Donald J. Stohr

The case involved plaintiff Eric Ringwald's challenge under ERISA to the termination of long-term disability benefits by defendant Prudential Insurance Company of America after 24 months. Ringwald had participated in an employer-sponsored plan through Harrah's Casino that provided benefits for disabilities but included a lifetime limit of 24 months for those caused in whole or part by mental illness, defined to include conditions like depression and bipolar disorder. Prudential initially paid benefits based on Ringwald's claimed disabilities from depression and HIV but discontinued them beyond the 24-month period, citing the mental illness limitation. On the defendant's motion for summary judgment, the court reviewed the administrative record and undisputed facts showing that Ringwald's condition involved mental illness treated by psychiatrists and psychologists. The court granted summary judgment to the defendant, concluding that the limitation applied because the disability was due at least in part to mental illness.

labor & employmenthealthcarebusiness & regulatory

This case was a landlord-tenant dispute in which the plaintiff shopping center owner sued the defendant tenant supermarket after negotiations for an expanded direct lease failed. The plaintiff sought to recover costs incurred in relocating other tenants based on a promissory estoppel claim, alleging reliance on the defendant's promise to enter a new lease. The court granted the defendant's motion for partial summary judgment on that count. The core reasoning was that the plaintiff, as a sophisticated party, could not reasonably rely on any promise without a binding signed lease or indemnification agreement, given explicit language in the letter of intent stating it was non-binding and the inherent risks of failed commercial negotiations between represented entities.

propertybusiness & regulatory

This case involves Lloyd Grass's federal habeas corpus petition challenging Missouri state court rulings on his applications for release from commitment to the Department of Mental Health. Grass had been committed in 1994 after pleading not guilty by reason of mental disease or defect to the 1992 stabbing death of his wife; after an escape and subsequent conviction, he sought unconditional release in 2003 and both conditional and unconditional release in 2004. The state trial court denied unconditional release but granted conditional release, a decision affirmed in part and remanded in part by the Missouri Court of Appeals, with the Missouri Supreme Court declining further review. The federal district court conducted de novo review of the magistrate judge's report recommending denial of habeas relief and addressed whether the state proceedings violated due process or other federal standards in applying Missouri's statutory criteria for release. The court ultimately denied the petition, upholding the state courts' denial of unconditional release.

criminal lawcivil rights

The case involved plaintiff Ricky Moore suing the City of Desloge, its police chief, and an officer under 42 U.S.C. § 1983, claiming that officers forcibly entered his apartment without a warrant based on a tip about drug distribution, conducted a search and seizure, interrogated him without Miranda warnings or counsel, and violated various Fourth, Fifth, and Fourteenth Amendment rights; the underlying criminal charges for drug possession were dismissed after the state court suppressed the evidence. The district court addressed cross-motions for summary judgment, with the plaintiff arguing that the state suppression ruling collaterally estopped the defendants from contesting liability. The court denied the plaintiff's motion and granted summary judgment to the defendants, holding that Missouri collateral estoppel rules did not bar relitigation because the issues decided in the criminal proceeding were not identical to the civil claims, the parties were not in privity, and the defendants lacked a full and fair opportunity to litigate the federal constitutional questions, while undisputed facts showed no constitutional violation occurred during the entry and search.

civil rightscriminal lawprocedure

This case involved a defendant charged with being a felon in possession of a firearm after officers executed arrest warrants at his home, found him hiding in the attic, removed and secured him in a police vehicle, and then reentered the attic to search and seize a handgun and cell phone. The defendant moved to suppress the evidence, arguing that the warrantless search violated the Fourth Amendment once he was no longer present. The court granted the motion to suppress, adopting the magistrate judge's recommendation. The core reasoning was that Arizona v. Gant limited the search-incident-to-arrest exception to situations where the arrestee remains unsecured and within reaching distance or where evidence of the offense might reasonably be found, neither of which applied here after the defendant was handcuffed and removed from the residence.

criminal lawprocedureguns

This case involved former employee Susan E. Poitras suing her employer Glaxo SmithKline Consumer Healthcare, alleging retaliation under the Family and Medical Leave Act following her termination from a manufacturing technician position. The plaintiff had received progressive discipline and was ultimately fired after incidents involving failures to properly verify and document lot numbers of raw materials, in violation of company SOPs and FDA regulations. The court granted the defendant's motion for summary judgment, concluding that the plaintiff failed to show that similarly situated employees were treated more favorably or that the employer's stated reasons for termination were pretextual. The ruling rested on the absence of evidence linking the termination to the plaintiff's FMLA leave beyond temporal proximity, with no genuine issue of material fact regarding retaliatory motive.

labor & employment

Beckon, Inc., a Missouri corporation that repairs industrial machinery, occupied property in Kirkwood without owning or leasing it and obtained a property insurance policy from AMCO Insurance Co. After the property suffered fire damage in March 2007 and wind damage in August 2007, Beckon filed claims that AMCO denied for lack of an insurable interest, though AMCO had advanced over $500,000 toward repairs. Beckon sued for breach of policy and vexatious refusal to pay, and AMCO counterclaimed for declaratory judgment and recoupment. The court granted AMCO summary judgment under Missouri law, ruling that Beckon lacked an insurable interest because it stood to gain no pecuniary benefit or suffer no pecuniary loss from damage to the property, rendering the policy void and entitling AMCO to recover the advances.

propertybusiness & regulatory

The case involved a Dutch company, Interfood Holding, B.V., suing its former president and vice president (Husmann and Rice) along with their new competing dairy business, DF Ingredients, Inc., for false advertising and trademark infringement under the Lanham Act based on alleged misuse of the INTERFOOD trade name and related statements, as well as a state-law breach of fiduciary duty claim. The court granted summary judgment to defendants Husmann and DF Ingredients on the Lanham Act claims (Counts I and II), dismissing them, while denying summary judgment on the fiduciary duty claim (Count III) as to Rice and rejecting Rice's separate summary judgment arguments for lack of compliance with procedural rules. The core reasoning centered on the plaintiff's failure to produce evidence linking Husmann and DF Ingredients to the statements at issue, the descriptive and unprotectable nature of the INTERFOOD mark without secondary meaning, and the application of Federal Rule of Civil Procedure 56 standards requiring the non-movant to show genuine issues of material fact after the movant meets its initial burden.

business & regulatoryprocedure

The case concerns a breach of contract dispute arising from a 2000 asset purchase agreement between Ferro Corporation and Solutia Inc. under which Solutia was obligated to use commercially reasonable efforts to subdivide and convey certain New Jersey real properties, including the Uplands Property and Riparian Property, or alternatively to modify a lease to a 99-year term if subdivision did not occur by June 30, 2001. Solutia obtained subdivision approvals in 2000 and 2002 but allowed both to lapse without recording, later filed for bankruptcy, and never transferred title to the properties. Ferro sued, and Solutia moved to dismiss for failure to state a claim. The court applied the Rule 12(b)(6) standard, reviewed the agreement's terms, and concluded that conveyance of the Riparian Property was expressly conditioned on completion of the Uplands subdivision.

business & regulatorypropertyprocedure

This case involves a Dutch company suing its former U.S. executives and a competing dairy business for trademark infringement and wrongful use of a domain name after the defendants allegedly formed a rival company and used similar marks. The plaintiff sought a preliminary injunction to halt use of its INTERFOOD name, Green Triangle logo, and the interfood.us domain. The court denied most of the requested relief, concluding that the marks appeared descriptive rather than inherently distinctive and that the plaintiff had not shown a likelihood of success or irreparable harm on the trademark claims. It granted a limited injunction requiring inactivation of the interfood.us domain name, based on a finding of likely bad faith intent to profit from and disparage the plaintiff's mark under the Lanham Act, along with favorable balancing of other Dataphase factors.

business & regulatoryprocedure

In Bradley v. Transportation Security Administration, pro se plaintiff Lee Bradley sued the TSA after jewelry and a table cover went missing from his checked luggage following a TSA search, claiming a TSA agent had taken the items under a conversion theory pursuant to the FTCA. The court reviewed the defendant's motion to dismiss or for summary judgment, liberally construing the pro se complaint but requiring specific facts to support the claims. The court granted the motion, concluding that TSA lacked exclusive control over the luggage and that the plaintiff failed to present evidence meeting the elements of conversion, particularly that a TSA agent took possession, given access by airline staff and others.

torts & liabilityprocedurefederal power

This case involves plaintiffs Cox Industrial Equipment Company, Inc. and Stephen Cox suing defendants Angela Smiley, Michael Smiley, and John Smiley for allegedly diverting funds from plaintiffs' bank account intended for tax payments, using their payroll services company American Payroll Systems. Plaintiffs asserted claims under the Racketeer Influenced and Corrupt Organizations Act (RICO), as well as state law claims for breach of contract, breach of fiduciary duty, and fraud. The U.S. District Court for the Eastern District of Missouri denied the defendants' motion to dismiss, holding that the individual defendants are distinct from the corporate enterprise for RICO purposes based on Supreme Court precedent in Cedric Kushner Promotions v. King. The court also found that the complaint sufficiently alleged personal liability and grounds for piercing the corporate veil to support the state law claims against the individual defendants.

criminal lawbusiness & regulatory

St. Charles County, Missouri, sued the State of Wisconsin in federal court to recover approximately $5,421 in costs for housing and medically treating a fugitive whom Wisconsin extradited under the Federal Extradition Act. The County argued that 18 U.S.C. § 3195 required the demanding state to pay those expenses and sought both damages and prospective injunctive relief. The district court granted Wisconsin's motion for judgment on the pleadings. It held that the statute creates no private right of action allowing a county to sue another state and that the Eleventh Amendment bars the action because Congress did not unequivocally abrogate state sovereign immunity in the Act; the court further ruled that Ex parte Young does not permit the requested injunctive relief against the state itself.

criminal lawfederal power

In this case, plaintiff Jerry Hummel sued the City of Montgomery, Missouri, after the city threatened to terminate his utility service if his adult son moved into his home, based on the son's unpaid utility bills from a prior residence under local ordinances. The plaintiff filed in state court, invoking a right to freedom of association, and the city removed the action to federal court. The plaintiff then moved to remand, arguing a lack of federal jurisdiction. The court granted the remand, holding that the complaint did not clearly present a federal question on its face because the Missouri Constitution also protects freedom of association, so federal law was not an essential element of the claim.

civil rightsfederal powerprocedure

This case involved Glasgow Enterprises, Inc., which purchased property at a St. Louis County tax sale in 2002 and sought to quiet title against prior liens, including a federal tax lien filed by the IRS in 1996 for unpaid employment taxes owed by the previous owner. The Small Business Administration disclaimed any interest and was dismissed from the suit. The court granted summary judgment to the IRS, holding that the federal tax lien survived the sale because the plaintiff failed to provide the IRS with proper notice under 26 U.S.C. § 7425, as the attempted notification was sent to an incorrect address and did not comply with statutory and regulatory requirements for timing and delivery. The core reasoning was that without adequate presale notice to the government, the tax lien is not discharged and remains attached to the property.

taxespropertyprocedure

In McGee v. Reliance Standard Life Ins. Co., plaintiff Robert McGee, a vice president at HASCO International, sued under ERISA after Reliance Standard terminated his long-term disability benefits for major affective disorder and anxiety, which it had initially approved following short-term benefits. The U.S. District Court for the Eastern District of Missouri granted summary judgment to McGee, awarding $71,663.72 in past benefits, and denied the insurer's cross-motion. The court reasoned that the medical evidence from treating psychiatrist Dr. Canale and psychologist Kelly, including GAF scores and impairment ratings showing serious functional limitations, supported ongoing total disability under the policy's "regular occupation" standard, while Reliance's internal reviews and termination lacked justification or evidence of changed circumstances. The decision emphasized that the records did not support a finding that McGee could return to work after May 2000.

labor & employmenthealthcare

In this employment discrimination case, a former flight attendant sued her airline employer under the Americans with Disabilities Act, claiming in Count V that the defendant failed to provide reasonable accommodations for her physical limitations. The defendant moved to dismiss that count, arguing the plaintiff had not exhausted her administrative remedies because her EEOC charge of discrimination did not allege disability discrimination. The court granted the motion, holding that the charge addressed only race, color, sex, religion, national origin, and retaliation, and made no assertion of an actual disability or request for accommodations; it further noted that claims based on being "regarded as" disabled do not require accommodations under Eighth Circuit precedent. The court declined to consider the plaintiff's intake questionnaire as part of the charge and found the allegations in the complaint were not like or reasonably related to those in the charge.

civil rightslabor & employmentprocedure

In Johnson v. Berry, plaintiff Johnnie Johnson, a former pianist in Chuck Berry's band, sued Berry and his music publishing company seeking a declaratory judgment that he was a co-owner of copyrights in 33 songs from 1955-1966, an accounting of profits, and damages for alleged breaches of fiduciary duty and fraud based on claims that he was a co-creator whose rights were concealed. The U.S. District Court for the Eastern District of Missouri granted the defendants' motion for summary judgment on all five counts. The court held that the copyright claims were barred by the three-year statute of limitations under 17 U.S.C. § 507(b), which begins to run when a plaintiff knows or has reason to know of the injury; Johnson's arguments for delayed accrual due to mental competence or recent discovery were insufficient to overcome the time bar on the record evidence. Related state-law claims for breach of fiduciary duty and fraud were similarly dismissed as untimely under applicable Missouri statutes of limitations.

propertyprocedure

This case involves an appeal from bankruptcy court orders dismissing a creditor's adversary proceeding objecting to discharge of a multimillion-dollar judgment debt and granting the debtor a discharge. The district court reversed both orders, concluding that the bankruptcy court abused its discretion by dismissing the proceeding with prejudice as a sanction for the creditor's nonappearance at a deposition. The reasoning centered on the creditor's unrebutted declaration establishing lack of personal knowledge of relevant facts, an uncontradicted medical excuse related to cancer surgery, and the absence of any showing of prejudice to the debtor from the lack of deposition testimony.

procedurebusiness & regulatory

In this case, Monsanto Technology LLC and Monsanto Company sued Syngenta Crop Protection, Inc. in the Eastern District of Missouri for false advertising, trademark infringement, unfair competition, and related claims under federal and Missouri law, alleging misleading statements in Syngenta's Touchdown herbicide promotions about comparative efficacy with Monsanto's Roundup products. Syngenta moved to transfer the case to Delaware, where it had filed an earlier parallel action against Monsanto raising similar advertising and disparagement claims involving the same competing herbicides. The court granted the transfer motion under the first-filed rule, finding substantial overlap in the core issues of herbicide performance and supporting evidence that would likely cause duplicative discovery and risk inconsistent rulings if the cases proceeded separately; after weighing convenience factors for parties, witnesses, and documents, the balance did not outweigh application of the rule. The court denied Syngenta's alternative requests to dismiss or stay the action.

business & regulatoryprocedure