Justia Civil Procedure Opinion Summaries

A fire captain who served as vice president of a local firefighters’ union was also a member of the Jefferson Parish Fire Civil Service Board. The union previously paid for legal counsel for members appearing before the Civil Service Board, but stopped doing so after the Louisiana Board of Ethics issued an advisory opinion, and later a binding declaratory opinion, stating that such payments violated Louisiana law while any union officer served on the board. The union challenged the Board of Ethics’ interpretation in state court, arguing that it misapplied state law, and then filed a federal lawsuit claiming this restriction violated its First Amendment rights.The United States District Court for the Eastern District of Louisiana granted the union a preliminary injunction on First Amendment grounds, preventing enforcement of the ethics board’s opinion against the union. The district court also declined to abstain under the doctrines established in Younger v. Harris and Railroad Commission of Texas v. Pullman Co. The Louisiana defendants appealed, arguing the district court should have abstained and that granting the injunction was an abuse of discretion. While the appeal was pending, all relevant state court proceedings concluded, and, just before oral argument, the fire captain resigned from the Civil Service Board.The United States Court of Appeals for the Fifth Circuit found that the case was moot due to the resignation, as neither party retained a legally cognizable interest in the outcome. The court determined that no live controversy remained, rejected arguments that mootness exceptions applied, and ruled that the appeal and the entire case must be dismissed for lack of jurisdiction. The court vacated the preliminary injunction and remanded to the district court with instructions to dismiss the case. View "Jefferson Parish Firefighters Association, Local 1374 v. Roberts" on Justia Law

Several related companies, along with an individual, operated the Inn of Chicago. After purchasing the property, they assumed an existing collective bargaining agreement (CBA) with a labor union. When the City of Chicago approached them to use the Inn to house displaced migrants, the operation resumed, but the employers did not use union members for typical hotel functions. Instead, these tasks were handled by an outside staffing agency and later by another company managed by the same people. The labor union learned of this arrangement, filed grievances alleging violations of the CBA, and submitted the dispute to arbitration. The union also filed an unfair labor practice charge with the National Labor Relations Board, which was consolidated with the arbitration.The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the arbitration award. The arbitrator had found that the Inn was operating as a “hotel” within the meaning of the CBA while housing migrants, that the related companies and individual were a “single employer” under the CBA, and that they violated both the CBA and the National Labor Relations Act by failing to use union employees and failing to provide notice or bargain with the union. The district court confirmed the arbitration award, rejecting the employers’ arguments regarding arbitrability, notice, and authority.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s confirmation of the arbitration award. The court held that the employers were bound by the arbitration because they participated without reserving objections, and the arbitrator’s findings drew from the CBA and issues submitted by the parties. The court found no due process or public policy violation and affirmed the district court’s confirmation of the award. View "Elmar Hotel Management, LLC v Unite Here Local 1" on Justia Law

After a homeowners association obtained a money judgment against a homeowner for unpaid assessments, it levied the homeowner’s interest in her property and proceeded with a sheriff’s sale. The homeowner did not satisfy the judgment or obtain release of the levy before the sale occurred. A third-party bidder purchased the homeowner’s interest in the property at auction. After the sale but before the court ratified it, the homeowner paid the judgment in full to the association. The association then notified the court of the satisfaction and requested that the sale be vacated, arguing the judgment had been satisfied prior to ratification.The District Court of Maryland, sitting in Prince George’s County, agreed with the association, concluding that the sale could be vacated since the homeowner satisfied the judgment before ratification. On appeal, the Circuit Court for Prince George’s County affirmed, holding a hearing and again ruling that the sale was not complete until ratification and thus could be undone by post-sale satisfaction of the judgment.The Supreme Court of Maryland reviewed the case. It held that a judgment-debtor’s satisfaction of the judgment after a sheriff’s sale, but before ratification, cannot be raised as an exception to the sale under Maryland Rule 14-305(e)(1). Post-sale satisfaction is not an irregularity in the sale and does not void the purchaser’s inchoate equitable interest in the property acquired at auction. The Court emphasized that the judgment-debtor may obtain release of the levy only before sale, and that post-sale options for release are not available. The Court reversed the Circuit Court’s judgment and remanded with instructions to allow the homeowner thirty days to file exceptions to the sale, beginning after remand to the District Court. View "Baltimore XV Props. v. Newsteps' Choice North Homeowners Association, Inc." on Justia Law

After enduring physical and sexual abuse while in the care of James and Susan McLaurie as a young child, the plaintiff obtained a $150 million judgment against both individuals in Missouri state court. Seeking to collect on this judgment, the plaintiff subsequently filed a new action in state court against the McLauries and their homeowner’s insurer, Liberty Mutual, asserting equitable garnishment claims against all three and additional claims, including bad faith and breach of contract, against Liberty Mutual.Liberty Mutual removed the action to the United States District Court for the Eastern District of Missouri, invoking diversity jurisdiction. At the time of removal, James McLaurie had not yet been served but later entered an appearance. The plaintiff moved to remand, arguing a lack of complete diversity, and James McLaurie joined this motion, expressly refusing to consent to removal. The district court disagreed that diversity was lacking but found that the absence of consent from all defendants rendered removal procedurally defective under the requirement of unanimity in 28 U.S.C. § 1446(b)(2)(A). The court granted remand on this procedural ground.On appeal, the United States Court of Appeals for the Eighth Circuit examined whether it had jurisdiction to review the district court’s remand order. The appellate court held that, under 28 U.S.C. § 1447(d), remand orders based on procedural defects—such as a lack of unanimity among defendants—are not reviewable, so long as the district court’s basis was at least “colorably” procedural. The court determined that the district court’s characterization of its order as resting on a procedural defect was colorable. Accordingly, the Eighth Circuit dismissed the appeal for lack of jurisdiction. View "G.T. v. Liberty Mutual Fire Insurance Company" on Justia Law

Two individuals became involved in a public dispute relating to allegations of Russian interference and the passage of the Magnitsky Act. One party, a British citizen, made several statements in media interviews and social media posts from New York, characterizing the other party—a Russian-American lobbyist—as a “spy operator in Washington, D.C.” and linking him to a controversial meeting at Trump Tower in New York. The lobbyist claimed these statements were defamatory and brought suit in the District of Columbia, arguing that the statements caused harm to his reputation in D.C. and that the speaker’s comments established personal jurisdiction.The United States District Court for the District of Columbia reviewed the claim and dismissed the case, holding that it lacked personal jurisdiction over the British citizen. The district court also denied the speaker’s request for attorney’s fees under the D.C. Anti–SLAPP Act, finding that such fees were not warranted because the dismissal was based on lack of jurisdiction rather than on a motion under the statute.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s decision. The court held that the British citizen did not “purposefully avail” himself of the benefits and protections of D.C. law, as required under the minimum-contacts test from International Shoe Co. v. Washington. The statements at issue did not focus on D.C. or create jurisdictionally significant contacts with the forum. The court also affirmed the denial of attorney’s fees, ruling that the D.C. Anti–SLAPP Act does not apply when the dismissal is for lack of personal jurisdiction rather than under the statute’s special motion to dismiss. The court denied the request for jurisdictional discovery. View "Akhmetshin v. Browder" on Justia Law

A group of plaintiffs, including Michael Kelly and several banking entities under his control, alleged that they lost substantial assets following the 2008 financial crisis when the federal government placed Fannie Mae and Freddie Mac into conservatorship. The plaintiffs had invested significant portions of their Tier 1 Capital in preferred shares of these government-sponsored enterprises, following government incentives. After the conservatorship was imposed, the value of these shares plummeted, causing regulatory insolvency in the banks and leading to receivership and asset liquidation. The plaintiffs claimed a loss of $19.4 billion in combined assets and asserted claims for breach of contract and an unconstitutional Fifth Amendment taking.The United States Court of Federal Claims reviewed the amended complaint, which was filed thirteen years after the events in question. The plaintiffs argued that their filing deadline was tolled during the pendency of Washington Federal v. United States, a related class action filed in the same court and appealed to the United States Court of Appeals for the Federal Circuit. The Federal Claims Court dismissed the complaint for lack of subject-matter jurisdiction, reasoning that the six-year statute of limitations in 28 U.S.C. § 2501 was not tolled by the Washington Federal litigation and was not subject to equitable or class action tolling.The United States Court of Appeals for the Federal Circuit reviewed the dismissal de novo. The court affirmed the decision, holding that 28 U.S.C. § 2501 is a jurisdictional time bar and is not subject to American Pipe tolling or any equitable tolling. As a result, the plaintiffs’ complaint was untimely, and the dismissal by the Court of Federal Claims was affirmed. The court did not reach the merits of the claims, as lack of jurisdiction was dispositive. View "KELLY v. US " on Justia Law

A property in Hollis was owned by a trust with Wisarat Manutsom as trustee. The trustee, often traveling abroad, provided various mailing addresses—including in California, Manchester (New Hampshire), and later Maine—as well as an email address, to the town for tax-related correspondence. Mark Copp was authorized to act for the trust and provided his Manchester address. Over several years, the town sent multiple certified mail notices regarding unpaid property taxes and impending tax liens and deeds to these addresses; some were signed for and received, but several were returned as undeliverable. The town also communicated about the delinquent taxes by email. In 2019, after more undelivered certified mailings and no payment for 2016 taxes, the town executed a tax deed transferring ownership to itself, then sent post-deed notices by regular mail and, years later, by certified mail and email.The plaintiff sued in the Superior Court, alleging the town’s notice regarding the 2016 and 2018 tax liens and the 2016 tax deed was constitutionally deficient under the Fourteenth Amendment. The Superior Court granted summary judgment to the town, finding the notice sufficient. The plaintiff's motion for reconsideration was denied, and she appealed.The Supreme Court of New Hampshire reviewed the case de novo. It held that the town’s failure to take additional reasonable steps—such as emailing notice—after certified notices of the impending 2016 tax deed were returned undelivered, and before executing the deed, violated the plaintiff’s due process rights. The court also found the town’s notice of the 2016 tax lien insufficient because it relied on an address that had repeatedly failed. However, notice of the 2018 tax lien, sent to both Manchester and Maine addresses, was deemed sufficient. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Manutsom v. Town of Hollis" on Justia Law

A group of plaintiffs, represented by the same counsel as earlier litigants, alleged injuries caused by cellphone radiation exposure. Their complaints were nearly identical to those in a previous set of cases involving similar claims. The plaintiffs agreed, through joint stipulations filed in their cases, that the outcome of expert admissibility litigation in the earlier cases would apply to their own. This agreement included being bound by both the substantive ruling on whether expert testimony about general causation was admissible and all procedural rulings leading up to that determination. The stipulations were signed by counsel for both sides, and subsequent court orders stayed the plaintiffs’ cases pending the resolution of expert admissibility in the earlier litigation.The Superior Court of the District of Columbia managed the earlier cases by first resolving whether the plaintiffs had admissible expert testimony on general causation, limiting discovery to that issue. After several hearings and rulings, the court ultimately excluded the plaintiffs’ expert testimony under the Daubert/Rule 702 standard, and granted summary judgment to the defendants because the plaintiffs lacked the necessary expert evidence to support their claims. The Brooks plaintiffs later moved to lift the stays in their cases, arguing for broader discovery and the opportunity to present new expert witnesses, but the court denied this motion.The District of Columbia Court of Appeals reviewed whether the Brooks plaintiffs were bound by their agreements and the trial court’s rulings. The court held that the plaintiffs had agreed—expressly or implicitly—to be bound by both the outcome of the expert admissibility litigation and the procedural rulings in the earlier cases. The court affirmed the Superior Court’s grant of summary judgment to the defendants, holding that the plaintiffs lacked admissible expert testimony required to prove their claims. View "Brooks v. Mitsubishi Electric & Electronics US, Inc." on Justia Law

The case involves a lawsuit filed in March 2024 by the City of Chicago against several major fossil fuel companies and a trade association. Chicago alleges the defendants misrepresented the effects of fossil fuel emissions on climate change, leading consumers to use more fossil fuels, which resulted in harm to the city such as increased illness, property damage, and environmental degradation. The city seeks damages only for harm attributable to increased fossil fuel usage due to the alleged misinformation, and specifically excludes claims related to federal property or specialized fuel sales to the federal government.After the complaint was filed in Illinois state court, the defendants removed the case to the United States District Court for the Northern District of Illinois, invoking the federal officer removal statute (28 U.S.C. § 1442(a)(1)). They argued that their work producing and supplying fossil fuels for the federal government brought the case within federal jurisdiction. The district court disagreed, finding the connection between the alleged misconduct and the defendants’ federal work too attenuated, and remanded the case to state court.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s remand order de novo. The Seventh Circuit held that the federal officer removal statute did not support removal here because the defendants’ federal work was not sufficiently connected to Chicago’s claims, which focus on alleged misrepresentations to consumers and resulting non-federal harm. The court noted that the city’s complaint expressly disclaimed injuries related to federal activities, and agreed with the reasoning of other circuits in similar cases. The Seventh Circuit therefore affirmed the district court’s remand order. View "City of Chicago v BP P.L.C." on Justia Law

On August 12, 2014, Eva Pena was injured while attempting to board a Rhode Island Public Transit Authority (RIPTA) bus in Providence. She alleged that the bus driver closed the doors on her, causing her to fall and sustain serious injuries. After her death in 2019, her estate continued the suit, claiming negligence by RIPTA. At trial, testimony was presented from multiple witnesses, including Pena’s deposition, the bus driver, a RIPTA supervisor, and Pena’s son. Central to the dispute was the supervisor’s account of a conversation with Pena, which had been facilitated by an unidentified Spanish interpreter at the scene.The Providence County Superior Court admitted the supervisor’s testimony and report about what Pena allegedly said through the interpreter, overruling objections that this constituted inadmissible hearsay. The jury returned a verdict for RIPTA, finding that the plaintiff had not proven negligence. The plaintiff moved for a new trial, arguing that the trial justice erred in allowing hearsay testimony via the unidentified interpreter. The trial court denied the motion, finding the issue unsettled under Rhode Island law and suitable for appellate clarification.The Supreme Court of Rhode Island reviewed the case and reversed the Superior Court’s denial of a new trial. The Supreme Court held that admitting the supervisor’s testimony and report regarding Pena’s statements, relayed through the unidentified interpreter, was an abuse of discretion because it constituted inadmissible hearsay lacking reliability and trustworthiness. The Court found that this evidence was not cumulative and its admission affected the substantial rights of the parties. The case was remanded for a new trial consistent with the Supreme Court’s opinion. View "Fernandez v. Rhode Island Public Transit Authority" on Justia Law