Justia Civil Procedure Opinion Summaries

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

A young child, Alice, made several allegations of sexual misconduct against her father over the course of multiple years, beginning in 2021. These allegations were investigated on several occasions by county departments of social services, but none found substantiating evidence, and some investigators suspected that Alice’s mother coached her to fabricate accusations. The parents, who never married, were engaged in an ongoing custody dispute. The Carteret County District Court ultimately awarded primary custody to Alice’s father, finding the mother’s denials of visitation willful and her testimony untruthful. Additional reports of abuse were made thereafter, including by Alice’s school counselor and a therapist. These led to further investigations and court actions, but again no evidence of abuse was substantiated.The District Court in Carteret County dismissed a subsequent juvenile petition alleging abuse, neglect, and dependency, relying on the doctrines of res judicata and collateral estoppel, finding the issues had already been litigated. The Court of Appeals vacated this order, holding that collateral estoppel precluded relitigation of the previously adjudicated abuse allegations but not new allegations arising after the prior custody and interference proceedings. The appellate court remanded for further proceedings on the new allegations.The Supreme Court of North Carolina reviewed the case to clarify the application of collateral estoppel. The Supreme Court held that collateral estoppel did not bar the Department of Social Services’ juvenile petition because the Department was neither a party nor in privity with a party to the prior child custody or interference proceedings. Additionally, the prior court findings did not “actually determine” the relevant abuse issues for collateral estoppel purposes. The Supreme Court reversed the decision of the Court of Appeals and remanded for further proceedings, also noting the Department’s conflict of interest in this matter. View "In re A.D.H" on Justia Law

The plaintiff owned a large tract of land in Cumberland County, North Carolina. In 1992 and 2006, the North Carolina Department of Transportation (NCDOT) filed official corridor maps under the Map Act, which imposed restrictions on portions of the plaintiff’s property, limiting development and affecting value. In 2002 and 2010, NCDOT initiated two direct condemnation actions to acquire parts of the plaintiff’s land—some of which overlapped with the previously restricted areas—resulting in two settlements and consent judgments. After the 2010 settlement, 28.041 acres of the plaintiff’s property remained subject to Map Act restrictions until the maps were repealed in 2016.Following the repeal and a 2016 North Carolina Supreme Court decision in Kirby v. North Carolina Department of Transportation, which held that Map Act restrictions constituted a taking, the plaintiff filed an inverse condemnation action in Cumberland County Superior Court in 2018. The plaintiff sought compensation specifically for the Map Act restrictions not addressed in prior settlements. The Superior Court dismissed some claims but allowed the action to proceed for the remaining 28.041 acres. The North Carolina Court of Appeals affirmed, holding that the plaintiff’s claims regarding the Map Act restrictions were not barred and could proceed as an independent interest not covered by the earlier condemnation actions.The Supreme Court of North Carolina reversed the Court of Appeals. It held that, under North Carolina’s eminent domain statutes, the plaintiff was required to raise claims related to the Map Act restrictions as part of the answer in NCDOT’s 2010 direct condemnation action, since those restrictions were pertinent to determining just compensation for the partial taking. Because the plaintiff failed to do so, he could not pursue a separate inverse condemnation claim for those restrictions under N.C.G.S. § 136-111. The Court’s disposition was to reverse the judgment of the Court of Appeals. View "Sanders v. N.C. Dep't of Transp" on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

A dispute arose from a business relationship between an individual and a contracting company, resulting in complex litigation in Texas. In 2012, the company sued the individual in Texas for fraud, and after a jury trial, a judgment was entered against the individual, awarding substantial compensatory and punitive damages, attorney fees, and interest. While the individual appealed the Texas judgment, the company initiated proceedings in Alabama to domesticate the Texas judgment under the Uniform Enforcement of Foreign Judgments Act. The Baldwin Circuit Clerk issued a certificate of judgment, and the individual unsuccessfully sought to stay enforcement of the domesticated judgment pending the Texas appeal.The Texas intermediate appellate court affirmed the judgment, but in April 2024, the Supreme Court of Texas reversed the judgment and remanded for determination of a settlement credit and entry of a new judgment. In November 2024, the individual filed a motion under Rule 60(b)(5), Alabama Rules of Civil Procedure, in Baldwin Circuit Court, seeking relief from the domesticated judgment on the basis that the underlying Texas judgment had been reversed. The circuit court denied the motion without a hearing, finding that Rule 60(b)(5) was not the appropriate procedural mechanism because it requires two separate judgments, and domestication does not create a second judgment independent of the foreign judgment.On appeal, the Supreme Court of Alabama reviewed whether the circuit court exceeded its discretion in denying relief. The court held that the circuit court did not abuse its discretion, finding that Rule 60(b)(5) does not apply to a domesticated foreign judgment based solely on the reversal of the underlying foreign judgment, and the individual failed to show entitlement to relief under any other subsection of Rule 60(b). The Supreme Court of Alabama affirmed the order of the circuit court. View "Shumate v. Berry Contracting L.P." on Justia Law

During the COVID-19 pandemic, a university in Nebraska instituted a policy requiring all students to be vaccinated against COVID-19 by a specified deadline, with the only exemptions allowed for medical reasons or until a vaccine received full FDA approval. Religious exemptions were not permitted. Students who failed to comply were unenrolled and barred from campus, and some had holds placed on their accounts, preventing access to transcripts. One student complied with the mandate but suffered adverse effects and was medically exempted from further doses. Another student withdrew voluntarily before the deadline.After the university enforced the mandate, several students sought injunctive relief in the District Court for Douglas County to prevent their unenrollment, alleging breach of contract and unjust enrichment. The court denied relief, finding that any contract included the Emergency Use Authorization waiver agreements and that the students breached the contract by not being vaccinated after FDA approval. An initial appeal was dismissed by the Nebraska Supreme Court for lack of a final, appealable order. The students then consolidated their actions and filed an operative complaint alleging breach of implied contract, denial of due process, conversion, negligence, and violations of the Nebraska Consumer Protection Act (NCPA). The district court dismissed the complaint with prejudice and denied leave to amend.The Nebraska Supreme Court reviewed the district court’s dismissal de novo and found that the students plausibly alleged claims for breach of an implied contract and conversion, based on the university’s unilateral modification of conditions mid-semester and the withholding of transcripts. The court affirmed the dismissal of the negligence and NCPA claims, finding them preempted by the federal Public Readiness and Emergency Preparedness Act, and held that the due process claim was abandoned on appeal. The case was affirmed in part, reversed in part, and remanded for further proceedings on the breach of contract and conversion claims. View "Ramaekers v. Creighton University" on Justia Law

An employee who suffered a workplace injury sued his employer’s workers’ compensation insurance carrier and related entities, alleging failure to authorize timely medical treatment and misrepresentation of his injuries to the Mississippi Workers’ Compensation Commission. The plaintiff filed the lawsuit in Hinds County, Mississippi, though the only resident defendant lived in Rankin County. The defendants, all nonresidents except one, removed the case to federal court, invoking diversity jurisdiction and asserting that the resident defendant was improperly joined. While in federal court, the defendants filed a motion to dismiss based on failure to exhaust administrative remedies but did not raise a venue objection.The United States District Court for the Southern District of Mississippi found that it lacked subject-matter jurisdiction because the defendants had not met their burden to show improper joinder and remanded the case to the Hinds County Circuit Court. After remand, and before filing an answer or conducting discovery, the defendants moved to transfer venue to Rankin County. The plaintiff argued that any venue objection was waived because it was not raised in federal court, and the Hinds County Circuit Court denied the motion to transfer based solely on waiver, relying on the Mississippi Supreme Court’s decision in Breal v. Downs Law Group.The Supreme Court of Mississippi held that the defendants did not waive their objection to venue by failing to raise it in federal court, as the issue of proper state-court venue was not available while the case was pending in federal court. The court distinguished the facts from those in Breal and clarified that the defense of improper venue was timely asserted at the first opportunity in state court. The Supreme Court of Mississippi reversed the trial court’s denial of the motion to transfer venue and remanded the matter for further proceedings. View "Benchmark Insurance Company v. Harris" on Justia Law

A dispute arose between two competing billboard companies after one company constructed an electronic billboard in Gulfport, Mississippi. The company that operated existing billboards nearby filed suit, claiming that the new billboard violated a city ordinance enacted as part of a settlement resolving earlier litigation involving the city and the plaintiff. The defendant, along with related entities, countered with claims for declaratory and injunctive relief and challenged the plaintiff’s standing to bring the suit. The property owner on whose land the disputed billboard was constructed also became a party to the litigation.The litigation began in the Chancery Court of Harrison County, which denied the defendants’ motion for summary judgment, specifically rejecting their standing argument. The defendants removed the case to federal court, which remanded it and awarded costs to the plaintiff. After the defendants’ interlocutory appeal was denied by the Supreme Court of Mississippi, the case was transferred to circuit court. There, the court again denied summary judgment, and further unsuccessful dispositive motions were filed by the defendants. Over several years, the case involved multiple motions, removal, transfer, and appeals, with no claims proceeding to trial. Eventually, after the defendants transferred their interest in the billboard to a third party who settled with the plaintiff, the plaintiff moved to dismiss the case with prejudice. The Circuit Court of Harrison County granted the motion and denied the defendants’ subsequent request for attorney’s fees and costs, finding that much of the litigation expense was due to the defendants’ own aggressive litigation strategies, and declined to impose sanctions, concluding the suit was not frivolous.The Supreme Court of Mississippi reviewed the appeal, focusing on whether the trial court erred in denying attorney’s fees and sanctions to the defendants. The court held that the decision to award attorney’s fees or impose sanctions was within the trial court’s discretion, and found no abuse of discretion in denying fees or sanctions, affirming the dismissal with prejudice. View "Busby v. The Lamar Company, LLC" on Justia Law

Plaintiffs filed a class action against the Department of Homeland Security and Immigration and Customs Enforcement, alleging that the agencies were arresting noncitizens without a warrant in violation of 8 U.S.C. § 1357(a)(2). After years of litigation, the parties entered into a Consent Decree in 2021, approved by the United States District Court for the Northern District of Illinois in 2022. The Decree required the agencies to issue a policy statement, train officers, and document compliance with § 1357(a)(2). It also outlined procedures for enforcement and modification if violations were alleged.Prior to the Decree’s scheduled expiration in May 2025, Plaintiffs moved to enforce its terms and to extend its duration, asserting substantial noncompliance by Defendants. While these motions were pending, a DHS official declared the Decree terminated. On October 7, 2025, the district court found Defendants had violated the Decree, extended its term by 118 days, and ordered compliance-related relief. Later, Plaintiffs sought release or alternative detention for hundreds of individuals allegedly arrested in violation of the Decree. On November 13, 2025, the district court ordered the release of 13 individuals whom both parties agreed were arrested unlawfully, and additionally ordered release or alternatives for approximately 442 “potential class members,” pending determinations of violation.The United States Court of Appeals for the Seventh Circuit reviewed Defendants’ emergency motion to stay the district court’s October 7 and November 13 orders. The Seventh Circuit denied the request to stay the extension of the Consent Decree, holding that Defendants were unlikely to succeed on the merits of their argument that the extension violated 8 U.S.C. § 1252(f)(1). However, the court granted the stay as to the November 13 release order for those arrested pursuant to I-200 warrants and for “potential class members” pending individualized determinations under the Decree. The ruling sets forth the standards for stays and clarifies the limitations of § 1252(f)(1) in the context of class-wide injunctive relief and consent decree enforcement. View "Castanon Nava v. Department of Homeland Security" on Justia Law

A dispute arose between two siblings, Wayne Orkin and Lisa Albert, over the operation and ownership of a business called Boost Web SEO, Inc. Orkin managed the day-to-day business and generated all of its revenue, while Albert incorporated the company and was listed as its registered agent and officer. No written agreements clarified their roles, profit sharing, or compensation. In 2014, residual income from a payment processing arrangement was assigned to Boost Web, which both parties treated as company revenue for years. In 2021, after a breakdown in their relationship, Albert cut Orkin’s access to company funds and accused him of fraudulent activities in communications with a third-party vendor. Orkin then redirected company revenues to an account he controlled, prompting legal action.The litigation began in Massachusetts Superior Court, where Orkin (and his father) sued Albert and her son for various state-law claims, and Albert removed the case to the U.S. District Court for the District of Massachusetts. Boost Web intervened with a crossclaim against Orkin. After partial summary judgment, the remaining claims—Orkin’s defamation and related claims against Albert, and Boost Web’s conversion claim against Orkin—proceeded to a bench trial. The district court ruled for Albert on the defamation claim, finding her email was not defamatory or was protected as true, and for Boost Web on conversion, awarding it damages for funds Orkin took as personal expenses and for redirected residuals. The court also found Orkin in contempt for interfering with its orders and permanently enjoined him from pursuing related litigation in Florida.The United States Court of Appeals for the First Circuit reviewed the case. It held that the district court erred in dismissing Orkin’s defamation claim, finding that Albert’s email could be defamatory per se and remanded for further proceedings on truthfulness. It affirmed the conversion judgment regarding the redirected residuals but vacated the judgment concerning personal expenses, holding that Orkin was entitled to some compensation and remanded to determine the appropriate amount. The court vacated the contempt order and the permanent injunction, finding the previous orders did not unambiguously decide Boost Web’s ownership. The case was remanded for further proceedings consistent with these holdings. View "Orkin v. Albert" on Justia Law