Justia Civil Procedure Opinion Summaries

In 2015, product liability cases involving the blood-pressure medication Olmesartan were consolidated into a multidistrict litigation (MDL) in the United States District Court for the District of New Jersey. Adam Slater and his law firm, Mazie Slater Katz & Freeman, LLC, represented over 200 plaintiffs, and the case settled for over $300 million. Subsequently, Anthony Martino, a plaintiff in the MDL, filed a class action in New Jersey state court against his former lawyers, alleging they received contingent fees in violation of New Jersey court rules. The case was removed to federal court and dismissed, with the dismissal affirmed on appeal.Following this, twenty-one individuals represented by the same defendants in the MDL filed a similar action in New Jersey state court, alleging breach of contract, legal malpractice, conversion, and unjust enrichment. Defendants removed the case to the District Court, citing diversity and federal-question jurisdiction. The District Court denied the plaintiffs' motion to remand, asserting ancillary enforcement jurisdiction, and granted defendants' motion for judgment on the pleadings, applying issue preclusion. The court also dismissed the parties' motions for sanctions as moot.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that ancillary enforcement jurisdiction does not confer original jurisdiction sufficient for removal under 28 U.S.C. § 1441(a). The court also found that the plaintiffs' state-law claims did not necessarily raise a federal issue to establish federal-question jurisdiction. The court vacated the District Court's judgment and remanded the case to determine if the amount in controversy exceeded $75,000 for diversity jurisdiction. Additionally, the court vacated the order dismissing the motions for sanctions as moot, instructing the District Court to consider the merits of each motion. View "Johnson v. Mazie" on Justia Law

Claudia Horn worked for Insure Idaho, LLC for over six years and signed a non-solicitation agreement prohibiting her from soliciting Insure Idaho customers. After leaving Insure Idaho to work for Henry Insurance Agency, LLC, several Insure Idaho customers followed her. Insure Idaho sought a preliminary injunction to prevent Horn and Henry Insurance from soliciting its customers, which the district court granted. The district court later found Horn in contempt for violating the preliminary injunction when another former Insure Idaho customer moved its business to Henry Insurance.The district court granted the preliminary injunction and found Horn in contempt, but did not impose any sanctions. Henry Insurance was dismissed from the contempt proceedings and awarded attorney fees. Horn appealed the contempt judgment, and both Henry Insurance and Insure Idaho cross-appealed.The Supreme Court of Idaho reviewed the case and determined that the district court erred in finding Horn in contempt, as it lacked the ability to impose any sanction. The court also found that the district court misinterpreted the term "solicitation" and that Horn's actions did not constitute solicitation under the plain meaning of the term. The court held that the district court abused its discretion by granting the preliminary injunction without adequately addressing whether Insure Idaho was likely to succeed on the merits of its claims.The Supreme Court of Idaho reversed the judgment of contempt, vacated the preliminary injunction, and remanded the case for further proceedings. The court affirmed the district court's dismissal of Henry Insurance from the contempt proceedings and awarded attorney fees to Henry Insurance. The court also awarded Horn attorney fees for the contempt trial and appellate attorney fees for both Horn and Henry Insurance. View "Insure Idaho v. Horn" on Justia Law

During the COVID-19 pandemic, K7 Design Group, Inc. (K7) offered to sell hand sanitizer to Walmart, Inc., doing business as Sam’s Club (Sam’s Club). K7 and Sam’s Club discussed and agreed upon the product, price, quantity, and delivery terms for various hand sanitizer products through email communications. K7 delivered over 1,000,000 units of hand sanitizer to Sam’s Club, which paid approximately $17.5 million. However, Sam’s Club did not collect or pay for the remaining hand sanitizer, leading to storage issues for K7.The United States District Court for the Western District of Arkansas held a jury trial, where the jury found in favor of K7 on its breach of contract claim and awarded $7,157,426.14 in damages. Sam’s Club’s motions for judgment as a matter of law and for a new trial were denied by the district court.The United States Court of Appeals for the Eighth Circuit reviewed the case. Sam’s Club argued that K7 failed to present sufficient evidence of an obligation to pay for the products, the jury’s verdict was against the weight of the evidence, and the district court abused its discretion in instructing the jury. The Eighth Circuit affirmed the district court’s decision, holding that the communications between K7 and Sam’s Club constituted binding orders under Arkansas’s Uniform Commercial Code (UCC). The court found that the evidence supported the jury’s verdict and that the district court did not abuse its discretion in its jury instructions or in denying Sam’s Club’s motions. The court also affirmed the district court’s award of prejudgment interest and attorney fees and costs. View "K7 Design Group, Inc. v. Walmart, Inc." on Justia Law

In April 2017, Mark Mehner was injured when a chair he was sitting on at a Panera café in Omaha collapsed. Mehner sued Panera and the chair manufacturer, Furniture Design Studios (FDS), for negligence, spoliation, and strict liability. He claimed permanent injuries, including spinal fractures. Panera's general manager filled out an incident report but discarded the broken chair and the handwritten report. Mehner alleged that he had requested the preservation of the chair and surveillance video, which Panera denied.The United States District Court for the District of Nebraska granted summary judgment to both FDS and Panera. The court found that Mehner failed to provide evidence of a specific defect in the chair or causation, particularly since the chair had been out of FDS's possession for nearly eight years. The court also denied Mehner's motion for spoliation sanctions, finding no intentional destruction of evidence by Panera. Additionally, the court rejected Mehner's motion for relief from judgment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of FDS, agreeing that Mehner did not present sufficient evidence of a defect or causation. The court also upheld the summary judgment for Panera, determining that Mehner failed to establish that Panera created or had notice of the chair's condition. The court rejected Mehner's res ipsa loquitur argument, noting that he did not show the chair was under Panera's exclusive control or that the incident would not have occurred without negligence.The Eighth Circuit also affirmed the district court's discovery rulings, including the denial of Mehner's motion to defer, the denial of his motion to extend progression, and the issuance of a protective order to Panera. The court found no abuse of discretion in these rulings. Finally, the court upheld the denial of spoliation sanctions and the denial of Mehner's motion to revise, alter, or amend the judgment. View "Mehner v. Furniture Design Studios, Inc." on Justia Law

Lamar Catchings, a 20-year-old pretrial detainee, died from undiagnosed acute leukemia while in custody at the St. Louis County Buzz Westfall Justice Center in February 2019. His mother, Tashonda Troupe, filed a 42 U.S.C. § 1983 lawsuit against St. Louis County and numerous jail officials, medical staff, and correctional officers, alleging deliberate indifference to her son’s serious medical needs and failure to train or supervise the staff responsible for his care.The United States District Court for the Eastern District of Missouri dismissed the claims against most defendants at the pleading stage, citing qualified immunity and insufficient factual allegations. The court found that many of Troupe’s allegations were based on “information and belief” and lacked specific factual support. The district court allowed the claim against defendant Anthony Young, a practical nurse, to proceed, but dismissed the claims against other defendants, including correctional officers and medical staff, for lack of sufficient allegations of personal involvement or knowledge of Catchings’s condition.The United States Court of Appeals for the Eighth Circuit reviewed the case and addressed whether Troupe’s “upon information and belief” allegations were sufficient to state a claim. The court held that such allegations are permissible if the facts are within the possession and control of the defendants or based on factual information that makes the inference of culpability plausible. The court found that Troupe’s allegations met this standard and reversed the district court’s dismissal of claims against certain defendants, including Swims, Beard, Oliver, Doucette, and Murphy. The court affirmed the dismissal of claims against Mohler and Williams and partially reversed the dismissal of claims against the County, allowing the failure-to-train-or-supervise claim to proceed. The case was remanded for further proceedings consistent with the appellate court’s findings. View "Troupe v. St. Louis County, Missouri" on Justia Law

Thomas Hamann brought a lawsuit against Heart Mountain Irrigation District (HMID) and its manager, Randy Watts, alleging that HMID, through Watts' actions, damaged his property and caused him bodily injury. Hamann sought damages based on claims of inverse condemnation and violation of his constitutional rights under 42 U.S.C. § 1983. The district court granted summary judgment in favor of HMID and Watts, dismissing Hamann’s lawsuit entirely. Hamann appealed only the dismissal of his inverse condemnation claim against HMID.The district court found that HMID had not taken any official action to authorize Watts to enter Hamann’s property beyond the limited scope of work on the Riolo bowl, which Hamann had consented to. The court held that without such authorization, Hamann’s inverse condemnation claim could not survive summary judgment. Hamann argued that there was a material issue of fact regarding whether Watts was acting under the scope, authority, and direction of HMID’s board.The Wyoming Supreme Court reviewed the case and found that there were genuine issues of material fact regarding the extent of Watts’ authority and whether his actions were authorized by HMID. The court noted that HMID’s bylaws allowed for delegation of responsibilities to its manager and other agents, and there was evidence suggesting that Watts had general discretion as HMID’s manager. Additionally, there was conflicting testimony about whether Watts had specific authorization to access Hamann’s property beyond the Riolo bowl.The court concluded that the district court erred in granting summary judgment to HMID, as there were unresolved factual issues regarding the authorization of Watts’ actions and the extent of damage to Hamann’s property due to activities on adjoining land. The Wyoming Supreme Court reversed the district court’s order and remanded the case for further proceedings. View "Hamann v. Heart Mountain Irrigation District" on Justia Law

Jason Rahimzadeh was injured while riding his bicycle and sought underinsured motorist (UIM) coverage from his employer's commercial automobile insurance policy with Ace American Insurance Company. Ace denied the claim, stating that Rahimzadeh did not qualify as an insured under the policy. Rahimzadeh then filed a lawsuit in Illinois state court, alleging breach of the insurance contract. Ace removed the case to the United States District Court for the Northern District of Illinois, which granted Ace's motion to dismiss for failure to state a claim.The district court found that the terms of the insurance policy were unambiguous and that Rahimzadeh did not meet the policy's requirement of "occupying" a covered vehicle to qualify as an insured. The court also rejected Rahimzadeh's argument that the occupancy requirement was unenforceable as contrary to public policy, distinguishing the case from Galarza v. Direct Auto Insurance Co., which involved a personal automobile insurance policy. The court relied on Stark v. Illinois Emcasco Insurance Co., which upheld occupancy requirements in commercial policies.The United States Court of Appeals for the Seventh Circuit reviewed the district court's decision de novo. The court affirmed the district court's judgment, holding that the occupancy requirement in the commercial automobile insurance policy was permissible and did not violate Illinois public policy. The court distinguished the case from Galarza, noting that the public policy concerns in personal insurance policies do not apply to commercial policies. Therefore, Rahimzadeh was not entitled to UIM coverage under his employer's policy. The court also declined to certify the question to the Supreme Court of Illinois, finding no genuine uncertainty about the state law issue. View "Rahimzadeh v. Ace American Insurance Co." on Justia Law

The case involves a dispute between Vermont’s Auditor of Accounts and the Attorney General. The Auditor sued the Attorney General, alleging non-compliance with the statutory obligation to provide legal advice. The Auditor sought a declaratory judgment affirming his right to retain counsel to sue the Attorney General and mandamus to compel the Attorney General to answer specific legal questions. The trial court dismissed the Auditor’s claims and denied his request for attorneys’ fees.The dispute arose from the Auditor’s audit of a Burlington tax increment financing (TIF) district. The Auditor encountered a perceived gap in TIF statutes and sought advice from the Attorney General, who answered one question but directed the Auditor to other entities for the remaining questions. The Auditor claimed this was a violation of the Attorney General’s duty under 3 V.S.A. § 159 and threatened to sue. The Attorney General responded, explaining her statutory obligations and asserting that the Auditor lacked authority to sue.The Vermont Supreme Court reviewed the case. It affirmed the trial court’s dismissal of the Auditor’s claims for mandamus and declaratory judgment related to the specific TIF questions, concluding that the Attorney General had provided legal advice as required by 3 V.S.A. § 159. The court also affirmed the dismissal of the broader declaratory judgment claim, finding no live controversy as the Attorney General had provided legal advice and there was no policy of refusing to do so.However, the court reversed the trial court’s dismissal of the Auditor’s claim for declaratory judgment regarding his right to retain counsel and sue for mandamus. The court held that the Auditor has implied statutory authorization to seek mandamus to enforce the Attorney General’s duty under 3 V.S.A. § 159. The court also affirmed the denial of attorneys’ fees, finding Rule 54 inapplicable for the relief sought by the Auditor. View "Office of the Auditor of Accounts v. Office of the Attorney General" on Justia Law

Petitioner James Fredrick filed a habeas corpus petition challenging his confinement in Vermont on a governor’s warrant pending extradition to New York for a second-degree murder charge. The superior court denied the petition, concluding that the extradition process requirements were met. On appeal, Fredrick argued that the governor’s warrant and New York’s extradition application lacked an authenticated copy of the indictment as required by Vermont law.The Caledonia Superior Court, Civil Division, held a hearing and denied Fredrick’s request, reasoning that the governor’s warrant was prima facie evidence that the extradition requirements were satisfied. The court found that the documents showed Fredrick was lawfully charged by indictment. Fredrick appealed the decision on January 9, 2025.During the appeal, Governor Scott recalled the original governor’s warrant and issued a new one, including a copy of the indictment signed by the grand jury foreperson. Fredrick filed another habeas corpus petition challenging the new warrant, which was also denied, and an appeal is pending.The Vermont Supreme Court dismissed the appeal as moot, noting that the original governor’s warrant was withdrawn and Fredrick’s confinement is now based on a new warrant. The court found no applicable exceptions to mootness, as Fredrick did not demonstrate that the issue was capable of repetition yet evading review, nor did he show negative collateral consequences. The court concluded that there was no longer an actual controversy, and the appeal was dismissed. View "In re James Fredrick" on Justia Law

The plaintiff, Aleksandra Veljovic, filed a lawsuit against TD Bank, N.A. and its former employee, Zlata Cavka, alleging negligence, negligent supervision, and respondeat superior. Veljovic claimed that Cavka negligently notarized a fraudulent document used by her ex-husband to secure a divorce order in Serbia, which resulted in the loss of her marital property. Veljovic argued that TD Bank should be held liable for Cavka's actions. The Superior Court, Chittenden Unit, Civil Division, dismissed Veljovic's complaint with prejudice, concluding that she could not recover for purely economic losses and failed to demonstrate a special relationship between the parties. The court also denied her post-judgment request to amend her complaint.TD Bank moved to dismiss the complaint under Vermont Rule of Civil Procedure 12(b)(6), arguing that Veljovic's claims were barred by the economic-loss rule, that neither TD Bank nor Cavka owed her an independent duty of care, and that she failed to plead facts establishing necessary causation. The court granted the motion, finding that Veljovic sought compensation solely for economic losses and did not establish a special relationship with the defendants. The court also dismissed the claims against Cavka after Veljovic failed to respond to a show-cause order.Veljovic appealed to the Vermont Supreme Court, arguing that the trial court erred in dismissing her complaint and denying her motion to amend. The Vermont Supreme Court affirmed the lower court's decision, agreeing that Veljovic did not allege sufficient facts to show a special relationship with the defendants and that her claims were barred by the economic-loss rule. The court also found no abuse of discretion in denying her motion to amend the complaint, as the proposed amendments would not have established a special relationship or overcome the economic-loss rule. View "Veljovic v. TD Bank, N.A." on Justia Law