Justia Business Law Opinion Summaries

Five employees of The Mayo Clinic, a Minnesota non-profit corporation, filed a lawsuit alleging that the organization failed to accommodate their religious beliefs under Title VII and the Minnesota Human Rights Act (MHRA). The employees claimed that they were terminated for refusing to comply with Mayo's Covid-19 vaccination or testing policies. The plaintiffs sought religious accommodations for the vaccination requirement, citing their Christian religious beliefs. Mayo denied the accommodations for three plaintiffs who refused to get the vaccine. It granted vaccination exemptions to two plaintiffs, but required them to test for Covid-19 weekly, which they refused.The district court dismissed the claims, ruling that two plaintiffs did not exhaust their administrative remedies under Title VII, the other plaintiffs failed to plausibly plead religious beliefs that conflict with Mayo’s Covid-19 policies, and the MHRA fails to provide relief for not accommodating religious beliefs.The United States Court of Appeals for the Eighth Circuit reversed the district court's decision and remanded the case. The appellate court found that the district court erred in finding that two plaintiffs did not exhaust their administrative remedies under Title VII. The court also found that all plaintiffs adequately pled a conflict between their Christian religious beliefs and Mayo Clinic’s Covid-19 policy. Furthermore, the appellate court disagreed with the district court's finding that the MHRA does not provide a cause of action for failure to accommodate religious beliefs. The appellate court held that the MHRA, being a remedial act, should be construed liberally to secure freedom from discrimination for persons in Minnesota, and thus provides protection against failures to accommodate religious beliefs. View "Ringhofer v. Mayo Clinic Ambulance" on Justia Law

This case involves a dispute between Jacam Chemical Company 2013, LLC (Jacam) and its competitor GeoChemicals, LLC, along with Arthur Shepard Jr., a former Jacam employee who later worked for GeoChemicals. Jacam sued both Shepard and GeoChemicals, alleging breach of contract, misappropriation of trade secrets, and tortious interference with contracts. Shepard and GeoChemicals countersued Jacam. The district court granted a declaratory judgment to Shepard, concluding that he owed no contractual obligations to Jacam, and dismissed the remaining claims of Jacam and GeoChemicals.The district court had previously reviewed the case and granted summary judgment to Shepard, holding that he had no enforceable agreements with Jacam. The court also dismissed all of Jacam’s and GeoChemicals’s other claims against each other. Both Jacam and GeoChemicals appealed aspects of the summary judgment order.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court found that neither the HCS Agreement nor the 2015 version of CES’s Conduct Code created an enforceable contract between Jacam and Shepard. The court also held that Jacam did not make reasonable efforts to keep its pricing information secret, which means the pricing information documents were not trade secrets which Shepard could misappropriate. Finally, the court agreed with the district court that Jacam’s tortious-interference claim fails. The court also dismissed GeoChemicals’s cross-appeal, holding that Jacam did not commit an independently tortious act that interfered with GeoChemicals’s relationship with Continental. View "Jacam Chemical Co. 2013, LLC v. Shepard" 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

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

Jonathan Weber Arrington, the defendant, was employed by Recon Roofing and Construction to handle their finances. He was found guilty of wire fraud, having embezzled a total of $315,835 from the company between August 2019 and March 2021. Arrington appealed his sentence and the related restitution order. He argued that the district court erred by assigning him the burden of proof regarding any offset to the restitution amount. The defendant also contended that the court didn't account for the value of payments he made towards the loss, and that the imposed sentence was unreasonably harsh.The United States Court of Appeals for the Eighth Circuit upheld the sentence but vacated the restitution order. The Appeals Court stated that the district court was correct in assigning Arrington the burden of proof for any offset to the amount of restitution. However, it was determined that the district court had erred in not reducing the restitution amount by the value of shares sold by the defendant back to the company. Therefore, the restitution amount was reduced by $50,000 to $265,835. The court found the prison sentence to be reasonable, considering the factors such as Arrington's position of trust within the company, the extent of the fraud, his attempt to cover it up, and his prior federal fraud conviction. View "United States v. Arrington" on Justia Law

Three shareholders of Fannie Mae and Freddie Mac sued the Federal Housing Finance Agency (FHFA) and the Department of the Treasury, alleging harm from the unconstitutional removal restriction of the Housing and Economic Recovery Act of 2008. Their claims were based on the premise that if President Trump had been able to remove the FHFA Director without restrictions, he would have ended a provision that, in the event of liquidation, allowed the Treasury to recover its full preference before any other shareholder. The district court dismissed the shareholders' claims, finding that they did not sufficiently demonstrate any harm.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court noted that to challenge agency action, a party must not only show that the removal restriction is unconstitutional but also that the provision caused or would cause them harm. The court found that the shareholders' assertions did not satisfy this standard. They relied heavily on a post-presidency letter from President Trump expressing his desire to have removed the FHFA Director during his presidency. The court determined that this letter did not meet the criteria of a "public statement expressing displeasure" as outlined by the Supreme Court in Collins v. Yellen. Furthermore, the court found the shareholders' circumstantial evidence of harm speculative and insufficient to state a claim for relief. Therefore, the court affirmed the dismissal of the claims. View "Bhatti v. Fed. Housing Finance Agency" on Justia Law

The case involves the Reporters Committee for Freedom of the Press, a nonprofit organization that sought to unseal court filings from federal criminal investigations. The District Court in Minnesota dismissed the application for lack of jurisdiction, and the case was appealed to the United States Court of Appeals for the Eighth Circuit.The Reporters Committee's application aimed to unseal electronic-surveillance filings, which were required to be filed under seal by a local rule. The District Court believed the request was too broad since the majority of the materials requested become unsealed after six months. The court suggested negotiations with the United States Attorney’s Office to reach a solution.The Reporters Committee subsequently filed an amended application, seeking an order directing the clerk of the court to presumptively unseal warrants and related documents after 180 days and to begin docketing the government’s applications for electronic surveillance regardless of whether a judge granted them. The Committee claimed these duties arose under the First Amendment and the common-law right of access to public records and documents.The District Court dismissed the application, concluding that the Committee lacked standing because all it had was a “generalized, abstract interest” in unsealing the records. This decision was affirmed by the Appeals Court, which held that the Committee failed to establish it suffered a “concrete” and “particularized” injury. It was also noted that the Committee did not sue anyone who could provide the relief it sought, hence there was a lack of adversity necessary for federal court adjudication. View "Reporters Comm. for Freedom of the Press v. United States" on Justia Law

The City of Richmond Heights, Missouri filed a claim with Mt. Hawley Insurance Company under a commercial property policy for losses of tax revenue due to government-mandated COVID-19 closures. Mt. Hawley denied the claim and sued for a declaratory judgment that it was not obligated to cover the losses. Richmond Heights counterclaimed with five counts: (1) breach of contract, (2) vexatious refusal to pay, (3) fraudulent inducement and misrepresentation, (4) negligent misrepresentation, and (5) breach of fiduciary duty. The United States District Court for the Eastern District of Missouri dismissed the counterclaims, denied amendments to two of them, and granted declaratory judgment to Mt. Hawley. On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the decision of the lower court.The appellate court held that the insurance policy required "direct physical loss of or damage to property" for coverage which was not met by the COVID-19 shutdowns. The court also rejected the city's argument that the Additional Covered Property Endorsement in the policy removed the "physical damage or loss" requirement for losses of sales tax revenues. Furthermore, the court found that the city's claims of fraud, misrepresentation and breach of fiduciary duty were not distinct from its breach of contract claim and thus were properly dismissed by the district court. Lastly, the court affirmed the district court's denial of the city's motion to amend its breach of contract and vexatious refusal claims, concluding that the proposed amendments would not have survived a motion to dismiss. View "Mt. Hawley Insurance Company v. City of Richmond Heights" on Justia Law