Justia Civil Procedure Opinion Summaries

The federal government initiated a project to replace the East Wing of the White House, completing demolition in December 2025 and beginning construction of a new wing, which included both a below-ground military installation and an above-ground ballroom. The National Trust for Historic Preservation challenged aspects of the ongoing construction and sought a preliminary injunction to halt the above-ground work due to concerns about its impact on aesthetic, cultural, and historical interests.The United States District Court for the District of Columbia granted the Trust’s motion for a preliminary injunction, allowing only construction strictly necessary for security purposes above ground but permitting below-ground work to continue. The government appealed, and the United States Court of Appeals for the District of Columbia Circuit initially stayed the injunction, then ultimately affirmed the district court’s order. With the injunction set to take effect, the government sought relief from the Supreme Court of the United States.The Supreme Court granted the requested stay of the district court's injunction pending the government’s petition for certiorari. The Court held that the government is likely to succeed in showing the Trust lacks Article III standing, as the Trust’s asserted injury—distress at viewing the new ballroom’s design—does not constitute a concrete and particularized injury. The Court also found that the government would likely suffer irreparable harm from halting construction, given national security concerns and operational needs, while the Trust’s claimed harm was outweighed by these factors. The stay will remain in effect until certiorari is denied or, if granted, until the judgment is issued. View "National Park Service v. National Trust for Historic Preservation in the United States" on Justia Law

Bryan Smith requested court records from the Bonneville County District Court in April 2025, specifically seeking copies of judgments and certificates of service for 169 small claims cases. The Clerk’s Office charged him $352 for the records, relying on a 2017 Administrative Order that set fees for electronic records production. Smith paid the fee after the Clerk refused to reduce the charge, then filed suit against the Clerk in his official capacity, alleging he was overcharged and that Idaho Code section 74-102(10) should control the fee charged for electronic records. He sought declaratory relief and damages for the alleged overcharge.The Seventh Judicial District, Bonneville County, heard cross motions for summary judgment. The Clerk asserted quasi-judicial immunity based on following an administrative court order. The district court granted summary judgment for the Clerk, holding he had absolute quasi-judicial immunity and declining to address the merits of Smith’s claims, including whether the fee was excessive or inconsistent with Idaho law.The Supreme Court of the State of Idaho reviewed the appeal. Applying a de novo standard, the Court held that quasi-judicial immunity is only a defense to personal liability, not official capacity suits, and the district court erred in applying that defense. On the merits, the Court found the 2017 Administrative Order’s fee structure was inconsistent with Idaho Court Administrative Rule 32 and Idaho Code section 74-102(10), which require fees to reflect actual labor and material costs. Smith was overcharged by $330.67. The Supreme Court reversed the district court’s grant of summary judgment, vacated the amended judgment, and remanded with instructions to enter judgment in favor of Smith, directing the Clerk to refund $330.67 and awarding Smith costs on appeal. View "SMITH v. POULTER" on Justia Law

A child who is an enrolled member of a federally recognized tribe was placed in the guardianship of his paternal grandmother after his biological parents were found unable to care for him. Over the years, concerns arose regarding the guardian’s ability to meet the child’s medical and educational needs, leading to multiple child welfare referrals. Ultimately, the county child welfare agency filed a juvenile dependency petition, asserting the guardian’s failure to protect and provide for the child due to alleged mental illness and neglect. The child’s tribe, which had been involved in the child’s probate and dependency matters for several years, requested a court-ordered psychological evaluation of the guardian to assess her capacity to care for the child.The Superior Court of Riverside County ordered the psychological evaluation but specified it was for “case planning purposes only.” When the tribe later sought access to the evaluation to assist in case monitoring and planning, the guardian objected, arguing privacy and privilege concerns. The juvenile court denied the tribe’s request, finding the evaluation was not ordered for the tribe’s benefit and that there were no compelling reasons to release it. The tribe appealed, contending that it had a presumptive right to the evaluation under state and federal law due to its role in protecting the welfare of its citizen child.The Court of Appeal of the State of California, Fourth Appellate District, Division Two, held that the tribe is presumptively entitled to access the guardian’s psychological evaluation under Welfare and Institutions Code section 827 and related statutes. The court concluded that the tribe, as a party to the proceedings and as a multidisciplinary team member, did not need to file a separate petition for access, and that neither privacy nor privilege barred disclosure of the court-ordered report. The appellate court reversed the juvenile court’s order and directed the release of the evaluation to the tribe. View "In re A.H." on Justia Law

Plaintiffs, who had donated funds to the Church of Jesus Christ of Latter-day Saints, alleged that the Church and its investment subsidiary, Ensign Peak Advisors, Inc., fraudulently induced donations by concealing the true use and accumulation of donated funds. They claimed that the Church misrepresented that tithing would be used for charitable and religious purposes, when instead large portions were invested and used for commercial ventures, such as the development of the City Creek Mall. A key event in the case was the publication of a whistleblower report in December 2019, which was widely reported in national and local media and described how the Church managed and concealed a large investment portfolio. The Church publicly responded, and three other lawsuits were filed by different donors based on similar allegations.After actions were filed in several federal district courts, the cases were consolidated in the United States District Court for the District of Utah. Plaintiffs brought claims for breach of fiduciary duty, fraud, fraudulent concealment, fraudulent misrepresentation, and unjust enrichment, seeking to represent a nationwide class of post-1997 donors. The district court dismissed the consolidated complaint with prejudice, ruling that the claims were untimely under Utah’s three-year statute of limitations for fraud. The court found that the widespread news coverage of the whistleblower report meant that plaintiffs, exercising reasonable diligence, should have discovered the alleged fraud more than three years before filing suit.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the district court’s dismissal. The Tenth Circuit held that the plaintiffs’ claims were time-barred because the whistleblower report and related media coverage provided sufficient public notice to trigger the statute of limitations, and that reasonable diligence would have led to earlier discovery. The court also found no error in the district court’s procedural rulings and denied the request for leave to amend. View "In re: Church of Jesus Christ of Latter-Day Saints" on Justia Law

Businesses selling flavored e-cigarettes in Utah challenged a state law passed in March 2024 that banned the sale of any e-cigarette flavors other than tobacco or menthol. The plaintiffs, representing Retail Tobacco Specialty Businesses (RTSBs), argued that this “Flavor Ban” would severely affect their operations, as the majority of their sales involved flavored products. They asserted that the ban was preempted by the Federal Family Smoking Prevention and Tobacco Control Act and also contended that the law’s enforcement mechanism, which authorized warrantless searches by local health departments, violated the Fourth Amendment.The plaintiffs filed suit in the United States District Court for the District of Utah, seeking preliminary injunctions against both the Flavor Ban and the enforcement mechanism. The district court denied the preliminary injunction regarding the Flavor Ban, concluding that federal law did not preempt the state’s action, but granted an injunction against the enforcement provision, finding the warrantless search mechanism unconstitutional. The court determined that the enforcement provision was severable from the rest of the Act, so it left the remainder of the law, including the Flavor Ban, intact. Both sides appealed the rulings adverse to them.After the Utah legislature amended the enforcement provision, both parties agreed that the Fourth Amendment issue was moot. The only remaining issue on appeal was whether the federal law preempted the state’s Flavor Ban. However, the plaintiffs failed to properly identify the relevant district court order denying the preliminary injunction against the Flavor Ban in their notice of appeal.The United States Court of Appeals for the Tenth Circuit held that because the plaintiffs’ notice of appeal did not specify the order they sought to challenge, the court lacked jurisdiction to consider the preemption issue. Accordingly, the court dismissed the appeal. View "Utah Vapor Business Association v. State of Utah" on Justia Law

Several individuals, including Richard and Jocelyn Markowitz, John and Elizabeth van Merkensteijn, and pension funds they controlled, were found by a jury to have defrauded the Danish tax authority (Skat) by submitting false claims for tax refunds. The defendants conceded before trial that they were never entitled to the refunds under the U.S.-Denmark tax treaty, admitting that they had not owned Danish shares or received dividends subject to Danish withholding tax. However, they argued that they had been misled by a London-based trading partner into believing otherwise and were unaware that the refund claims submitted on their behalf were fraudulent.The United States District Court for the Southern District of New York presided over the case after it was consolidated as part of multidistrict litigation. The defendants unsuccessfully moved to dismiss Skat’s claims, contending that the common law revenue rule barred the suit. The district court held that because the defendants never owned the relevant Danish stocks or paid taxes, Skat’s claims were for commercial fraud rather than enforcement of Danish tax law. After trial, the jury found each defendant liable, and the district court entered judgments totaling over $476 million based on Skat’s gross payments and prejudgment interest.On appeal, the United States Court of Appeals for the Second Circuit reviewed the case. The court held that Skat’s lawsuit was not barred by the revenue rule because it did not seek to enforce foreign tax laws, but rather sought recovery for fraud. The court also found no abuse of discretion in the district court’s exclusion of certain evidence and upheld the sufficiency of evidence supporting judgments against Jocelyn Markowitz and Elizabeth van Merkensteijn under an agency theory. The Second Circuit affirmed the district court’s judgment. View "Skatteforvaltningen v. Markowitz" on Justia Law

An employee who had previously worked for the Department of State, and later for the Department of Homeland Security (DHS) as a criminal investigator, was removed from his position by DHS. The removal was based on a charge of lack of candor, relating to allegedly deceptive or incomplete responses he gave during the background investigation process, including failing to disclose an agreement with the U.S. Attorney’s Office that led to his resignation from State, and omitting details about prior criminal charges and a security clearance suspension. The employee contested the removal, arguing that his omissions were not deceptive and that he had legitimate reasons for his responses.After his removal, the employee filed a "mixed case" complaint with DHS’s Office of Diversity and Civil Rights, alleging both discrimination and non-discrimination grounds for his termination. DHS failed to meet certain regulatory deadlines for handling his complaint. The employee eventually appealed to the Merit Systems Protection Board (the Board), including a motion for sanctions against DHS for missing deadlines. The Board’s administrative judge denied the sanctions request, sustained four of the eleven specifications supporting the lack of candor charge, and upheld the penalty of removal. The full Board split, making the initial decision final and appealable.On review, the United States Court of Appeals for the Federal Circuit held that, because the employee had formally abandoned his discrimination claims, the court lacked jurisdiction to review the denial of sanctions, as those arguments were based solely on the discrimination aspects of the case. The court affirmed the Board’s findings that four specifications of lack of candor were supported by substantial evidence and that the penalty of removal was reasonable. The court dismissed the appeal as to sanctions for lack of jurisdiction and affirmed the Board in all other respects. View "JADUE v. DHS " on Justia Law

A dispute arose from the City and County of Honolulu’s first special election for the District IV councilmember seat, held August 8, 2026. The controversy centered on whether the term limit provision in the Revised Charter—which prohibits anyone from being “elected to the office of councilmember for more than two consecutive four-year terms”—barred the incumbent, who had been elected in both 2019 (in a special election following the invalidation of the 2018 results) and 2022, from running again for the 2027–2031 term. The 2019 election had followed a court-ordered re-run between the same two candidates after irregularities invalidated the 2018 contest.After the Acting City Clerk rejected objections to the incumbent’s eligibility, a candidate filed a declaratory judgment action in the Circuit Court of the First Circuit, which ruled the incumbent ineligible. Because ballots had already been printed, election officials notified voters that votes for the incumbent would not count toward determining an eligible candidate for the next round. As no candidate received a majority in the August election, officials prepared to advance the top two eligible candidates, excluding the incumbent, to the second special election.The Supreme Court of the State of Hawai‘i reviewed both the procedural and substantive issues. The court held that the Circuit Court should have dismissed the declaratory judgment action as procedurally improper, because Hawai‘i Revised Statutes § 12-8 provided the exclusive remedy for pre-election eligibility challenges. However, the Supreme Court determined it could address the merits under the statutes governing election contests. On the merits, the court concluded the incumbent was “elected to” two consecutive four-year terms and was thus ineligible to run for a third consecutive term under the Revised Charter. The court ordered that only the two eligible candidates be placed on the ballot for the second special election. Judgment was entered for the defendants. View "Iwasa v. Nago" on Justia Law

The plaintiff alleged she experienced race and gender discrimination, harassment, and retaliation while employed at a facility operated by a subsidiary corporation in Michigan. Initially, she sued the parent corporation, claiming it was her employer and responsible for the alleged misconduct. The parent corporation contended she had sued the wrong entity and provided evidence that the subsidiary, not the parent, was her employer. The district court in the first case sided with the parent corporation, finding that it was not the plaintiff’s employer and that the complaint did not support a joint-employer theory or veil-piercing. After this ruling, the plaintiff filed a new suit against the subsidiary, asserting similar factual allegations and an additional hostile work environment claim under Michigan law.In the United States District Court for the Eastern District of Michigan, the subsidiary moved to dismiss the new case, arguing that claim preclusion barred the suit because the parent and subsidiary were in privity. The district court rejected the argument that the subsidiary had controlled the prior litigation but applied a “close-and-significant-relationship” test based on the parent-subsidiary relationship and equitable considerations. Concluding that privity existed and the other elements of claim preclusion were met, the district court granted the subsidiary’s motion to dismiss.The United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The appellate court held that the district court erred by applying the “close-and-significant-relationship” test for privity, rather than the six recognized exceptions to nonparty preclusion from Taylor v. Sturgell. None of the exceptions—pre-existing substantive legal relationship, control, or adequate representation—applied to the facts. Therefore, claim preclusion did not bar the plaintiff’s suit against the subsidiary. The Sixth Circuit reversed the district court’s decision. View "Williams v. Mastronardi Produce-USA, Inc." on Justia Law

A family group brought claims in Oklahoma state court against an energy company, alleging underpayment of oil and gas royalties over several decades. These claims overlapped with those in a separate class action brought by another party against the company and its related entities, also concerning underpayment of royalties. The class action was removed to federal court, where a settlement was reached and approved by the United States District Court for the Eastern District of Oklahoma. The settlement covered claims for a defined period, and included a permanent injunction barring class members from pursuing similar claims. The family did not opt out of the settlement and received compensation under its terms.Later, the energy company sought summary judgment in the family’s original state case, arguing that the federal settlement released the company from liability for claims during the covered period. When summary judgment was denied, the company returned to the federal district court, seeking enforcement of the settlement’s injunction against further pursuit of those claims by the family in state court. The federal court declined to issue a new injunction but found that the family’s ongoing litigation of released claims violated the original injunction. The court ordered the family to either show cause for their violation or agree to abide by the injunction and dismiss the released claims. The family appealed this order to the United States Court of Appeals for the Tenth Circuit.The Tenth Circuit determined that it lacked appellate jurisdiction over the order. The court held that a post-judgment civil contempt or enforcement order is not final and appealable unless the district court both finds contempt and imposes a specific, unavoidable sanction. Because the district court’s order did neither, and because no alternative grounds for appellate jurisdiction applied, the Tenth Circuit dismissed the appeal. View "Fischer v. XTO Energy" on Justia Law