Justia Contracts Opinion SummariesArticles Posted in US Court of Appeals for the Eighth Circuit
Miller v. Huron Regional Medical Center
The Eighth Circuit affirmed the district court's denial of HRMC's motion for remittitur or a new trial following the jury's award of damages to plaintiff, one of HRMC's former physicians, in a breach of contract action. The court held that the jury's award was not so grossly excessive that the district court committed a manifest abuse of discretion in failing to order remittitur for a lesser amount; even if HRMC's analysis of the Health Care Quality Improvement Act of 1986 immunity provision was correct, HRMC failed to properly preserve the issue; and there was no injustice in this case where HRMC had ample opportunity to raise this defense but failed to do so until it was too late. View "Miller v. Huron Regional Medical Center" on Justia Law
Landmark Infrastructure Holding Co. v. R.E.D. Investments, LLC
Lamar maintained and operated a billboard on land that it leased from R.E.D. After R.E.D. and Landmark executed an agreement under which Landmark agreed to pay R.E.D. in exchange for, among other things, the right to receive rent from Lamar, Landmark sued R.E.D. for breach of contract and sued R.E.D. and Defendant Van Stavern for fraudulent and negligent misrepresentation. The Eighth Circuit affirmed the district court's judgment and held that the district court did not err by excluding the testimony of defendants' expert witness where the expert's opinions were not relevant because they were not supported by facts in the record. Furthermore, the district court did not err by denying defendants' request for reconsideration, because the discovery deadlines had passed and defendants failed to offer a substantial justification for their delay. Finally, the court held that the damages award were not duplicative and affirmed the attorneys' fee award. View "Landmark Infrastructure Holding Co. v. R.E.D. Investments, LLC" on Justia Law
Jet Midwest International Co., Ltd. v. Jet Midwest Group, LLC
After JetMidwest filed suit against JMG for breaching a loan agreement, the district court granted summary judgment to JetMidwest but denied its motion for reimbursement of its attorneys' fees under the agreement. As a preliminary matter, the Eighth Circuit held that a Hong Kong limited company is equivalent to a U.S. corporation under 28 U.S.C. 1332. Therefore, the district court properly exercised subject matter jurisdiction under section 1332 and the court had appellate jurisdiction under 28 U.S.C. 1291. On the merits, the court disagreed with the district court's interpretation of the agreement, holding that the use of the sweeping language "all costs and expenses" reflects the parties' intent that JMG would pay Jet Midwest's attorneys' fees and other costs for enforcing as well as preparing the agreement. Accordingly, the court reversed and remanded for consideration of an appropriate award. View "Jet Midwest International Co., Ltd. v. Jet Midwest Group, LLC" on Justia Law
Advance Conveying Technologies v. Lemartec Corp.
Lemartec appealed the district court's entry of judgment in favor of ACT on ACT's breach of contract claim. Lemartec argued that the district court erred in concluding that Lemartec's bid package was incorporated into the parties' contract. Although the bid package was not incorporated in so many words, the Eighth Circuit nonetheless affirmed the judgment, because when the contract is considered in light of the usage-of-trade evidence that the district court found credible, there is no error in the determination that Lemartec breached the purchase order. View "Advance Conveying Technologies v. Lemartec Corp." on Justia Law
Air Evac EMS, Inc. v. USAble Mutual Insurance Co.
The Eighth Circuit affirmed the district court's dismissal of Air Evac's claims in an action alleging that Arkansas Blue inadequately reimbursed Air Evac for ambulance services that Air Evac provided Arkansas Blue plan members. The court held that Air Evac's assignment did not convey the right to sue for equitable relief under section 1132(a)(3) of the Employee Retirement Income Security Act (ERISA). Furthermore, the district court did not err by finding that Arkansas Blue's conduct was not actionable because it fell within the Arkansas Deceptive Practices Act's safe harbor for actions or transactions permitted under the laws administered by the insurance commissioner. Finally, the district court did not err by rejecting Air Evac's claims for breach of contract and unjust enrichment. View "Air Evac EMS, Inc. v. USAble Mutual Insurance Co." on Justia Law
Enterprise Financial Group Inc. v. Podhorn
The absence of a judgment in the state court litigation does not mean that plaintiff lacks Article III standing to bring this suit. Enterprise filed suit against several defendants, alleging a claim under the Missouri Uniform Fraudulent Transfer Act. The district court dismissed the complaint without prejudice based on the ground that there was no case or controversy because Enterprise lacked Article III standing. The Eighth Circuit reversed and held that Enterprise has alleged facts sufficient to demonstrate the elements of standing. In this case, Enterprise has sufficiently alleged a present injury in fact, fairly traceable to defendants, as the transferees of the funds. Therefore, the court remanded for further proceedings. View "Enterprise Financial Group Inc. v. Podhorn" on Justia Law
Soueidan v. St. Louis University
The Eighth Circuit affirmed the district court's dismissal of plaintiff's Missouri state-law claims for breach of contract, breach of the implied covenant of good faith and fair dealing, and fraudulent misrepresentation against St. Louis University. Plaintiff's claims stemmed from his unsuccessful attempts to receive a Ph.D from the university in mechanical and aerospace engineering in four years. The court held that the educational malpractice doctrine barred all of plaintiff's claims. In this case, all of the statements plaintiff relied on in the student catalog and handbook were aspirational in nature. The court also held that the district court did not abuse its discretion by denying plaintiff leave to amend his complaint when he did not submit a proposed amendment or include anything in his motion to indicate what an amended complaint would contain. View "Soueidan v. St. Louis University" on Justia Law
Alleruzzo v. SuperValu, Inc.
A group of customers filed suit against SuperValu after hackers accessed customer financial information from hundreds of grocery stores operated by defendant. The Eighth Circuit previously affirmed the dismissal of all but one of the suit's named plaintiffs for lack of standing and, on remand, the district court dismissed the remaining plaintiff for failure to state a claim and denied plaintiffs' motion for leave to amend. The court affirmed, holding that the district court did not abuse its discretion by denying the motion for leave to amend because plaintiffs' postjudgment motion was untimely. The court also held that the remaining plaintiff's allegations fell short of stating a claim for relief under Illinois law for negligence, consumer protection, implied, contract, and unjust enrichment. View "Alleruzzo v. SuperValu, Inc." on Justia Law
Posted in: Civil Procedure, Consumer Law, Contracts, Personal Injury, US Court of Appeals for the Eighth Circuit
Qwest Communications Corp. v. Free Conferencing Corp.
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
Radiance Capital Receivables Eighteen, LLC v. Concannon
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