Justia Civil Procedure Opinion Summaries

Tijuana Decoster, an African American, served as the Chief Grants Management Officer for the National Institute of Neurological Disorders & Stroke at the U.S. Department of Health and Human Services (HHS). Her working relationship with her supervisor, Robert Finkelstein, deteriorated in 2019, leading to allegations of racial discrimination. Decoster claimed Finkelstein singled her out, treated her with contempt, and threatened to fire her. She was issued a Letter of Expectation and placed on an Opportunity to Demonstrate Acceptable Performance plan. Despite her complaints to Human Resources and Finkelstein, the alleged harassment continued, leading Decoster to retire in February 2020.Decoster filed a formal discrimination complaint with the National Institutes of Health (NIH) in December 2019, alleging harassment, discrimination based on race, and retaliation. NIH's Final Agency Decision in November 2020 found that Decoster was subjected to retaliation but denied her other claims. Decoster then filed a complaint in the District of Maryland, raising three claims under Title VII: hostile work environment, constructive discharge, and retaliation. The district court dismissed her complaint for failure to state a claim under Fed. R. Civ. P. 12(b)(6).The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Decoster’s hostile work environment and constructive discharge claims, finding that her allegations did not establish severe or pervasive conduct or intolerable working conditions. However, the court reversed the dismissal of her retaliation claim, holding that Decoster had sufficiently stated a plausible claim of retaliation under Title VII. The case was remanded for further proceedings on the retaliation claim. View "Decoster v. Becerra" on Justia Law

Provisur Technologies, Inc. owns patents related to food-processing machinery, specifically high-speed mechanical slicers and a fill and packaging apparatus. Provisur sued Weber, Inc. and its affiliates, alleging that Weber's food slicers and SmartLoader products infringed on these patents. The case was tried before a jury, which found that Weber willfully infringed several claims of Provisur's patents and awarded Provisur approximately $10.5 million in damages.The United States District Court for the Western District of Missouri denied Weber's motions for judgment as a matter of law (JMOL) on noninfringement and willfulness, as well as a motion for a new trial on infringement, willfulness, and damages. Weber appealed these decisions.The United States Court of Appeals for the Federal Circuit reviewed the case. The court affirmed the district court's denial of JMOL for noninfringement regarding the '812 and '436 patents, as Weber conceded its noninfringement arguments were no longer available due to an intervening decision. However, the court reversed the district court's denial of JMOL for noninfringement of the '936 patent, finding that Provisur failed to provide sufficient evidence that Weber's SmartLoader could be readily configured to infringe the patent.The court also reversed the district court's denial of JMOL on willfulness, ruling that the evidence presented, including testimony about Weber's failure to consult a third party, was insufficient to establish willful infringement. Additionally, the court found that the district court abused its discretion in allowing Provisur to use the entire market value rule for calculating damages without sufficient evidence that the patented features drove customer demand for the entire slicing line. Consequently, the court reversed the denial of a new trial on damages.The case was remanded for further proceedings consistent with the Federal Circuit's decision. View "PROVISUR TECHNOLOGIES, INC. v. WEBER, INC. " on Justia Law

The City of Chicago’s Department of Water Management hired Tinka Vassileva as a Filtration Engineer (FE) in 2001. Vassileva, who started as an FE II, was promoted to FE III in July 2019. She applied unsuccessfully for promotions to FE V in April 2018 and FE IV in July 2019. Vassileva claimed that the City’s decisions not to interview her for these positions were based on age, gender, national origin, and retaliation for previous discrimination charges she filed with the Illinois Department of Human Rights (IDHR) and the Equal Employment Opportunity Commission (EEOC).The United States District Court for the Northern District of Illinois granted summary judgment in favor of the City on all claims. The court found that Vassileva did not provide sufficient evidence that her age, gender, national origin, or EEOC charges motivated the City’s decision not to interview her for the 2018 FE V position. Additionally, the court concluded that Vassileva had not administratively exhausted her claims related to the 2019 FE IV openings, as she failed to file an EEOC charge based on the City’s 2019 actions before filing the lawsuit.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that Vassileva did not present evidence suggesting that the City’s explanation for not interviewing her in 2018 was pretext for discrimination or retaliation. The court also noted that Vassileva failed to show that the decision-maker was aware of her EEOC charges. Regarding the 2019 claims, the court found that Vassileva waived her argument about administrative exhaustion by not addressing it until oral argument. Thus, the appellate court affirmed the summary judgment in favor of the City. View "Vassileva v. City of Chicago" on Justia Law

A motor vehicle collision occurred in Sussex County, Delaware, involving Joanne Dudsak, a New Jersey resident insured by New Jersey Manufacturers (NJM), and Christopher Koester, a Maryland resident insured by Allstate Insurance Company. NJM paid Personal Injury Protection (PIP) benefits to Dudsak and sought inter-company arbitration in Delaware to recover these costs. Allstate opposed, arguing that NJM's policy, being from New Jersey, did not qualify for arbitration under Delaware law, which requires the vehicle to be registered in Delaware for PIP subrogation rights.The arbitrator ruled in favor of NJM, awarding the full amount and rejecting Allstate's jurisdictional challenge. Allstate then filed a Petition to Vacate the Arbitration Award in the Delaware Chancery Court, arguing that the arbitrator exceeded his authority. NJM moved to dismiss the petition, claiming the issue was moot because Allstate had agreed to tender its policy limits, which would extinguish NJM's subrogation rights under Delaware law.The Delaware Chancery Court denied NJM's Motion to Dismiss, finding that a real dispute remained. The court then addressed the merits of Allstate's Motion for Summary Judgment. The court applied the standard of review under 10 Del. C. §5714(a)(5), which allows vacating an arbitration award if the arbitrated claim was barred by limitation and the objection was raised from the outset. The court found that §2118 of the Delaware PIP statute applies only to vehicles required to be registered in Delaware and does not cover out-of-state policies like NJM's. Consequently, the arbitrator exceeded his authority by accepting jurisdiction over the case. The court granted Allstate's Motion for Summary Judgment, vacating the arbitration award. View "Allstate Insurance Co. v. New Jersey Manufacturers Insurance Co." on Justia Law

A Californian plaintiff purchased several bottles of Banana Boat sunscreen between 2017 and 2020, including Ultra Sport SPF 100, SPF 50, and SPF 30. She later discovered that the SPF 50 bottle contained 0.29 parts per million (ppm) of benzene, a known carcinogen. She alleged that the products were falsely advertised as safe and that the presence of benzene was not disclosed on the labels. The plaintiff claimed she would not have purchased the products, or would have paid less for them, had she known about the benzene contamination.The United States District Court for the Central District of California dismissed the plaintiff’s suit for lack of Article III standing, concluding that she did not demonstrate a non-speculative increased health risk or actual economic harm. The court relied on FDA guidelines permitting up to 2 ppm of benzene in sunscreen, determining that the plaintiff’s allegations did not establish that 0.29 ppm of benzene posed a credible risk of harm or economic injury.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal. The appellate court held that the district court erred by resolving disputed facts in favor of the defendants and prematurely addressing merits issues intertwined with the jurisdictional question of standing. The Ninth Circuit found that the plaintiff adequately established an injury in fact for purposes of Article III standing, as she alleged economic harm from purchasing a product she would not have bought, or would have paid less for, absent the defendants’ misrepresentations. The court also determined that the plaintiff met the causation and redressability elements of standing, as her injury was likely caused by the defendants' alleged misrepresentations and could be redressed by judicial relief. The case was remanded for further proceedings. View "BOWEN V. ENERGIZER HOLDINGS, INC." on Justia Law

In 2022, NavSav Holdings, LLC, a Texas insurance company, acquired Universal Group, Ltd., a Nebraska insurance company. Following the acquisition, NavSav required Universal’s employees to sign noncompete and nonsolicitation covenants, which included Texas choice-of-law and forum-selection clauses. In June 2023, three employees—Austin Michael Beber, Cody Roach, and Jackie Damon—resigned from NavSav and joined a rival company, taking customers with them. NavSav claimed these customers were worth approximately $510,000 in annual premiums.Beber, Roach, and Damon filed lawsuits in Nebraska state court seeking declaratory and injunctive relief, arguing that Nebraska law should apply and the covenants were unenforceable. NavSav filed a lawsuit in Texas state court against the three employees and their new employer, seeking to enforce the covenants under Texas law. The Nebraska cases were removed to the United States District Court for the District of Nebraska, and the Texas case was removed to the United States District Court for the Eastern District of Texas. The Nebraska federal court issued antisuit and preliminary injunctions in favor of the employees, preventing NavSav from litigating in Texas and enforcing the covenants.The United States Court of Appeals for the Eighth Circuit reviewed the case. It vacated the antisuit injunctions for Roach and Damon, affirming only Beber’s antisuit injunction, as his Nebraska case was filed first. The court vacated all preliminary injunctions, finding that the district court erred in its analysis of irreparable harm, which should focus on the individual movants rather than state public policy. The court remanded Beber’s case for consideration of his request for declaratory relief and instructed the district court to evaluate the status of the Texas litigation for Roach and Damon’s cases to determine appropriate actions. The court dismissed NavSav’s appeal regarding the forum-selection clauses for lack of jurisdiction. View "Beber v. Navsav Holdings, LLC" on Justia Law

The case involves Bradley Rodriguez, who applied for disability benefits and supplemental security income, claiming a disability due to a traumatic brain injury, bipolar disorder, and depression. His application was denied by an Administrative Law Judge (ALJ) with the Social Security Administration (SSA). The Appeals Council also denied his request for review. Rodriguez then filed a federal lawsuit challenging the denial of benefits, raising several constitutional issues regarding the appointment of SSA ALJs, Appeals Council members, and the Commissioner of the SSA. He also argued that the ALJ’s decision was not supported by substantial evidence.The United States District Court for the Southern District of Florida granted summary judgment in favor of the Commissioner of the SSA. The court found that the ALJ was properly appointed, the Appeals Council members were not principal officers requiring presidential appointment and Senate confirmation, and the for-cause removal provision for the Commissioner was unconstitutional but severable. The court also held that Rodriguez was not entitled to a new hearing because he did not show that the unconstitutional removal provision caused him any harm. Additionally, the court determined that the ALJ’s decision was supported by substantial evidence.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the Commissioner had the statutory authority to appoint SSA ALJs and properly exercised that authority through ratification in July 2018. The Appeals Council members were deemed inferior officers, not principal officers, and thus did not require presidential appointment and Senate confirmation. The court also agreed that the for-cause removal provision for the Commissioner was unconstitutional but severable, and Rodriguez did not demonstrate entitlement to retrospective relief. Finally, the court found that the ALJ’s decision was supported by substantial evidence, including medical records and vocational expert testimony. View "Rodriguez v. Social Security Administration" on Justia Law

In 2020, East Fork Funding LLC filed a quiet title action against U.S. Bank, N.A., regarding a mortgage recorded against East Fork’s property. The mortgage had been subject to three foreclosure actions, two of which were voluntarily discontinued by the mortgagee. The district court granted summary judgment in favor of East Fork, holding that under the Foreclosure Abuse Prevention Act (FAPA), enacted in December 2022, the voluntary discontinuances did not reset the six-year statute of limitations for bringing a foreclosure action. Consequently, the statute of limitations continued to run from the commencement of the first foreclosure action in 2010 and expired six years later, entitling East Fork to quiet title.The United States District Court for the Eastern District of New York reviewed the case and granted summary judgment in favor of East Fork. The court held that FAPA applied retroactively to the voluntary discontinuances, meaning they did not reset the statute of limitations. Therefore, the statute of limitations began running with the filing of the 2010 action and expired before East Fork commenced the quiet title action. The court also found that retroactive application of FAPA did not violate the U.S. Constitution and that even under pre-FAPA law, the statute of limitations had expired.The United States Court of Appeals for the Second Circuit is currently reviewing the case. The main issue on appeal is whether FAPA applies retroactively to voluntary discontinuances that occurred before its enactment. The court has certified this question to the New York Court of Appeals, as it is a novel question of state law necessary to resolve the appeal. The Second Circuit seeks clarification on whether Sections 4 and/or 8 of FAPA apply to a unilateral voluntary discontinuance taken prior to the Act’s enactment. The court retains jurisdiction pending the New York Court of Appeals' response. View "E. Fork Funding LLC v. U.S. Bank, Nat'l Ass'n" on Justia Law

Crusader Gun Group, L.L.C. applied for a Federal Firearms License (FFL) in November 2020, with Alan Aronstein identified as the president and responsible person. The Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) denied the application, citing Aronstein's history of willfully violating federal firearms laws through his previous roles in other firearms businesses. These violations included over 6,000 recordkeeping errors, failure to report the theft or loss of firearms, and possession of unlawful machine guns. Crusader requested a hearing, but the ATF upheld its decision, leading Crusader to seek judicial review.The United States District Court for the Southern District of Texas reviewed the case and granted summary judgment in favor of the ATF. The court found that the ATF was authorized to deny the application based on Aronstein's willful violations of federal firearms laws. Crusader's cross-motion for summary judgment was denied, prompting an appeal to the United States Court of Appeals for the Fifth Circuit.The Fifth Circuit affirmed the district court's decision. The court held that the ATF was authorized to deny Crusader's FFL application under 18 U.S.C. § 923(d)(1)(C) because Aronstein, as the responsible person, had willfully violated federal firearms laws. The court also rejected Crusader's due process claims, noting that adequate procedural safeguards were in place, including notice, a hearing, and the opportunity for judicial review. Additionally, the court found no abuse of discretion in the district court's decision to stay discovery, as the administrative record was sufficient for summary judgment. The court concluded that the ATF's denial of the FFL application was lawful and supported by substantial evidence. View "Crusader Gun Group v. James" on Justia Law

Plaintiffs Jay and Siv Bennett, along with their corporation Kesha Marketing, Inc., were long-time associates of Isagenix International LLC, a multi-level marketing company. In May 2023, Isagenix informed the Bennetts that it would not renew their accounts, which were set to expire in June 2023. The Bennetts, whose sole income came from Isagenix commissions, sued the company and obtained a preliminary injunction to prevent the termination of their business relationship.The United States District Court for the District of Arizona granted the preliminary injunction, finding that the Bennetts were likely to succeed on the merits of their claims. The court concluded that the contracts between the Bennetts and Isagenix were likely bilateral and that the modifications allowing Isagenix to terminate the contracts at will were not valid under Arizona law. The district court also found that the Bennetts would suffer irreparable harm due to the contractual limitation on consequential damages.The United States Court of Appeals for the Ninth Circuit reviewed the case and agreed with the district court that the Bennetts had shown a likelihood of success on the merits. The Ninth Circuit held that the contracts were likely bilateral and that the modifications were not validly executed under Arizona law. However, the Ninth Circuit found that the district court erred in its analysis of irreparable harm. The appellate court held that a contractual limitation on consequential damages does not constitute irreparable harm for purposes of equity. Consequently, the Ninth Circuit vacated the preliminary injunction and remanded the case for further proceedings to address the Bennetts' other theories of irreparable injury. View "BENNETT V. ISAGENIX INTERNATIONAL LLC" on Justia Law