Justia Civil Procedure Opinion Summaries

Several parties in Broadwater County, Montana, hold water rights to Beaver Creek based on a 1906 decree. In 1973, a major owner of these rights, Olive McMaster, transferred portions of her interest to others, including the predecessors of CX Ranch, Baum, and Riis. That conveyance imposed specific conditions for water distribution in times of shortage. Years later, disputes arose over changes to the period of use for some of these water rights and whether historical restrictions still governed distribution. In 2018, the parties reached a stipulation that added remarks about the 1973 restrictions to the official records for certain water rights. These remarks were incorporated into a 2018 Water Court order and, subsequently, into a 2022 Preliminary Decree for Basin 41I.During the 2024 irrigation season, the court-appointed Water Commissioner reduced water allocations pro rata among all rights holders due to low water levels and altered the method of delivery to facilitate Riis’ usage downstream. The Hoeffners, who own Pole Creek Ranch and Staubach Creek Ranch, objected to this administration, arguing that their rights were not subject to the 1973 restrictions and that the Water Commissioner’s practices were inconsistent with the applicable decree. The District Court denied their complaint, finding that only parties to the 1973 conveyance could enforce its terms, that the Hoeffners lacked standing, and that pro rata reduction and the delivery method used were permissible.The Supreme Court of the State of Montana reversed the District Court’s decision. It held that the Water Commissioner was required to administer water rights in accordance with the 2022 Preliminary Decree for Basin 41I, which incorporated the 2018 Water Court order and its adjudicated terms, including the distribution remarks. The District Court erred by not first determining whether the Water Commissioner’s practices conformed with the decree. The case was remanded for further proceedings consistent with a decree-first analysis. View "In re Petition for Water Commissioner" on Justia Law

Christopher and Jennifer Atkinson purchased a lot in the Ridgeview Trails Major Subdivision in Livingston, Montana, in 2012. The City of Livingston had approved the subdivision in 2005 and 2006, and a geotechnical report identifying problematic soils was created for the subdivision developers but was not provided to the Atkinsons when they purchased the lot. The Atkinsons received a building permit from the City to construct a residence, which was substantially completed in June 2013. In 2021, the Atkinsons began to observe cracking and structural problems in their home. After later discovering the existence of the geotechnical report, they sued the City in April 2024, alleging negligence and negligent misrepresentation for the City’s failure to disclose known soil issues during the permitting process.The case was heard in the Montana Sixth Judicial District Court, Park County. By agreement, the parties proceeded directly to cross-motions for summary judgment to address threshold legal issues before discovery. The District Court granted summary judgment for the City, holding that the claims were barred by Montana’s statute of repose for construction-related claims, found in § 27-2-208, MCA. The District Court also found that the City owed no duty to the Atkinsons, that the public duty doctrine barred the claims, that the Atkinsons had disclaimed claims relating to permits and inspections, and that the geotechnical report was for the developer’s exclusive use.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s judgment. The Supreme Court held that the Atkinsons’ claims were barred by the ten-year statute of repose in § 27-2-208, MCA, because their claims arose from the City’s planning and inspection activities and were filed more than ten years after substantial completion of the home. The Court also held that the statute applies to municipalities and that no statutory exception applied. View "Atkinson v. Livingston" on Justia Law

A devastating fire occurred in Lahaina on August 8, 2023, resulting in over one hundred deaths and widespread property and economic damage. Following the fire, individually represented plaintiffs and class action plaintiffs filed lawsuits in state and federal courts against entities including Hawaiian Electric, Kamehameha Schools, the State of Hawaiʻi, and the County of Maui. These class actions were eventually consolidated and refiled as a single case in the Circuit Court of the Second Circuit. Through court-ordered mediation, parties reached a “global settlement” in August 2024, resolving all claims for a total of $4.037 billion, with a portion allocated to a class settlement fund.Prior to the present appeal, the Circuit Court of the Second Circuit coordinated complex proceedings, including appointment of a special settlement master and consolidation of cases. The court issued an order establishing exclusive jurisdiction over subrogation claims related to the settlement. After the settlement was publicized and the Hawaiʻi Supreme Court issued its opinion in In re Maui Fire Cases, which clarified that insurers’ exclusive remedy after settlement is a statutory lien under HRS § 663-10, Subrogating Insurers moved to intervene in the class action, claiming protectable equitable subrogation rights if some class members did not file claims.The Supreme Court of the State of Hawaiʻi held that Subrogating Insurers do not possess a protectable interest that justifies intervention by right or permissive intervention in the class action settlement under Hawaiʻi Rules of Civil Procedure Rule 24. The court found that the statutory lien process under HRS § 663-10 is the exclusive remedy for insurers, and settlement extinguishes subrogation rights, even if some class members do not claim settlement funds. The court affirmed the Circuit Court’s order denying intervention. View "Burnes v. Hawaiian Electric Company, Inc." on Justia Law

In 1965, individuals filed a class action lawsuit against the public schools in St. Mary Parish, Louisiana, seeking to end segregation and secure injunctive relief. The district court granted an injunction requiring desegregation and oversight, with subsequent orders and modifications over the years as the parties and courts responded to compliance issues and changes in the law. After a period of inactivity, new representatives and counsel stepped in around 2018–2019, seeking to further modify the original injunction. The School Board responded by filing motions challenging the procedural propriety of the new plaintiffs, the court’s subject matter jurisdiction, and the ongoing validity of the injunction.The United States District Court for the Western District of Louisiana allowed the substitution of new plaintiffs, denied the Board’s motions to dismiss, and recertified the class, despite acknowledging factors that weighed against doing so. The Board did not appeal immediately but later renewed its objections, moving to dissolve the decades-old injunction and to strike or dismiss the new plaintiffs’ motions for further relief. The district court denied the Board’s motions to dismiss and to strike, and clarified that the Board could not present certain arguments under Rule 60(b)(5) at an upcoming hearing. The Board appealed these rulings.The United States Court of Appeals for the Fifth Circuit reviewed whether it had appellate jurisdiction under 28 U.S.C. § 1292(a)(1), which allows interlocutory appeals of orders granting, continuing, modifying, or refusing to dissolve injunctions. The Fifth Circuit held that the district court’s orders did not have the practical effect of continuing, modifying, or refusing to dissolve the injunction, but merely maintained the status quo pending further proceedings. As such, the appellate court determined it lacked jurisdiction to consider the appeal and dismissed it for want of appellate jurisdiction. View "Navy v. Sch Bd of St. Mary Prsh" on Justia Law

Eight residents of Boothbay and Boothbay Harbor challenged a school board’s refusal to put their petition for a new referendum before the voters. The underlying issue concerned a voter-approved bond to renovate local schools. After the bond passed, the residents submitted a petition containing two articles: one seeking to reconsider and repeal the prior vote, and another proposing a new, smaller bond for a different renovation project if the repeal succeeded. The school board rejected the petition, reasoning that it did not present a proper reconsideration question as required by statute and that the second article was unrelated to reconsidering the original referendum.The residents sought judicial review in the Lincoln County Superior Court under Rule 80B and also filed independent claims for a declaratory judgment and attorney fees, alleging a First Amendment violation. The Superior Court found that the petition was not a proper reconsideration petition because it included an additional article and that the independent claims were barred by the exclusivity principle. The residents then appealed.The Maine Supreme Judicial Court reviewed the case. It held that the statute governing reconsideration petitions imposes a ministerial duty on the board to initiate a referendum if the statutory requirements are met; thus, the Superior Court had jurisdiction. However, the Court found that the residents’ petition did not comply with the statutory requirements for a reconsideration petition, as it sought affirmative repeal and included a second, unrelated article, making it ineligible for submission to voters. The Court also affirmed the dismissal of the independent claims, holding there was no First Amendment violation. The judgment of the Superior Court was affirmed. View "Minerich v. Boothbay-Boothbay Harbor Community School District" on Justia Law

A healthcare provider and several of its employees became involved in a dispute after the Idaho Department of Health and Welfare took protective custody of a child suffering from severe malnutrition. Following the hospital’s treatment of the child, a relative of the child, using media platforms and political organizations, publicly accused the hospital and its staff of participating in a conspiracy to kidnap, traffic, and harm children. These accusations led to public protests, threats, and disruptions at the hospital. The healthcare provider and its employees then sued the relative, his associates, and affiliated entities, alleging defamation, invasion of privacy, intentional infliction of emotional distress, trespass, and civil conspiracy, among other claims. They sought compensatory and punitive damages, injunctive relief, and removal of false statements.During proceedings in the District Court of the Fourth Judicial District, the defendant repeatedly failed to comply with discovery orders, missed depositions, and did not attend court hearings, despite multiple warnings and opportunities to comply. The court imposed escalating sanctions, culminating in striking the defendant’s pleadings and entering default as to liability. The court held a jury trial solely on damages, at which the defendant did not appear in person despite being given the opportunity. The jury awarded $52.5 million in compensatory and punitive damages, and the court issued a permanent injunction preventing further defamatory statements or harassment.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in imposing sanctions, entering default, and excluding evidence not properly disclosed. The court found that the defendant’s due process rights were not violated given repeated, willful noncompliance with court orders. The Supreme Court affirmed the district court’s judgment, including the damages award and the injunction, and awarded attorney fees and costs on appeal to the respondents. View "St. Luke's Health System, LTD v. Rodriguez" on Justia Law

An individual was convicted in 1997 of indecent assault and battery on a child under fourteen and served a sentence of incarceration. Before his release, the Commonwealth petitioned to have him civilly committed as a sexually dangerous person (SDP) under Massachusetts law. Two qualified examiners evaluated him but, misunderstanding the scope of evidence they could consider, both opined that he did not meet the statutory criteria for an SDP. Despite this, the case proceeded to trial, and, based on other expert testimony and additional evidence, a judge found him to be an SDP and ordered his civil commitment in 2002. The individual unsuccessfully attempted to appeal, and over the years, filed and withdrew several discharge petitions.A Superior Court judge had denied his original motion for summary judgment, finding that a fact finder could rely on other expert testimony, not just that of the qualified examiners. After his commitment, his attempt to appeal the judgment was dismissed as untimely. Years later, he filed a petition for a writ of habeas corpus, arguing that, following the Massachusetts Supreme Judicial Court’s decision in Johnstone, petitioner, 453 Mass. 544 (2009), his commitment was unlawful because neither qualified examiner had opined that he was an SDP. The Superior Court granted the writ, but the Appeals Court reversed, holding that habeas corpus was not available since alternative remedies existed.The Supreme Judicial Court of Massachusetts reviewed the case and held that, under the statutory scheme, the individual was entitled to a required finding of not sexually dangerous where neither qualified examiner so opined. However, the court concluded that habeas corpus was not available because he had alternative remedies, specifically a motion for relief from judgment. The court vacated the grant of habeas corpus and remanded the case to the Superior Court with instructions to treat the petition as a motion for relief from judgment, which must be allowed. View "Pierce, Petitioner" on Justia Law

A Texas nonprofit health center, CentroMed, experienced a data breach in 2024 that exposed the personal information of its patients. Arturo Gonzalez, representing himself and others affected, filed a class action in Bexar County, Texas, alleging that CentroMed failed to adequately protect their private information. CentroMed, which receives federal funding and has occasionally been deemed a Public Health Service (PHS) employee under federal law, sought to remove the case to federal court, claiming removal was proper under 42 U.S.C. § 233 and 28 U.S.C. § 1442.After CentroMed was served, it notified the Department of Health and Human Services (HHS) and the United States Attorney, seeking confirmation that the data breach claims fell within the scope of PHS employee immunity. The United States Attorney appeared in state court within the required 15 days, ultimately informing the court that CentroMed was not deemed a PHS employee for the acts at issue because the claims did not arise from medical or related functions. Despite this, CentroMed removed the case to the United States District Court for the Western District of Texas 37 days after service. The district court granted Gonzalez’s motion to remand, concluding that removal was improper under both statutes: the Attorney General had timely appeared, precluding removal under § 233, and removal under § 1442 was untimely.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s remand. The Fifth Circuit held that CentroMed could not remove under § 233 because the Attorney General had timely appeared and made a case-specific negative determination. The court further held that removal under § 1442 was untimely, as CentroMed did not remove within 30 days of receiving the initial pleading. Thus, the remand to state court was affirmed. View "Gonzalez v. El Centro Del Barrio" on Justia Law

Several plaintiffs brought suit against a court-appointed receiver and his company, alleging breach of fiduciary duty. The underlying facts involve a criminal prosecution against one of the plaintiffs, Simon Semaan, for insurance fraud. In connection with the prosecution, the criminal court issued a temporary restraining order that froze certain assets and appointed the receiver to manage them. Later, the court ordered the receiver to liquidate specific stock holdings “as soon as practicable.” The receiver did not immediately liquidate the assets, citing ongoing settlement negotiations and concerns about account closure requirements. Plaintiffs alleged that, as a result of the receiver’s delay, the value of the investment accounts declined, causing them over $1.1 million in damages.After the receiver was replaced, the plaintiffs filed a civil lawsuit for breach of fiduciary duty in the Superior Court of Orange County. The defendants responded with an anti-SLAPP motion, arguing the claims arose from protected activity and that quasi-judicial immunity applied. The trial court granted the anti-SLAPP motion. The court found that the receiver’s conduct occurred within the scope of his appointment, that the litigation privilege applied, and that the receiver was protected by quasi-judicial immunity.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court affirmed the trial court’s order. It held that a court-appointed receiver is protected by quasi-judicial immunity for discretionary acts and decisions performed in the course of carrying out court orders. The court found that the plaintiffs’ claims arose out of the receiver’s discretionary decisions as receiver, which are constitutionally protected activities under the anti-SLAPP statute. Because of this immunity, the plaintiffs failed to show that their claims had the minimal merit necessary to survive an anti-SLAPP motion. The court thus affirmed the order striking the complaint. View "Semaan v. Mosier" on Justia Law

The parties in this case are neighbors whose homes are situated with their backyards facing one another, separated by a narrow commons area. Prior to the events at issue, there was significant animosity between them. In December 2024, one party filed petitions for harassment protection orders against the other parties, alleging ongoing disputes including the use of police resources to gather information, failure to restrain their dogs after warnings, installation of a bright work light shining into her home, and incidents that made her feel she was being watched or followed. The district court issued ex parte harassment protection orders the same day, effective for one year.After the orders were issued, the subjects of the orders requested a show cause hearing before the District Court for Lancaster County. At this hearing, they presented evidence and explained their actions, asserting lawful purposes for their conduct, including security and documenting a potential ordinance violation. The district court found their explanations unpersuasive, concluded that their actions were intended to intimidate, and affirmed the harassment protection orders to remain in effect for one year. The parties subject to the orders appealed, and the appeals were consolidated and moved to the Nebraska Supreme Court’s docket.While the appeal was pending before the Nebraska Supreme Court, the harassment protection orders expired, rendering the appeals moot. However, the court determined that the issue of interpreting the phrase “which serves no legitimate purpose” under Neb. Rev. Stat. § 28-311.02(2)(a) presented a matter of public interest warranting review despite mootness. The Nebraska Supreme Court held that, under this statute, determining whether conduct serves a legitimate purpose requires (1) a genuine, justifiable purpose and (2) a logical connection between the conduct and that purpose under the circumstances. The court dismissed the appeals as moot. View "Flinn v. Strode" on Justia Law