ST. LOUIS — The U.S. Court of Appeals for the Eighth Circuit has affirmed a lower court ruling against a former Honeywell International employee who alleged the company lied about the circumstances of his termination and that his disability insurers failed to pay all benefits owed to him.
In an opinion filed May 1, a three-judge panel upheld the dismissal of claims brought by John Carl Michel Jr. against Honeywell International and the grant of summary judgment in favor of Cigna and Life Insurance Company of North America.
The appeal stemmed from proceedings in the U.S. District Court for the Western District of Missouri before Judge Roseann A. Ketchmark. Michel had accused Honeywell of wrongful termination and defamation and also asserted disability discrimination claims.
He further alleged that the insurers improperly handled and calculated his disability benefits.
The Eighth Circuit panel, Judges Raymond Gruender, L. Steven Grasz and David Stras, concluded that the district court properly dismissed the claims against Honeywell because Michel was an at-will employee and could not establish wrongful termination under applicable law.
The opinion cited prior precedent holding that an employer’s internal rules do not create an enforceable employment contract.
The court also determined Michel failed to timely pursue his disability discrimination claim, citing a 90-day filing deadline that the panel said barred the action.
In addressing the defamation claim, the panel said Michel’s allegations were based on statements Honeywell made to a state agency that were protected under Missouri law.
The opinion referenced a Missouri statute codifying privilege protections for such statements and cited prior Missouri appellate precedent recognizing the privilege.
The court further rejected Michel’s reliance on what he described as “newly discovered evidence.”
The panel stated the alleged flaws in his claims were legally fatal “with or without” the additional evidence he urged the district court to consider.
The opinion also cited precedent explaining that motions for reconsideration cannot be used to introduce evidence that could have been presented earlier or to advance new legal theories.
Regarding the insurance-related claims, the Eighth Circuit found that the insurers reasonably interpreted Honeywell’s group policy when calculating Michel’s benefits and when determining that he no longer qualified as disabled under the plan.
The panel applied an abuse-of-discretion standard in reviewing the benefit determination and concluded the insurers’ reliance on the policy language supported summary judgment in their favor.
The court also held that federal law preempted Michel’s breach-of-contract claim against the insurers.
The panel ultimately affirmed the district court’s judgment in full under Eighth Circuit Rule 47B and denied Michel’s motion to expedite the appeal as moot.
U.S. Court of Appeals for the Eighth Circuit case number: 25-2665
