Stetson Skender v. Eden Isle Corporation, No. 21-2556 (8th Cir. 2022)
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Plaintiff sued Defendants claiming they violated the Fair Labor Standards Act and the Arkansas Minimum Wage Act. The district court entered an order granting summary judgment to Defendants. After the court entered its order, but before the clerk had entered a separate judgment dismissing Plaintiff’s claims, Plaintiff filed a notice stating that he had accepted an offer of judgment that Defendants had extended in which they agreed to pay him four thousand dollars plus costs and reasonable attorneys' fees.
Plaintiff maintained that, under Rule 68(a), he could accept the offer anytime up to fourteen days after Defendants had served him with it, and therefore it had survived the court's grant of summary judgment. The clerk nevertheless entered judgment consistent with the summary-judgment order. Plaintiff moved the court to amend the judgment to reflect the terms in the offer of judgment. The district court, relying on Perkins, granted Plaintiff’s motion, and the clerk entered a new judgment. Defendants appealed, maintaining that the judgment should have reflected the court's summary judgment ruling rather than the offer of judgment.
The Eighth Circuit affirmed the district court’s ruling and denied Defendants' requested relief and affirmed the district court’s denial of Plaintiff’s motion for recusal and from the court’s order granting Plaintiff only one dollar in attorneys' fees. The court reasoned that only its’ en banc court may overrule a prior panel's decision. Further, the court held that the district court did not abuse its discretion in awarding only one dollar in fees.
Court Description: [Arnold, Author, with Loken and Kobes, Circuit Judges] Civil case - Civil procedure.The district court did not err in entering judgment based on plaintiff's timely acceptance of an offer of judgment - see Perkins v. U.S. W. Commc'ns, 138 F.3d, 336, 339 (8th Cir. 1998); in this set of circumstances, the district court's post-judgment order denying plaintiff's recusal motion was not final and appealable and plaintiff's notice of appeal from that order and a subsequently-entered order on attorneys' fees and costs was timely and within this court's jurisdiction to consider; the district court did not abuse its discretion in denying the recusal motion - see Oden v. Shane Smith Enters., Inc., 27 F.4th 631 (8th Cir. 2022); award of $1 in attorneys' fees was not an abuse of the district court's discretion. [ May 03, 2022 ]
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