Articles Posted in US Court of Appeals for the Eighth Circuit

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The Eighth Circuit affirmed the district court's denial, on remand, of Qwest's unjust enrichment claim against FC. The court held that the district court did not abuse its discretion by concluding that it would not be inequitable for FC to retain the benefit conferred by Qwest. In this case, the district court explained that FC earned the benefit conferred by Qwest because it provided conference-calling services, 24-hour customer support, and access to a website in exchange for two cents per minute for calls placed to FC's conferencing bridges at Sancom. Furthermore, Qwest paid its own conference-calling vendor between two and four-and-a-half cents per minute. View "Qwest Communications Corp. v. Free Conferencing Corp." on Justia Law

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The Eighth Circuit affirmed the district court's judgment holding that defendant was liable for amounts owed in a consent judgment stemming from loan defaults. Defendant had signed a general guaranty for a company that he thought he owned in part with his trusted friend and financial advisor. His friend purportedly failed to mention that the guaranty would make defendant liable for millions of dollars of debt from loans that his friend had obtained and was unable to pay. The court held that the FDIC's creation of CADC and its sale of Premier Bank's assets thereto fell within its broad power; there was no clear error in finding that defendant's agent delivered the guaranty with his implied actual authority because defendant signed the guaranty, understood its contents, and gave express authority to conduct business; and there was no error in finding that the bank did not fail in its duty to ensure that the agent acted with implied actual authority and in rejecting defendant's fraud in the factum defense. View "Radiance Capital Receivables Eighteen, LLC v. Concannon" on Justia Law

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The Eighth Circuit affirmed an adverse order by the FAA's Office of Dispute Resolution for Acquisition (ODRA) regarding property Southern leased to the Administration. Southern subsequently sold the property and surrounding land to Prairie Land, assigning its lease with the FAA to Prairie Land. After the FAA refused to vacate the premises, Prairie Land initiated a contract dispute with the ODRA. The court held that the FAA's continued occupancy of the property was permitted, and the ODRA did not err by concluding that the holdover provisions permitted the FAA to holdover on the property until either a new lease was agreed upon or it acquired the property in fee. Therefore, the FAA was fully within its rights to continue possessing the property. View "Prairie Land Holdings, LLC v. FAA" on Justia Law

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After Mako acquired a historic building with intentions to restore it using state and federal historic tax credits, it retained the law firm of Winthrop & Weinstine to draft the tax credit bond. CRBT then retained Winthrop to represent it in connection with the building tax credit project. CRBT, through counsel Winthrop, later sought to foreclose on the building. Mako retained separate counsel and moved to dismiss the complaint and to disqualify Winthrop. The district court denied both of Mako's motions and awarded $5.2 million to CRBT. The Eighth Circuit held that the district court did not err by denying Mako's motion to dismiss the action for failure to join Chevron as a necessary party under Federal Rule of Civil Procedure 19(a)(1); the district court did not err in calculating the money judgment; and, although the district court erred in failing to disqualify Winthrop as counsel for CRBT, the error was harmless. Accordingly, the court affirmed the district court's judgment for money damages; reversed the district court's denial to disqualify counsel in any future proceedings; and, as proceedings continue and the Winthrop law firm has a conflict of interest necessitating removal as counsel, remanded for further proceedings. View "Cedar Rapids Bank & Trust Co. v. Mako One Corp." on Justia Law

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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

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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

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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

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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

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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

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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