Justia Civil Procedure Opinion Summaries

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Harrison Sanders and Trinity Turner, divorced parents of two children, were involved in a legal dispute over compliance with a Family Court Order of Protection From Abuse (PFA Order) against Turner. The PFA Order required Turner to undergo evaluations by a certified treatment program and obtain a psychological evaluation. Turner failed to comply, leading to a contempt finding and a daily fine of $200 until compliance.The Family Court Commissioner found Turner in contempt twice. The first contempt order imposed a daily fine for noncompliance, and the second contempt order calculated the total fine at $51,200 for continued noncompliance. Initially, the Commissioner directed that the fine be paid to Sanders. Turner sought review by a Family Court Judge, who upheld the contempt finding and fine amount but ruled that the fine should be paid to the court, not Sanders. Sanders filed a motion for reargument, which the court denied, maintaining that the fine was to be paid to the court as it was intended to coerce compliance with the court's order.The Supreme Court of Delaware reviewed the case and affirmed the Family Court's decision. The court held that coercive contempt fines, unless compensatory in nature, should be paid to the court. The court reasoned that it is the court's authority being vindicated through such fines, not the rights of a private litigant. The court also addressed procedural arguments, concluding that the Family Court Judge had the authority to review and modify the Commissioner’s orders and that Sanders suffered no prejudice from the court’s decision to consider the payment recipient issue. The Supreme Court denied Sanders' request for attorneys' fees, affirming the Family Court's judgment. View "Sanders v. Turner" on Justia Law

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Kenneth Ray Jenkins, a pretrial detainee at Wilson County Detention Center (WCDC) in 2018, alleged that he was subjected to unsanitary living conditions, including confinement in cells infested with feces, which led to a bacterial illness. Jenkins, who suffers from mental health disorders, claimed that he was denied his medication, placed in solitary confinement, and later moved to an unsanitary "Rubber Room." He further alleged that he was denied medical attention for severe rectal bleeding for several months, which resulted in a diagnosis of multiple medical conditions.Jenkins filed a pro se complaint under 42 U.S.C. § 1983, asserting violations of his Fourteenth Amendment rights. The United States District Court for the Eastern District of North Carolina dismissed most of his claims but allowed his conditions-of-confinement and deliberate-indifference claims against Sheriff Calvin Woodard to proceed. Jenkins requested additional time for discovery and appointment of counsel, both of which were denied by the district court. The court granted summary judgment in favor of Sheriff Woodard, finding that Jenkins failed to demonstrate a material factual dispute.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court abused its discretion in denying Jenkins’s requests for counsel and additional time for discovery. The appellate court noted that Jenkins’s severe mental illness, lack of legal knowledge, and inability to access legal materials and evidence while incarcerated demonstrated that he lacked the capacity to present his claims. The Fourth Circuit reversed the district court’s denials of Jenkins’s requests for discovery and counsel, vacated the summary judgment decision, and remanded the case for further proceedings, directing the district court to appoint counsel for Jenkins. View "Jenkins v. Woodard" on Justia Law

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In July 2019, Tyler Blue, an inmate at Spring Creek Correctional Center, assaulted fellow inmate Patrick Torrence, causing abrasions, bruising, a mild concussion, and aggravation of a preexisting hip injury. Blue was criminally charged and pleaded guilty to assault in the fourth degree. In May 2022, Torrence filed a civil complaint against Blue, seeking damages for the injuries he sustained from the assault. Torrence's complaint referenced criminal statutes and sought restitution and compensation under various Alaska Statutes.The Superior Court of the State of Alaska, Third Judicial District, Seward, dismissed Torrence's complaint for failure to state a claim. The court concluded that the criminal statutes cited by Torrence did not support a private cause of action. Blue had argued that he could not be subjected to double jeopardy and that the court had already rendered judgment against him in the criminal case, including restitution. Torrence opposed the motion, asserting that the damages ordered in the criminal case were paid to the government, not to him, and that he had not been compensated for his injuries.The Supreme Court of the State of Alaska reviewed the case and concluded that Torrence's complaint, despite its reliance on criminal statutes, stated a claim for civil battery. The court held that the Superior Court erred in dismissing the complaint because Torrence had alleged facts consistent with a civil tort claim for battery. The court noted that the criminal conviction for assault did not preclude Torrence's civil suit for damages and that double jeopardy did not apply to civil claims. The Supreme Court reversed the Superior Court's dismissal and remanded the case for further proceedings, including providing procedural guidance to the self-represented litigants. View "Torrence v. Blue" on Justia Law

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Cephia Hayes, an employee of the New Jersey Department of Human Services (NJDHS) since 2004, alleged that her supervisor began sexually harassing her in 2016 and retaliated against her when she rebuffed his advances. In October 2019, Hayes filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC). The EEOC decided not to pursue her case and communicated this decision to Hayes's lawyer via email on March 11, 2020, stating that a right-to-sue letter would be issued. The EEOC also posted the right-to-sue letter to its online portal on the same day.The United States District Court for the District of New Jersey granted summary judgment in favor of NJDHS, ruling that Hayes's Title VII claims were time-barred. The court determined that the 90-day filing period began either when the EEOC emailed Hayes's lawyer or when the right-to-sue letter was posted to the EEOC's online portal. Consequently, the court found that Hayes's lawsuit, filed on November 24, 2020, was untimely.The United States Court of Appeals for the Third Circuit reviewed the case and vacated the District Court's decision. The Third Circuit held that the March 11 email from the EEOC to Hayes's lawyer did not start the 90-day clock because it was not equivalent to a right-to-sue letter. The court also ruled that the posting of the right-to-sue letter to the EEOC's online portal did not suffice to start the 90-day period without direct communication to Hayes or her lawyer. The court found that Hayes had presented sufficient evidence to rebut the presumption that she received the right-to-sue letter three days after it was mailed, creating a genuine issue of material fact regarding the timeliness of her lawsuit. The case was remanded for further proceedings. View "Hayes v. New Jersey Department of Human Services" on Justia Law

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The case involves a failed business relationship between Mike Jones, Jeremy Sligar, and Sligar's business, Overtime Garage, LLC. Jones claimed they formed a joint venture in 2011 to buy and sell used vehicles, which Sligar disputed. The relationship deteriorated, and Sligar terminated the venture in 2016. Jones filed a complaint in 2016 seeking a declaratory judgment, dissolution of the joint venture, and other relief. Sligar counterclaimed for similar relief. During the litigation, Safaris Unlimited, LLC, bought Jones's interest in the case at a sheriff's sale and settled the case by dismissing Jones's claims against Sligar.The District Court of the Fifth Judicial District, Twin Falls County, denied Jones's motion to set aside the judgment in the first case (Sligar I) and granted summary judgment to Sligar in the second case (Sligar II), finding that Jones's claims were barred by res judicata. The court also awarded attorney fees to Sligar and Safaris, finding Jones's motion to set aside the judgment was frivolous and untimely. Jones appealed these decisions, arguing the consolidation of small claims actions with Sligar I was improper and that his Rule 60(b) motion was timely.The Supreme Court of Idaho affirmed the district court's decisions. It held that the consolidation of the small claims actions with Sligar I was proper, as the small claims were related to the disputed property in Sligar I. The court also found that Jones did not file his Rule 60(b) motion within a reasonable time, as he delayed over five months without a valid reason. Additionally, the court upheld the summary judgment in Sligar II, agreeing that Jones's claims were barred by res judicata. The court awarded attorney fees to Sligar for the appeal in Sligar I but not in Sligar II, as Sligar did not prevail on its cross-appeal. View "Jones v. Sligar" on Justia Law

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Koss Corporation (Koss) owns several patents related to wireless earphones. Koss filed a patent infringement lawsuit against Bose Corporation (Bose) in the Western District of Texas, alleging infringement of three patents. Bose challenged the venue and also filed for inter partes review (IPR) of the patents with the Patent Trial and Appeal Board (PTAB). Concurrently, Bose sought a declaratory judgment of noninfringement in the District of Massachusetts. The Texas court dismissed Koss's case for improper venue, leading Koss to file counterclaims in Massachusetts. The Massachusetts court stayed the case pending the IPR outcomes.In parallel, Koss's infringement action against Plantronics, Inc. was transferred to the Northern District of California. Plantronics moved to dismiss the case, arguing that the patents were invalid under 35 U.S.C. § 101. The California court agreed, invalidating all claims of the patents. Koss amended its complaint but eventually stipulated to dismiss the case with prejudice, without appealing the invalidation order.The United States Court of Appeals for the Federal Circuit reviewed the PTAB's decisions on the IPRs. However, since the California court had already invalidated all claims of the patents and Koss did not appeal this decision, the Federal Circuit found the appeals moot. The court held that the invalidation order from the California court was final and precluded any further action on the patents, leading to the dismissal of the appeals. View "KOSS CORPORATION v. BOSE CORPORATION " on Justia Law

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T.W., a Harvard Law School graduate with disabilities, sued the New York State Board of Law Examiners for denying her requested accommodations on the New York State bar exam in 2013 and 2014. She alleged violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. T.W. claimed that the Board's actions caused her to fail the bar exam twice, resulting in professional and financial harm.The United States District Court for the Eastern District of New York initially denied the Board's motion to dismiss, finding that the Board had waived its sovereign immunity under the Rehabilitation Act. However, the United States Court of Appeals for the Second Circuit reversed this decision, holding that the Board was immune from suit under Section 504. On remand, the district court granted the Board's motion to dismiss T.W.'s Title II claim, ruling that the Board was an "arm of the state" and entitled to sovereign immunity. The court also held that Title II did not abrogate the Board's sovereign immunity for money damages and that T.W. could not seek declaratory and injunctive relief under Ex parte Young.The United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that the Board is an arm of the state and thus entitled to sovereign immunity. It further concluded that Title II of the ADA does not validly abrogate sovereign immunity in the context of professional licensing. Additionally, the court found that the declaratory relief sought by T.W. was retrospective and therefore barred by the Eleventh Amendment. The court also ruled that the injunctive relief sought by T.W. was not sufficiently tied to an ongoing violation of federal law, making it unavailable under Ex parte Young. Consequently, the court affirmed the dismissal of T.W.'s claims for compensatory, declaratory, and injunctive relief. View "T.W. v. New York State Board of Law Examiners" on Justia Law

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Webuild S.P.A., an Italian investment company, formed a consortium with other companies to work on the Panama Canal expansion project. After the project's completion, Webuild initiated an arbitration against Panama under the ICSID, alleging that Panama breached its obligations under a bilateral investment treaty by providing incomplete information and making unfair financial demands. Webuild sought discovery from WSP USA, which had acquired the project's engineering consultant, Parsons Brinkerhoff.The United States District Court for the Southern District of New York initially granted Webuild's ex parte application for discovery under 28 U.S.C. § 1782. However, following the Supreme Court's decision in ZF Automotive US, Inc. v. Luxshare, Ltd., which limited § 1782 to governmental or intergovernmental tribunals, the district court vacated its order and quashed the subpoena. The court concluded that the ICSID arbitration tribunal did not qualify as a governmental or intergovernmental entity under § 1782.The United States Court of Appeals for the Second Circuit reviewed the district court's decision de novo. The appellate court affirmed the lower court's ruling, agreeing that the ICSID tribunal did not exercise governmental authority as required by § 1782. The court noted that the tribunal was formed specifically for the arbitration, funded by the parties, and its members had no official governmental affiliation. Thus, the ICSID tribunal did not meet the criteria established by the Supreme Court in ZF Automotive for a "foreign or international tribunal" under § 1782. View "Webuild v. WSP USA Inc." on Justia Law

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Healthy Blue, a vendor, submitted a proposal to operate Nebraska’s Medicaid managed care program but was not selected. After its bid protest and request for reconsideration were denied by the Nebraska Department of Health and Human Services (DHHS), Healthy Blue filed a lawsuit in the district court for Lancaster County against state officials and the winning bidders. Healthy Blue sought declaratory and injunctive relief under the Uniform Declaratory Judgments Act (UDJA), claiming DHHS acted unlawfully in awarding the contracts.The district court overruled the state officials' motion to dismiss, which argued that Healthy Blue lacked standing as a taxpayer and that the claim was barred by sovereign immunity. The court found that Healthy Blue adequately pled taxpayer standing and that the claim was not barred by sovereign immunity because it sought relief from an invalid act by public officers. The state officials then moved for summary judgment, reiterating their sovereign immunity argument. The district court denied this motion, maintaining that the claim was an official-capacity suit not barred by sovereign immunity.The Nebraska Supreme Court reviewed the case. The court held that the state officials' motion for summary judgment was not based on the assertion of sovereign immunity, as they did not appeal the district court's ruling that the claim was an official-capacity suit. The court emphasized that standing and sovereign immunity are distinct jurisdictional concepts and that the question of standing can be reviewed on appeal of a final order without being effectively lost. Consequently, the Nebraska Supreme Court dismissed the appeal for lack of jurisdiction. View "Community Care Health Plan of Nebraska, Inc. v. Jackson" on Justia Law

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In 2006, David and Jill Landrum, along with Michael and Marna Sharpe, purchased land in Madison County to develop a mixed-use project called the Town of Livingston. The project stalled due to the 2008 financial crisis and legal issues. In 2010, Jill and Marna formed Livingston Holdings, LLC, which owned the development properties. Marna contributed more financially than Jill, leading to a disparity in ownership interests. In 2014, Marna sold her interest to B&S Mississippi Holdings, LLC, managed by Michael Bollenbacher. Jill stopped making her required monthly contributions in December 2018.The Madison County Chancery Court disqualified Jill as a derivative plaintiff, realigned Livingston Holdings as a defendant, and dismissed several claims. The court found that Jill did not fairly and adequately represent the interests of the company due to personal interests and economic antagonisms. The court also granted summary judgment in favor of several defendants and denied the Landrums' remaining claims after a bench trial.The Supreme Court of Mississippi reviewed the case and affirmed the lower court's decision to disqualify Jill as a derivative plaintiff and exclude the Landrums' expert witness. The court found that Jill's personal interests and actions, such as failing to make required contributions and attempting to gain control of the company, justified her disqualification. The court also affirmed the dismissal of claims for negligent omission, misstatement of material facts, civil conspiracy, fraud, and fraudulent concealment due to the Landrums' failure to cite legal authority.However, the Supreme Court reversed and remanded the case on the issues of remedies and attorneys' fees under the Second Memorandum of Understanding (MOU) and the alleged breach of fiduciary duty between B&S and Jill. The court found that the chancellor erred in interpreting the Second MOU as providing an exclusive remedy and remanded for further proceedings to determine if Livingston is entitled to additional remedies and attorneys' fees. The court also remanded for factual findings on whether B&S breached its fiduciary duty to Jill regarding property distribution and tax loss allocation. View "Landrum v. Livingston Holdings, LLC" on Justia Law