void under Missouri law. Furthermore, assuming that Hartford properly pleaded the affirmative defense of mutual mistake, the court held that the company failed to identify any mutual mistake during the formation of the contract. View "Employers Preferred Insurance Co. v. Hartford Accident & Indemnity Co." on Justia Law

by
Graco sought to set a jury verdict aside that found in favor of Rydex in its breach of contract claim against Graco. Graco renewed its motion for judgment as a matter of law and moved for a new trial. After the district court denied these motions, the district court further awarded $204,221.50 in attorneys' fees to Rydex. The Eighth Circuit affirmed and held that the jury's determinations, rather than the district court's findings as a matter of law, resolved the materiality issue. The court explained that these factual determinations were uniquely in the jury's purview and the court declined to upset it on appeal. The court also held that the jury instructions fairly and adequately presented the applicable law and there was no error in reducing the amount of attorneys' fees requested by plaintiff. View "Ryan Data Exchange, Ltd. v. Graco, Inc." on Justia Law

by
The Eighth Circuit affirmed the district court's grant of Medtronic's motion to remand an employment contract dispute back to state court. Applying Minnesota law, the court held that plaintiff waived his right to remove the case to federal court because the employment contract he signed contained an enforceable forum selection clause. In this case, Medtronic alleged that plaintiff failed to repay the company pursuant to the Repayment Agreement. The court held that the Employee Agreement contained a clear and unequivocal forum selection clause that unambiguously encompassed the Repayment Agreement. View "Medtronic Sofamor Danek, Inc. v. Gannon" on Justia Law

by
The Eighth Circuit affirmed the district court's dismissal of Irmat's complaint against Express Scripts, alleging various contract claims, a promissory estoppel claim, and violations of federal antitrust laws and state Any Willing Provider laws. The court held that the inclusion of Express Scripts's unilateral right to terminate the agreement between the parties upon thirty days written notice was, by itself, insufficient to support a claim of unconscionability; the agreement was not unconscionable because it was a non-negotiable form contract (i.e., a contract of adhesion); Express Scripts did not violate its duty of good faith and fair dealing when it terminated Irmat from its network; and the e-mail Express Scripts sent to Irmat in August 2015 did not constitute a novation where it lacked essential contractual provisions. The court also held that Irmat failed to plausibly plead promissory estoppel. Finally, the court rejected Irmat's claim that Express Scripts violated Sections 1 and 2 of the Sherman Act, and that Express Scripts violated the Any Willing Provider laws. Irmat was not entitled to leave to amend its complaint. View "Park Irmat Drug Corp. v. Express Scripts Holding Co." on Justia Law

by
The Eighth Circuit affirmed the district court's grant of summary judgment for Medalist in an action seeking damages for breach of contract and promissory estoppel. Plaintiff operates Cane Creek, which supplies, grows, and delivers sod. Medalist specializes in building high-end golf courses. The parties' dispute stemmed from a Grass Supplier Agreement to reserve grasses for a set price. The court held that Medalist was entitled to summary judgment on the breach of contract claim because plaintiff could not show that Medalist wrongfully rejected the sod. The court also held that a reasonable jury could find that an enforceable requirements contract existed in this case, which could bar plaintiff from recovery under a theory of promissory estoppel. Even if a promissory estoppel claim were available, the court held that this was not the extreme case that would entitle plaintiff to such extraordinary relief. View "Williams v. Medalist Golf, Inc." on Justia Law

by
The Eighth Circuit affirmed the district court's grant of summary judgment to the government in an action to enforce a settlement agreement. The court held that OSC's press release stating that its investigation found that Nebraska Beef had engaged in illegal employment practices did not constitute a material breach of the settlement agreement. Therefore, because the government did not fail to fulfill any promise, Nebraska Beef's breach of contract counterclaim failed and the government's claim for enforcement prevailed. View "United States v. Nebraska Beef, Ltd." on Justia Law

by
The Supreme Court remanded this case after holding that retroactive application of Minnesota's revocation-upon-divorce statute did not violate the Contracts Clause. In light of the Supreme Court's remand, the Eighth Circuit affirmed the district court's grant of summary judgment awarding the policy proceeds to the deceased's children. View "Metropolitan Life Insurance Co. v. Melin" on Justia Law

by
Plaintiff filed the underlying action against BNSF after he was injured when the backrest of his locomotive seat broke, and alleged that the seat did not comply with the federal standards in the Locomotive Inspection Act (LIA). BNSF settled a Federal Employers' Liability Act (FELA) claim with plaintiff. BNSF then filed suit against Seats to recover the costs of settlement. The Eighth Circuit reversed and held that the district court erred in determining that the LIA preempted BNSF's claims for products liability and breach of contract. Because the district court did not address defendant's other grounds for dismissal of the two claims, the court remanded for further proceedings on those alternative arguments. View "BNSF Railway Co. v. Seats, Inc." on Justia Law