Case Explained: Board of Trustees of the Iron Workers St. Louis District Council Pension Fund Trust; Board of Trustees of the Iron Workers St. Louis District Council Annuity Trust; Board of Trustees of the Iron Workers St. Louis District Council Welfare Plan; Iron Workers Local No. 103 of the International Association of Bridge Structural, Ornamental and Reinforcing Iron Workers; Iron Workers Local No. 321 of the International Association of Bridge, Structural, Ornamental and Reinforcing Iron Workers; Iron Workers Local No. 782 of the International Association of Bridge, Structural, Ornamental and Reinforcing Iron Workers v. Barnhart Crane & Rigging Co., a Tennessee Corporation

Court: United States Court of Appeals for the Eighth Circuit

Filed: 2026-07-13

The Eighth Circuit affirmed the district court’s exclusion of expert witness testimony and its grant of summary judgment to the defendant, while dismissing the portion of the appeal challenging the award of attorneys’ fees for lack of jurisdiction. The court held that the district court did not abuse its discretion in excluding the testimony of Bradley Soderstrom because the plaintiffs failed to disclose him as an expert witness under Federal Rule of Civil Procedure 26(a)(2), and his proposed opinions relied on specialized knowledge and assumptions beyond lay perception, constituting expert testimony under Federal Rule of Evidence 702. The court further affirmed summary judgment on all counts, ruling that without Soderstrom’s admissible testimony, the plaintiffs failed to present competent evidence sufficient to prove damages, as the underlying business records were too voluminous and complex for a jury to calculate without expert assistance. Regarding the attorneys’ fees award, the court dismissed the appeal because the district court had not yet determined the specific amount of fees, rendering the issue unripe for appellate review under 28 U.S.C. § 1291. Consequently, the judgment in favor of Barnhart stands, and the fee dispute must be resolved by the district court before it can be appealed.

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