Justia Civil Procedure Opinion Summaries

A nurse employed by Puerto Rico’s State Insurance Fund Corporation reported sexual harassment by a coworker in 2020 and subsequently filed an administrative charge of discrimination and retaliation. After dropping her sexual harassment claim, she pursued a retaliation claim, arguing that she endured a hostile work environment and was involuntarily transferred to a different office. The incidents underlying her claim included several allegedly meritless disciplinary actions and the eventual transfer.The United States District Court for the District of Puerto Rico granted a preliminary injunction separating her from the coworker and, after trial, a jury found in her favor on the retaliation claim, awarding $300,000 in damages. The district court later denied her request for a permanent injunction seeking reassignment to her former office and expungement of disciplinary records. The court awarded her approximately $301,000 in attorney fees and costs, but she challenged the amount as insufficient. Finally, although the defendant did not appeal the judgment or fee award, the district court stayed execution of both under Puerto Rico law, pending approval of a payment plan by the Secretary of Justice.The United States Court of Appeals for the First Circuit affirmed the denial of permanent injunctive relief and the attorney fee award, finding that the district court did not abuse its discretion on either point and that the fee reductions and denial of injunctive remedies were reasonable. The Court of Appeals also vacated the stay of execution of judgment and fees, holding that Puerto Rico’s statutory payment plan requirement could not delay enforcement of a federal judgment under Title VII. The case was remanded for further proceedings consistent with these rulings. View "Garcia Colon v. State Insurance Fund Corporation" on Justia Law

The case centers on a challenge to a provision in the Los Angeles Administrative Code, section 8.33, which grants the mayor special powers upon declaring a “local housing and/or homelessness emergency.” In July 2023, the mayor declared such an emergency, and the city council subsequently renewed it. The emergency declaration was later lifted in November 2025. During the period the declaration was in place, Fix the City, Inc. contended that section 8.33 was invalid because it conflicted with the California Emergency Services Act (CESA) and another provision in the city’s code, arguing that the city had acted illegally during the emergency.The Superior Court of Los Angeles County reviewed Fix the City’s claims for writ and declaratory relief, which sought to vacate the emergency declaration and any resulting directives, as well as a declaration that section 8.33 was void for conflicting with CESA and local law. The city responded with a demurrer, asserting that section 8.33 was a proper exercise of municipal authority and did not conflict with CESA or the city’s own code. The superior court agreed, finding that CESA did not apply to charter cities unless there was a clear legislative directive, and that section 8.33 was not inconsistent with other city code provisions. The court sustained the demurrer without leave to amend, and Fix the City appealed.The California Court of Appeal, Second Appellate District, Division One, affirmed the lower court’s judgment. The appellate court held that CESA does not preempt section 8.33 because the two do not conflict; section 8.33 is a valid exercise of the city’s home rule powers over municipal affairs. Additionally, section 8.33 did not violate other provisions of the city’s administrative code. The denial of leave to amend was also upheld. View "Fix the City, Inc. v. City of Los Angeles" on Justia Law

A homeowner alleged that he hired a roofing company in 2011 to install a specific type of roof on his residence. After installation, problems with roof materials became apparent, including issues with a protective layer that remained unresolved despite multiple repair attempts by both the roofing company and the manufacturer over more than a decade. The homeowner asserted that these defects persisted, and that communication from the roofing company ceased in early 2024. As a result, he filed a lawsuit in Etowah County, Alabama, alleging breach of express and implied warranties, as well as negligent or wanton installation and repair, and sought damages.The roofing company moved to dismiss the lawsuit for improper venue, arguing that a forum-selection clause in a “Service Agreement” required all disputes to be heard in Madison County, Alabama. The company attached an unsigned and undated sample agreement to its motion, but did not produce a copy signed by the homeowner or any evidence that the homeowner had agreed to such a clause. The homeowner responded that he had never signed, nor was he aware of, the agreement submitted by the company and also challenged the clause’s reasonableness. The Etowah Circuit Court denied the company’s motion to dismiss for improper venue.The Supreme Court of Alabama reviewed the company’s petition for a writ of mandamus, which sought to compel the lower court to dismiss the case or transfer it to Madison County. The Supreme Court held that the company failed to meet its burden of proving that the forum-selection clause applied, as it did not present evidence linking the blank agreement to the parties’ actual contract. Therefore, the Supreme Court of Alabama denied the petition, concluding that the circuit court did not clearly err in refusing to dismiss or transfer the case. View "Ex parte Continental Roofing Company, LLC" on Justia Law

The case centers on a dispute involving a pharmaceutical company founded by the plaintiff, who also served as its CEO. The plaintiff obtained investment from a Canadian entity controlled by one of the defendants, who later became a director. The company entered into a profitable licensing agreement for a drug, and the plaintiff claims he was personally entitled to 30% of the profits based on an oral agreement. The investor and his affiliates, however, allege that the plaintiff wrongfully diverted corporate assets by taking this share. After disagreements arose, the investor replaced himself and another director on the board with officers from his own affiliates, who began investigating the alleged diversion. In response, the plaintiff initiated litigation, asserting that the investigation was a breach of fiduciary duty and that the investor and his affiliates acted in bad faith for their own benefit.Previously, the Court of Chancery of the State of Delaware was asked to consider several claims, including breach of fiduciary duty, civil conspiracy, and tortious interference against the investor, his affiliates, and the two new directors. The investor’s affiliate moved to dismiss for lack of personal jurisdiction, and the court found it had no jurisdiction over the affiliate. The court also examined whether it had jurisdiction over the investor for claims other than those related to his service as a director, finding it did not because the complaint failed to state a viable claim against him in that capacity.In the present decision, the Court of Chancery held that it lacked personal jurisdiction over the investor’s affiliate and over the investor in his non-director capacities, dismissing those claims without prejudice. The court further dismissed with prejudice the breach of fiduciary duty and conspiracy claims against the directors and the investor in his director capacity, finding no viable claims were stated. However, the court allowed the plaintiff’s claim for a declaratory judgment regarding his right to the profits from the drug to proceed against the company, provided an amended complaint is filed naming the company as a proper defendant. View "MacLaughlan v. Einheiber" on Justia Law

A journalist requested internal affairs records from the City of Reno related to a former police officer, relying on the Nevada Public Records Act. After the City denied these requests several times, the journalist filed a petition with the Second Judicial District Court, seeking a writ of mandamus to compel disclosure. Instead of following the standard process that would have required the City to receive notice and an opportunity to respond before any court order, the journalist specifically asked for, and the district court granted, an ex parte alternative writ of mandamus. This writ ordered the City to either produce the records or appear at a hearing to show cause, but the district court did not explain why ex parte action was justified.Following the issuance of the ex parte writ, the City was served and attended the hearing, where it secured a continuance in order to seek relief from the Supreme Court of Nevada. The City then petitioned the Supreme Court for a writ of mandamus, arguing that ex parte writs should only be issued in emergency or exceptional circumstances, and that the district court had erred by granting such relief without explanation.The Supreme Court of Nevada held that before issuing an ex parte alternative writ of mandamus—particularly in the context of public records requests under the Nevada Public Records Act—a district court must make specific findings as to why regular notice and an opportunity for the opposing party to be heard would be inadequate. The court clarified that ex parte relief is appropriate only in exceptional circumstances where immediate action is necessary and routine procedures are insufficient. Because the district court did not make such findings in this case, the Supreme Court concluded that it had manifestly abused its discretion and ordered the district court to vacate the ex parte alternative writ. View "CITY OF RENO VS. DIST. CT." on Justia Law

A long-time authorized equipment dealer, operating under two dealer sales agreements with a manufacturer, received notice in September 2024 that its agreements would be terminated in ninety days. The manufacturer cited alleged false and misleading statements, including altered business records, as grounds for termination under the agreements. The dealer responded by challenging the termination in court, invoking North Dakota statutes that regulate equipment dealer terminations and asserting that the filing of its action triggered an automatic stay against termination during litigation.The District Court of Morton County was asked by the manufacturer to dissolve or modify the automatic stay, arguing that the statutory stay only applied to certain products and not to the bulk of equipment covered by the agreements. The manufacturer presented evidence and legislative history to support its position. However, the district court denied the motion, holding that the statute mandates a procedural automatic stay upon the filing of the dealer’s action, and that the court lacked authority to dissolve or modify the stay at this stage. The court deferred any determination of which products were covered by which statute to later proceedings. The manufacturer then sought appellate review, but the district court did not rule on its request for certification under N.D.R.Civ.P. 54(b) due to the pending appeal.The Supreme Court of the State of North Dakota reviewed whether it had jurisdiction over the appeal. The court concluded that, although the automatic stay functioned as a statutory temporary injunction making the order appealable under N.D.C.C. § 28-27-02(3), the absence of Rule 54(b) certification rendered the order not appealable at this stage. The Supreme Court dismissed the appeal and, finding no extraordinary circumstances or public interest, declined to exercise its supervisory jurisdiction. View "Bobcat of Mandan v. Doosan Bobcat North America" on Justia Law

Two individuals were involved in a car accident in 2020 and received a payment from the other driver’s insurer. Seeking further compensation, they pursued a claim against their own underinsured motorist policy with their insurance company. After the insurer offered less than the policy limit, the insureds initiated a breach of contract lawsuit. Ultimately, the insurer settled by paying the full policy limit, and that litigation was dismissed. Subsequently, the insureds filed a second lawsuit alleging that the insurer acted in bad faith by delaying settlement, leading to emotional and financial distress.During discovery in the bad-faith action, the insureds requested the insurer’s claims file, including documents generated after the prior litigation began. The insurer withheld certain documents, citing attorney-client privilege and the work-product doctrine, and provided a privilege log. The Hamilton County Court of Common Pleas ordered production of the entire unredacted claims file up to the date of payment, without conducting an in camera review. The insurer appealed, arguing that the trial court erred by not applying statutory requirements for privilege and failing to conduct an in camera inspection.The First District Court of Appeals affirmed the trial court’s order, relying on Boone v. Vanliner Insurance Co., holding that in bad-faith claims, materials created prior to denial of coverage are discoverable. The appellate court reasoned that the insureds’ allegations of bad faith were sufficient to override privilege protections and rejected the insurer’s arguments about statutory requirements and the need for an in camera review, concluding that the insurer had not asserted privilege with sufficient detail.The Supreme Court of Ohio reversed the appellate court’s judgment. It held that the Boone decision had been superseded by statute: attorney-client communications are subject to discovery only after a prima facie showing of bad faith and an in camera review under R.C. 2317.02(A)(2). The work-product doctrine is governed by Civil Rule 26(B)(4) and allows disclosure only upon a showing of good cause. The case was remanded to the trial court for compliance with these standards. View "Eddy v. Farmers Property Cas. Ins. Co." on Justia Law

J.S. sought a domestic violence restraining order (DVRO) against her former fiancé, D.A., alleging ongoing abuse that included physical violence and threatening communications while D.A. was incarcerated. J.S. described several incidents of abuse during their relationship and stated that she was fearful of further harm upon D.A.’s eventual release from prison. After J.S. filed for a DVRO, the Superior Court of San Diego County issued a temporary restraining order, and scheduled an evidentiary hearing to decide on a permanent order. D.A., still incarcerated, responded to the court by requesting an opportunity to appear telephonically at the hearing, citing his inability to attend in person.The Superior Court of San Diego County continued the initial hearing but did not address D.A.’s request to appear telephonically. At the rescheduled hearing, D.A. was not present, and the court did not document any attempt to facilitate his participation or check his custody status. Based on J.S.’s testimony and the evidence on file, the court issued a five-year DVRO against D.A. Afterward, D.A. filed motions seeking discovery, an expert, and assistance for telephonic appearance, but there was no indication the court acted on these filings. D.A. then appealed, arguing he was denied meaningful access to the court.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that the trial court abused its discretion by not considering and ruling on D.A.’s request for telephonic appearance, depriving him of his right to meaningful access to the courts as an indigent inmate in a bona fide civil action. The appellate court reversed the judgment and remanded for further proceedings, ordering the trial court to ensure D.A. is provided with meaningful access. The temporary restraining order remains in effect pending further proceedings. View "J.S. v. D.A." on Justia Law

A company operating a private detention facility in Colorado under contract with U.S. Immigration and Customs Enforcement was sued in a class action by a former detainee. The lawsuit challenged two of the company’s work policies for detainees: a sanitation policy that required unpaid cleaning under threat of punishment, and a voluntary work program offering minimal pay. Plaintiffs alleged that the sanitation policy violated federal anti-forced-labor laws and that the voluntary work program constituted unjust enrichment under Colorado law.After discovery, the United States District Court for the District of Colorado considered the company’s argument that, under the Supreme Court’s decision in Yearsley v. W. A. Ross Construction Co., it could not be held liable for conduct that the government had lawfully “authorized and directed.” The District Court concluded that the government contract did not instruct the company to adopt the specific work policies at issue and that the company had developed those policies on its own. Therefore, the court held that the Yearsley doctrine did not shield the company from liability and allowed the case to proceed to trial.The company appealed immediately, but the United States Court of Appeals for the Tenth Circuit dismissed the appeal for lack of jurisdiction, holding that a denial of Yearsley protection is not subject to interlocutory appeal under Cohen v. Beneficial Industrial Loan Corp.The Supreme Court of the United States affirmed the Tenth Circuit’s decision, holding that Yearsley provides a merits defense, not an immunity from suit. Therefore, a pretrial order denying Yearsley protection cannot be immediately appealed; any review must wait until after final judgment. The Court remanded the case for further proceedings. View "Geo Group, Inc. v. Menocal" on Justia Law

A former employee of a Mississippi school district brought a lawsuit alleging employment discrimination and retaliation, claiming she was forced to resign after ending a coerced sexual relationship with a school administrator in exchange for ADA accommodations and job security. She asserted that the resulting discrimination led to significant mental and physical health issues. Throughout the proceedings, the plaintiff alternated between being represented by counsel and representing herself. She cited deteriorating mental health and financial hardship, repeatedly sought appointment of counsel, and submitted medical documentation supporting her claims of severe mental illness.Proceedings in the United States District Court for the Southern District of Mississippi were marked by multiple disputes over compliance with court orders, particularly the court’s order that the plaintiff undergo a mental examination at her own expense. The plaintiff objected, stating she could not afford the examination and claimed to be competent to understand her case but not to represent herself. After failing to attend several hearings and not communicating as ordered, the court interpreted her actions as contumacious conduct—deliberately resisting court authority. The district court ultimately dismissed her case with prejudice, assigned all costs to her, and ordered her to pay the school district’s attorneys’ fees for hearings she failed to attend.The United States Court of Appeals for the Fifth Circuit reviewed the case. It held that the district court did not abuse its discretion in dismissing the case with prejudice under Federal Rule of Civil Procedure 41(b), finding a clear record of contumacious conduct and concluding that lesser sanctions would not have served the interests of justice. The appellate court affirmed the dismissal with prejudice but vacated and remanded the portion of the judgment concerning attorneys’ fees. View "Boudy v. McComb School District" on Justia Law