Justia Civil Procedure Opinion Summaries

Diego Pavia, a college football player, sought to play for Vanderbilt University during the 2025 season. After a successful 2024 season, Pavia faced ineligibility under National Collegiate Athletic Association (NCAA) rules, which limit athletes to four seasons of intercollegiate competition, including seasons played at junior colleges. Pavia’s path included time at a junior college, New Mexico State University, and Vanderbilt. The NCAA counted his 2021 junior college season toward his eligibility, effectively barring him from playing in 2025. Pavia argued that this rule violated the Sherman Act and sought injunctive relief to allow him to play in the 2025 and 2026 seasons.The United States District Court for the Middle District of Tennessee granted Pavia a preliminary injunction, preventing the NCAA from enforcing the rule against him for the 2025 season and from applying its restitution rule to Vanderbilt or Pavia based on his participation. The NCAA appealed this decision to the United States Court of Appeals for the Sixth Circuit.While the appeal was pending, the NCAA issued a waiver allowing all similarly situated athletes, including Pavia, to play in the 2025 season. The NCAA confirmed that this waiver would remain in effect regardless of the outcome of the appeal. The United States Court of Appeals for the Sixth Circuit determined that, because Pavia had already received the relief he sought at the preliminary injunction stage, the appeal was moot. The court held that it could not grant any further effectual relief and dismissed the appeal for lack of jurisdiction. The court also declined to vacate the preliminary injunction, finding that the NCAA’s own actions had caused the case to become moot. View "Pavia v. NCAA" on Justia Law

The dispute centers on the extension of a grading and grubbing permit issued by the Director of the Department of Public Works, County of Maui, to Maui Lani Partners for excavation work at a residential development site containing ancestral Hawaiian burial sites. In March 2018, an unincorporated association and its members challenged the validity of the permit extension, alleging violations of state and county laws requiring consultation with the State Historic Preservation Division and arguing that the Director exceeded his authority in granting the extension without good cause.The Circuit Court of the Second Circuit granted motions to dismiss the complaint on all counts without prejudice, finding no regulatory or statutory authority requiring consultation with the State Historic Preservation Division for permit extensions and that the Director acted within his discretionary authority. The court denied the plaintiffs’ motion for summary judgment and later denied their HRCP Rule 60(b)(6) motion for reconsideration, concluding that the plaintiffs had not presented new law or argument. The plaintiffs appealed to the Intermediate Court of Appeals (ICA), which affirmed the circuit court’s denial of costs and the motion for reconsideration but held that the notice of appeal was untimely because the Rule 60(b) motion was not filed within ten days of judgment and thus did not toll the appeal deadline.The Supreme Court of Hawaiʻi reviewed the case and held that a motion for reconsideration filed under HRCP Rule 60(b) is a “tolling motion” under HRAP Rule 4(a)(3) if filed within a reasonable time and before the appeal deadline, thereby extending the time to file a notice of appeal. The court also held that the ICA did not err in affirming the circuit court’s denial of the Rule 60(b)(6) motion for reconsideration. The Supreme Court vacated the ICA’s judgment in part and remanded for further proceedings. View "Kakanilua v. Director of the Department of Public Works" on Justia Law

Tristin Fahrnow was injured when a hot-oil truck operated by an employee of E-5 Oilfield Services struck him on an icy Montana highway. Fahrnow had been inspecting his own vehicle after a prior collision at the intersection, and was standing in the roadway when the E-5 truck lost control and hit him. Fahrnow sued E-5 for negligence under a theory of vicarious liability, alleging that the E-5 driver failed to operate the truck safely given the hazardous conditions. E-5 asserted that Fahrnow’s own actions, including parking in the traffic lane and failing to display warning devices, constituted comparative negligence.The Seventh Judicial District Court of Montana granted summary judgment in favor of E-5, finding that Fahrnow was solely responsible for his injuries as a matter of law. The District Court also denied Fahrnow’s motions for sanctions against E-5 for alleged spoliation of evidence (loss of truck data and employment records) and denied his motion to compel E-5 to answer an interrogatory comparing the parties’ medical experts’ qualifications, granting E-5’s cross-motion for a protective order.The Supreme Court of the State of Montana reviewed the case de novo. It held that the record presented a genuine issue of material fact regarding the comparative negligence of both drivers, making summary judgment inappropriate. The Court reversed the District Court’s grant of summary judgment to E-5 and remanded for trial. However, the Supreme Court affirmed the District Court’s denial of Fahrnow’s motions for default judgment as a sanction for spoliation and its denial of the motion to compel further expert discovery, finding no abuse of discretion in those rulings. View "Fahrnow v. E-5 Oil Services" on Justia Law

A nonprofit organization sought access to confidential court records from child protective and adoption proceedings involving a young girl who died after being placed in foster care and later adopted. The girl was reported missing in 2021, and her death was confirmed in 2023. The records also contained information about her siblings. The siblings, through their counsel, did not object to disclosure as long as their identities were protected through redactions. The Department of Human Services and the adoptive father opposed disclosure, arguing that the records were confidential and that redactions would not sufficiently protect privacy.The Family Court of the First Circuit denied the request, reasoning that releasing redacted records would be misleading and would not serve the public interest in understanding the response of agencies and the court to child abuse and neglect. The court concluded that the records should remain sealed, citing concerns about the completeness and potential for misunderstanding of the redacted information.The Supreme Court of the State of Hawaiʻi reviewed the case and held that, under Hawaiʻi Revised Statutes §§ 587A-40 and 578-15, public access to confidential child protective and adoption records is permitted when a foster child is missing, has suffered a near fatality, been critically injured, or has died, provided that information about living siblings is redacted to protect their privacy. The court overruled prior precedent to the extent it limited disclosure to only those purposes that further the best interests of the child, clarifying that a “legitimate purpose” for disclosure can exist independently. The court ordered the release of the redacted records and provided guidance for future requests, affirming the family court’s authority to require agencies to prepare redacted versions for public access. View "Public First Law Center v. Viola" on Justia Law

The plaintiff sought medical care for severe headaches and related symptoms from various providers in Oklahoma and Missouri, including Freeman Health System (FHS) and Dr. Gulshan Uppal in Joplin, Missouri. After multiple visits and treatments, she was ultimately diagnosed with serious neurological conditions and suffered lasting health consequences. She alleged that several healthcare providers, including FHS and Dr. Uppal, negligently diagnosed, treated, and discharged her.She filed suit in the District Court of Ottawa County, Oklahoma, naming multiple defendants. FHS and Dr. Uppal moved to dismiss for lack of personal jurisdiction, arguing their actions and contacts were insufficient for Oklahoma courts to exercise jurisdiction. The district court granted the motion, finding it lacked both general and specific personal jurisdiction over these defendants, primarily because the relevant treatment occurred in Missouri and the claims did not arise from FHS’s Oklahoma contacts. The Oklahoma Court of Civil Appeals affirmed this decision.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. It held that the district court erred by only considering whether the suit “arose out of” the defendants’ contacts with Oklahoma, and not whether it “related to” those contacts, as required by the two-pronged standard for specific personal jurisdiction clarified in Ford Motor Co. v. Montana 8th Judicial District Court. The Supreme Court found that the plaintiff met her burden regarding FHS’s contacts with Oklahoma, warranting further proceedings to determine if her claims “relate to” those contacts. However, the plaintiff failed to show sufficient contacts for personal jurisdiction over Dr. Uppal. The Supreme Court vacated the appellate court’s opinion, affirmed the district court’s dismissal of Dr. Uppal, reversed the dismissal of FHS, and remanded for further proceedings. View "Barfell v. Freeman Health System" on Justia Law

Several homeowners initiated a lawsuit against an individual, alleging conversion, trespass, outrage, reformation of restrictive covenants, quiet title, and seeking injunctive relief to prevent interference with their use of common areas in a real estate development. The defendant retained counsel and filed a timely answer. However, when the homeowners moved for summary judgment, the defendant’s attorney failed to respond or inform his client about the motion. The district court granted summary judgment for the homeowners, awarding substantial actual and punitive damages, as well as attorney’s fees, far exceeding the amount requested in the motion.After more than 30 days had passed since judgment, the defendant moved to vacate the judgment in the District Court of Cherokee County, Oklahoma, arguing that unavoidable casualty or misfortune, fraud, and irregularity had prevented him from defending the action. The district court held an evidentiary hearing and denied the motion to vacate. The defendant appealed, and the Court of Civil Appeals, Division III, affirmed the district court’s decision, finding that the defendant had not properly pled a valid defense and that his attorney’s negligence was imputed to him.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. It held that the attorney’s abandonment of the case without the client’s knowledge, combined with a breakdown in office procedures and lack of communication, constituted unavoidable casualty or misfortune under Oklahoma law. The court further found that the district court’s award of damages and attorney’s fees without a hearing or proper evidentiary support violated the defendant’s due process rights. The Supreme Court vacated the opinion of the Court of Civil Appeals, reversed the district court’s judgment, and remanded the case for further proceedings. It also vacated the appellate attorney fee award previously granted to the homeowners. View "Bjorkman v. Noble" on Justia Law

A woman who immigrated from China to the United States and later became a U.S. citizen founded an educational institution that participated in a Department of Defense tuition program. In 2010, the FBI began investigating her for statements made on immigration forms, conducting interviews, searches, and seizing personal and business materials. Although the U.S. Attorney’s Office ultimately declined to file charges, Fox News later published reports about her, including confidential materials from the FBI investigation. These reports cited anonymous sources and included documents and photographs seized during the FBI’s search. Following the reports, the Department of Defense terminated her institution’s participation in the tuition program, resulting in significant financial losses.She filed a lawsuit in the United States District Court for the District of Columbia against the FBI and other federal agencies, alleging violations of the Privacy Act due to the unauthorized disclosure of her records. During discovery, she was unable to identify the source of the leak despite extensive efforts. She then subpoenaed a Fox News journalist, who authored the reports, to reveal her confidential source. The journalist invoked a qualified First Amendment reporter’s privilege. The district court found that the plaintiff had met the requirements to overcome this privilege—demonstrating both the centrality of the information to her case and exhaustion of alternative sources—and ordered the journalist to testify. When the journalist refused, the court held her in civil contempt.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s orders. The appellate court held that, under its precedents, a qualified First Amendment reporter’s privilege may be overcome in civil cases if the information sought is crucial to the case and all reasonable alternative sources have been exhausted. The court also declined to recognize a broader federal common law reporter’s privilege. View "Chen v. FBI" on Justia Law

A married couple, both employees of UT-Battelle, objected to their employer’s COVID-19 vaccine mandate on religious grounds, specifically because of their belief that the vaccines’ development involved the use of fetal cell lines from abortions, which conflicted with their Christian faith. UT-Battelle required employees seeking religious exemptions to undergo a panel interview and read a “fact sheet” presenting religious leaders’ support for vaccination. Employees granted religious accommodations were placed on unpaid leave, while those with medical accommodations were not. Mrs. Bilyeu ultimately received a medical exemption before the policy took effect and did not lose pay or work time. Mr. Bilyeu, however, was placed on unpaid leave after exhausting his vacation days, returning to work only after the policy was rescinded.The United States District Court for the Eastern District of Tennessee granted summary judgment to UT-Battelle on all claims except Mrs. Bilyeu’s retaliation claim, which was later settled. The court found that Mrs. Bilyeu lacked standing and that Mr. Bilyeu had not suffered a materially adverse employment action under Title VII.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment as to Mrs. Bilyeu, holding she lacked Article III standing because she suffered no cognizable injury after receiving her medical accommodation. For Mr. Bilyeu, the Sixth Circuit vacated the summary judgment on his disparate treatment and failure-to-accommodate claims, instructing the district court to reconsider them in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, which eliminated the “materially adverse” requirement for adverse employment actions under Title VII. The court reversed the summary judgment on Mr. Bilyeu’s retaliation claim, finding sufficient evidence for a reasonable jury to conclude that the interview process could dissuade a reasonable worker from seeking a religious accommodation, and remanded for further proceedings. View "Bilyeu v. UT-Battelle, LLC" on Justia Law

After tripping and falling on a raised portion of sidewalk in front of a residence, the plaintiff sued the owners of the adjacent properties and the City for negligence and premises liability. The claim against one property owner, Goode, was based on the theory that a tree in the parkway in front of her house had roots extending under the sidewalk where the plaintiff fell, potentially causing the damage. The City maintained and inspected the tree and sidewalk, but the plaintiff alleged Goode’s ownership of the tree contributed to the dangerous condition.The Ventura County Superior Court granted summary judgment in favor of Goode, finding no triable issue of material fact regarding her liability. The plaintiff did not oppose Goode’s motion for summary judgment, but the City did file an opposition and attempted to file a cross-complaint against Goode. The trial court declined to consider the City’s opposition, ruling that the City lacked standing because it had not filed a cross-complaint, and rejected the cross-complaint on procedural grounds.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. It held that a codefendant with an adverse interest has standing to oppose a motion for summary judgment, regardless of whether a cross-complaint has been filed. The court further found that the City’s cross-complaint was properly filed and should not have been rejected. However, after reviewing the evidence de novo, the appellate court concluded that Goode could not be held liable as a matter of law because she did not own, control, or maintain the sidewalk or tree in a manner that created the dangerous condition. The judgment granting summary judgment in favor of Goode was affirmed. View "Bean v. City of Thousand Oaks" on Justia Law

A flight attendant on a Delta Air Lines flight observed a 13-year-old passenger crying during turbulence and believed the man accompanying her was behaving inappropriately. Concluding that the man was sexually assaulting and trafficking the child, the attendant reported her concerns to the flight captain, who relayed the information to a station manager. The manager contacted local police, who detained and questioned the man, Nicholas Cupp, and his daughter upon landing. After investigation, police determined Cupp was the child’s father and released him without charges. Cupp later filed suit, alleging the report was false and reckless, and claimed significant emotional distress and harm to his relationship with his daughter.The case was initially filed in the Circuit Court of Newport News, Virginia, but was removed to the United States District Court for the Eastern District of Virginia based on diversity jurisdiction. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), arguing immunity under Virginia Code § 63.2-1512 for good-faith reports of suspected child abuse. The district court granted the motion, finding the immunity statute applicable even though the report was made to law enforcement rather than directly to social services, and concluded that Cupp had not sufficiently alleged bad faith or malicious intent.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether a nonmandatory reporter who makes a good-faith complaint of suspected child abuse to law enforcement, rather than directly to social services, is entitled to immunity under Virginia Code § 63.2-1512. Finding no controlling Virginia precedent, the Fourth Circuit certified this question to the Supreme Court of Virginia, as its answer will determine whether the district court’s dismissal should be affirmed or reversed. View "Cupp v. Delta Air Lines, Inc." on Justia Law