Justia Civil Procedure Opinion Summaries

A Michigan state prisoner filed a lawsuit against various defendants, alleging constitutional violations and seeking to proceed in forma pauperis, which would allow him to pay filing fees over time or not at all. The key dispute concerned whether the prisoner had accumulated three “strikes” under 28 U.S.C. § 1915(g), which would bar him from proceeding in forma pauperis unless he was in imminent danger of serious physical injury. Two of the actions identified as strikes by the district court involved claims dismissed on Eleventh Amendment immunity grounds.The United States District Court for the Western District of Michigan denied the prisoner’s request to proceed in forma pauperis, finding that he had three strikes under § 1915(g) and that the imminent-danger exception did not apply. Because he had not paid the filing fee, the court dismissed his action without prejudice. The prisoner appealed, specifically challenging the district court’s determination that two actions dismissed on Eleventh Amendment immunity grounds counted as strikes.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. It held that dismissals based solely on Eleventh Amendment immunity grounds do not count as strikes under § 1915(g), unless the dismissing court explicitly labels the claims as frivolous or malicious, which was not done in the actions at issue. The appellate court also determined that issue preclusion did not bar the prisoner from contesting the strike status because the relevant issue was not actually litigated in prior proceedings. Additionally, the court found that the timing of another proposed strike did not meet the statutory requirements. As a result, the Sixth Circuit vacated the district court’s order and remanded for further proceedings, concluding that the prisoner is not barred from proceeding in forma pauperis in this action. View "Henderson v. Kent County" on Justia Law

A train carrying hazardous chemicals derailed in East Palestine, Ohio, resulting in a release of dangerous substances into the environment. This incident led to a class-action lawsuit involving nearly half a million residents. After extensive environmental testing and expert analysis, both sides reached a settlement to avoid prolonged litigation. The settlement established a $600 million fund, allowing residents to receive direct payments and, if desired, additional compensation for waiving personal injury claims. Those with extraordinary losses or injuries could submit claims for further individualized consideration.Prior to this appeal, some objectors challenged the settlement, asserting that class counsel should have reviewed and disclosed more expert evidence regarding long-term risks. The United States District Court for the Northern District of Ohio, after a fairness hearing, approved the settlement and rejected these objections. The United States Court of Appeals for the Sixth Circuit affirmed that approval, citing the adequacy and fairness of the settlement process and the sufficiency of the evidence considered.A small group of residents who had waived personal injury claims subsequently sought relief from the settlement, alleging fraud and misconduct by class counsel and Norfolk Southern. The Sixth Circuit reviewed the district court's denial of relief under Rule 60 for abuse of discretion. The court held that the movants failed to demonstrate fraud on the court, fraud by an opposing party, or extraordinary circumstances warranting relief under Rule 60(b)(3), 60(d)(3), or 60(b)(6). The court further concluded that the district court did not abuse its discretion in denying an evidentiary hearing. The main holding is that the settlement approval stands and the movants are not entitled to relief from judgment. The disposition by the Sixth Circuit is affirmed. View "In re: E. Palestine Train Derailment" on Justia Law

Three individuals challenged the constitutionality of a Missouri statute enacted during an extraordinary legislative session. The statute, Senate Bill 3, involved tax credits for sporting events, support for athletic and entertainment facilities, tax credits for homestead damage, and property tax credits. The plaintiffs, who included a state senator, a state representative, and a Missouri taxpayer, alleged that the law violated several provisions of the Missouri Constitution and sought to enjoin its enforcement. They claimed standing as taxpayers due to alleged direct expenditures of public funds, as legislators because their votes were allegedly nullified, and as a county resident affected by the statute’s property tax provisions.The case was first heard by the Cole County Circuit Court. The defendants moved to dismiss for lack of standing, and legislative leaders intervened in support of dismissal. The circuit court granted the motion, finding that the plaintiffs had not demonstrated taxpayer standing because the statutes cited did not constitute direct expenditures of funds, and that Missouri does not recognize legislative standing. The court dismissed the action with prejudice. After a motion to reconsider based on a new Missouri Supreme Court decision, the circuit court issued an amended judgment, again dismissing for lack of standing and explicitly rejecting arguments based on the fiscal note and legislative standing.Upon appeal, the Supreme Court of Missouri reviewed the circuit court's dismissal de novo. The Court held that the plaintiffs failed to allege facts showing a direct expenditure of funds as required for taxpayer standing, rejected the legislative standing theory, and found no direct standing for the plaintiff from Maries County. The Court affirmed the circuit court’s dismissal, holding that the plaintiffs lacked standing to challenge the statute. The judgment was affirmed. View "Moon vs. State" on Justia Law

The case centers on a government investigation into a leak of highly classified information regarding a military operation. After a news article revealed details previously unreported, authorities suspected that journalists associated with the news outlet might have communicated with confidential sources via LinkedIn. The government obtained two orders under the Stored Communications Act: one requiring LinkedIn to disclose metadata records for the journalists over an eighteen-month period, and another barring LinkedIn from informing anyone, including the journalists and their employer, about the existence of the orders for one year. LinkedIn challenged both orders, arguing that they were substantially overbroad and threatened First Amendment protections by sweeping in unrelated confidential sources.A magistrate judge for the United States District Court for the Eastern District of Virginia found LinkedIn had standing but sided with the government on the merits, holding that LinkedIn could only challenge the orders based on logistical or practical burdens, not on overbreadth or constitutional grounds. The district court adopted this recommendation, rejecting LinkedIn’s arguments regarding overbreadth and First Amendment protections, and upholding both the Disclosure and Secrecy Orders. LinkedIn’s motion for access to ex parte materials and for reconsideration following new information about the government’s disclosure to the news outlet was also denied.Upon appeal, the United States Court of Appeals for the Fourth Circuit found LinkedIn had standing to challenge both orders. The court held that the Disclosure Order was substantially overbroad, violating statutory and constitutional norms, and required the district court to narrow its scope. The court also held that the Secrecy Order was overly broad as a prior restraint and must be modified to allow LinkedIn to disclose the existence of the orders to a single vetted attorney for the news outlet. However, the court affirmed the district court’s denial of LinkedIn’s request for access to ex parte materials, citing national security concerns. The case was affirmed in part, reversed in part, and remanded. View "In re: Application" on Justia Law

The appellants, a family involved in the ballet community, brought a lawsuit against a former student who had publicly accused the family patriarch, her former ballet teacher, of sexual abuse committed in the 1970s and 1980s. The accusations were aired on a podcast, where the defendant discussed her own experiences and those of other named victims, alleging recurring abuse and a coverup at the dance studio. She also made disparaging remarks about the teacher’s wife and son, who had also been active in the studio. The teacher had previously been criminally charged with abuse of another student in the 1980s but was acquitted after trial.The Superior Court of Orange County reviewed the defendant’s anti-SLAPP motion, which argued that the plaintiffs’ slander claims arose from protected activity—statements made in a public forum on matters of public interest—and lacked merit. The trial court found that, while some statements attributed to the defendant were not accurately alleged, those that did accuse the teacher of criminal conduct were privileged under section 47.1 of the California Civil Code, which provides a qualified privilege for sexual assault survivors speaking out without malice. The trial court also found that statements about the wife and son did not accuse them of crimes and therefore did not constitute slander per se.The Court of Appeal of the State of California, Fourth Appellate District, Division Three, affirmed the trial court’s order granting the anti-SLAPP motion. The appellate court held that the defendant’s statements were protected as they were made in connection with an issue of public interest, and plaintiffs did not establish a probability of prevailing. The court interpreted section 47.1 broadly to cover statements about other alleged victims and clarified that malice requires wrongful intent beyond emotional response. The order striking the complaint was affirmed, and the matter remanded for determination of attorney fees. View "Sellars v. Rose" on Justia Law

Eight former employees of a space technology company were dismissed shortly after they circulated an open letter to management expressing concerns about workplace conduct they believed constituted sexual harassment. The letter specifically criticized the company founder’s posts on social media, which the plaintiffs alleged created a hostile work environment. After their termination, the plaintiffs filed suit asserting claims under California law, including hostile work environment sexual harassment, gender discrimination, failure to prevent discrimination and retaliation, and retaliatory termination for opposing alleged sexual harassment.The plaintiffs originally brought their case in state court. The defendant responded by filing an answer and then removed the case to the United States District Court for the Central District of California, asserting diversity jurisdiction. Once in federal court, the defendant moved to compel arbitration, citing arbitration agreements signed by each plaintiff as part of their employment contracts. The defendant argued that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) did not exempt the plaintiffs’ claims from arbitration, contending that the statute required “adequately alleged” sexual harassment—allegations sufficient to survive a federal motion to dismiss.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of the motion to compel arbitration de novo. The Ninth Circuit held that the EFAA exempts the plaintiffs’ case from arbitration. The court ruled that the EFAA’s definition of a “sexual harassment dispute” is satisfied when the complaint asserts conduct alleged to amount to sexual harassment, without requiring allegations sufficient to survive a motion to dismiss. The court affirmed the district court’s order, concluding that the plaintiffs properly invoked the EFAA and that their case “relates to” a sexual harassment dispute. Thus, the arbitration agreements are not enforceable for this case. View "HOLLAND-THIELEN v. SPACEX" on Justia Law

A homeowners association filed suit against a property owner, seeking declaratory judgment and injunctions to prohibit the use of the property for short-term rentals. The owner admitted operating short-term rentals and argued that the restrictive covenants did not clearly prohibit such activity, contending the terms were ambiguous. The association imposed fines and assessments for violations, and neighbors reported nuisance activities such as late-night parties and disruptive behavior by renters. The owner counterclaimed for breach of contract, asserting unequal enforcement and lack of due process.After a five-day bench trial, the District Court of Oklahoma County found that the owner’s use of the property constituted a prohibited business under the clear and unambiguous language of the restrictive covenant, awarded damages based on accumulated fines, issued an injunction, and dismissed the owner’s breach of contract claim. The court found the association to be the prevailing party and awarded attorney fees to be determined later.The owner appealed, and the Oklahoma Court of Civil Appeals, Division II, partially reversed, vacating the injunction and prevailing party status, and remanded for further proceedings on nuisance claims unrelated to restrictive covenants. The association petitioned for certiorari.The Supreme Court of the State of Oklahoma granted certiorari, vacated the appellate court’s opinion, and affirmed the District Court’s judgment. The Court held that the owner’s short-term rental activities violated the clear and unambiguous language of the restrictive covenant, the challenges to fines and assessments lacked merit, the injunction was supported by the evidence, and no abuse of discretion occurred regarding the denial of a new trial. The owner’s challenge to the attorney fees was not preserved for review. The judgment of the District Court was affirmed in full. View "SILVERHAWK HOMEOWNERS ASSOCIATION, INC. v. TAWOSE" on Justia Law

Maria Diaz contracted with a franchisee, SOL Pools, LLC, to build a swimming pool, while SOL Pools operated as a franchisee of Premier Franchise Management, LLC. Diaz initially brought a small claims action in 2022 against SOL for breach of contract and property damage, resulting in a default judgment in her favor. Subsequently, in 2023, Diaz filed suit in district court against both SOL and Premier, alleging breach of contract, fraud, negligence, and violations of the Home Repair Fraud Act, including claims against Premier based on apparent authority. SOL again failed to appear, leading to a default judgment against SOL for damages and punitive damages.The District Court of Oklahoma County allowed Premier to amend the pretrial conference order to assert the defense of res judicata, relying on the prior small claims judgment. The district court then vacated the default judgment against SOL, dismissed Diaz’s claims against SOL with prejudice, and dismissed Diaz’s apparent authority claims against Premier based on claim preclusion. The district court certified its order for immediate appeal under Oklahoma law, and Diaz sought review by petition for certiorari.The Supreme Court of the State of Oklahoma granted certiorari. It held that the district court did not abuse its discretion by permitting Premier to amend the pretrial conference order to add the defense of res judicata. However, it found that the district court erred in dismissing Diaz’s apparent authority claims against Premier without first developing the necessary factual record to determine whether claim preclusion applies under Oklahoma law. The Supreme Court reversed the district court’s certified interlocutory order in part and remanded for further proceedings consistent with its opinion. View "DIAZ v. PREMIER FRANCHISE MANAGEMENT, LLC" on Justia Law

Five individuals who participated as peaceful protesters and independent journalists at demonstrations outside the U.S. Immigration and Customs Enforcement (ICE) facility in Portland, Oregon, alleged that federal law enforcement officers targeted them with non-lethal crowd-control munitions such as tear gas and pepper balls. The plaintiffs claimed this was retaliation for exercising their First Amendment rights. The protests, which occurred between June 2025 and February 2026, often involved both peaceful dissent and significant unrest, including vandalism, trespassing, and obstruction of law enforcement. The plaintiffs were exposed to crowd-control devices during these protests, frequently while in proximity to unlawful activity.The United States District Court for the District of Oregon issued a preliminary injunction prohibiting federal officers from using non-lethal munitions except against individuals posing an imminent threat of physical harm, and ordered that agents’ uniforms be redesigned with conspicuous identifying markings. The district court also certified a provisional class encompassing all individuals who had protested or reported on DHS activities at the Portland ICE facility since June 2025, and denied the government’s motion to stay the injunction pending appeal.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s orders. The Ninth Circuit vacated the preliminary injunction and provisional class certification, holding that the plaintiffs did not demonstrate a likelihood of success on their First Amendment claim. The court found no evidence of an unwritten policy or pattern of retaliation by DHS and held that law enforcement may use non-lethal force to clear crowds and restore order without waiting for an imminent threat of physical harm. The injunction was found to be overbroad, improperly granting relief to non-parties, and unworkable. The class certification was vacated for lack of commonality and failure to satisfy Rule 23(b)(2)’s indivisible-remedy requirement. View "United States v. Robinson" on Justia Law

Apria Healthcare provides home healthcare products and services, employing delivery drivers through third-party agencies and licensed vocational nurses directly. Travis Smith and Uriel Arauz, both former employees, commenced a class action against Apria in Sutter County Superior Court alleging wage and hour violations on behalf of similarly situated employees. Proposed interveners Angela Tisdale and Terrance Pratt are former delivery drivers and named plaintiffs in a separate, related federal action against Apria for similar wage and hour claims, covering delivery drivers hired after the class certification date in another Los Angeles County action.The Sutter County Superior Court preliminarily approved a settlement in the Smith action, which conditionally certified a class and found the settlement fair. Tisdale and Pratt, concerned about a collusive “reverse auction” settlement that might undermine the rights of putative class members in their federal action, filed an ex parte application to intervene in the Smith action after the court’s preliminary approval and class notice. Their application was supported by evidence of their early awareness and concern over the settlement process, but was filed several months after those concerns were first raised.The Court of Appeal of the State of California, Third Appellate District, reviewed the trial court’s denial of the intervention application. The appellate court held that Tisdale and Pratt’s application was untimely, noting that they knew or should have known of risks to their interests well before filing, and their delay prejudiced the settlement process and the original parties. The court affirmed the trial court’s order denying intervention, concluding that the untimeliness of the application defeated both mandatory and permissive intervention. Respondents were awarded costs on appeal. View "Smith v. Apria Healthcare" on Justia Law