Justia Civil Procedure Opinion Summaries

Three Venezuelan nationals, alleged by the government to be members of the Tren de Aragua gang, were detained in Texas following a presidential proclamation under the Alien Enemies Act (AEA). This proclamation, issued in March 2025, authorized immediate removal of Venezuelan citizens aged fourteen or older, residing in the United States, who were not naturalized or lawful permanent residents and were identified as members of the gang. The petitioners challenged the proclamation, arguing that it exceeded the President’s authority under the AEA and violated due process rights. They sought class certification and injunctive relief to prevent removal under the AEA.The United States District Court for the Northern District of Texas denied temporary restraining orders and class certification. On appeal, the Fifth Circuit initially dismissed the case for lack of jurisdiction. The Supreme Court, in A.A.R.P. v. Trump, vacated that dismissal and remanded, instructing the Fifth Circuit to address two issues: whether the petitioners were entitled to a preliminary injunction against removal under the AEA, and whether the notice provided for due process claims was sufficient for the putative class. The Supreme Court also allowed the government to remove the petitioners under other lawful authorities.After remand, the three named petitioners were removed from the United States under the Immigration and Nationality Act (INA), not the AEA. The United States Court of Appeals for the Fifth Circuit concluded that, because the petitioners were no longer in the country and no class had been certified, it was impossible to grant any effectual relief. The Fifth Circuit dismissed the appeal as moot for lack of jurisdiction, declining to substitute new class representatives on appeal but leaving open the possibility for future proceedings in the district court. View "W.M.M. v. Trump" on Justia Law

Reginald Chapman was convicted by an Illinois state court jury of murdering Angela Butler and her son, C.B., in 1998. After his conviction, Chapman sought post-conviction DNA testing on evidence collected during the investigation that had not been tested or could be tested with new technology. He filed a motion under 725 Ill. Comp. Stat. 5/116-3, the Illinois statute governing post-conviction DNA testing. Although the county prosecutor’s office initially agreed to DNA testing, the state court rejected the agreement and dismissed Chapman’s motion, finding the evidence at trial was overwhelming and that further testing would not have altered the verdict. Chapman appealed, but the Illinois Appellate Court affirmed the dismissal, and the Illinois Supreme Court denied his request for review.Following the denial in state court, Chapman filed a suit in the United States District Court for the Northern District of Illinois against the Cook County State’s Attorney, Eileen O’Neill Burke. He challenged the constitutionality of the Illinois post-conviction DNA testing statute on its face under the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial. The district court dismissed the case for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine, which bars lower federal courts from reviewing state court judgments.On appeal, the United States Court of Appeals for the Seventh Circuit found that Chapman had standing to sue, as his injury was fairly traceable to Burke’s refusal to allow DNA testing. The court also held that the Rooker-Feldman doctrine did not bar Chapman’s federal claim because he was challenging the constitutionality of the statute itself, not seeking to overturn the state court judgment. Therefore, the Seventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Chapman v Burke" on Justia Law

Underwood Towers Limited Partnership leased land from the city of Hartford to build apartment buildings and financed the project with a mortgage loan. After defaulting, Underwood executed additional notes and a second mortgage in favor of HUD. Following further defaults and transfers, LPP Mortgage Inc. acquired the second mortgage and notes but did not receive the original of one note—only a lost note affidavit. LPP Mortgage then brought a foreclosure action, seeking not only to foreclose the mortgage but also damages against Underwood and its management agent, CDC Management Corporation.The Superior Court, Complex Litigation Docket, denied Underwood and CDC’s motion to dismiss, ruling that LPP Mortgage had standing to foreclose as the owner of the debt, even without possession of the lost note, relying on New England Savings Bank v. Bedford Realty Corp. Judgment of strict foreclosure and damages was entered. On appeal, the Connecticut Appellate Court affirmed, concluding that LPP Mortgage had standing to pursue foreclosure as the debt owner, despite not being able to enforce the note under the UCC. The case was remanded for setting new law days. After remand, Underwood and CDC again moved to dismiss, arguing that the Connecticut Supreme Court’s later decision in Bank of New York Mellon v. Tope changed the law, requiring possession of the note to foreclose.The Connecticut Supreme Court reviewed the case after transfer from the Appellate Court. The Court held that res judicata barred Underwood and CDC from relitigating LPP Mortgage’s standing, as the issue had already been fully litigated and decided by the Appellate Court. The Supreme Court further held that Bank of New York Mellon v. Tope did not overrule Bedford Realty Corp., and thus the law had not changed. The trial court’s denial of the motions to dismiss was affirmed, and the case was remanded for further proceedings. View "LPP Mortgage Ltd. v. Underwood Towers Ltd. Partnership" on Justia Law

The petitioner challenged the renewal of an annual permit granted to a hotel operator for the use of state-owned, ceded lands fronting the Kahala Hotel. The permit, which allowed the hotel to use the land for recreational and maintenance purposes, was extended several times by the Board of Land and Natural Resources (BLNR). The petitioner requested a contested case hearing (CCH) during a public meeting about the most recent renewal, arguing that the practice of pre-setting lounge chairs on the land discouraged public use. The BLNR denied the request for a hearing and approved the permit renewal. The petitioner appealed this denial.The Circuit Court of the First Circuit affirmed the BLNR’s actions, rejecting the petitioner’s arguments. The petitioner then appealed to the Intermediate Court of Appeals (ICA), which found that the petitioner had a constitutionally protected property interest in a clean and healthful environment under the Hawai‘i Constitution. The ICA concluded that the petitioner was entitled to a CCH and that the denial of such a hearing violated procedural due process. However, since the permit had expired, the ICA remanded the case to the circuit court to determine what relief could be granted, and denied the petitioner’s request for attorney fees under the private attorney general (PAG) doctrine, finding that the requirements for the doctrine had not yet been satisfied.Upon certiorari, the Supreme Court of the State of Hawai‘i held that the PAG doctrine does not require a party to obtain further relief before recovering attorney fees, and that all requirements for the doctrine were met. The court ruled that the hotel operator is liable for all reasonable attorney fees incurred by the petitioner during the certiorari proceedings, including fees for seeking fees, and remanded to the ICA to determine the amount of reasonable fees for the appellate stage. View "Ralston v. Board of Land and Natural Resources." on Justia Law

The case concerns a civil lawsuit brought by a woman, identified by pseudonym, against her uncle and godfather for sexual abuse that occurred when she was a minor. The defendant was previously convicted in a criminal court for related offenses and was incarcerated at the time the civil suit commenced. The plaintiff sought significant compensatory and punitive damages for the injuries suffered due to years of abuse, and a jury ultimately found the defendant liable for several torts, awarding millions in damages.Prior to the civil trial in the Superior Court of Alameda County, the defendant initially had legal representation, paid for with personal funds. However, after those funds were exhausted, he was unable to access additional money held in a blocked account due to an order in his divorce proceedings. The defendant, while incarcerated and unrepresented, made several attempts to gain access to these funds to retain new counsel, but delays in the family court process and issues with notice and communication impeded his efforts. The trial court granted multiple continuances as the defendant sought to resolve the funding issue, but ultimately denied further requests for continuance even after he finally obtained access to some funds, resulting in his proceeding to trial without counsel.The California Court of Appeal, First Appellate District, Division Four, reviewed the trial court’s denial of the defendant’s requests for a continuance. The appellate court held that the trial court abused its discretion and violated the defendant’s constitutional right to meaningful court access by refusing to grant a continuance once he had obtained funds to retain counsel. The appellate court reversed the judgment and remanded the case for a new trial, including on the issue of punitive damages, instructing the trial court to ensure the defendant’s meaningful access to the court consistent with established precedent if he continues to meet the relevant criteria. View "Mary D. v. McCauley" on Justia Law

A naturalized U.S. citizen originally from Iraq was sought for extradition by the Iraqi government to stand trial for two counts of premeditated murder. Iraq alleged that he served as a local leader of Al-Qaeda in Iraq (AQI), involved in the planning and execution of the murders of two Iraqi police officers in Fallujah in 2006. The extradition request was supported by witness statements, including those from a cooperating witness and eyewitnesses who placed him at the scene and described his participation. The defendant had previously fled Iraq for Syria before coming to the United States.After Iraq’s extradition request, the United States filed a complaint in the U.S. District Court for the District of Arizona, where a magistrate judge certified the defendant’s extradition. The defendant challenged the certification through a habeas petition under 28 U.S.C. § 2241. He argued that there was not sufficient probable cause for the charges, that the alleged offenses constituted political acts covered by the political offense exception in the U.S.-Iraq Extradition Treaty, that humanitarian considerations should bar extradition, and that Iraq might prosecute him for offenses beyond those charged. The district court denied the habeas petition, finding the probable cause standard was met, the political offense exception inapplicable, and declining to consider humanitarian grounds or speculative future prosecutions.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of habeas relief. The court held that competent evidence supported probable cause for the charged murders, the district court correctly excluded newly submitted contradictory declarations, and the political offense exception did not apply because AQI was not part of the domestic Sunni insurgency but an international terrorist organization. The panel also held that humanitarian objections and speculative concerns about additional charges were not grounds for relief in this context. View "AL-NOURI V. RUBIO" on Justia Law

Devas Multimedia Private Limited, an Indian corporation, along with several related entities, sought to confirm a $562.5 million international arbitral award against Antrix Corporation Limited, a company wholly owned by India. The award stemmed from a 2005 agreement between Devas and Antrix, under which Antrix was to provide satellite capacity to Devas in exchange for fees. In 2011, Antrix terminated the agreement following a policy decision by the Indian government. Devas initiated arbitration before the International Chamber of Commerce, which resulted in an award in Devas’s favor. Devas then petitioned to confirm the award under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“New York Convention”) in the United States District Court for the Western District of Washington.The district court confirmed the award, finding it had subject matter jurisdiction under the Foreign Sovereign Immunities Act (“FSIA”) arbitration exception and the New York Convention, and personal jurisdiction under the FSIA. The court also rejected Antrix’s argument that the case should be dismissed under the doctrine of forum non conveniens. Antrix appealed, and the Ninth Circuit initially ruled in Antrix’s favor on personal jurisdiction grounds. However, the Supreme Court in CC/Devas (Mauritius) Ltd. v. Antrix Corp., 605 U.S. 223 (2025), reversed, holding that the FSIA does not require a minimum contacts analysis beyond its statutory provisions, and remanded for consideration of alternative arguments.On remand, the United States Court of Appeals for the Ninth Circuit held that the FSIA’s arbitration exception supplied subject matter jurisdiction, the exercise of personal jurisdiction over Antrix was reasonable and comported with the Fifth Amendment, and that forum non conveniens does not apply to actions to confirm foreign arbitral awards under the New York Convention. The Ninth Circuit affirmed the district court’s judgment in part, and reversed and vacated in part on issues related to the standing of certain intervenors, remanding for further proceedings. View "DEVAS MULTIMEDIA PRIVATE LTD. V. ANTRIX CORP. LTD." on Justia Law

A group of plaintiffs, including a data privacy company serving public officials and several individually named police and correctional officers, alleged that a broad range of defendants, such as data brokers and marketing companies, continued to disclose the home addresses and phone numbers of individuals protected under Daniel’s Law after receiving formal requests to cease disclosure. The data privacy company, acting as an assignee for thousands of covered persons, facilitated these take-down requests. Plaintiffs claimed that, despite notice, defendants failed to comply within the statutory period, exposing individuals to risks such as stalking and threats.After the plaintiffs filed numerous civil actions in New Jersey state court, defendants removed the cases to federal court, where the United States District Court for the District of New Jersey, with a judge from the Eastern District of Pennsylvania presiding, consolidated and considered the cases. Defendants moved to dismiss, arguing Daniel’s Law was facially unconstitutional, particularly objecting to the apparent lack of a mental state requirement for liability. The district court denied the motions, reasoning that the statute could be interpreted to require at least negligence, not strict liability, for actual damages, to avoid constitutional concerns.On appeal, the United States Court of Appeals for the Third Circuit certified to the Supreme Court of New Jersey the question of whether Daniel’s Law requires a mental state for liability. The Supreme Court of New Jersey held that Daniel’s Law, as currently written, does not require any mental state—such as negligence, knowledge, or recklessness—to impose liability for actual damages under its civil cause of action. The Court based its decision on the statute’s text, legislative history, and the legislature’s omission of a mental state requirement where such language was used elsewhere in the statute. View "Atlas Data Privacy Corp. v. We Inform, LLC" on Justia Law

A worker was severely injured while operating a piece of agricultural machinery at his place of employment. The machine’s power take-off (PTO) shaft, which should have been equipped with safety guards, lacked those guards at the time of the accident. The worker alleged that the absence of these safety guards was due to his employer’s deliberate removal, and that this action directly caused his injuries. He sued his employer for an intentional tort under Ohio law, specifically invoking a statutory provision that creates a rebuttable presumption of intent to injure when an employer deliberately removes an equipment safety guard and an injury results.The Madison County Court of Common Pleas denied the employer’s motion for summary judgment, finding a genuine dispute of material fact as to whether the employer had deliberately removed the safety guard. The case proceeded to trial, where the jury heard evidence about the condition of the machinery, the employer’s repair practices, and the employer’s responses to safety concerns. The jury found in favor of the worker, awarding significant compensatory damages for his injuries. On appeal, the Twelfth District Court of Appeals reversed, holding that the evidence did not support a finding of deliberate removal as a matter of law, and that the statutory presumption did not apply unless the employer both removed the guard and made a conscious decision not to replace it.The Supreme Court of Ohio reversed the judgment of the court of appeals. It held that when reviewing the denial of summary judgment after a trial, appellate courts must consider the full trial record, not just the pretrial record. The court further held that the statutory presumption applies when there is evidence of deliberate removal of a safety guard, and that courts may not require proof of a separate, additional decision not to replace the guard. The case was remanded for further proceedings consistent with this holding. View "Camara v. Gill Dairy, L.L.C." on Justia Law

A woman and her husband, after marrying, received a parcel of real estate from her parents, which they held as tenants by the entirety in Massachusetts. They planned and undertook substantial renovations, initially funded by gifts from the husband’s parents. When those funds ran out, the husband’s parents provided over $1.5 million more, which was later documented as a loan in a promissory note signed only by the husband, not the wife. The couple’s marriage deteriorated, leading to divorce proceedings. During the divorce, the husband’s parents obtained a default judgment against the husband (but not the wife) for the loan and secured a writ of execution against his interest in the property, which was recorded. After the divorce, the family court awarded the property solely to the wife, free from any claim by the husband, and clarified that it could not adjudicate the parents’ rights under the promissory note.Subsequently, the husband’s parents transferred their judgment to a family trust, which noticed a sheriff’s sale of the husband’s purported interest in the property. The wife sued in state court to stop the sale, the case was removed to federal court, and both sides sought summary judgment. The United States District Court for the District of Massachusetts granted summary judgment to the wife, holding that the divorce and property distribution extinguished the creditor’s interest and that, even if the loan were valid, the wife was not jointly liable because the funds were not spent on “necessaries” under Massachusetts law.On appeal, the United States Court of Appeals for the First Circuit vacated the district court’s prediction of state law concerning the effect of divorce on a creditor’s interest and remanded for factual findings on the validity of the loan as to the wife. The court also found that neither preclusion nor the state’s domestic relations exception barred the wife’s challenge, and that factual disputes remained as to whether the loan was spent on necessaries. The court affirmed, reversed, and vacated in part, remanding for further proceedings. View "Cosel v. Wendt" on Justia Law