Scott Olin Wright

In Downey v. Hartford Life Group Insurance, plaintiff Michael Downey sued Hartford under ERISA after it terminated his long-term disability benefits following an initial 24-month period, claiming he no longer met the plan's "any occupation" standard for disability. Hartford, acting as both plan administrator and insurer, based its decision on medical opinions from treating physicians and an independent reviewer indicating Downey could perform sedentary to light work. The court granted summary judgment to Hartford, holding that the denial was reasonable and supported by substantial evidence in the record, including assessments that did not list medication side effects as work limitations, even though one physician and the Social Security Administration reached a different conclusion.

labor & employmenthealthcare

This case involved two plaintiffs seeking judicial review under the Administrative Procedure Act of the Department of Education's denial of their applications for discharge of federally guaranteed student loans based on disability. The plaintiffs argued that the agency violated their procedural due process rights by failing to provide adequate notice of the reasons for denial, an opportunity to submit additional evidence, or guidance on what evidence was needed. The court treated the parties' cross-motions as requests for judgment on the stipulated administrative record under Federal Rule of Civil Procedure 52. It held that the Department of Education's process denied the plaintiffs due process and therefore granted the plaintiffs' motion, denied the defendant's motion, and remanded the matter to the agency for further administrative proceedings without reaching the arbitrary-and-capricious claim.

procedurefederal power

This case concerned a dispute over life insurance benefits following the death of Johnny West from glioblastoma multiforme. His wife, plaintiff Ronia West, sought payment under a policy issued by defendant Wilton Reassurance Life Company of New York, but the insurer had rescinded the policy after discovering that Mr. West answered "NO" to a question about recent hospitalization on his application, even though he was in the hospital at the time for symptoms that led to his brain tumor diagnosis. The court granted the defendant's motion for summary judgment, holding that the misrepresentation was material because Wilton would not have issued the policy if the question had been answered truthfully and because the hospitalization was directly related to the condition that caused Mr. West's death. The decision rested on undisputed facts showing the timing of the hospitalization and the insurer's underwriting process, as well as Missouri law defining materiality in insurance applications.

business & regulatoryprocedure

The case involved defendant Robert Joseph Smart, who was found incompetent to stand trial due to mental illness and refused antipsychotic medication. The government sought court authorization for forcible medication to restore his competency for trial, pursuant to Sell v. United States. The court denied the motion for involuntary medication, determining that the government's interest in prosecution did not sufficiently outweigh the defendant's liberty interest in refusing treatment. Instead, the defendant was committed for a psychiatric evaluation to assess whether civil commitment under 18 U.S.C. § 4246 was appropriate due to potential danger to others. This decision followed recommendations from the defendant's treatment team and an evidentiary hearing.

criminal lawcivil rights

This case involved a challenge by the Sierra Club against the U.S. Army Corps of Engineers' decision to prepare an Environmental Assessment rather than a full Environmental Impact Statement for a proposed levee project on the Missouri River near Jefferson City, Missouri, under the National Environmental Policy Act (NEPA) and the Administrative Procedure Act. The court granted summary judgment in favor of the Sierra Club on claims that the Corps failed to adequately consider the cumulative impacts of the levee combined with existing flood control structures on flood heights, finding this omission arbitrary and capricious. However, the court denied summary judgment and ruled for the defendants on the adequacy of the Corps' evaluation of secondary impacts from potential development. The core reasoning centered on the Corps' failure to account for the broader effects of adding the new levee to the extensive existing modifications along the river, while determining that the analysis of development effects was sufficient.

environmentfederal power

This case involved an insurance company's declaratory judgment action under the Federal Declaratory Judgment Act seeking a ruling that its policy's criminal act exclusion precluded any duty to defend or indemnify a doctor in underlying state court claims brought by defendant Kelly Pope. Following an Eighth Circuit reversal of an initial no-coverage ruling and remand, this court granted summary judgment requiring coverage. On the defendants' motions, the court granted attorney fees and costs for the district court proceedings, reasoning that Missouri law permits equitable awards of such fees in declaratory judgment actions under unusual circumstances where the suit is collateral to successful underlying claims, but it denied fees for the pending appeal and an appeal bond.

business & regulatoryprocedure

In this case, plaintiff Natalie Rector sued her former employer Cheryl Kelly and State Farm Mutual Automobile Insurance Company, alleging gender and pregnancy discrimination and a hostile work environment under Title VII. The court granted Kelly's motion to dismiss and State Farm's motion to dismiss or for summary judgment. It held that Kelly could not be liable in her individual capacity because individuals are not employers under Title VII, and her company never employed fifteen or more people as required by the statute. The court further held that State Farm was not Rector's employer, based on the parties' agreement stating she was not a State Farm employee and the absence of evidence that State Farm and Kelly operated as an integrated enterprise.

labor & employmentcivil rights

This case involved a challenge by plaintiff Karen Everett to the termination of her long-term disability benefits under an ERISA-governed employee welfare benefit plan sponsored by her employer Wal-Mart and insured by defendant Hartford Life and Accident Insurance Company. After initially paying benefits for about 18 months following a six-month elimination period, Hartford terminated them based on an employability analysis report and medical reviews by consulting physicians concluding that Everett could perform full-time sedentary work despite her urological and knee conditions. The court granted Hartford's motion for summary judgment and denied Everett's, applying an abuse-of-discretion standard due to the plan's grant of discretionary authority to the administrator and finding the termination supported by substantial evidence from the reports and physician opinions, including input from her treating specialists. The court rejected Everett's procedural arguments about review of reports and consultation with her primary care physician, noting she did not challenge the substance of the medical conclusions or show prejudice.

labor & employmenthealthcare

This case involved a constitutional challenge by Reproductive Health Services of Planned Parenthood and a physician to the Missouri Infant’s Protection Act, a state law that criminalized causing the death of a partially born or born infant through an overt act and defined procedures such as intact dilation and extraction as felonies. The U.S. District Court granted the plaintiffs’ motion for summary judgment and permanently enjoined enforcement of the Act. The court’s decision rested on the U.S. Supreme Court’s ruling in Stenberg v. Carhart, which held that a statute banning such abortion procedures is unconstitutional if it lacks an exception to preserve the health of the mother. The Missouri law contained only a life exception and no health exception, and state court interpretations confirmed that it applied to the banned procedures without providing for maternal health. The federal court therefore concluded that the statute violated the Constitution under controlling precedent.

abortion

This case involved plaintiff Dayco Products suing defendant Total Containment for infringement of several patents related to hose constructions and couplings. After a prior appeal and remand, the parties filed cross-motions for summary judgment on literal infringement, unenforceability due to inequitable conduct before the PTO, and invalidity under 35 U.S.C. §§ 102 and 103. The court denied Dayco's motion and granted TCI's motions, finding the patents unenforceable because Dayco had intentionally withheld material prior art references and information about a co-pending application from the examiner. The court also held the patents invalid under § 102 because prior art references such as the Lusher and Titeflex patents anticipated the claimed inventions by disclosing the same hose-coupling structures and fluid seals.

business & regulatory

This case involves two companion lawsuits brought by former employees Tiffany Jarred and Patricia Silver against Walters Industrial Electronics, Inc., alleging sex discrimination, hostile work environment, and constructive discharge under Title VII of the Civil Rights Act of 1964. The defendant moved to dismiss for lack of subject matter jurisdiction, arguing that it did not meet Title VII's definition of an employer because it had fewer than 15 employees. The plaintiffs countered that Walters and a related company, Test & Measurement, Inc., should be treated as a single employer to satisfy the statutory numerosity requirement. The court denied the motions, finding that the two entities were sufficiently integrated to count as one employer under Title VII and that the related entity had received adequate notice of the claims through an identity of interest with the named defendant.

civil rightslabor & employmentprocedure

This case under the Fair Housing Act arose from a 1997 cross-burning on the lawn of a non-white tenant and her children in Rushville, Missouri, which prompted HUD to issue a discrimination charge; the United States then filed a civil action after the defendants elected court proceedings over an administrative hearing. The court granted the government's motion for default judgment against defendant Ted Fenton and for summary judgment against defendants Dennis Pospisil and Barney Pospisil, while denying Barney Pospisil's cross-motion for summary judgment. The core reasoning was that the defendants' prior criminal convictions for conspiracy and related offenses established the elements of a violation of 42 U.S.C. § 3617 by estoppel, including racially motivated interference with housing rights, and that the single-family home exemption did not apply to the defendants.

civil rightscriminal law

In United States v. Chavez, the defendant was charged with possession with intent to distribute cocaine and conspiracy after being arrested at a Kansas City bus station, where officers found drugs in her and a co-defendant's luggage. She moved to suppress her statements and the evidence, arguing lack of probable cause for arrest, failure to provide Miranda warnings, coercion, and lack of consent to the search. The magistrate judge recommended denial after a hearing, finding that officers had probable cause based on the women's nervous behavior, one-way cash tickets from a drug-source area, and the co-defendant's consent; that Miranda warnings were given in Spanish before questioning; that there was no evidence of intimidation; and that consent to search was voluntary. The district judge adopted the recommendation without further comment and denied the motion to suppress.

criminal lawprocedure

Wanda J. Ingram, a pro se plaintiff and African-American woman over age 50, sued her employer the VA Medical Center alleging a hostile work environment based on age, race, and sex under Title VII that led to her constructive discharge after incidents with supervisor Chaplain Summers. The court granted the defendant's motion for summary judgment. It reasoned that the described incidents failed to show a causal nexus between the harassment and Ingram's protected characteristics, and that the VA's prompt transfer of Ingram to another department with no further contact with Summers rendered her resignation one month later unreasonable as a constructive discharge.

civil rightslabor & employment

In this case, a former city employee sued the City of Archie, its mayor, city clerk, and board of aldermen, alleging that she was denied a substantial raise because of her gender in violation of the Missouri Human Rights Act and 42 U.S.C. § 1983. The defendants moved to dismiss several counts, arguing legislative immunity for the aldermen and mayor, lack of action under color of state law, redundant official-capacity claims, and that punitive damages were unavailable against a municipality. The court granted the motions in part and denied them in part, holding that the raise decisions were administrative rather than legislative acts because they singled out specific individuals, that the mayor could be sued under § 1983, that official-capacity claims against individuals were redundant, and that the MHRA permits punitive damages against municipal employers based on the statute's plain language. The core reasoning relied on precedents distinguishing legislative from administrative acts and on the absence of any statutory exemption for municipalities from punitive damages.

labor & employmentcivil rights

The case involved a plaintiff suing Habitat for Humanity under 42 U.S.C. § 1981, alleging discriminatory employment policies and practices affecting the terms and conditions of his employment. The defendant moved to dismiss, arguing that the complaint failed to plead a contract and that an at-will employee lacks the contractual relationship required for a § 1981 claim. The court denied the motion, reasoning that notice pleading standards were met and that at-will employment constitutes a contractual relationship under the ordinary meaning of "contract" as expanded by the 1991 Civil Rights Act amendments, which cover terms and conditions of employment. The court also declined to certify the order for interlocutory appeal, finding it would not materially advance the litigation.

civil rightslabor & employmentprocedure

The case involves plaintiffs Melissa and Tim Lancaster suing Sheffler Enterprises (doing business as McDonald's) for alleged sexual harassment experienced by Melissa during her employment, with claims under Title VII, the Missouri Human Rights Act, intentional infliction of emotional distress, and loss of consortium. The defendants moved for summary judgment, arguing that the conduct was not egregious enough to create a hostile work environment, that injuries were undiagnosable or pre-existing, that the employer lacked notice under Faragher and Burlington defenses, and that the husband's claim was derivative. The court denied the motion, holding that genuine issues of material fact existed on all points when viewing evidence in the light most favorable to the plaintiffs, including references to severe comments, medical opinions linking harm to the workplace, inadequate policy enforcement, and supervisory knowledge of complaints.

labor & employmentcivil rights

This case involves plaintiffs, trustees of a testamentary trust created in 1966, challenging the IRS assessment of a generation-skipping transfer tax on assets distributed to the settlor's grandchildren after the beneficiary exercised a general power of appointment in her 1993 will. The court granted summary judgment to the United States and denied the plaintiffs' motion, upholding the tax of $47,391 plus interest. The core reasoning was that the transfer qualified as a direct skip under IRC sections 2611, 2612, and 2601, and it did not fall under the grandfather provision of TRA 1986 section 1433(b)(2)(A) because that provision protects only transfers from irrevocable pre-1985 trusts to the extent they avoid post-1985 corpus additions, and the post-1985 exercise of the power here triggered the tax without qualifying for exclusion.

taxes

This case concerned a plaintiff's motion to remand a lawsuit against Quaker Oats Company back to state court, based on the defendant's alleged delay in removing the action to federal court. The plaintiff had mailed a copy of the petition in March 1998 and contacted defense counsel in April, but the defendant asserted it was formally served only on May 28 and removed the case on June 22. The court denied the motion to remand. It held that under Eighth Circuit precedent interpreting 28 U.S.C. § 1446(b), the 30-day removal period starts only upon actual service of process rather than informal receipt of the pleading, as requiring formal service prevents plaintiffs from circumventing proper procedures.

procedure

This case is a patent infringement dispute in which Rival alleged that Sunbeam's steam cooking appliance infringed multiple claims of Rival's U.S. Patent No. 4,509,412 relating to a steam utensil with a boiling reservoir, heater, thermostat, condensate trough, and food tray features. After a Markman hearing to construe the disputed claim terms using intrinsic evidence, the court compared the construed claims to Sunbeam's device covered by U.S. Patent No. 5,400,701. The court granted Sunbeam's motion for summary judgment and denied Rival's, concluding that Sunbeam's product did not infringe the asserted claims either literally or under the doctrine of equivalents. The ruling rested on the legal determination of claim scope and the absence of matching elements in the accused device.

business & regulatoryproperty