Justia Injury Law Opinion Summaries

Mario Mancini, an inmate at FCI Sandstone, sued the United States under the Federal Tort Claims Act (FTCA) for medical malpractice. Mancini alleged that the government caused him permanent injury by negligently delaying necessary medical care. He experienced neck and back pain from a prior workplace injury, which worsened in 2017. Despite reporting increasing pain and numbness, his MRI and subsequent surgery were delayed. Mancini claimed these delays resulted in permanent nerve damage, loss of strength, muscle atrophy, numbness, and pain.The United States District Court for the District of Minnesota dismissed Mancini's FTCA claim. The court found that Mancini's expert affidavit, provided by Dr. Gary Wyard, failed to meet the requirements of Minn. Stat. § 145.682. The affidavit did not adequately define the standard of care, explain how the government deviated from that standard, or establish a causal connection between the delays and Mancini's injuries. The court also excluded Dr. Wyard's testimony under Rule 702 and Daubert, citing factual errors and a lack of methodology in his affidavit.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that Dr. Wyard's affidavit did not satisfy the statutory requirements of Minn. Stat. § 145.682. The affidavit lacked specific details about the standard of care and failed to outline a chain of causation between the government's actions and Mancini's injuries. The court also upheld the exclusion of Dr. Wyard's testimony under Rule 702 and Daubert. The court concluded that the district court did not abuse its discretion in dismissing the case with prejudice, as Mancini did not correct the deficiencies in the affidavit within the provided safe-harbor period. View "Mancini v. United States" on Justia Law

Jeremy James Allen, while incarcerated at the Minnesota Correctional Facility in Faribault, filed a complaint against several officials alleging deliberate indifference and medical malpractice related to a hand injury from December 2017. He did not file any grievances with prison officials regarding his injury or medical treatment during his incarceration. Allen's complaint was initially filed in state court and later removed to federal court. After his release from custody, Allen amended his complaint, substituting Charles Brooks and Cheryl Piepho for previously unidentified defendants.The United States District Court for the District of Minnesota granted Allen's unopposed motion to amend his complaint after his release. The defendants moved to dismiss the complaint for lack of subject matter jurisdiction and failure to state a claim, but did not initially raise the issue of exhaustion of administrative remedies. The district court denied the motion to dismiss on qualified immunity grounds, finding that Allen plausibly alleged a violation of his Eighth Amendment right to adequate medical care.Brooks and Piepho later raised the failure to exhaust defense in a summary judgment motion, arguing that Allen's original complaint, filed while he was incarcerated, was subject to the Prison Litigation Reform Act (PLRA) exhaustion requirement. The district court denied their motion, ruling that the amended complaint, filed after Allen's release, was not subject to the PLRA's exhaustion requirement and did not relate back to the original complaint under Federal Rule of Civil Procedure 15(c).The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The court held that Allen's amended complaint, filed after his release, was the operative complaint and not subject to the PLRA's exhaustion requirement. Additionally, the court found that the amended complaint did not relate back to the original complaint because naming John and Jane Doe defendants did not qualify as a "mistake" under Rule 15(c). View "Allen v. Brooks" on Justia Law

Sandra Jones, representing the estate of her deceased son Antonio Jones, filed a lawsuit under 42 U.S.C. § 1983 and Arkansas state law against Faulkner County, Arkansas, and jail officials Garry Stewart, Karen Grant, and Leanne Dixon. She claimed that the officials exhibited deliberate indifference to Antonio’s serious medical needs, violating his Fourteenth Amendment rights, and that Stewart committed medical malpractice. Jones also alleged that Faulkner County’s policies contributed to Antonio’s death.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. The court found that the jail officials were not deliberately indifferent to Antonio’s medical needs and that Jones could not establish a medical malpractice claim against Stewart due to the absence of a doctor-patient relationship. The court also dismissed the municipal liability claim against Faulkner County, concluding that no jail policy caused Antonio’s death.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the actions taken by Grant and Dixon did not constitute deliberate indifference. Grant responded to Antonio’s symptoms by placing him on a medical watch and took appropriate actions based on the information available to her at the time. Dixon, who was not a medical professional, followed her superior’s instructions and did not disregard any substantial risk of harm. The court also affirmed the dismissal of the municipal liability claim, as there was no constitutional violation by the county employees. Lastly, the court found no abuse of discretion in the district court’s exercise of supplemental jurisdiction over the state law claim against Stewart. View "Jones v. Faulkner County, Arkansas" on Justia Law

Judy Brown, a biracial woman, was hired by Conagra Brands, Inc. in October 1997. After a workplace injury in 2015, she became disabled and filed a workers' compensation claim in 2017. Conagra temporarily transferred her to a different position as an accommodation and continued paying her at the higher rate until July 2020, when her work restrictions became permanent, and her pay was reduced. Following the death of a colleague, Conagra posted job openings, and Brown applied for a position but was not selected. She was assigned to less favorable shifts and subsequently filed discrimination charges. Brown was fired in December 2021 and sued Conagra, alleging race and disability discrimination, retaliation, and violation of Nebraska common law.The United States District Court for the District of Nebraska granted Conagra’s motion to dismiss for failure to state a claim. Brown did not challenge the district court’s finding that her race and disability discrimination claims based on the July 2020 pay reduction were time-barred.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The court affirmed the dismissal, finding that Brown failed to plead sufficient facts to support her claims. Specifically, she did not provide enough details to infer race discrimination, did not plausibly allege a disability under the ADA or NFEPA, and did not establish a causal connection for her retaliation claims. Additionally, the court found that Brown did not state a plausible claim for common law unlawful retaliation, as she did not allege any immediate precipitating events or facts that could infer a causal nexus between her workers' compensation claim and the adverse employment actions. View "Brown v. Conagra Brands, Inc." on Justia Law

Vernon Holland was fatally injured by a rewinder machine at his workplace. Robert Cearley, Jr., representing Holland’s estate, filed a wrongful death lawsuit against Bobst Group North America, Inc. (Bobst NA), the company responsible for delivering and installing the rewinder. The lawsuit sought damages based on several tort claims.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of Bobst NA. The court ruled that Arkansas’s statute of repose, which limits the time frame for bringing claims related to construction or design defects, barred Cearley’s claims. Cearley appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court examined whether Bobst NA was protected under Arkansas Code § 16-56-112(b)(1), which is a statute of repose for claims arising from personal injury or wrongful death caused by construction defects. The court concluded that Bobst NA’s involvement in the delivery, installation, integration, and commissioning of the rewinder constituted the construction of an improvement to real property. The court also determined that the rewinder was an improvement to real property because it was affixed to the plant, furthered the purpose of the realty, and was designed for long-term use.As the lawsuit was filed more than four years after the installation of the rewinder, the court held that the claims were barred by the statute of repose. Consequently, the Eighth Circuit affirmed the district court’s judgment in favor of Bobst NA. View "Cearley v. Bobst Group North America Inc." on Justia Law

Devin Nunes, a former Member of Congress, along with NuStar Farms, LLC, and its owners, sued journalist Ryan Lizza and Hearst Magazine Media, Inc., for defamation. The lawsuit stemmed from an article published by Esquire, which implied that Nunes and his family were hiding the fact that NuStar Farms employed undocumented labor. The plaintiffs alleged both express defamation and defamation by implication.The United States District Court for the Northern District of Iowa initially dismissed Nunes's express defamation claim but allowed the defamation by implication claim to proceed. On remand, Nunes filed an amended complaint focusing solely on defamation by implication. NuStar Farms and its owners also filed a new lawsuit alleging both express defamation and defamation by implication. The district court consolidated the cases and ultimately granted summary judgment for the defendants, ruling that the plaintiffs failed to create a genuine dispute of material fact on certain elements of their defamation claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court concluded that Nunes did not present sufficient evidence to prove special damages, which are required under California law for defamation claims when general and exemplary damages are not recoverable due to failure to comply with the notice and demand statute. Nunes's claims of impaired career opportunities and diminished fundraising ability were unsupported by evidence.For the NuStar plaintiffs, the court applied Iowa law and found insufficient evidence of economic harm or reputational damage. The plaintiffs failed to demonstrate a preexisting good reputation that could have been damaged by the article. Consequently, the Eighth Circuit affirmed the district court's summary judgment in favor of the defendants. View "Nunes v. Ryan" on Justia Law

Plaintiffs filed suit in state court against defendants, alleging claims of defamation, invasion of privacy, and intentional and negligent infliction of emotional distress. Plaintiff alleged that defendants published false information to discredit and humiliate him in retaliation for his public allegations that he was sexually abused by priests. On appeal, plaintiff challenged the district court's orders denying plaintiff's motion for remand and dismissing his causes of action for failure to state a claim. The court agreed with defendants that Missouri Defendants McLiney and O'Laughlin were fraudulently joined; Defendants KCCL sufficiently consented to removal; and thus the court affirmed the denial of plaintiff's motion for remand. The court also affirmed the district court's dismissal of plaintiff's defamation claim as time-barred under Missouri's borrowing statute. Because plaintiff alleged that false statements injured his reputation, defamation, not invasion of privacy, was in fact the basis of his cause of action. Therefore, the court affirmed the district court's dismissal of plaintiff's invasion of privacy claim. Finally, the court affirmed the dismissal of plaintiff's claims for intentional infliction of emotional distress and negligent infliction of emotional distress. View "Couzens, Jr. v. Donohue" on Justia Law

Plaintiffs filed suit against BNSF for the deaths of two BNSF employees. Plaintiffs' suit arises under the Federal Employers' Liability Act (FELA), 45 U.S.C. 51 et seq. The jury found in favor of plaintiffs and the district court subsequently denied BNSF's motion to alter or amend the judgment based on an agreement that plaintiffs had entered with BNSF prior to trial. BNSF moved the district court to enter judgment as a matter of law (JMOL) based on plaintiffs' failure to offer any evidence that BNSF should have or could have foreseen the conduct that caused the harm, and plaintiffs' failure to offer any expert testimony to establish the standard of care applicable to BNSF for crew calls and train movements. The court concluded that it has no basis to review BNSF's foreseeability argument because it challenges the sufficiency of the evidence and was not renewed in a Rule 50(b) motion; BNSF was required to, but did not, renew in a Rule 50(b) motion its contention that lay testimony was insufficient to establish a standard of care and that expert testimony was required; the court rejected BNSF's claims of evidentiary errors; and the district court did not abuse its discretion in denying BNSF's motion to alter or amend the judgment pursuant to Rule 59(e) where the district court found that the agreement that was the basis for BNSF's claimed setoff was collateral to the merits of plaintiffs' FELA action. Accordingly, the court affirmed the judgment. View "Burckhard v. BNSF Railway Co." on Justia Law

After a federal employee injured plaintiff in a car accident, plaintiff filed suit against the United States under the Federal Tort Claims Act (FTCA), 28 U.S.C. 1346(b)(1). The district court found the government 100% at fault, but 20% liable for plaintiff's injury. Under Carlson v. K-Mart Corp., the Missouri standard of an award for “directly caused or directly contributed to cause” means that the jury can determine that damages suffered solely due to a pre-existing condition were “neither caused nor contributed to by” a collision. Based on the evidence here, the district court found the collision contributed to only 20% of plaintiff's need for shoulder surgery. Plaintiff's own orthopedic surgeon opined that imaging indicated advanced degeneration that developed over time and did not result from the traumatic injury - even if the collision triggered symptoms in the left shoulder. Therefore, the court concluded that the district court did not err in concluding that, under Missouri law, it could find 80% of the damages attributable to an unrelated pre-existing condition and 20% of the damages attributable to the aggravation caused by the collision. Finally, the court rejected plaintiff's arguments that the district court erred in reducing by 80% both the medical expense and pain and suffering awards. Accordingly, the court affirmed the judgment. View "Lockhart v. United States" on Justia Law

Plaintiff filed suit against Principia, alleging claims arising from events that occurred during plaintiff's time as a student at Principia. The district court granted Principia's motion to dismiss. The court held that plaintiff failed to state a claim for breach of contract because none of the policies and provisions that she identifies in her Third Amended Complaint create obligations that Principia owed to plaintiff; the district court did not err in dismissing plaintiff's intentional infliction of emotional distress (IIED) claim where the allegations set forth in plaintiff's complaint detail, at most, insults, indignities, threats, annoyances, petty oppressions, or other trivialities to which liability for IIED clearly does not extend; and the district court properly dismissed the negligent infliction of emotional distress claim (NIED) where, under Missouri law, plaintiff failed to allege that her emotional distress or mental injury is medically diagnosable. Accordingly, the court affirmed the judgment. View "Gillis v. The Principia Corp." on Justia Law