Justia Civil Procedure Opinion Summaries

Casey Cotton rear-ended Caleb Crabtree, causing significant injuries. Cotton, insured by Allstate, faced potential liability exceeding his policy limit. Allstate allegedly refused to settle with Crabtree and failed to inform Cotton of the settlement negotiations or his potential liability, giving Cotton a potential bad-faith claim against Allstate. The Crabtrees sued Cotton, who declared bankruptcy. The bankruptcy court allowed the personal-injury action to proceed, resulting in a $4 million judgment for the Crabtrees, making them judgment creditors in the bankruptcy proceeding. Cotton’s bad-faith claim was classified as an asset of the bankruptcy estate. The bankruptcy court allowed the Crabtrees to purchase Cotton’s bad-faith claim for $10,000, which they financed through Court Properties, Inc.The Crabtrees sued Allstate, asserting Cotton’s bad-faith claim. The United States District Court for the Southern District of Mississippi dismissed the action for lack of subject matter jurisdiction, holding that the assignments of Cotton’s claim to Court Properties and then to the Crabtrees were champertous and void under Mississippi law. Consequently, the court found that the Crabtrees lacked Article III standing as they had not suffered any injury from Allstate.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court certified a question to the Supreme Court of Mississippi regarding the validity of the assignments under Mississippi’s champerty statute. The Supreme Court of Mississippi held that the statute prohibits a disinterested third party engaged by a bankruptcy creditor from purchasing a cause of action from a debtor’s estate. Based on this ruling, the Fifth Circuit held that the assignment of Cotton’s claim to Court Properties was void, and thus, the Crabtrees did not possess Cotton’s bad-faith claim. Therefore, the Crabtrees lacked standing to sue Allstate, and the district court’s dismissal was affirmed. View "Crabtree v. Allstate Property" on Justia Law

UnitedHealthCare Insurance Company and its affiliates (collectively, United) were sued by Fremont Emergency Services and other emergency medical providers (collectively, TeamHealth) for underpaying claims for emergency medical services provided to United’s members. TeamHealth alleged that United failed to adequately reimburse them for services rendered under the Emergency Medical Treatment and Labor Act (EMTALA) after their contract with United expired, leaving them as out-of-network providers. TeamHealth claimed United was unjustly enriched and breached an implied-in-fact contract, also asserting statutory claims under the Prompt Pay and Unfair Claims Practices Acts.The case was initially removed to federal court, which found no ERISA preemption and remanded it to state court. The Eighth Judicial District Court of Nevada ruled in favor of TeamHealth, awarding them compensatory and punitive damages, prejudgment interest, and attorney fees. United appealed the judgment and petitioned to seal certain court documents.The Supreme Court of Nevada reviewed the case and found substantial evidence supporting the jury’s verdict on unjust enrichment but not on the implied-in-fact contract or statutory claims. The court held that ERISA did not preempt TeamHealth’s claims and that United was entitled to judgment as a matter of law on the Unfair Claims Practices Act claim, as the statute did not provide a private right of action for medical providers. The court affirmed the compensatory damages for unjust enrichment but vacated the punitive damages award, remanding for recalculation to a 1:1 ratio of compensatory to punitive damages. The court also reversed the prejudgment interest and attorney fees awards under the Prompt Pay Act and remanded for a new determination of prejudgment interest.Additionally, the court denied United’s petition to seal certain documents, finding that United failed to meet its burden to demonstrate the necessity of sealing. The court concluded that the district court did not abuse its discretion in refusing to seal parts of the record. View "UnitedHealthCare Insurance Company v. Fremont Emergency Services" on Justia Law

TWD, LLC filed a complaint against Grunt Style LLC in 2018, alleging trademark infringement. Both companies sell goods with military-related trademarks. Grunt Style counterclaimed, asserting TWD was infringing on its prior trademark. The district court granted Grunt Style's motion for partial summary judgment in April 2022, dismissing all of TWD's claims. The case was reassigned to Judge Hunt, who held a bench trial in 2024 and ordered TWD to pay Grunt Style $739,500. Grunt Style moved to amend the judgment to include interest and permanent injunctive relief, which the district court granted in January 2025.TWD filed a notice of appeal from the amended judgment, which was docketed as appeal No. 25-1305. During a preliminary review, the Seventh Circuit identified a potential jurisdictional issue because the district court's judgment did not explicitly address TWD's counterclaims. The court directed the parties to address whether the judgment was deficient. TWD filed an amended notice of appeal, which was docketed as a new appeal, No. 25-1341. The district court later issued an indicative ruling, signaling its intent to correct the judgment if the case was remanded.The United States Court of Appeals for the Seventh Circuit agreed with the district court's solution and decided to remand the case for correction of the clerical mistake in the judgment. The court retained jurisdiction over the appeal and dismissed the second appeal (No. 25-1341) as unnecessary, without collecting an additional fee. The court emphasized the importance of clear and complete judgments to avoid jurisdictional issues and ensure appellate jurisdiction is clear. View "Grunt Style LLC v TWD, LLC" on Justia Law

The plaintiff, Jeanette Runey, filed a lawsuit against her neighbor, Wayne S. Faring, over a boundary dispute involving a shared driveway between their properties. The plaintiff owns property at 930 East Wallum Lake Road, while the defendant owns property at 860-900 East Wallum Lake Road. In 2019, the defendant initiated an action to determine ownership of the driveway, claiming easement by prescription, necessity, implication, and/or estoppel. The plaintiff counterclaimed for declaratory relief. In 2021, a Superior Court justice ruled in favor of the plaintiff, concluding that she had title to the disputed land, and the defendant did not. Neither party appealed this decision.The plaintiff then sought a preliminary injunction to remove the defendant’s personal property from the disputed land. The defendant opposed, claiming adverse possession. A different Superior Court justice denied the plaintiff’s motion for a preliminary injunction, finding that the plaintiff failed to establish a reasonable likelihood of success on the merits. The plaintiff appealed this decision.The Rhode Island Supreme Court reviewed the case and concluded that the Superior Court erred in dismissing the plaintiff’s appeal after it had been docketed in the Supreme Court. The Supreme Court noted that the proper method to seek review of the denial of a preliminary injunction is through a petition for writ of certiorari, not a direct appeal. Consequently, the Supreme Court denied and dismissed the plaintiff’s appeal.The Supreme Court also expressed concern over the motion justice’s disregard for the unappealed April 7, 2022 judgment, emphasizing the importance of res judicata, which bars the relitigation of issues that were or could have been tried in an earlier action. The case was remanded to the Superior Court for further proceedings consistent with these principles. View "Runey v. Faring" on Justia Law

A transgender girl, D.P., and her mother challenged a new policy by the Mukwonago Area School District that required D.P. to use the boys’ bathroom or a gender-neutral alternative. They argued that the policy violated Title IX of the Education Amendments of 1972 and the Fourteenth Amendment’s Equal Protection Clause. They filed an emergency motion for a temporary restraining order and a preliminary injunction to prevent the policy's enforcement during litigation, citing the precedent set by Whitaker v. Kenosha Unified School District No. 1 Board of Education.The United States District Court for the Eastern District of Wisconsin granted the temporary restraining order and, shortly after, converted it to a preliminary injunction without holding a hearing. The judge found that the case was controlled by the Whitaker precedent and concluded that D.P. was likely to succeed on the merits of her claims. The school district appealed, arguing that the judge erred by not holding an evidentiary hearing and urging the court to overrule Whitaker and a related case, A.C. v. Metropolitan School District of Martinsville.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The appellate court held that an evidentiary hearing is not always required before issuing a preliminary injunction, especially when the opponent does not request one or identify material factual disputes. The court also declined to revisit or overrule Whitaker and Martinsville, reaffirming that the district judge did not abuse his discretion in granting the preliminary injunction based on binding circuit precedent. The court concluded that the slight differences in D.P.'s case did not warrant a different outcome. View "Doe v Mukwonago Area School District" on Justia Law

In October 2017, the FBI mistakenly raided the home of Hilliard Toi Cliatt, Curtrina Martin, and her 7-year-old son in suburban Atlanta, instead of the intended gang hideout. The error occurred due to Special Agent Guerra's reliance on a personal GPS device and the team's failure to notice the correct street sign and house number. The raid resulted in personal injuries and property damage. The plaintiffs sued the United States under the Federal Tort Claims Act (FTCA) for the officers' negligent and intentional actions.The district court granted summary judgment to the government, and the Eleventh Circuit affirmed. The Eleventh Circuit applied a unique approach to FTCA claims, holding that the law enforcement proviso in §2680(h) overrides all exceptions, including the discretionary-function exception, allowing intentional-tort claims to proceed without further analysis. The court also allowed the government to assert a Supremacy Clause defense, which it found valid, leading to summary judgment for the United States.The Supreme Court of the United States reviewed the case and held that the law enforcement proviso in §2680(h) overrides only the intentional-tort exception, not the discretionary-function exception or other exceptions in §2680. The Court also held that the Supremacy Clause does not afford the United States a defense in FTCA suits. The case was vacated and remanded to the Eleventh Circuit to reconsider whether the discretionary-function exception bars the plaintiffs' claims and to assess liability under Georgia state law without reference to a Supremacy Clause defense. View "Martin v. United States" on Justia Law

Donte Parrish, a federal inmate, was placed in restrictive segregated confinement for 23 months due to his suspected involvement in another inmate's death. After being cleared of wrongdoing by a hearing officer, Parrish filed a lawsuit in Federal District Court seeking damages for his confinement. The District Court dismissed his case on March 23, 2020, citing some claims as untimely and others as unexhausted. Parrish, who had been transferred to a different facility, received the dismissal order three months later and promptly filed a notice of appeal, explaining the delay.The Fourth Circuit recognized that Parrish's notice of appeal was filed after the 60-day appeal period for suits against the United States. The court construed his filing as a motion to reopen the time to appeal under 28 U.S.C. §2107(c). On remand, the District Court granted a 14-day reopening period, but Parrish did not file a second notice of appeal. Both Parrish and the United States argued that the original notice was sufficient, but the Fourth Circuit held that Parrish's failure to file a new notice within the reopened period deprived the court of jurisdiction.The Supreme Court of the United States reviewed the case and held that a litigant who files a notice of appeal after the original appeal deadline but before the court grants reopening does not need to file a second notice after reopening. The original notice relates forward to the date reopening is granted. The Court reversed the Fourth Circuit's decision, allowing Parrish's appeal to proceed. View "Parrish v. United States" on Justia Law

Mitek Systems, Inc. (Mitek) filed a declaratory judgment action against United Services Automobile Association (USAA) seeking a declaration of non-infringement concerning four patents related to its MiSnap software product. Mitek argued that it faced potential liability for direct, induced, and contributory infringement, as well as indemnification demands from its licensees after USAA sent them letters seeking to sell licenses to USAA patents.The United States District Court for the Eastern District of Texas initially dismissed Mitek’s complaint for lack of subject-matter jurisdiction and alternatively declined to exercise jurisdiction. On appeal, the Federal Circuit vacated the dismissal and remanded for further proceedings, instructing the district court to conduct a more detailed analysis. On remand, the district court again dismissed the case, finding no subject-matter jurisdiction and reiterating its decision to decline jurisdiction even if it existed.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the district court’s decision. The court agreed that Mitek did not have a reasonable apprehension of suit for direct, induced, or contributory infringement based on the record evidence, including USAA’s allegations and claim charts from prior litigation. The court also found that Mitek’s potential indemnification liability was not sufficient to establish jurisdiction, as the indemnification agreements contained applicable carve-outs and did not create a reasonable potential for liability. Additionally, the court upheld the district court’s discretionary decision to decline jurisdiction, noting that intervention in future litigation involving Mitek’s customers would be a more effective remedy. View "MITEK SYSTEMS, INC. v. UNITED SERVICES AUTOMOBILE ASSOCIATION " on Justia Law

James Hess filed an employment discrimination lawsuit against Union Pacific Railroad Company, claiming he was unlawfully terminated due to his disability. Union Pacific has a "Fitness-for-Duty" policy requiring employees to disclose certain health conditions. Hess, who began working for Union Pacific in May 2013, was prescribed Xanax for post-traumatic stress disorder in 2015. In 2016, Union Pacific prohibited medications like Xanax, and in January 2017, Hess was removed from service and later disqualified from his job following a fitness-for-duty evaluation.The District Court for the District of Nebraska dismissed Hess's action as untimely, agreeing with Union Pacific that the statute of limitations was not tolled while the Harris class action was pending because Hess was not a member of the certified class. The Harris class action, filed in 2016, alleged that Union Pacific's fitness-for-duty policy discriminated against employees with disabilities. The class was initially defined broadly but was later certified under a narrower definition, excluding Hess. The class was decertified by the Eighth Circuit in March 2020, after which Hess filed an EEOC charge and received a right-to-sue letter.The United States Court of Appeals for the Eighth Circuit reviewed the case. Citing its recent decision in DeGeer v. Union Pacific Railroad Co., the court held that Hess was entitled to American Pipe tolling because he was not unambiguously excluded from the certified class. Therefore, the statute of limitations was tolled until the class was decertified. The Eighth Circuit reversed the district court's dismissal and remanded the case for further proceedings, concluding that Hess's lawsuit was timely filed. View "Hess v. Union Pacific Railroad Co." on Justia Law

Robert L. Palmer, a long-time employee of Union Pacific, alleged that the company discriminated against him due to his disability, diabetes, which led to diabetic retinopathy. After undergoing surgery for his right eye in 2011, Palmer continued working until November 2013, when his left eye developed blurred vision. Union Pacific then initiated a fitness-for-duty evaluation, resulting in a February 2014 letter from Dr. Holland, the Chief Medical Officer, imposing permanent work restrictions on Palmer. Despite submitting medical information from his eye doctor in May 2014, which cleared him for work, Palmer received a December 2014 letter reaffirming the permanent restrictions and stating that no further medical information would be considered.Palmer was part of a putative class action (Harris class) filed in February 2016, which alleged that Union Pacific's fitness-for-duty policy discriminated against employees with disabilities. The class was certified in February 2019 but decertified in March 2020. Palmer then filed an individual charge of discrimination with the EEOC in April 2020 and subsequently filed this action under the ADA, claiming his suit was timely due to tolling during the class action.The United States District Court for the District of Nebraska dismissed Palmer's claims as time-barred, concluding that the only adverse employment action occurred in February 2014, outside the class definition period. Palmer's motion to reconsider or amend was denied, as the court found the December 2014 letter was not a separate adverse action but a consequence of the February 2014 action.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the district court relied on an outdated standard for adverse employment actions. Under the new standard from Muldrow v. City of St. Louis, Palmer's allegations that the December 2014 letter caused him harm by denying future review opportunities were sufficient to constitute an adverse employment action. The appellate court reversed the district court's denial of reconsideration and leave to amend, remanding for further proceedings. View "Palmer v. Union Pacific Railroad Co." on Justia Law