Raeburn Bedford v. John Doe, 880 F.3d 993

Bedford, a truck driver, was injured when boxes fell from a trailer after he opened its door; he sued International Paper Co. (IP) and an IP employee (Doe) for negligence and vicarious liability.
IP moved for summary judgment; Bedford did not file a timely response, instead seeking to designate an expert out of time or dismiss without prejudice.
The district court, applying Local Rule 56.1(c), treated IP’s asserted facts as admitted, granted summary judgment for IP, and dismissed the Doe claim as apparently abandoned.
Bedford moved for reconsideration under Fed. R. Civ. P. 59(e); the district court denied the motion.
On appeal, Bedford did not contest that he violated Local Rule 56.1(c); he argued there was evidence of IP/Doe negligence and that IP’s facts were incomplete or misleading.
The Eighth Circuit considered whether it had jurisdiction to review the underlying summary-judgment order (Bedford’s notice only named denial of reconsideration) but concluded it could review the summary-judgment ruling and reviewed it de novo.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bedford preserved facts defeating summary judgment despite failing to respond to Local Rule 56.1(c)	Bedford: evidence exists showing IP/Doe breached duty and IP’s statement of facts is incomplete/misleading	IP: Bedford failed to produce any evidence of negligence or proximate causation; moving papers showed absence of evidence	Held: Bedford’s failure to respond admitted IP’s facts; no evidence of breach or causation; summary judgment affirmed
Whether negligence may be presumed from the accident	Bedford: urge inference that Doe was negligent in loading the trailer	IP: negligence cannot be presumed; plaintiff must prove negligence and eliminate other causes	Held: Arkansas law forbids presuming negligence; plaintiff must prove and rule out other causes; no presumption allowed
Whether denial of Rule 59(e) reconsideration is reviewable alone	Bedford: appealed denial of reconsideration (notice omitted underlying order)	IP: did not contest appellate review of underlying summary judgment	Held: Court treated appeal of denial as permitting review of underlying summary-judgment order and proceeded to review de novo
Whether district court abused discretion in denying reconsideration	Bedford: asserted same arguments presented earlier	IP: denial was within discretion because arguments lacked merit	Held: Denial of Rule 59(e) motion was not an abuse of discretion

Chambers v. City of Fordyce, Ark., 508 F.3d 878 (8th Cir. 2007) (appellate court’s independent duty to ensure jurisdiction)
Prince v. Kids Ark Learning Ctr., LLC, 622 F.3d 992 (8th Cir. 2010) (appeal from denial of Rule 59(e) can challenge underlying ruling)
Weed v. Jenkins, 873 F.3d 1023 (8th Cir. 2017) (standard of review for summary judgment)
Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (movant may show absence of evidence supporting nonmoving party’s case)
Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (summary-judgment burden and response requirements)
St. Jude Med., Inc. v. Lifecare Int’l, Inc., 250 F.3d 587 (8th Cir. 2001) (movant’s initial burden is not stringent)
Gibson v. Am. Greetings Corp., 670 F.3d 844 (8th Cir. 2012) (nonmoving party cannot rely on mere denials; must present evidence supporting a jury finding)
Yanmar Co. v. Slater, 386 S.W.3d 439 (Ark. 2012) (elements of negligence under Arkansas law)
St. Paul Fire & Marine Ins. Co. v. Brady, 891 S.W.2d 351 (Ark. 1995) (plaintiff must eliminate other causes to avoid speculation)
Mangrum v. Pigue, 198 S.W.3d 496 (Ark. 2004) (negligence not imposed without proof)
Peterson v. Travelers Indem. Co., 867 F.3d 992 (8th Cir. 2017) (standard for reviewing denial of Rule 59(e) motion)