Justia Civil Procedure Opinion Summaries

R & J Sheet Metal, Inc. (R&J) appealed an order directing it to pay contribution to W.E. O’Neil Construction Co. of California (WEO), Continental Casualty Company (Continental), and Western Surety Company (Western) (collectively, the WEO defendants). R&J and the WEO defendants were co-debtors on a joint and several judgment in favor of Joseph Karscig, Inc., doing business as Architectural Systems, Inc. (ASI). R&J appealed the judgment, while the WEO defendants satisfied it and sought contribution from R&J. The trial court initially took the motion off calendar due to R&J’s pending appeal. After the appeal was resolved, the WEO defendants filed a second contribution motion, including postjudgment interest, which the trial court granted, ordering R&J to pay one-half of the judgment.The Superior Court of Los Angeles County granted the WEO defendants' motion for contribution, deeming them a single entity for liability purposes and ordering R&J to pay one-half of the judgment. R&J argued the motion was untimely and that the trial court should not have allocated liability pro rata without taking evidence on the judgment debtors’ proportionate liability. R&J also contended that Western should not have been included as a single entity with WEO and Continental.The California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s order. The appellate court held that the original contribution motion was valid despite being filed during the pendency of R&J’s appeal, as taking the motion off calendar did not affect the appeal’s status quo. The court also found that the second motion was a permissible update of the original motion to include postjudgment interest. The court rejected R&J’s argument that the trial court should have determined the judgment debtors’ proportionate liability through an evidentiary hearing, holding that pro rata contribution was proper in the absence of a judgment or underlying instrument allocating liability. The court also found that R&J had forfeited its argument regarding Western’s inclusion in a single entity with WEO and Continental by failing to raise it below. View "R & J Sheet Metal v. W.E. O'Neil Construction" on Justia Law

Plaintiffs, 640 Octavia LLC and Edward Kountze, owned an apartment building in San Francisco and hired Walston Law Group to represent them in a federal unlawful detainer action against a tenant. During the trial, it was discovered that Walston's attorney had created a document with new house rules during the trial, which led to the federal judge excluding the document and giving a curative instruction to the jury. The jury found in favor of the tenant, and plaintiffs subsequently sued Walston for legal malpractice, alleging various breaches and negligence.The San Francisco Superior Court dismissed plaintiffs' complaint with prejudice due to their failure to comply with discovery orders, and the case proceeded to trial on Walston's cross-complaint for unpaid attorney fees. The jury awarded Walston $78,905.43 in damages plus $29,826.25 in prejudgment interest. Plaintiffs appealed, arguing that the trial court's pretrial order excluding evidence of their malpractice allegations was erroneous and prejudicial.The California Court of Appeal, First Appellate District, Division Five, reviewed the case and concluded that the trial court erred in applying the doctrine of claim or issue preclusion to exclude evidence supporting plaintiffs' malpractice allegations. The appellate court held that the dismissal of plaintiffs' complaint was interlocutory and not a final judgment, thus preclusion doctrines did not apply. The court found that the exclusion of evidence was prejudicial, as it prevented the jury from properly considering plaintiffs' defense that Walston's alleged malpractice excused them from paying the fees.The appellate court reversed the judgment and remanded the case for a new trial, allowing plaintiffs to present evidence of Walston's alleged malpractice. View "640 Octavia LLC v. Walston" on Justia Law

T.M. has a medical condition that causes psychosis when she ingests gluten. After an episode in 2023, she was involuntarily committed to Baltimore Washington Medical Center. Despite her and her father's request for voluntary admission, an administrative hearing led to her involuntary commitment. A clinical review panel approved forcibly injecting T.M. with antipsychotic medication, a decision affirmed by a Maryland administrative law judge. T.M. and the medical center later reached an oral agreement for her release, which was formalized in a consent order by a state court. The consent order required T.M. to follow certain conditions, including taking prescribed medications and dismissing other lawsuits.The United States District Court for the District of Maryland dismissed T.M.'s claims, citing the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court found it lacked subject matter jurisdiction over T.M.'s claims and dismissed the parents' claims for failure to state a claim. T.M.'s claims were dismissed with prejudice, while the parents' claims were dismissed without prejudice.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal of T.M.'s claims for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. The court held that T.M. was a state court loser seeking to overturn a state court judgment, which is barred by the doctrine. The court vacated the dismissal with prejudice and remanded with instructions to modify the judgment to dismiss T.M.'s claims without prejudice. The court also affirmed the dismissal of the parents' claims for failure to state a claim, noting that the complaint did not allege a violation of their First Amendment rights. View "T.M. v. University of Maryland Medical System Corporation" on Justia Law

Epic Systems Corporation sued Tata Consultancy Services Limited and Tata America International Corporation for unauthorized use of confidential information. A jury awarded Epic $240 million in compensatory damages and $700 million in punitive damages. The district court reduced these amounts to $140 million and $280 million, respectively, and entered judgment in 2017. The Seventh Circuit affirmed the compensatory damages but limited the punitive damages to $140 million, leading to a new judgment in 2022. Tata agreed to pay postjudgment interest on the compensatory damages from 2017 but argued that interest on the punitive damages should start from 2022. The district court sided with Tata, and Epic appealed.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that both the 2017 and 2022 judgments included $140 million in compensatory damages and at least $140 million in punitive damages. The court referenced the Supreme Court's decision in Kaiser Aluminum & Chemical Corp. v. Bonjorno, which held that postjudgment interest should be based on the date when damages became ascertainable. The Seventh Circuit concluded that the $140 million punitive damages were ascertainable from the 2017 judgment, as neither the district court nor the appellate court had ever deemed this amount excessive.The Seventh Circuit reversed the district court's decision and remanded the case with instructions to award postjudgment interest on the $140 million punitive damages starting from October 3, 2017. View "Epic Systems Corporation v Tata Consultancy Services Limited" on Justia Law

Anna Palova, a flight attendant for United Airlines since 1992, was terminated in February 2020 for allegedly engaging in "parking," a prohibited scheduling tactic. United Airlines claimed that Palova manipulated flight assignments, violating the collective bargaining agreement (CBA). Palova, however, argued that her termination was due to age discrimination, as she and two other older flight attendants were fired while younger attendants who committed similar infractions were not.The United States District Court for the Southern District of Texas granted summary judgment in favor of United Airlines. The court concluded that the Railway Labor Act (RLA) precluded Palova's Age Discrimination in Employment Act (ADEA) claim and preempted her Texas Commission on Human Rights Act (TCHRA) claim. The court reasoned that resolving Palova's claims would require interpreting the CBA, which falls outside the court's jurisdiction under the RLA.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the RLA does not preclude or preempt Palova's age discrimination claims. The court found that Palova's claims of age discrimination were independent of the CBA and did not require its interpretation. The court noted that while the CBA might be referenced, it was not dispositive of the discrimination claims. Consequently, the Fifth Circuit vacated the district court's summary judgment order and remanded the case for further proceedings consistent with its opinion. View "Palova v. United Airlines" on Justia Law

Julie Sprafka underwent knee replacement surgery in August 2016 using the ATTUNE knee replacement system designed by DePuy Orthopaedics, Inc. Four years later, she required revision surgery due to the debonding of the tibial baseplate. Sprafka filed a lawsuit against DePuy, claiming strict liability, negligent products liability, and breach of warranties. She later withdrew the warranty claims and proceeded with the products liability claims, alleging defective design and failure to warn.The United States District Court for the District of Minnesota reviewed the case. DePuy moved to exclude the opinions of Sprafka’s design defect expert, Dr. Mari S. Truman, and for summary judgment. The district court granted DePuy’s motions, excluding Dr. Truman’s opinions for failing to meet the requirements of Rule 702 and Daubert standards. Consequently, the court granted summary judgment in favor of DePuy, as Sprafka could not prove her design defect claim without expert testimony.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, agreeing that Dr. Truman’s opinions were unreliable and speculative. The appellate court noted that Dr. Truman’s opinions were not based on independent research and lacked scientific scrutiny. The court also found that Sprafka did not preserve the argument that Dr. Kristoffer Breien’s expert opinion alone could support her design defect claim. Additionally, the court concluded that the district court did not err in granting summary judgment, as Sprafka failed to provide sufficient expert testimony to support her claims. The judgment of the district court was affirmed. View "Sprafka v. Medical Device Bus. Services" on Justia Law

In June 2018, Leslie Davies and volunteers from the Animal Protection and Rescue League, Inc. protested against a pet store in a Temecula shopping mall, alleging the store sourced dogs from puppy mills. They were asked by mall officials to move their protest due to a table reservation conflict. When Davies refused, Riverside Sheriff’s Deputy Rudy Leso threatened her with arrest if she did not comply. Davies requested a citation instead, but Leso insisted on arrest. Consequently, Davies and the volunteers left the area.The plaintiffs, Davies and the League, filed a lawsuit against the County of Riverside and Deputy Leso in August 2019. The Superior Court of Riverside County sustained demurrers without leave to amend for several causes of action, including negligence, Bane Act, and Ralph Act claims. The court also granted summary judgment in favor of the defendants on the remaining cause of action for declaratory relief.The California Court of Appeal, Fourth Appellate District, reviewed the case. The court affirmed the lower court’s decisions, finding no error. It held that Davies’s negligence claim failed because she did not allege physical injury or a breach of duty. The Ralph Act claim was dismissed as the threat of arrest did not constitute violence. The Bane Act claim was also dismissed because the threat of arrest alone did not amount to coercion or intimidation. Lastly, the court upheld the summary judgment on the declaratory relief claim, noting there was no actual controversy since the County agreed that mall rules are not laws and cannot provide probable cause for arrest. The appellate court affirmed the judgment in favor of the County and Deputy Leso. View "Animal Protection and Rescue v. County of Riverside" on Justia Law

The defendant was previously convicted of murder and criminal possession of a firearm. This court reversed the murder conviction due to the prosecutor's improper comments on the defendant's post-Miranda silence, violating Doyle v. Ohio. The defendant then moved to dismiss the murder charge, arguing that double jeopardy protections barred a retrial because the prosecutor intended to prevent an acquittal that was imminent without the impropriety.The trial court denied the motion to dismiss, finding that the defendant did not establish that the prosecutor intended to prevent an acquittal. The court based its decision on the trial transcripts and this court's previous decision, which concluded that the evidence was sufficient to support the conviction. The defendant appealed, renewing his argument that the double jeopardy clause barred a retrial and asserting that the Connecticut constitution provided broader protections.The Supreme Court of Connecticut affirmed the trial court's decision. The court held that the defendant failed to demonstrate that the prosecutor engaged in impropriety with the intent to prevent an acquittal that the prosecutor believed was imminent. The court noted that the evidence at trial, although not overwhelming, was sufficient to support a conviction, and the prosecutor's actions did not indicate an intent to provoke a mistrial or prevent an acquittal. The court also declined to overrule its previous decisions in State v. Colton and State v. Michael J., maintaining that the Connecticut constitution does not provide broader double jeopardy protections than the federal constitution. View "State v. Patrick M." on Justia Law

Raymond Vuoncino, a corporate-finance professional, worked for U.S. Pipe Fabrication, LLC (Fabrication). After Fabrication implemented new accounting practices for inter-company sales, Vuoncino objected to these practices as potentially fraudulent. Subsequently, he was fired by an executive of Fabrication’s parent company, Forterra, Inc. Vuoncino sued Fabrication, Forterra, and two Forterra executives, alleging violations of the Sarbanes-Oxley Act’s anti-retaliation provision.The United States District Court for the Northern District of Texas dismissed Vuoncino’s first amended complaint for failure to state a claim, denied his motion for leave to amend his complaint, and denied reconsideration of those orders. Vuoncino appealed these decisions.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s denial of Vuoncino’s motion for leave to file a second amended complaint, finding the proposed amendments were time-barred and did not relate back to the original complaint. The court also affirmed the district court’s denial of reconsideration, noting that Vuoncino’s motion rehashed previously rejected arguments and did not present newly discovered evidence.However, the Fifth Circuit reversed the district court’s dismissal of the Sarbanes-Oxley Act claim against Fabrication, concluding that Vuoncino’s first amended complaint plausibly alleged that Fabrication employed him. The court found that Vuoncino’s allegations, taken as true, were sufficient to raise a plausible inference that he was a Fabrication employee. The court affirmed the dismissal of the Sarbanes-Oxley Act claims against Forterra, Bradley, and Kerfin, as Vuoncino failed to sufficiently plead that these defendants were his employer’s alter ego or that he could sue Forterra directly without establishing an employment relationship.The Fifth Circuit affirmed in part, reversed in part, and remanded the case for further proceedings. View "Vuoncino v. Forterra" on Justia Law

Cascade County discovered petroleum contamination under a county shop complex in 1996 and notified the Department of Environmental Quality (DEQ). A 2000 report identified the contamination source as four county-owned tanks. The DEQ approved a corrective action plan in 2006, and the County requested the site be designated as a multiple release site for reimbursement eligibility, which the DEQ declined. The County completed remediation in 2008 and submitted receipts to the Montana Petroleum Tank Release Compensation Board, but the costs exceeded the statutory maximum for a single release. The Board indicated further reimbursement requests would be denied.The County sought a writ of mandamus to compel the DEQ to assign multiple release numbers, but the DEQ and the County eventually stipulated to dismiss the action in 2013. The County then filed four separate applications for reimbursement in 2014, which the Board denied, stating the DEQ had classified all contaminations under a single release number. The County contested this, and a Hearing Examiner found four discrete releases but ruled the claims were time-barred. The Board adopted most of the Examiner's findings but rejected the conclusion of four releases. The district court later ruled in favor of the County, and the Montana Supreme Court affirmed, directing the Board to reimburse the County.The Montana Supreme Court reviewed the case and determined that the Board had a clear legal duty to review the County's reimbursement claims, despite the County not submitting them in the manner required by Board regulations. The Court held that the Board must review and determine the eligibility of the claims submitted by the County for reimbursement of remediation costs. The District Court's order denying the County's writ of mandamus was reversed, and the case was remanded with instructions to issue the alternative writ of mandate. View "Cascade v. Petroleum Tank Release Compensation Board" on Justia Law