Life Investors Ins. Co. v. Federal City Region, No. 14-1573 (8th Cir. 2015)
Annotate this CaseLife Investors filed suit against defendants, alleging breach of a settlement agreement that required defendants to repay advances of monies defendants received from Life Investors. On appeal, defendants challenged the district court's grant of summary judgment to Life Investors. The court affirmed, concluding that defendants' laches defense failed because they cannot show unreasonable delay on the part of Life Investors in bringing this suit nor can defendants show that they were prejudiced; even if the alleged inconsistencies were material, defendants chose not to investigate further and thus the determination that they ratified the Settlement Agreement was correct; the district court correctly granted summary judgment on the question of ratification of the Settlement Agreement after certifying that question to the Iowa Supreme Court and receiving its answer; and defendants' attempt to argue an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., violation as a defense in this action is barred as a matter of issue preclusion.
Court Description: Shepherd, Author, with Chief Judge Riley and Loken, Circuit Judges Civil Case - diversity. On remand following this court?s reversal of grant of summary judgment to insurance company on breach of contract claim and the Iowa Supreme Court's answer to a question certified to it by the district court, the district court's grant of summary judgment is affirmed. The State Supreme Court answered the ratification issue; the laches defense failed for lack of unreasonable delay or prejudice; and the claim of inconsistencies were not material. Corrado's claim that the settlement agreement violated ERISA is barred as a matter of issue preclusion. Application of judicial estoppel is not proper in this case.
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