Justia Civil Procedure Opinion Summaries

A jury found that the defendant was negligent and awarded the plaintiff over $18.5 million in damages, which, after adding costs and interest, resulted in a judgment of more than $20 million. To stay enforcement of this judgment pending appeal, the defendant was required to post a bond under California law. The defendant, despite having about $1.75 million in assets, asserted that he could not obtain a bond in the statutorily required amount, which was over $30 million, and requested the trial court to waive or reduce the bond to the limit of his insurance policy ($1.25 million).The Superior Court of Sacramento County considered the defendant’s financial declaration and a supplemental declaration detailing the costs and collateral requirements for various bond levels from a bond broker. After evaluating these submissions and hearing arguments, the trial court found the defendant qualified for relief under Code of Civil Procedure section 995.240 and ordered him to post a reduced bond of $1.25 million. The plaintiff then filed a petition for writ of mandate or prohibition, challenging the trial court’s interpretation of “indigent” within the statute and the sufficiency of the evidence supporting the bond reduction.The Court of Appeal of the State of California, Third Appellate District, reviewed the trial court’s decision for abuse of discretion. The appellate court held that “indigent” under section 995.240 is not limited to those in extreme poverty but includes any person unable to obtain sufficient sureties, considering access to the judicial process. The trial court retains discretion to weigh all relevant factors, including the nature of the obligation and the potential harm to the beneficiary. The appellate court also found no evidentiary error in the trial court’s consideration of the defendant’s declarations. Accordingly, the petition was denied, and the trial court’s order was affirmed. View "Guzman v. Super. Ct." on Justia Law

A nonprofit organization dedicated to gun violence prevention filed several administrative complaints with the Federal Election Commission (FEC) in 2018, alleging violations of the Federal Election Campaign Act by two entities associated with a national advocacy group. After the FEC failed to act within the statutory 120-day period, the nonprofit filed suit in the United States District Court for the District of Columbia, seeking an order compelling the FEC to act. Due to a lack of quorum, the FEC remained inactive for an extended period. Eventually, the District Court granted summary judgment to the nonprofit, ordered the FEC to act within 30 days, and later determined the FEC had not complied, thereby allowing the nonprofit to file a citizen suit against the NRA-associated entities.The national advocacy group sought to dismiss the citizen suit, arguing the District Court lacked jurisdiction. It also moved to intervene in the original action, but only for the limited purpose of unsealing the judicial record. Subsequently, after the District Court’s final judgment, the advocacy group filed a motion under Rule 60(b)(4) seeking relief from the orders and judgment, contending that the District Court lacked subject-matter jurisdiction due to mootness and lack of adversity. The District Court denied this motion, holding that the group, as a nonparty, lacked standing to seek relief under Rule 60(b).The United States Court of Appeals for the District of Columbia Circuit reviewed the appeal from the denial of the Rule 60(b) motion. The Court held that only parties to a lawsuit, or those who properly become parties, may appeal an adverse judgment. Since the advocacy group had not used any procedural mechanism to become a party to the underlying suit, it lacked the procedural ability to appeal. Accordingly, the Court dismissed the appeal as impermissible under binding precedent. View "Giffords v. FEC" on Justia Law

Michael Ramirez purchased a house in Texas City, Texas, intending to remodel and resell it. After a fire caused substantial but repairable damage, the City declared the property substandard and, following an inspection, determined it posed a clear and imminent danger. The City sent notice to Ramirez, halted the permit process pending an engineer’s report (which Ramirez never obtained), and the house remained unrepaired for over a year, with Ramirez storing valuable personal property inside. In May 2023, the City demolished the house without further notice. Ramirez then sued, claiming violations of state and federal constitutional rights, including procedural due process and takings, and sought damages for the house, expected profits, personal property, and attorney’s fees.Upon removal to the United States District Court for the Southern District of Texas, Ramirez repeatedly requested a jury trial in various filings. The parties signed a joint case management plan acknowledging a jury demand. The district court initially scheduled a jury trial but, shortly before trial, ordered a bench trial instead, finding the jury demand procedurally deficient. After the bench trial, the court held the City had violated Ramirez’s procedural due process rights but justified the demolition under nuisance abatement, awarding only nominal damages and denying attorney’s fees as Ramirez was not considered the prevailing party.The United States Court of Appeals for the Fifth Circuit reviewed the case, focusing on the denial of a jury trial and damages determinations. The court held that the district court abused its discretion by denying Ramirez’s Rule 39(b) motion for a jury trial, as there were no strong or compelling reasons to do so and Ramirez’s repeated demands were sufficient. The court vacated the district court’s judgment and remanded for further proceedings, including a jury trial and reconsideration of damages and fees. View "Ramirez v. City of Texas City" on Justia Law

The plaintiffs, projects focused on protecting water quality, brought a suit against a clay recycling facility located near Temescal Creek in California, alleging violations of stormwater-permit requirements under the Clean Water Act. The facility, operated by Corona Clay Company, discharged stormwater into Temescal Creek, a tributary of the Santa Ana River. Regulatory authorities had previously issued violation notices to Corona, but no enforcement action was taken by the state. The plaintiffs sought relief for both substantive discharge violations and procedural violations such as monitoring and reporting.The United States District Court for the Central District of California initially found in favor of Corona following a trial. The Ninth Circuit Court of Appeals reversed and remanded, citing an intervening Supreme Court decision, County of Maui v. Hawaii Wildlife Fund, which expanded the scope of the Clean Water Act to include indirect discharges that are the “functional equivalent” of direct discharges. On retrial, the plaintiffs prevailed, and Corona was assessed significant penalties. After the Supreme Court’s Sackett v. EPA decision, which narrowed the definition of “waters of the United States,” Corona moved to dismiss for lack of subject-matter jurisdiction and alternatively sought a new trial. The district court denied both motions, holding that the jurisdictional requirement was met and the issue of whether Temescal Creek qualified as a water of the United States had been conceded.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of Corona’s post-judgment motion to dismiss for lack of subject-matter jurisdiction, holding that whether a waterbody qualifies as a “water of the United States” is a merits question, not a jurisdictional one. However, it reversed the denial of Corona’s motion for a new trial under Federal Rule of Civil Procedure 59, concluding that the intervening Sackett decision rendered a previously foreclosed issue viable. The panel remanded for further proceedings to determine, under Sackett’s standard, whether Temescal Creek is a water of the United States. View "INLAND EMPIRE WATERKEEPER V. CORONA CLAY COMPANY" on Justia Law

A former employee entered into a noncompete agreement with his employer, which barred him from engaging in similar business activities for 12 months within the company’s client base area after his employment ended in April 2024. Months later, the employer alleged that the former employee and his new business violated the agreement and sought a temporary restraining order (TRO) and a preliminary injunction to enforce it. After the parties exchanged filings, the district court issued a TRO in June 2025, set to remain in effect indefinitely, and delayed the hearing on the preliminary injunction multiple times, citing new evidence related to a superseding noncompete agreement.The district court clarified the TRO’s scope, found the petitioners in contempt for violating it, and denied their motion to dissolve the TRO. The court eventually allowed the employer to amend its complaint to reflect the new agreement and later issued an amended TRO. A preliminary injunction was finally issued in April 2026. The petitioners challenged the original TRO by writ petition, arguing that it exceeded the 14-day limit allowed by Nevada Rule of Civil Procedure 65(b).The Supreme Court of Nevada reviewed the case and clarified that, under NRCP 65(b)(2), the 14-day time limit applies to TROs regardless of whether they are issued with or without notice. The court held that a TRO cannot be indefinite and must expire after 14 days unless properly extended for good cause or by consent. Because the district court’s TRO was indefinite and not properly extended, it automatically expired 14 days after issuance. The Supreme Court of Nevada granted the writ of mandamus and directed the district court to declare the TRO expired as of June 23, 2025. View "HAVENS VS. DIST. CT." on Justia Law

A dispute arose over a deed transferring a one-half interest in a farm from a mother to her son, Peter, without consideration, while she was alive. After the mother’s death, her estate, left to four children in equal shares, was inventoried; the contested property was listed as belonging to Peter due to the earlier transfer. David, another son and a beneficiary, objected, claiming that the mother lacked capacity and was unduly influenced when she executed the deed. The estate administrator declined to pursue the claim, believing litigation costs would outweigh the benefit. David then initiated a separate action to invalidate the deed and impose a constructive trust, seeking to restore the property interest to the estate.The 6th Circuit Court–Concord Probate Division held a trial and ruled in favor of David, finding that Peter had unduly influenced the mother and that she lacked capacity at the time of the transfer. The probate court invalidated the deed, deferred ruling on the constructive trust, and awarded attorney’s fees to David. Peter’s motion for reconsideration was denied. He appealed to the New Hampshire Supreme Court and subsequently moved in probate court to vacate all orders for lack of subject matter jurisdiction; the probate court declined to address the motion, noting the issue was already raised on appeal.The Supreme Court of New Hampshire reviewed the case and determined that the probate court lacked statutory subject matter jurisdiction over David’s claims. The court found that the claims, concerning an inter vivos property transfer, did not have the direct connection to estate administration or distribution required for probate court jurisdiction. The Supreme Court vacated the probate court’s order and remanded with instructions to dismiss the petition without prejudice. View "Allen v. Allen" on Justia Law

A medical institution in Puerto Rico borrowed over $10 million from a bank in 1984 to build a hospital, but soon disputes arose regarding the loan. The bank claimed the institution defaulted, while the institution asserted the bank failed to disburse funds as required. Litigation and bankruptcy proceedings followed. In 1991, the parties settled, but the terms of that settlement—whether the debt was split into interest-bearing and non-interest-bearing portions—remained contested. Over the next decades, the loan changed hands, and in 2013 the institution filed for Chapter 11 bankruptcy again. The current loan-holder claimed a significantly higher outstanding balance than the institution believed was owed, due in part to differing interpretations of the 1991 agreement and subsequent bankruptcy plan.The United States Bankruptcy Court for the District of Puerto Rico previously addressed these disputes. It issued orders requiring the institution to demonstrate, with evidence, that the 1991 agreement created a non-interest-bearing note and that it had made payments in accordance with the bankruptcy plan. The court denied discovery, required summary judgment briefing, and ultimately issued an order with minimal analysis, granting the loan-holder’s motion to dismiss and denying the institution’s motion for summary judgment. The court’s reasoning was ambiguous, referencing both summary judgment and pleading standards, and did not clearly identify the basis for its decision.On appeal, the United States District Court for the District of Puerto Rico affirmed, concluding the bankruptcy plan did not incorporate the 1991 bifurcated note arrangement. The United States Court of Appeals for the First Circuit, reviewing the case, found the bankruptcy court’s order insufficiently reasoned to permit meaningful appellate review. The First Circuit vacated the lower courts’ decisions and remanded for further proceedings, instructing the bankruptcy court to clarify its reasoning, identify the applicable legal standards, and consider whether summary judgment or further fact-finding is appropriate. View "Instituto Medico del Norte, Inc. v. Greengift Capital, LLC" on Justia Law

Several counties and municipalities in New York initiated lawsuits in state courts against two pharmacy benefit managers, Express Scripts, Inc. and OptumRx, Inc., alleging that these companies contributed to the opioid epidemic in their communities. The claims are based on state law and center on the defendants’ alleged practices in negotiating with opioid manufacturers and managing prescription formularies, which plaintiffs contend led to an oversupply of prescription opioids and caused substantial public harm and government expense.The defendants removed the cases to federal court—the United States District Courts for the Southern and Eastern Districts of New York—arguing removal was proper under the federal officer removal statute, 28 U.S.C. § 1442(a)(1), because some of the challenged conduct was performed under contracts with federal agencies, such as the Department of Defense (TRICARE), the Office of Personnel Management (FEHBP), and the Veterans Health Administration. After removal, the plaintiffs amended their complaints to disclaim any claims based on the defendants’ work for federal clients, seeking to have the cases remanded to state court. The district courts accepted the disclaimers and remanded the cases.The United States Court of Appeals for the Second Circuit reviewed the district courts’ decisions. It concluded that the disclaimers were ineffective because the alleged wrongful conduct and resulting harms could not be separated between federal and non-federal clients; the conduct was indivisible. Relying on the Supreme Court's decision in Chevron USA Inc. v. Plaquemines Parish, the Second Circuit held that the defendants satisfied all statutory requirements for federal officer removal: they acted under federal direction, were sued for acts relating to federal authority, and asserted colorable federal defenses. The Second Circuit therefore reversed the remand orders and returned the cases to the district courts for further proceedings. View "County of Westchester v. Express Scripts" on Justia Law

The plaintiff suffered severe injuries while working at a drilling site in New Mexico. Nearly two years and eight months after the incident, he filed his first lawsuit in Texas state court, alleging negligence and related claims against the defendants. Texas law provides a two-year statute of limitations for personal injury actions, and the Texas court dismissed his suit with prejudice as time-barred. The plaintiff did not appeal that dismissal. Four months later, the plaintiff brought a substantially similar lawsuit in New Mexico state court, seeking to take advantage of New Mexico’s three-year statute of limitations and its savings statute, which allows a plaintiff to refile within six months after certain dismissals.The New Mexico district court dismissed the second suit, agreeing with the defendants that the savings statute did not apply because the plaintiff failed to timely file his first action. The New Mexico Court of Appeals affirmed, reasoning that pursuing the claim in Texas constituted a failure to prosecute with reasonable diligence, and that the savings statute’s exception for negligence in prosecution applied. The Court of Appeals relied on precedent that interpreted the exception broadly.The Supreme Court of the State of New Mexico granted certiorari to review whether the lower courts correctly applied the savings statute in light of its new decision in Zangara v. LSF9 Master Participation Trust. The Supreme Court clarified that the “negligence in prosecution” exception only applies when the first action is dismissed for failure to prosecute, and rejected the Court of Appeals’ broader analysis. However, the Supreme Court held that the New Mexico savings statute requires the first action to be timely commenced. Because the plaintiff’s Texas lawsuit was itself untimely, the New Mexico savings statute did not apply, and the second suit could not proceed. The Supreme Court affirmed the dismissal. View "Moreno v. Ranger Energy Servs." on Justia Law

The federal government initiated a project to replace the East Wing of the White House, completing demolition in December 2025 and beginning construction of a new wing, which included both a below-ground military installation and an above-ground ballroom. The National Trust for Historic Preservation challenged aspects of the ongoing construction and sought a preliminary injunction to halt the above-ground work due to concerns about its impact on aesthetic, cultural, and historical interests.The United States District Court for the District of Columbia granted the Trust’s motion for a preliminary injunction, allowing only construction strictly necessary for security purposes above ground but permitting below-ground work to continue. The government appealed, and the United States Court of Appeals for the District of Columbia Circuit initially stayed the injunction, then ultimately affirmed the district court’s order. With the injunction set to take effect, the government sought relief from the Supreme Court of the United States.The Supreme Court granted the requested stay of the district court's injunction pending the government’s petition for certiorari. The Court held that the government is likely to succeed in showing the Trust lacks Article III standing, as the Trust’s asserted injury—distress at viewing the new ballroom’s design—does not constitute a concrete and particularized injury. The Court also found that the government would likely suffer irreparable harm from halting construction, given national security concerns and operational needs, while the Trust’s claimed harm was outweighed by these factors. The stay will remain in effect until certiorari is denied or, if granted, until the judgment is issued. View "National Park Service v. National Trust for Historic Preservation in the United States" on Justia Law