James Hargrove Meredith

This case involved an employee suing his former employer after termination, claiming violation of Missouri's service letter statute for failing to provide required documentation of employment (Count I) and a prima facie tort for discontinuing medical insurance coverage (Count II), which the defendant removed to federal court under ERISA. The court denied the defendant's motion for summary judgment on Count I, as a genuine factual dispute existed over whether the employer had seven or more employees when the claim arose. It granted partial summary judgment on Count II on grounds of ERISA preemption, ruled that no jury trial was available for that count, denied the defendant's motion to strike a filing, and denied the plaintiff's discovery motions for not complying with local rules requiring good-faith conferral efforts.

labor & employmentprocedurefederal power

The case involved Lucille Fogerty's 1986 lawsuit against Metropolitan Life Insurance Company seeking disability benefits under a group insurance plan sponsored by her former employer, General Electric, which she claimed entitled her to payments from late 1976 onward after her benefits were terminated. The plan was governed by ERISA, but because ERISA lacks its own statute of limitations, the court applied Missouri law. Defendant moved to dismiss on the ground that the claim was untimely, and the court granted the motion, holding that the five-year limitations period for contract actions applied rather than the ten-year period for writings for the payment of money. The core reasoning was that the insurance plan was a contract for services, not an acknowledgment of indebtedness on its face, so establishing liability required extrinsic proof such as the extent of the plaintiff's disability.

labor & employmentprocedure

In Holcomb v. United Automotive Ass'n of St. Louis, a beneficiary of a pension plan established by a union and employer association sued to challenge the trust indenture's trustee selection and removal rules, claiming they violated ERISA fiduciary duties and the equal-representation requirements of section 302(c)(5)(B) of the LMRA. The district court granted summary judgment to defendants on the ERISA claim, holding that provisions allowing removal of union trustees only for cause did not create a structural conflict with fiduciary obligations. On the LMRA claim the court granted summary judgment to the plaintiff, concluding that the indenture's asymmetric removal rules denied the union equal authority to appoint and remove its trustees, contrary to the statute's parity mandate. The court therefore ordered the offending sections stricken and directed that each side could remove and replace its designated trustees at any time.

labor & employmentbusiness & regulatory

The case involved St. Louis Federal Savings and Loan Association seeking recovery of $10,000 in audit expenses under a savings and loan blanket employee fidelity bond issued by Fidelity and Deposit Company of Maryland, after an audit prompted by alleged misconduct by former president Emmett Capstick. The Association had previously settled a wrongful dismissal suit with Capstick and executed a broad release of all claims against him, before notifying the insurer of its bond claim. Applying Missouri law in this diversity action, the court granted directed verdicts for the defendant insurer against the Association and for Capstick against the insurer's third-party subrogation claim, holding that the pre-claim release without the insurer's consent impaired its subrogation rights and thereby barred recovery under the bond.

business & regulatorytorts & liability

This case involved a dispute over a $12,574.13 surplus from the foreclosure sale of the Jordans' property under a first deed of trust. The Small Business Administration, as holder of a second deed of trust securing a defaulted business loan, and the Jordans, who had received a bankruptcy discharge, both claimed the surplus after the sale. The court granted the SBA's motion for summary judgment. It reasoned that junior lienholders take priority over the mortgagors for any surplus proceeds, the bankruptcy discharge did not extinguish the SBA's secured interest in the property, and the terms of the first deed of trust could not override the SBA's rights as a junior lienholder.

propertybusiness & regulatoryprocedure

This case concerns Medicare health care providers seeking reimbursement for malpractice insurance premiums allocable to Medicare patients, following an earlier court order that invalidated the Malpractice Rule and required use of prior regulations. The Secretary of Health and Human Services moved for partial relief from that order as to St. Francis Hospital and St. Mary's Health Center, asserting lack of subject matter jurisdiction because those providers filed untimely appeals with the Provider Reimbursement Review Board and the Board denied their requests for good cause exceptions. The court granted the motion, ruling that the 180-day filing deadline under 42 U.S.C. § 1395oo(a) is a jurisdictional prerequisite that cannot be waived and that the Board has exclusive authority to grant or deny extensions, leaving no reviewable final decision. The court also denied the providers' motion to remand those claims and the Secretary's request for an extension of time to appeal or entry of a new final judgment.

healthcarefederal powerprocedure

This case involves the National Credit Union Administration Board (NCUAB), as liquidating agent for an insolvent federal credit union, suing to collect on three promissory notes totaling $28,000 that the defendant had issued to the credit union. The defendant raised an affirmative defense of payment, asserting he had made equivalent payments to a separate Missouri corporation and its officer. The court entered judgment for the plaintiff in the amount of the outstanding balances plus interest, attorneys' fees, and costs. The core reasoning was that the defendant bore the burden of proving payment and failed to show the recipients were agents of the credit union, so payments to unauthorized parties did not discharge the notes.

business & regulatoryfederal powerprocedure

Interco sued its insurers, Hartford and Mission, seeking reimbursement for defense costs and a settlement paid to a former employee who claimed emotional distress, humiliation, and reputational harm after being fired. The court held that neither insurer had a duty to defend or indemnify Interco. It reasoned that the firing was not an "occurrence" under either policy because it was intentional rather than unexpected or unintended from the insured's standpoint, and Hartford's policy contained an unambiguous exclusion for injuries related to employment. The decision applied Massachusetts law to the Hartford policy and Missouri law to the Mission policy, both of which required giving plain meaning to clear policy terms.

labor & employmentbusiness & regulatory

In Evans v. Missouri Pacific R. Co., a railroad employee sued his employer and a supervisor for common-law slander, alleging the supervisor falsely stated during a work-reassignment proceeding that the plaintiff could not be trusted to tell the truth, and also asserted a claim under the Federal Employers' Liability Act. The U.S. District Court for the Eastern District of Missouri granted the defendants' motion to dismiss the entire complaint. The court held that the slander claim constituted a minor dispute under the Railway Labor Act because it arose from the employment relationship and was at least arguably governed by the collective bargaining agreement, requiring exclusive arbitration before the National Railroad Adjustment Board rather than court adjudication; no exception for outrageous conduct applied. The FELA claim was dismissed because the statute covers only personal injuries caused by negligence, not the alleged intentional tort, and the plaintiff alleged no physical injury.

labor & employmenttorts & liability

This ERISA case involved a former Monsanto employee who retired in July 1982 under the company's Combo-80 voluntary retirement program and later sued for additional benefits under a Special Incentive Retirement (SIR) program adopted in September 1982 for certain divisions and then extended company-wide. The plaintiff claimed Monsanto failed to disclose ongoing deliberations about the SIR plan before his retirement date, despite his inquiries and the company's June 1982 announcement that it was considering extensions to other units. The district court entered judgment for Monsanto, finding no misrepresentations, no existing plan at the time of retirement, and no ERISA duty to disclose formative-stage deliberations that might never be implemented. The court reasoned that ERISA sections on fiduciary duties and information disclosure do not require advance notice of potential future benefits, and any such disclosure could have been misleading given uncertainties over cost, accounting, and other factors. The stipulated amount of disputed benefits was $48,793.68.

labor & employmentbusiness & regulatory

In this case, farmers who had borrowed $286,000 from the Farmers Home Administration (FmHA) and later conveyed their farm deed to the agency after defaulting sued the Secretary of Agriculture for failing to notify them of potential relief rights under 7 U.S.C. section 1981(a). The court granted the defendant's motion to dismiss, holding that it lacked subject matter jurisdiction over claims for damages and that no claim was stated for which relief could be granted. The core reasoning was that at the time of the conveyance in 1982, the legal obligation to provide notice under the statute was not clearly established, entitling the government official to qualified immunity under Harlow v. Fitzgerald, as district courts in the Eighth Circuit were split on the issue until a later appellate decision. The court also found requests for injunctive or declaratory relief moot because the FmHA was no longer contesting its obligations under the statute and had begun implementing required procedures following a separate injunction.

federal powerpropertyprocedure

This case arose from a 1980 barge breakaway on the Mississippi River caused by the fracture of a defective timberhead on the barge Jackie 21, which led to damages claims by Vollmar Bros. Construction, Federal Barge Lines, and the U.S. Army Corps of Engineers against Archway Fleeting & Harbor Service and Consolidated Grain and Barge. The court found that the timberhead was defectively manufactured, creating an unreasonably dangerous condition that rendered the barge unseaworthy and proximately caused the incident, with liability tracing through a chain of sales from Dreyfus to Azalea to Consolidated. It entered judgments awarding specific damages totaling over $74,000 to the plaintiffs, apportioned equally between Archway and Consolidated, and granted successive indemnity claims with attorneys' fees along the supply chain from Consolidated against Azalea, Azalea against Dreyfus, while denying others against Equitable and Dibert. The reasoning rested on strict products liability under Restatement (Second) of Torts § 402A, the latent nature of the defect, and the reasonable use of the timberhead under anticipated stresses.

torts & liabilitybusiness & regulatory

This case involved a dispute over whether an insurance company and employer were obligated to provide health insurance benefits for medical expenses related to an eye injury sustained by the plaintiff's son. The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the defendants, Travelers Insurance Company and Altorfer Machinery Company, dismissing the plaintiff's claims for declaratory judgment and damages. The court reasoned that no contract existed between the plaintiff and Altorfer to provide benefits, and the group health policy issued by Travelers clearly limited coverage to expenses incurred while the insured was covered under the policy, which terminated on October 1, 1981, after the son's 19th birthday. Although the injury occurred in 1979 while coverage was in effect, the policy language specified that benefits applied only to expenses incurred during the coverage period, distinguishing it from cases with ambiguous terms.

healthcarelabor & employmentbusiness & regulatory

The case involved plaintiff Clarice King suing Nashua Corporation and H.S. Crocker for personal injury allegedly caused by a product linked to 'meat wrappers' asthma.' The court had previously granted motions to dismiss, and the plaintiff sought reconsideration. The court denied the motion, holding that the claims were barred by the applicable statutes of limitations. Illinois' two-year limit applied to the amended complaint filed in 1982, and the Missouri five-year limit under § 516.120 also barred the action because the injury was capable of ascertainment by 1978 when the plaintiff's expert had knowledge of relevant medical articles. The Missouri non-suit and borrowing statutes did not toll or extend the periods under the facts presented.

proceduretorts & liability

This case involved a dispute between Perma Greetings, Inc. and Russ Berrie & Co., Inc. over coaster and mug mat products, with the plaintiff alleging that the defendant had fraudulently misrepresented its intent not to independently produce a product shown to it during joint venture discussions, while also claiming breach of contract and copyright infringement on certain designs. The court granted the defendant's motion for summary judgment in part and denied it in part, dismissing the breach of contract claim because it repeated a prior claim barred by the statute of frauds and dismissing the copyright infringement claim after finding no substantial similarity of expression between the parties' works. It denied summary judgment on the fraudulent misrepresentation and punitive damages claims, as disputed facts existed regarding the alleged promise, its falsity, reliance, and resulting injury. The rulings rested on side-by-side product comparisons showing only unprotected similarities in ideas rather than expression, along with review of pleadings and depositions for material factual disputes.

business & regulatorypropertyprocedure

This case involved two consolidated actions by plaintiffs as general partners of limited partnerships against multiple defendants for breach of contracts to purchase the Wellington Green and Cedar Point apartment complexes. The court had previously entered judgment awarding plaintiffs damages of $474,429 for the Cedar Point contract and $503,746 for the Wellington Green contract, calculated as the difference between the contract prices and the fair market values of the properties on the breach date of June 14, 1979, using expert testimony on present values derived from the contracts. Defendants moved to amend the judgment and findings, primarily challenging the use of present values, the expert's qualifications, and the loan rates considered in valuing the contracts. The court denied the motion, reaffirming that its damage calculations properly relied on fair market value versus contract price and that prejudgment interest was not warranted because the damages were not readily ascertainable from the contracts without court findings based on evidence.

propertybusiness & regulatoryprocedure

The case involved the Metropolitan St. Louis Sewer District challenging the application of Missouri's Hancock Amendment to its federal grant obligations under the Clean Water Act, which required a user charge system for sewage treatment facilities funded by EPA grants. The district court dismissed the complaint, abstaining from deciding the federal constitutional issues because pending state court proceedings could resolve related state law questions and potentially moot the federal claims. The court further reasoned that the Hancock Amendment did not unconstitutionally impair the grant contracts, as those contracts did not mandate bypassing voter approval and the amendment did not alter the contractual terms requiring an approved user charge system.

environmentfederal powerproceduretaxes

In Premachandra v. United States, a federal employee sued the government under the Federal Tort Claims Act after being discharged from his position as a Veterans Administration research endocrinologist. The Merit Systems Protection Board had already reviewed the discharge, reinstated the plaintiff with back pay, and awarded attorney fees, finding the agency's action unfounded. The district court granted the United States' motion to dismiss, holding that it lacked jurisdiction because the comprehensive remedies under the Civil Service Reform Act and the Merit Systems Protection Board procedures are the exclusive means for addressing such federal employment disputes. The court reasoned that Congress intended these specialized remedies to preclude FTCA claims for wrongful discharge of federal workers, with judicial review available instead in the Court of Claims or courts of appeals under 5 U.S.C. § 7703.

labor & employmentfederal powerprocedure

The case involved a construction company, Daniel Construction, seeking to vacate part of an arbitrator's award against a union local for a walkout that violated the no-strike provisions of a project collective bargaining agreement at a nuclear power plant site. The arbitrator found the union had permitted the violation but denied any damages to the company on the ground that it had been fully reimbursed for costs by the site owner under a cost-plus contract and thus suffered no actual loss. The district court granted summary judgment to the union, upholding the award as drawing its essence from the agreement and finding the arbitrator correctly applied contract law principles, including that the collateral source rule does not apply to breach of contract claims. The court also denied the company's request for attorneys' fees.

labor & employmentbusiness & regulatoryprocedure

This case involved trustees of a multiemployer pension plan seeking to collect withdrawal liability payments from a former contributing employer under the Multiemployer Pension Plan Amendments Act (MPPAA) provisions of ERISA. The employer had withdrawn from the plan in August 1980, after the Act's retroactive effective date of April 29, 1980, but before its enactment on September 26, 1980, and refused to pay or arbitrate the assessed liability of over $50,000. The court granted summary judgment to the plaintiffs and denied the defendant's cross-motion, rejecting constitutional challenges. It held that retroactive application of the MPPAA's withdrawal liability rules satisfied Fifth Amendment due process because it was a rational means to achieve the legitimate goal of protecting multiemployer pension plans, and it similarly found no violation of the takings clause or contracts clause.

labor & employmentbusiness & regulatory