Justia Civil Procedure Opinion Summaries

A tenured teacher employed by a city was charged with a criminal offense, resulting in his placement on paid administrative leave. Over a year later, while the charge was still pending, the city changed the teacher's status to unpaid suspension. The teacher’s union filed a grievance contesting the unpaid suspension, leading to arbitration, where the arbitrator determined that the city had good and just cause for the suspension without pay. After the criminal charge was dismissed, the city reinstated the teacher. The union then filed a second grievance seeking back pay for the period of unpaid suspension, which both parties agreed to arbitrate.Following this, while the arbitration on the back-pay grievance was still pending, the teacher independently filed an action for declaratory relief in the Providence County Superior Court, seeking a declaration that he was entitled to back pay under the Teachers’ Tenure Act. The city moved to dismiss, arguing that the teacher had already selected the grievance and arbitration process as his remedy. The trial justice granted the motion, citing the election of remedies doctrine and relying on precedent, specifically Martone v. Johnston School Committee, which precludes pursuing multiple remedies for the same dispute when a party has already elected a process under a collective bargaining agreement.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s dismissal. The Court held that once a party elects to pursue a remedy through the grievance and arbitration procedures in a collective bargaining agreement, they are foreclosed from simultaneously or subsequently seeking judicial relief for the same dispute under the doctrine of election of remedies. The disposition by the Supreme Court of Rhode Island was to affirm the lower court’s judgment. View "Peasley v. City of Providence" on Justia Law

A licensed sidewalk vendor who had operated outside Petco Park in San Diego since 2009 was cited multiple times in mid-2024 under newly enacted city ordinances regulating sidewalk vending. On two occasions, city officials also impounded his merchandise and, in one instance, his sales proceeds. The vendor, who holds a valid city vending permit, alleged that the new ordinances, particularly those related to impoundment and restrictions on vending during certain hours and events, conflicted with state law enacted in 2018 designed to protect the rights of sidewalk vendors. He sought a writ of mandate, as well as declaratory and injunctive relief to prevent enforcement of these local provisions.The Superior Court of San Diego County denied the vendor’s motion for a preliminary injunction. The court acknowledged the negative impact on the vendor’s livelihood but found there was a minimal probability of success on the merits, reasoning that the city’s restrictions were permissible under the state law’s allowance for regulations related to health, safety, or welfare. The court concluded that the balance of harms favored the city, given public interest considerations, and thus refused to enjoin enforcement of the challenged ordinances.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, examined both the factual record and the legal questions concerning the interplay between the municipal code and state law. The appellate court held that the city’s ordinances authorizing impoundment of vending equipment and restricting vending hours in nonresidential areas more stringently than for other businesses are in direct conflict with state law. The court found the trial court erred by not adequately considering these conflicts. The appellate court reversed the denial of the preliminary injunction and remanded for further proceedings, instructing the lower court to apply the correct legal standards and further develop the record as needed. View "Mustaqeem v. City of San Diego" on Justia Law

Taylor L. Wood, her husband, and her son received medical care from physicians employed by Intermountain Emergency Physicians, PLLC (IEP). The resulting medical debt was assigned to Medical Recovery Services, LLC (MRS) for collection. After Wood’s attorneys alleged violations of state law, the Woods and IEP entered into a settlement that discharged the debt and provided payment to the Woods. Nevertheless, MRS later sued Wood to collect the same debt. Wood responded by counterclaiming and bringing IEP into the case as a third-party defendant, relying on the settlement agreement. MRS dismissed its complaint upon learning of the prior settlement, and all claims were eventually dismissed by the court.After judgment was entered, both sides sought a determination of the prevailing party and an award of attorney fees. The District Court of the Seventh Judicial District, Bingham County, found that Wood was the prevailing party over MRS and ordered MRS to pay Wood’s costs and attorney fees, concluding that MRS’s complaint was frivolous due to lack of proper investigation and communication regarding the settlement. MRS and IEP filed a first motion for reconsideration of the fees order, which was denied. They then filed a second motion for reconsideration, also denied, and subsequently appealed.The Supreme Court of the State of Idaho reviewed the case. It held that it lacked jurisdiction to review the district court’s order awarding costs and attorney fees to Wood because MRS and IEP’s notice of appeal from that order was untimely under Idaho Appellate Rule 14(a). The court did have jurisdiction to review the denial of the second motion for reconsideration, but because MRS and IEP failed to provide argument or authority on that issue, they waived it. The Supreme Court affirmed the district court’s denial of the second motion for reconsideration. View "Medical Recovery Services, LLC v. Wood" on Justia Law

Solomon Jones, acting without an attorney, brought a civil rights lawsuit in federal court against several local government entities in Illinois. He alleged that his constitutional rights had been violated during a series of events in 2023, including his being ticketed and arrested for trespassing and disorderly conduct. Subsequent to filing his lawsuit, Jones filed multiple motions, including one requesting the district judge’s recusal.The United States District Court for the Central District of Illinois denied Jones’s motion for recusal. Acting on its own initiative, the court also determined it should abstain from hearing Jones’s claims under the doctrine established in Younger v. Harris, because a related state criminal case was still pending. The district court stayed the federal case, instructing Jones to provide a status update after the conclusion of the state proceedings. While this appeal was pending, Jones notified the court that he had been acquitted in the state criminal case.The United States Court of Appeals for the Seventh Circuit determined it lacked jurisdiction to review the denial of the recusal motion, as no final judgment had been entered. However, it found the stay order based on Younger abstention was immediately appealable. Since the state court proceedings had ended, the appellate court held that the basis for abstention no longer existed. Consequently, the Seventh Circuit vacated the district court’s stay order and remanded the case for further proceedings, directing the district court to address any new developments, such as additional state charges Jones reported, and determine their relevance to the federal case. View "Jones v. Kankakee County Sheriff's Department" on Justia Law

The individual in this case is a litigant who had previously been subject to a filing sanction by the United States Court of Appeals for the Second Circuit. The sanction required that, before submitting any future appeal or other proceedings in that court, the individual must first obtain leave of the court to file such materials. The current matter involved the individual’s attempt to initiate further proceedings related to a case involving a municipality.Previously, the United States District Court for the Western District of New York had been involved in the underlying litigation. Following actions in that court, the matter was appealed to the United States Court of Appeals for the Second Circuit. Subsequently, the Second Circuit imposed a leave-to-file sanction on the individual due to his filing history. After this sanction was imposed, the individual attempted to file a motion to recall the mandate in his ongoing case without first obtaining leave from the court, as required by the sanction order.Upon review, the United States Court of Appeals for the Second Circuit clarified that its prior leave-to-file sanction applies broadly. This includes not only new cases but also filings in ongoing and previously filed cases. The court denied the individual’s motion for leave to file and found the motion to recall the mandate moot. The main holding is that a litigant subject to a leave-to-file sanction must obtain permission from the court before submitting any new filings in any case, including those initiated before the sanction was imposed. View "Lettieri v. Town of Colesville" on Justia Law

The case involves a dispute over discovery between two companies engaged in mining operations in Peru and a group of law firms representing Peruvian plaintiffs who allege injuries from toxic exposure. The companies, seeking to defend themselves against these claims and pursuing a related criminal complaint in Peru alleging document falsification and other misconduct by a former attorney, Victor Careaga, filed an ex parte application under 28 U.S.C. § 1782 in the Southern District of Florida. They sought discovery from Careaga, who had worked for the law firms and played a key role in recruiting plaintiffs. The law firms intervened, seeking protective orders to prevent disclosure of certain documents, asserting attorney-client privilege and work product protection.Previously, the United States District Court for the Eastern District of Missouri, where the underlying personal injury cases (Reid and Collins) were pending, had denied the companies' discovery requests as to the active plaintiffs. When the companies sought discovery in Florida, the Southern District of Florida granted the application, which led to the disputed subpoena. The law firms then moved for protective orders, but the magistrate judge and the district judge found that the privilege claims were insufficiently supported—citing vague, bundled privilege logs, lack of individualized document identification, and inadequate supporting affidavits. The district court denied the motions for protective orders.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed only the Halpern law firm's appeal after the other intervenors voluntarily dismissed their appeals. The Eleventh Circuit affirmed, holding that the district court did not abuse its discretion in denying the protective order because Halpern failed to substantiate its privilege and work product claims with adequate evidence and document-specific explanations. The court also found that Halpern was not entitled to further process, such as in camera review or amendment of the privilege log, given these deficiencies. View "The Renco Group Inc. v. Napoli Shkolnik PLLC" on Justia Law

A public employee working for the Pennsylvania Department of Human Services alleged that the union representing her bargaining unit failed to fairly represent her during a workplace grievance process. After being temporarily reassigned during a purported investigation, she lost opportunities for overtime work. She requested the union file a grievance, but claimed the union delayed providing information and failed to adequately pursue her complaint. When she followed up, union officials allegedly made derogatory remarks about her non-membership status and admitted to providing minimal representation. By the time she received notice of the grievance resolution, the period to appeal had expired, and she was dissatisfied with the outcome, believing she was denied proper relief under the collective bargaining agreement.The employee filed suit in the Cambria County Court of Common Pleas against the union, seeking compensatory and punitive damages for breach of the duty of fair representation, but did not request an order for arbitration or join her employer as a party. The trial court granted the union’s preliminary objections and dismissed the complaint with prejudice, finding the claim for damages legally insufficient. On appeal, the Commonwealth Court reversed and remanded, holding it was not free from doubt that the employee could seek damages against the union for such a breach.The Supreme Court of Pennsylvania reviewed the case and held that, under the Public Employe Relations Act (PERA), when a public employee’s claim against a union arises from the union’s handling of a grievance, the employee’s remedy is limited to a court order compelling the union and the employer to arbitrate the grievance nunc pro tunc. Damages against the union are not available in this context, and the public employer is an indispensable party to such proceedings. The Supreme Court reversed the Commonwealth Court’s decision. View "Gustafson v. American Fed. of State" on Justia Law

A woman who uses a wheelchair and her husband sued Uber Technologies, Inc. and others after an incident in which an Uber driver failed to provide her with a seatbelt while transporting her in a wheelchair-accessible vehicle, causing her to fall and sustain injuries. The plaintiffs alleged negligence and other claims. Uber responded by filing a petition to compel arbitration, arguing that the plaintiffs had agreed to arbitrate their claims when they enrolled in Uber’s service. The trial court granted Uber’s petition, stayed the litigation, and ordered the parties to proceed to arbitration.After this order, the plaintiffs appealed to the Superior Court of Pennsylvania, contending that the trial court’s order to compel arbitration was an immediately appealable collateral order under Pennsylvania Rule of Appellate Procedure 313. The Superior Court, sitting en banc, agreed that the arbitration order qualified as a collateral order and reversed the trial court’s decision, holding that there was no valid agreement to arbitrate and remanding for further proceedings. There was a dissent in the Superior Court, which argued that the order was not a collateral order and that any issues could be addressed after arbitration under the applicable statutes.The Supreme Court of Pennsylvania reviewed whether an order compelling arbitration and staying proceedings is an immediately appealable collateral order. The court held that such an order does not meet the requirements for a collateral order because the issue can be reviewed after the entry of final judgment, and thus does not result in irreparable loss if review is postponed. The court vacated the Superior Court’s judgment and remanded with instructions to quash the appeal for lack of jurisdiction. The Supreme Court did not address the validity of the arbitration agreement or the merits of compelling arbitration. View "Chilutti v. Uber" on Justia Law

An investor brought a derivative action against the managers of a limited liability company, alleging unauthorized transactions conducted under their management. After a bench trial, the investor lost both at trial and on appeal. The investor’s claims were rejected, and the court awarded costs to the prevailing manager. Although both managers were originally involved in the case, only one remained relevant for the cost award proceedings at this stage.Following the trial and appellate losses, the Superior Court of Los Angeles County awarded costs to the prevailing manager under Code of Civil Procedure section 1032 and California Rules of Court, rule 8.891, which together provide that a prevailing party is generally entitled to recover costs. The plaintiff had previously defeated the manager’s motion for a security bond under Corporations Code section 17709.02, a statute intended to deter frivolous derivative suits. The plaintiff argued that this earlier success on the bond motion should bar any subsequent award of costs, claiming that section 17709.02 overrides the ordinary cost rules.The California Court of Appeal, Second Appellate District, Division Eight, reviewed this argument. The appellate court held that Corporations Code section 17709.02 does not preclude an award of ordinary litigation costs to a prevailing defendant in a derivative action where the bond motion was denied. The court found no statutory language supporting the plaintiff’s position and noted that case law, including Brusso v. Running Springs Country Club, Inc., confirms that the bond statute is special-purpose and does not displace general cost-recovery rules. The appellate court affirmed the Superior Court’s judgment, awarding costs to the prevailing defendant. The court also found that the plaintiff had forfeited several additional arguments by failing to support them with adequate briefing or legal authority. View "Barrios v. Chraghchian" on Justia Law

Vista-Pro Automotive, LLC initiated bankruptcy proceedings in 2014 and brought an adversary action against Coney Island Auto Parts Unlimited, Inc. to recover $50,000 in unpaid invoices. Vista-Pro attempted to serve Coney Island by mail but allegedly did not comply with the required service rules. Coney Island did not respond, leading the Bankruptcy Court to enter a default judgment in 2015. Over the next six years, the bankruptcy trustee sought to enforce the judgment, including notifying Coney Island’s CEO of the judgment in 2016. In 2021, a marshal seized funds from Coney Island’s bank account to satisfy the judgment, prompting Coney Island to seek relief from the judgment, alleging it was void due to improper service.The United States Bankruptcy Court denied Coney Island’s motion to vacate the judgment, finding that Coney Island failed to meet the requirement under Federal Rule of Civil Procedure 60(c)(1) that such motions be brought within a “reasonable time.” The United States District Court and the United States Court of Appeals for the Sixth Circuit both affirmed this decision, agreeing that the reasonable-time limit applied to motions alleging a void judgment.The Supreme Court of the United States reviewed the case to resolve a split among lower courts over whether the reasonable-time requirement of Rule 60(c)(1) applies to motions under Rule 60(b)(4) claiming a judgment is void. The Court held that the plain language and structure of Rule 60 make the reasonable-time requirement applicable to all Rule 60(b) motions, including those asserting voidness. The Supreme Court affirmed the judgment of the Sixth Circuit, concluding that motions for relief from allegedly void judgments must be made within a reasonable time. View "Coney Island Auto Parts Unlimited, Inc. v. Burton" on Justia Law