Justia Civil Procedure Opinion Summaries

The case involves Maine healthcare workers who were terminated from their employment for refusing to comply with a COVID-19 vaccine mandate based on their religious beliefs. The mandate, initially promulgated by emergency rule on August 12, 2021, was no longer enforced as of July 12, 2023, and was repealed effective September 5, 2023. The plaintiffs filed suit in the United States District Court for the District of Maine, asserting that the mandate's lack of religious exemptions violated the First and Fourteenth Amendments. Their motion for a temporary restraining order and preliminary injunction was denied, and the denial was affirmed by the First Circuit. The Supreme Court also denied their application for emergency injunctive relief.The defendants moved to dismiss the complaint for failure to state a claim, which was granted. The First Circuit affirmed in part and reversed in part, reinstating the First Amendment Free Exercise and Fourteenth Amendment Equal Protection Clause claims for declaratory and injunctive relief against state health officials. Following the repeal of the mandate, the defendants moved to dismiss the remaining claims as moot, and the district court granted the motion, also denying the plaintiffs leave to amend the complaint.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's determinations. The court held that the challenge was moot because the COVID-19 vaccine mandate had been repealed and was no longer in effect. The court also found that no exceptions to mootness, such as voluntary cessation or capable of repetition yet evading review, applied. The court further affirmed the denial of the plaintiffs' request to amend their complaint, concluding that justice did not require permitting further amendments to broaden the scope of their claims. View "Lowe v. Gagne-Holmes" on Justia Law

In this case, the plaintiff, a Chapter 11 Trustee for BK Racing, LLC, initiated an adversary proceeding against multiple defendants, including Ronald and Brenda Devine, various family trusts, and corporate entities. The defendants were accused of obstructing the bankruptcy process by failing to comply with discovery obligations, including not producing required financial documents and records, despite multiple court orders.The bankruptcy court found that the defendants willfully disregarded their discovery obligations and engaged in a pattern of obstruction and delay. As a result, the court entered a default judgment against the defendants as a discovery sanction, awarding the plaintiff $31,094,099.89. The district court affirmed this decision, noting the defendants' repeated noncompliance and the necessity of deterrence.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court upheld the lower courts' decisions, finding no abuse of discretion in the entry of default judgment. The court applied the Wilson factors, determining that the defendants acted in bad faith, caused significant prejudice to the plaintiff, necessitated deterrence, and that lesser sanctions would be ineffective. The court also affirmed the decision to pierce the corporate veil, holding the defendants jointly and severally liable, based on evidence that the corporate entities were mere instrumentalities of the Devines, lacking proper corporate formalities and used to siphon funds.The Fourth Circuit concluded that the bankruptcy court's findings were not clearly erroneous and that the default judgment and the amount awarded were appropriate given the defendants' egregious conduct. The decision of the district court was affirmed. View "Smith v. Devine" on Justia Law

A Montana State Representative, William W. Mercer, requested access to certain child abuse and neglect case records from the Montana Department of Public Health and Human Services (DPHHS) under a statute that allows legislators to review such records. The DPHHS provided some records but withheld others, including emails, text messages, and attorney-client privileged materials. Mercer filed a petition for a writ of mandamus and for declaratory and injunctive relief to compel the DPHHS to release the additional records.The First Judicial District Court of Lewis and Clark County granted a mandatory preliminary injunction requiring the DPHHS to provide the requested records, including those claimed to be attorney-client privileged, but imposed additional confidentiality protections. The DPHHS appealed, arguing that the District Court misinterpreted the statute and that the attorney-client privilege should exempt certain records from disclosure.The Supreme Court of the State of Montana reviewed the case. The court affirmed the District Court's decision, holding that the plain language of the statute required the disclosure of the records to the legislator, subject to confidentiality protections. The court found that the District Court did not abuse its discretion in granting the preliminary injunction, as Mercer demonstrated a clear likelihood of success on the merits, irreparable harm without the injunction, that the balance of equities tipped in his favor, and that the injunction was in the public interest. The court emphasized that the preliminary injunction did not resolve the ultimate merits of the case, which would be determined in further proceedings. View "Mercer v. Department of Public Health and Human Services" on Justia Law

A motorist, a physician, was injured when a truck struck the rear of her car while she was stopped at a construction site. She sued the truck driver and his employer for lost earnings and other damages. The superior court found that her future earning capacity was affected but dismissed her claim for future lost earnings, stating she failed to prove the amount of damages to a reasonable certainty.The superior court awarded her $1,036,491 for future medical and life care expenses, $79,961 for past lost income, and $500,000 in noneconomic damages. However, it dismissed her claim for future lost earning capacity. On appeal, the Alaska Supreme Court reversed the dismissal, stating that once the fact of damages for future lost earning capacity was established to a reasonable certainty, the court could reasonably estimate the amount from the evidence in the record. The case was remanded to the superior court to determine the damages for future lost earning capacity.On remand, the superior court used the evidence in the record to fashion a damages award. It found that the motorist's pre-accident earning capacity was $1,169,554 and estimated her post-accident earning capacity to be $1,018,087.40. The court calculated her annual expected loss of income to be $150,746.60 and determined that she would suffer this loss for 6.3 years, the average remaining work life for a woman her age. The total damages for loss of earning capacity were calculated to be $949,703.58, bringing the total award to $2,566,155.58.The Alaska Supreme Court reviewed the superior court's estimation of lost earning capacity and found no clear error. The court affirmed the damages award, concluding that the superior court's method of calculating the damages was reasonable and grounded in the evidence. The superior court's order on remand was affirmed. View "Downing v. Shoreside Petroleum, Inc." on Justia Law

The Wisconsin Voter Alliance filed identical petitions for writ of mandamus against the registers in probate for 13 circuit courts in Wisconsin, seeking access to Notice of Voting Eligibility (NVE) forms under Wisconsin’s public records law. These forms document when a court finds an individual incompetent to vote. The Alliance argued that they needed this information to ensure the Wisconsin Elections Commission (WEC) was updating voter records accurately.The Walworth County Circuit Court dismissed the Alliance’s petition, agreeing with the register in probate, Kristina Secord, that the NVE forms were exempt from disclosure under Wisconsin Statute § 54.75. The Alliance appealed to the Court of Appeals, District II. Meanwhile, the Court of Appeals, District IV, had already ruled in a similar case (Reynolds) that NVE forms were exempt from disclosure under the same statute, affirming the Juneau County Circuit Court’s dismissal of the Alliance’s petition.In the current case, the Court of Appeals, District II, issued a split opinion. The majority held that the Alliance was entitled to the NVE forms, possibly with redactions, and reversed the circuit court’s dismissal. However, the Wisconsin Supreme Court reviewed the case and found that District II violated the precedent set by Cook v. Cook, which mandates that the Court of Appeals must follow prior published opinions unless overruled by the Supreme Court.The Wisconsin Supreme Court held that District II was bound by the Reynolds decision and should have either certified the appeal to the Supreme Court or adhered to the prior opinion while expressing its disagreement. Consequently, the Supreme Court reversed the decision of the Court of Appeals, District II, and remanded the case with instructions to follow the precedent established in Reynolds. View "Wisconsin Voter Alliance v. Secord" on Justia Law

In 2020, Sarah E. Martin was injured in a car accident involving an 18-wheel tractor-trailer driven by Charles Streeter, an employee of Al-Amin Brothers Transportation, LLC. Martin sued the LLC, several individuals, and 18 fictitiously named defendants. In January 2023, Martin settled with the original defendants, agreeing to release them and related parties from any claims arising from the accident. Subsequently, Martin amended her complaint to add PEI Ohio, Inc. and Premium Transportation Group, Inc. (the corporations) as defendants, alleging various negligence and breach of contract claims.The Jefferson Circuit Court enforced the settlement agreement in favor of the corporations, dismissed Martin's third amended complaint, and awarded attorney fees to the corporations. Martin filed a fourth amended complaint, which remains pending. The circuit court certified its orders as final under Rule 54(b), Ala. R. Civ. P., and Martin appealed both the enforcement of the settlement and the attorney fee award.The Supreme Court of Alabama reviewed the case and determined that the circuit court exceeded its discretion in certifying the orders as final under Rule 54(b). The court found that the adjudicated and unadjudicated claims were closely related, the need for review might be mooted by future developments in the circuit court, and there was a possibility of having to consider the same issue again, particularly regarding attorney fees. Consequently, the Supreme Court of Alabama dismissed Martin's appeals, emphasizing the preference to avoid piecemeal litigation and the need for a final judgment on all pending claims before appellate review. View "Martin v. PEI Ohio, Inc." on Justia Law

Irva E. Reed sought to run for a seat on the Montgomery County Commission in 2024. She submitted her qualifying papers to the Montgomery County Democratic Party in November 2023 and confirmed she would submit a "Statement of Economic Interests" (SEI) to the Alabama Ethics Commission within five days, as required by Alabama law. However, she filed her SEI 41 days late. The Director of the Commission informed the Party that Reed was not qualified to appear on the ballot. Reed requested a five-day extension due to illness, but the Commission denied her request.Reed then sued the Director, the Chairman of the Commission, and the Secretary of State in their official capacities in the Montgomery Circuit Court, seeking a judgment declaring her illness as a valid reason for the delay and an injunction to place her name on the ballot. The trial court granted her request for a preliminary injunction, ordering the Commission and the Party to certify Reed as a candidate. The defendants appealed the trial court's order, and the Supreme Court of Alabama stayed the injunction while addressing the appeal.The Supreme Court of Alabama reviewed the case de novo and found that Reed's claim was moot because the election had already occurred. The court held that a judgment in Reed's favor would not affect the rights of the parties. The court also determined that none of the exceptions to mootness cited by Reed—capable of repetition but evading review, public interest, and collateral rights—applied in this case. Consequently, the Supreme Court of Alabama dismissed the appeal and instructed the trial court to dissolve the injunction and dismiss Reed's complaint. View "Plunk v. Reed" on Justia Law

Phillip and Jodi Peterson hired Brandon Coverdell Construction, Inc. (BCC) to perform work on their home following a hailstorm. The Petersons were dissatisfied with the quality of BCC's work, while BCC was unhappy with the Petersons' partial payment. Both parties accused each other of breaching their written agreement and filed lawsuits in the county court. The county court ruled in favor of BCC, finding that the Petersons committed the first material breach.The Petersons appealed to the District Court for Douglas County but failed to file a statement of errors. They obtained a continuance to amend the bill of exceptions in the county court. The district court eventually found that the county court had committed plain error by entering judgment in favor of BCC, concluding that the written agreement was an unenforceable illusory contract. BCC then appealed to the Nebraska Supreme Court.The Nebraska Supreme Court reviewed the case and found that the district court erred in considering the supplemental bill of exceptions, which was not properly part of the record. The Supreme Court also determined that the county court did not commit plain error. The county court's decision to focus on the issues presented by the parties, rather than the enforceability of the contract, did not result in damage to the integrity, reputation, or fairness of the judicial process. Consequently, the Nebraska Supreme Court reversed the district court's order and remanded the case with directions to affirm the county court's judgment. View "Peterson v. Brandon Coverdell Constr." on Justia Law

Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law

J.M.H. pleaded guilty to disorderly conduct in juvenile court in 2022. The trial court judge issued a disposition order with certain conditions, which J.M.H. violated multiple times. In October 2022, the judge issued a warrant for her arrest. J.M.H.'s lawyer challenged the warrant, arguing it did not comply with JuCR 7.16, the rule for issuing juvenile warrants. The trial court denied the motion, and J.M.H. appealed.The appeal was reviewed by the Court of Appeals. By that time, the trial court judge who issued the warrant had been appointed to the Court of Appeals and sat on the panel reviewing his own decision. The panel dismissed the appeal, stating the order was not appealable under RAP 2.2(a). J.M.H. sought discretionary review, arguing it was reversible error for the judge to sit on the appellate panel.The Supreme Court of the State of Washington reviewed the case. The court held that a judge cannot review an appeal of a decision they made as a trial court judge in the same case, citing In re Murchison and In re Dependency of A.N.G. The court found that this violated due process and required automatic reversal. The Supreme Court reversed the decision and remanded the case to the Court of Appeals for further proceedings. View "State v. J.M.H." on Justia Law