Justia Transportation Law Opinion Summaries

Articles Posted in US Court of Appeals for the Eighth Circuit
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The Eighth Circuit affirmed the district court's judgment in favor of defendants, holding that plaintiffs were not entitled to equitable tolling on their claims under the Driver's Privacy Protection Act. The court held that no extraordinary circumstances prevented plaintiffs from pursuing their rights and therefore violations of the Act that occurred before September 15, 2009 were untimely. In this case, plaintiffs' confusion over the scope of a Driver and Vehicle Services audit was insufficient to warrant equitable tolling. View "Kampschroer v. Anoka County" on Justia Law

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Plaintiff appealed an adverse jury verdict on his retaliation claims under the Federal Railroad Safety Act, challenging the jury instructions. The Eighth Circuit agreed with plaintiff that the jury instructions misstated the "honestly held belief" defense in the context of the Act's contributing-factor standard, and misallocated and misstated the burden of proof. The court explained that the plaintiff bears the burden of proving that intentional retaliation in response to protected conduct served as a contributing factor in an adverse employment action, and the defendant then bears the burden of proving an affirmative defense. In this case, the "honestly held belief" instruction failed to reference the contributing-factor standard and the instructions as a whole expressly incorporated this defense into plaintiff's case. Therefore, this failure to allocate the burden of proof to BNSF and to identify that burden of proof as clear and convincing evidence constituted prejudicial error. Accordingly, the court reversed the district court's judgment and remanded for further proceedings. View "Blackorby v. BNSF Railway Co." on Justia Law

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Plaintiff filed suit against the police chief, the city, and other public officials, alleging violations of the Driver's Privacy Protection Act (DPPA). After the police chief admitted liability for six violations of the Act, the jury awarded plaintiff punitive damages. The district court ruled that plaintiff failed to present sufficient evidence that the city was directly liable for the violations, but authorized the jury's finding that the city was vicariously liable for the police chief's actions. The Eighth Circuit affirmed and held that the district court did not abuse its discretion by ruling that plaintiff's proposed class failed to satisfy the numerosity requirement of Federal Rule of Civil Procedure 23(a) and the predominance requirement of Rule 23(b)(3); the district court properly refused to entertain direct liability against the city where the police chief acted for personal reasons, not under the auspices of official policymaking authority, and thus his actions did not represent a policy of the city; the district court correctly construed the civil action provisions of the Act to incorporate background tort-related rules of vicarious liability; the district court did not abuse its discretion in excluding certain evidence at trial; and the district court did not err in declining to award requested costs. The court rejected plaintiff's remaining claims and denied the city's motion to strike portions of plaintiff's appendix and brief. View "Orduno v. Pietrzak" on Justia Law

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The Eighth Circuit affirmed the district court's denial of plaintiff's request for declaratory and injunctive relief, seeking a ruling that the Missouri State Highway Patrol is forbidden to stop and inspect his 54,000-pound dump truck, used in furtherance of his private commercial venture, without probable cause. The court held that plaintiff is a member of the closely regulated commercial trucking industry, and that the patrol's random stops and inspections of his truck would comport with the Fourth and Fourteenth Amendments. Furthermore, Missouri's regulatory scheme advances a substantial government interest as applied to plaintiff, and warrantless inspections are necessary to further the regulatory scheme. View "Calzone v. Olson" on Justia Law

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The Eighth Circuit reversed the district court's order finding that the trustee's claim under the Carmack Amendment against Canadian Pacific was untimely. This appeal stemmed from a train accident killing 47 people and destroying an entire town in Quebec. The court held that WFE's claim based on a claim letter and denial in April 2014 made the trustee's April 2016 lawsuit timely. In regard to Irving Oil, the court held that there was a genuine dispute over the very existence of contractual terms in the bill of lading providing for a nine-month notice period and a two-year suit limitation, precluding both dismissal on the pleadings or summary judgment as a matter of law. Accordingly, the court remanded for further proceedings. View "Whatley v. Canadian Pacific Railway Ltd." on Justia Law

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The Eighth Circuit affirmed the district court's dismissal of an action brought by four taxicab drivers against Uber, alleging that Uber tortiously interfered with a valid business expectancy. The court held that it need not decide whether there was a valid business expectancy because plaintiffs failed to allege the absence of justification under Missouri law. In this case, there was no evidence that the legislature intended to create a private cause of action based on violation of the Missouri Taxicab Commission's code and requirements. View "Vilcek v. Uber Technologies, Inc." on Justia Law

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Plaintiff filed the underlying action against BNSF after he was injured when the backrest of his locomotive seat broke, and alleged that the seat did not comply with the federal standards in the Locomotive Inspection Act (LIA). BNSF settled a Federal Employers' Liability Act (FELA) claim with plaintiff. BNSF then filed suit against Seats to recover the costs of settlement. The Eighth Circuit reversed and held that the district court erred in determining that the LIA preempted BNSF's claims for products liability and breach of contract. Because the district court did not address defendant's other grounds for dismissal of the two claims, the court remanded for further proceedings on those alternative arguments. View "BNSF Railway Co. v. Seats, Inc." on Justia Law

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The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against defendants in an action alleging claims under the Driver's Privacy Protection Act (DPPA), 18 U.S.C. 2721-25. The court held that the district court properly dismissed plaintiff's claims against Defendant Kopp as untimely under the applicable statute of limitations; plaintiff failed to state a claim for direct municipal liability against Duluth because she failed to plead sufficient facts supporting an inference that the City knowingly allowed Kopp to access the database for any reason other than her official duties; and plaintiff failed to preserve any vicarious liability claim. View "Loeffler v. City of Duluth" on Justia Law

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Plaintiff, a former MLB player, filed suit alleging violations of the Driver's Privacy Protection Act (DPPA), 18 U.S.C. 2721-25, after an audit revealed that officers from over thirty departments had accessed his information more than 125 times. After the issuance of the Eighth Circuit's opinions in McDonough v. Anoka County, 799 F.3d 931 (2015), and Tichich v. City of Bloomington, 835 F.3d 856 (2016), plaintiff conceded that only his claims against the City of Bloomington and the City of Shakopee were timely and plausible. With respect to these claims, the court affirmed the district court's grant of defendants' motion to dismiss because plaintiff failed to plead sufficient facts to show an impermissible purpose by defendants. View "Berenguer v. Anoka County" on Justia Law

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Plaintiff, a former MLB player, filed suit alleging violations of the Driver's Privacy Protection Act (DPPA), 18 U.S.C. 2721-25, after an audit revealed that officers from over thirty departments had accessed his information more than 125 times. After the issuance of the Eighth Circuit's opinions in McDonough v. Anoka County, 799 F.3d 931 (2015), and Tichich v. City of Bloomington, 835 F.3d 856 (2016), plaintiff conceded that only his claims against the City of Bloomington and the City of Shakopee were timely and plausible. With respect to these claims, the court affirmed the district court's grant of defendants' motion to dismiss because plaintiff failed to plead sufficient facts to show an impermissible purpose by defendants. View "Berenguer v. Anoka County" on Justia Law