In 2008, Penford Corporation suffered extensive flood damage to its Cedar Rapids manufacturing plant and sought coverage under an all-risk property insurance policy issued by National Union Fire Insurance Company and ACE American Insurance Company, which included a $300 million overall limit but also specific flood sublimits of $10 million for certain zones. The insurers maintained that those sublimits capped both property damage and related business interruption (time element) losses, while Penford argued the sublimits applied only to direct physical damage; Penford sued for declaratory relief, breach of contract, and bad faith. After trial, the district court granted the insurers judgment as a matter of law on all claims, and the Eighth Circuit affirmed. The appeals court held that the policy language, including the sublimits provision stating they applied “per occurrence” for all “coverages involved,” unambiguously extended the caps to business interruption losses, and that undisputed testimony from Penford’s own broker confirmed the parties’ shared understanding that the flood sublimits governed both categories of loss. Because no material factual dispute existed on the contract’s meaning, judgment as a matter of law was proper on the coverage and bad-faith claims alike.
In 2004, Vickie Fields, a Miller County, Missouri jailer, was seriously injured when two inmates took her hostage after she escorted them unhandcuffed to the jail’s law library and opened the cell door; she later sued the county, its sheriff, and county commissioners under 42 U.S.C. § 1983, alleging that known jail conditions—including an interior door handle that inmates could grab, understaffing, and lax transfer procedures—violated her substantive due process rights. The district court denied qualified immunity to the individual defendants, but on interlocutory appeal the Eighth Circuit reversed that ruling. The court held that the defendants’ conduct amounted at most to gross negligence and did not demonstrate the deliberate indifference or criminal recklessness required to establish a substantive due process violation. Because no constitutional violation occurred, the individual defendants were entitled to qualified immunity, and the case was remanded for further proceedings solely against Miller County.
K-V Pharmaceutical Company, based in Missouri, sued Spanish company J. Uriach & CIA for breach of contract and misappropriation of trade secrets arising from a 1993 agreement to develop and sell an antifungal cream using KV's drug-delivery system, which Uriach allegedly misused after the contract's termination. The district court dismissed the case for lack of personal jurisdiction over Uriach, finding insufficient contacts with Missouri. On appeal, the Eighth Circuit reversed, holding that Uriach's contract negotiations, amendments, choice-of-law provision, and ongoing confidentiality obligations established minimum contacts sufficient for jurisdiction under Missouri's long-arm statute and due process. The court also denied Uriach's alternative request to dismiss on forum non conveniens grounds, noting that public-interest factors favored Missouri as the forum, and remanded the failure-to-state-a-claim issue for further consideration.
This case involved a dispute between Triple H Debris Removal, Inc. and Companion Property and Casualty Insurance Company over the cancellation of two workers' compensation insurance policies due to an unpaid premium following an audit that increased the amount owed. After a jury trial, the district court entered judgment in favor of Companion on the ground that Triple H had not raised a bona fide dispute under the policy's dispute-resolution protocol and had not paid the premium. On appeal, the Eighth Circuit affirmed, holding that the evidence permitted the jury to find both that Triple H failed to supply the detailed written explanation required to raise a bona fide dispute and that the local insurance agent was not Companion's agent for purposes of the policies at issue.
The case involved Chad Miller, who was indicted for possessing a firearm while subject to a state court protective order against harassing or threatening an intimate partner, in violation of federal law under 18 U.S.C. §§ 922(g)(8) and 924(a)(2). Miller moved to dismiss the indictment, arguing that his conviction should be vacated because he was unaware that his possession was prohibited and invoking a limited exception to the rule that ignorance of the law is not a defense. The district court denied the motion, accepted his guilty plea, and sentenced him to 69 months' imprisonment, which Miller appealed as unreasonable. The Eighth Circuit affirmed the conviction and sentence, holding that the protective order provided sufficient notice of the firearm prohibition and that the sentence was justified by the aggravated circumstances, including threats to a law enforcement officer.
In United States v. Butler, Kendrick Butler was convicted by a jury of six counts of bank fraud for recruiting individuals to cash counterfeit checks as part of a scheme run by others. The district court imposed an 80-month sentence after applying a two-level enhancement under U.S.S.G. § 2B1.1(b)(10) for device-making equipment and a three-level enhancement under § 3B1.1(b) for Butler's role as a manager or supervisor. The Eighth Circuit held that the device-making equipment enhancement was improper because the offense involved only transfers by paper instrument, which are excluded from the statutory definition of access devices. The court affirmed the aggravating role enhancement, concluding that the recruited individuals qualified as participants because they knew or were willfully blind to the fraud. The sentence was vacated and the case remanded for resentencing without the erroneous enhancement.
