Justia Civil Procedure Opinion Summaries

In this dispute, two renewable-energy generating companies, Tyngsboro Sports II Solar, LLC and 201 Oak Pembroke Solar LLC, appealed to the United States Court of Appeals for the First Circuit after their class-action lawsuit was dismissed by the District Court for the District of Massachusetts due to lack of subject-matter jurisdiction. The plaintiffs had a longstanding disagreement with defendants, utility companies National Grid USA Service Company, Inc. and Massachusetts Electric Company, over certain tax-related fees charged to them. The plaintiffs sought redress in federal court after unsuccessful petitions to state authorities.The plaintiffs argued that the district court had jurisdiction due to the case's connection to federal tax law, however, the appellate court disagreed, stating that the plaintiffs' complaint did not bring any claim that arose under federal law. The plaintiffs had brought forth four claims against National Grid, including a request for declaratory relief, a state-law claim for a breach of the covenant of good faith and fair dealing, a state-law claim for restitution and unjust enrichment, and a state-law claim for violating a statutory requirement that public utilities assess only just and reasonable charges.The appellate court affirmed the district court's dismissal of the case, finding that the plaintiffs could not establish federal-question jurisdiction simply by asserting a state-law claim to which there was a federal defense. The court noted that the state-law claims did not necessarily raise a federal issue, and to the extent that one did, the issue was not substantial. As such, the court concluded that the district court lacked jurisdiction over the claims. View "Tyngsboro Sports II Solar, LLC v. National Grid USA Service Co., Inc." on Justia Law

The United States Court of Appeals for the Eleventh Circuit reviewed the decision of the United States District Court for the Northern District of Georgia regarding a dispute over the enforceability of a restrictive covenant in Georgia. The plaintiff, Charles Baldwin, had worked for various franchisees of Express Oil Change, LLC, and was asked to sign a restrictive covenant as a condition of receiving a payment after the franchisees' stores were sold to Express. The covenant restricted Baldwin from engaging in certain competitive business activities for a specified duration and within a specified geographic area. After leaving Express, Baldwin sued, seeking a declaration that the covenant was unenforceable under the Georgia Restrictive Covenants Act (GRCA). The district court preliminarily enjoined the enforcement of the covenant, finding it unreasonable in terms of its geographic scope and duration. On appeal, the Eleventh Circuit found that the district court correctly concluded that the covenant's geographic scope was unreasonable under the GRCA, but that it applied the wrong presumption in concluding that the covenant's duration was unreasonable. The Eleventh Circuit affirmed in part, vacated in part, dismissed the appeal in part, and remanded the case to the district court for reconsideration of its preliminary injunction under the proper presumptions. View "Baldwin v. Express Oil Change, LLC" on Justia Law

K&C Logistics, LLC, brought suit in Madison County, Mississippi Circuit Court against Old Dominion Freight Line, Inc., and Daniel Cooper as the result of a vehicle accident that occurred in Nogales, Arizona. The trial court determined that it did not have personal jurisdiction over Old Dominion. K&C Logistics appealed, asking the Mississippi Supreme Court to find that courts in Mississippi had jurisdiction over Old Dominion. The Court was further requested to interpret the Mississippi Business Corporation Act to hold that Old Dominion, a foreign corporation registered to do business in Mississippi, consented to general personal jurisdiction when it registered to do business in the state. Finding no reversible error in the circuit court order, the Supreme Court affirmed. View "K&C Logistics, LLC v. Old Dominion Freight Line, Inc., et al." on Justia Law

Southern Lift Trucks, LLC ("Southern"), was an Alabama-based, heavy-equipment dealer for Hyundai Construction Equipment Americas, Inc. ("Hyundai Construction"). In May 2022, it filed suit against Hyundai Construction and its alleged parent company, Hyundai Heavy Industries Co., Ltd. (collectively, "Hyundai") asserting various claims. It also sought a preliminary injunction to prevent Hyundai from, among other things, unlawfully allowing Hyundai's dealers to sell certain equipment in Southern's designated territories or advertising that other dealers are authorized to sell that equipment in Southern's territories. Following a hearing, the circuit court entered an order granting Southern's request for a preliminary injunction. After the circuit court issued its injunction order, Southern learned that another Hyundai dealer had allegedly sold some equipment in one of Southern's territories. As a result, Southern filed a petition seeking a finding of contempt and sanctions against Hyundai. Following a hearing, the circuit court entered an order granting Southern's contempt petition. Hyundai appealed that contempt order on due process grounds. Because Hyundai was not given adequate notice of all the contempt allegations asserted against it before the hearing on those allegations (as required by Rule 70A, Ala. R. Civ. P.), the Alabama Supreme Court reversed the contempt order and remanded the case for further proceedings. View "Hyundai Construction Equipment Americas, Inc.v. Southern Lift Trucks, LLC" on Justia Law

Petitioners Insurance Express, LLC ("Insurance Express"), Wayne Taylor, and Julie Singley sought a writ of mandamus to direct a circuit court to vacate an order staying the underlying action against defendants Lynne Ernest Insurance, LLC ("LEI"), Lynne Ernest, Chynna Ernest, and Deadra Stokley. According to the complaint, Lynne and Stokley were longtime employees of Insurance Express. It alleged that they, while still employed by Insurance Express, entered Insurance Express's office after business hours and, without authorization, made electronic copies of various business records related to Insurance Express's clients and insurance policies. Lynne and Stokley resigned soon after and began employment with LEI, which purportedly had been formed by Lynne and Chynna and was a direct competitor of Insurance Express. Lynne and Stokley, it is alleged, then induced some Insurance Express clients to transfer their policies to LEI. Insurance Express sought injunctive relief to, among other things, prevent defendants from communicating with past or current customers of Insurance Express and to require defendants to return any customer information taken by them. It further sought damages for breach of contract, conversion, intentional interference with business relations, breach of fiduciary duty, and civil conspiracy. After review, the Alabama Supreme Court found petitioners established they had a clear legal right to the relief they sought. The Court granted their petition and directed the trial court to vacate its order granting a stay. View "Ex parte Insurance Express, LLC, et al." on Justia Law

Dolgencorp, LLC, appealed a judgment entered on a jury verdict in favor of Deborah Gilliam. In March 2016, Daisy Pearl White Freeman was operating her vehicle in the parking lot of the Northwood Shopping Center. Freeman lost control of the vehicle, ran over a six-inch curb, crossed a sidewalk, and crashed through the storefront of a Dollar General store, striking Gilliam -- a customer of the store. Gilliam sustained serious and permanent injuries. According to an Alabama Uniform Traffic Crash Report, Freeman reported that, immediately before the accident, she had been traveling across the shopping center parking lot when the vehicle's steering wheel began to shake, the vehicle jerked to the left, and the vehicle's brakes failed. The traffic report also indicated that witnesses had observed Freeman's vehicle traveling across the parking lot at a "high rate of speed." The traffic report listed the speed limit in the parking lot at 15 miles per hour; it was estimated that Freeman's vehicle had been traveling approximately 33-34 miles per hour when it collided with the storefront. Gilliam filed suit against, among others, Dolgencorp, which owned the Dollar General store, alleging that Dolgencorp had been negligent and wanton in failing to erect barriers such as bollards outside the store's entrance, which, she claimed, could have prevented Freeman's vehicle from crashing into the storefront and injuring her. Dolgencorp moved for a summary judgment, arguing, among other things, that Gilliam's claims were precluded as a matter of law. The Alabama Supreme Court concurred with the company, finding Gilliam's negligence claim failed as a matter of law. It therefore reversed the trial court's judgment and rendered judgment in favor of Dolgencorp. View "Dolgencorp, LLC v. Gilliam" on Justia Law

A writ of mandamus is reserved for extraordinary circumstances. TikTok, Incorporated, and various related entities contend that the district court’s denial of their motion to transfer to the Northern District of California was so patently erroneous that this rare form of relief is warranted. The district court denied Petitioners’ motion to transfer after finding that five of the eight factors were neutral, and three weighed against transferring to California.The Fifth Circuit granted the petition for writ of mandamus, finding that denying Petitioners’ motion to transfer was a clear abuse of discretion. The court explained that in the district court’s view, Petitioners’ large presence in the Western District of Texas raises an “extremely plausible and reasonable inference” that these employees possess some relevant documents. But the district court cannot rely on the mere fact that Petitioners have a general presence in the Western District of Texas because Volkswagen commands courts to assess its eight factors considering the circumstances of the specific case at issue. Further, the court explained that under Volkswagen’s 100-mile threshold, the Northern District of California is a clearly more convenient venue for most relevant witnesses in this case. The district court committed a clear abuse of discretion in concluding otherwise. View "In Re: TikTok, Inc." on Justia Law

Monarch Casino & Resort, Inc. appealed a district court’s grant of Affiliated FM Insurance Company’s (“AFM”) motion for partial judgment on the pleadings, which denied Monarch coverage under AFM’s all-risk policy provision, business-interruption provision, and eight other additional-coverage provisions. Monarch also moved the Tenth Circuit Court of Appeals to certify a question of state law or issue a stay. Monarch presented AFM with claims incurred through business interruption losses from COVID-19 and government orders directing Monarch to close its casinos. AFM denied certain coverage on the ground that COVID-19 did not cause physical loss of or damage to property. Monarch sued for breach of contract, bad faith breach of insurance contract, and violations of state law. The Tenth Circuit denied Monarch’s motions to certify a question of state law and issue a stay. And it affirmed the district court’s judgment: (1) AFM’s policy had a Contamination Exclusion provision that excludes all-risk coverage and business-interruption coverage from the COVID-19 virus; and (2) Monarch could not obtain coverage for physical loss or damage caused by COVID-19 under AFM’s all-risk provision, business-interruption provision, or eight additional-coverage provisions because the virus could not cause physical loss or damage and no other policy provisions distinguished this case. Accordingly, Monarch could not obtain the coverage that the district court denied. View "Monarch Casino & Resort v. Affiliated FM Insurance Company" on Justia Law

In 2008 Plaintiff Bill Grubb signed an employment agreement with Defendant DXP Enterprises to lead the development and production of horizontal pumps. The agreement recited that the parties intended to create a new company to produce the pumps, and Grubb would own 10%. If the project became a success, Grubb had the right under the employment agreement to require DXP to buy his ownership stake at a price based on the new company’s gross revenue. The project was successful; in March 2019, Grubb gave notice to DXP that he wanted to sell his ownership stake in accordance with the agreement. But DXP informed Grubb it had never formed the new company, so there was nothing for it to purchase under the agreement. Grubb brought this action in the United States District Court for the Northern District of Oklahoma against DXP, asserting claims for breach of contract, actual and constructive fraud, conversion, breach of fiduciary duty, and unjust enrichment; and sought a declaratory judgment. After the parties filed cross-motions for summary judgment, the district court granted summary judgment in favor of DXP on all claims. Grubb appealed. After review, the Tenth Circuit found sufficient evidence of bad faith by DXP (in failing to form the new company) to support Grubb’s breach-of-contract claim but otherwise found no error in the rulings by the district court. Accordingly, the Court reversed in part the judgment below and remanded for further proceedings. View "Grubb v. DXP Enterprises" on Justia Law

Facing foreclosure, Ralph and Paula Isom entered into a deed in lieu of foreclosure agreement with Farms, LLC (“Farms”). The Isoms then leased the real property (a farm and various houses) back from Farms, subsequently defaulted on their obligations under the lease agreement, and filed a Chapter 11 bankruptcy, which was later converted to a Chapter 7. During the Isoms’ bankruptcy, Farms also acquired several third-party claims against the Isoms from other independent creditors of the Isoms. The bankruptcy court denied the Isoms a discharge, and after the bankruptcy case closed, Farms sued the Isoms personally, alleging three counts of breach of contract. Following a one-day bench trial, the district court awarded Farms a judgment of $1,281,501.68 as to Count III—related to Farms’ purchase of the third-party claims—but concluded that Farms’ remaining two claims related to the lease were barred by the applicable statute of limitations. The Isoms appealed, arguing the district court erred in determining the applicable statute of limitations as to Count III. Farms cross-appealed, arguing the district court erred in applying the statutes of limitation as to Counts I and II. After review, the Idaho Supreme Court affirmed the district court’s judgment as to Count III but reversed and vacated the judgment on Counts I and II. View "Farms, LLC v. Isom" on Justia Law