Justia Civil Procedure Opinion Summaries

David Burke died after falling down retractable steps attached to his motorhome. His estate, wife, and children filed product liability claims against Lippert Components, Inc., and LCI Industries, who had purchased the product brand after the Burkes bought the vehicle. The plaintiffs alleged negligence, design defects, manufacturing defects, and inadequate instructions and warnings. They later sought to add the previous owners of the product brand as defendants and amend the scheduling order, but the district court denied these motions and granted summary judgment in favor of Lippert and LCI.The United States District Court for the Northern District of Iowa denied the plaintiffs' motions to amend the complaint and the scheduling order, citing unreasonable delay. The court then granted summary judgment for Lippert and LCI, finding that they did not manufacture, distribute, or sell the steps in question, and thus were not liable under Iowa law. The plaintiffs appealed these decisions.The United States Court of Appeals for the Eighth Circuit affirmed the district court's rulings. The appellate court held that Lippert and LCI were not required to plead an affirmative defense regarding successor liability, as their defense negated an essential element of the plaintiffs' claims. The court also found that Lippert and LCI did not assume liability through the purchase agreement and that expert testimony was necessary to support the claim of inadequate post-sale warnings. Finally, the court agreed that the plaintiffs failed to show good cause for their delayed motions to amend the complaint and scheduling order. The judgment of the district court was affirmed. View "Burke v. Lippert Components, Inc." on Justia Law

Henry Stursberg, a financial consultant, sued Morrison Sund PLLC, a Minnesota law firm, for allegedly running up legal fees without achieving results. After Stursberg decided to change counsel, Morrison Sund filed an involuntary bankruptcy petition against him. Stursberg sought to dismiss the petition, which the bankruptcy court granted under 11 U.S.C. § 305(a)(1), noting the petition was used improperly to collect fees. Stursberg then filed a diversity action in Pennsylvania, asserting state law tort claims against Morrison Sund.The Eastern District of Pennsylvania dismissed Stursberg’s claims due to lack of personal jurisdiction and improper venue, transferring the case to the District of Minnesota. The Minnesota district court dismissed the state law claims, ruling they were preempted by the Bankruptcy Code, specifically 11 U.S.C. § 303(i), which provides remedies for bad faith filings of involuntary bankruptcy petitions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s dismissal, holding that the federal court that dismisses an involuntary bankruptcy case has exclusive jurisdiction to enforce debtor remedies under § 303(i). The court concluded that Stursberg’s state law claims were preempted by the federal statute, and his failure to appeal the bankruptcy court’s denial of his motion for attorney’s fees and costs under § 303(i)(1) precluded him from seeking further damages. The court emphasized that § 303(i) provides an exclusive remedy for bad faith filings, precluding state law tort claims in this context. View "Stursberg v. Morrison Sund PLLC" on Justia Law

A group of plaintiffs, including William Clardy, Michelle Tucker, two state representatives, and a nonprofit corporation, filed a lawsuit against Maine's Senate President, Speaker of the House, and Governor. They sought to invalidate a special legislative session called by the Governor, arguing it was unconstitutional. The plaintiffs claimed the session was based on a "contrived" extraordinary occasion and that the legislative leaders ceded power to the executive branch. They sought declarations that the session and the legislation passed during it were void.The Kennebec County Superior Court dismissed the complaint for failure to state a claim. The court did not decide on the plaintiffs' standing but ruled that the Governor's determination of an extraordinary occasion to convene the Legislature was not subject to judicial review. Additionally, the court found that the legislative leaders were immune from suit for their actions. The plaintiffs appealed the decision.The Maine Supreme Judicial Court reviewed the case and affirmed the dismissal, but on different grounds. The court held that the plaintiffs lacked standing to bring the suit. The court found that the individual plaintiffs, as citizens and taxpayers, did not demonstrate a particularized injury distinct from the general public. The state representatives failed to show a concrete injury arising from the Governor's proclamation or the convening of the special session. Lastly, the nonprofit corporation lacked standing because its members did not have standing to sue individually. The court concluded that no plaintiff had suffered an injury sufficient to confer standing, thus affirming the lower court's dismissal of the case. View "Clardy v. Jackson" on Justia Law

Jacquelyn N’Jai filed a lawsuit against the U.S. Department of Education, New York University (NYU), Long Island University (LIU), Immediate Credit Recovery, Inc. (ICR), and FMS Investment Corporation (FMS), alleging various violations of federal law. N’Jai claimed that she had repaid her student loans but was falsely certified for additional loans by a bank analyst, with NYU and LIU allegedly signing her name on fraudulent loan applications. She contended that the Department of Education and its debt collectors used unlawful practices to collect on these loans, including garnishing her tax refund and threatening to garnish her Social Security checks.The United States District Court for the District of Columbia dismissed N’Jai’s claims against LIU, NYU, ICR, and FMS for lack of personal jurisdiction, citing the government contacts exception. This exception prevents the assertion of personal jurisdiction based solely on a defendant’s contact with federal government agencies in the District of Columbia. The court dismissed the claims against the remaining defendants for other reasons.The United States Court of Appeals for the District of Columbia Circuit reviewed the case, focusing on whether the government contacts exception under D.C. law is limited to First Amendment activities. The court noted the ongoing uncertainty about the scope of this exception, referencing previous cases where the D.C. Court of Appeals had not definitively resolved whether the exception is confined to First Amendment activity. Due to this uncertainty, the appellate court certified two questions to the D.C. Court of Appeals: whether the government contacts exception is limited to First Amendment activity and, if so, whether the contacts alleged in this case fall under that exception. The appellate court did not make a final ruling on the personal jurisdiction issue, pending the D.C. Court of Appeals' response to the certified questions. View "N'Jai v. Department of Education" on Justia Law

Four registered voters and several non-profit organizations sued the Cobb County Board of Elections and Registration, alleging that the 2022 redistricting map for the Cobb County School Board was an unconstitutional racial gerrymander. They claimed the map packed Black and Latino voters into certain districts to dilute their political power and maintain a majority white School Board. The plaintiffs sought declaratory and injunctive relief to prevent the use of the 2022 map in future elections.The Cobb County School District intervened as a defendant and moved for judgment on the pleadings, arguing it was not liable for any constitutional violation because the Georgia General Assembly, not the School Board, enacted the map. The district court granted the School District’s motion based on Monell v. Department of Social Services of New York, but did not immediately enter judgment. The School District continued to participate in the case, prompting the court to formally terminate it as a party. The plaintiffs and the Election Defendants then entered a settlement, leading to a preliminary injunction against the 2022 map.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court dismissed the School District’s appeal for lack of jurisdiction, holding that the School District, as a nonparty, lacked standing to appeal the preliminary injunction. The court emphasized that only parties or those who properly become parties may appeal, and the School District had not sought to reintervene for purposes of appeal. The court also noted that the School District’s participation as an amicus did not grant it the right to appeal. View "Cobb County School District" on Justia Law

A group of property owners sued Columbia County over stormwater drainage issues that caused damage to their property. The property, purchased in 1996, contained a metal pipe used in the County's stormwater system. Over the years, heavy rains caused the pipe to fail multiple times, leading to significant property damage. The property owners sent a notice to the County in October 2013, outlining their claims, but the County declined to make repairs. The property owners then filed a lawsuit in March 2014, seeking damages and an injunction to prevent further damage.The trial court found in favor of the property owners, ruling that the County maintained a nuisance that amounted to a taking without just compensation. The court awarded damages and issued a permanent injunction against the County. The County appealed to the Court of Appeals, which affirmed some parts of the trial court's decision and vacated others. The Court of Appeals vacated the damages award for harms incurred after the October 2013 notice and reversed the award of attorneys' fees. However, it upheld the injunction against the County.The Supreme Court of Georgia reviewed the case and vacated the Court of Appeals' decision to uphold the injunction, ruling that it exceeded the bounds of the Georgia Constitution's limited waiver of sovereign immunity. The Court directed the Court of Appeals to remand the case to the trial court to consider a new injunction within the constitutional limits. The Supreme Court also concluded that it should not have granted certiorari on the issue of damages for harms incurred after the October 2013 notice, as the Court of Appeals' ruling was specific to the facts of this case and did not establish a general rule of law. The petition for certiorari on this issue was therefore denied. View "Satcher v. Columbia County" on Justia Law

Bruce Molzan, a well-known chef, filed a lawsuit against Bellagreen Holdings, LLC, and other associated entities and individuals, alleging trademark infringement and other claims under the Lanham Act and Texas law. Molzan claimed that he had been using the "RUGGLES" trademarks for over forty years and that the defendants misused these trademarks after a forced sale of his restaurants. He alleged that the defendants continued to use the "RUGGLES GREEN" trademark and domain name without authorization, causing consumer confusion.The United States District Court for the Southern District of Texas dismissed all of Molzan's claims under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The court found that Molzan's allegations were conclusory and did not establish a connection between the defendants and the third-party websites causing the confusion. The court also determined that the Settlement Agreement between the parties addressed the alleged infringements and provided a remedy for such transgressions.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that Molzan's complaint contained well-pleaded factual allegations that made his claims facially plausible. The court noted that the allegations established a likelihood of confusion due to the defendants' continued use of the "RUGGLES" trademarks. The court also found that the district court erred in assuming the veracity of the defendants' assertions over Molzan's well-pleaded allegations. The Fifth Circuit reversed the district court's dismissal of Molzan's federal and state trademark infringement, false advertising, unfair competition, and state trademark dilution claims. The court also reversed the dismissal of Molzan's breach of contract and unjust enrichment claims and remanded the case for further proceedings. Additionally, the court vacated the district court's dismissal of the Web Defendants and the denial of Molzan's motion for leave to amend his complaint. View "Molzan v. Bellagreen Holdings" on Justia Law

Cynthia Roberge, a State of Rhode Island employee, was involved in a car accident with an underinsured motorist while driving her personal vehicle during the course of her employment. She sought uninsured/underinsured motorist (UM/UIM) coverage under the State's insurance policy issued by Travelers Property Casualty Company of America. Travelers denied her claim, stating that she was not entitled to UM/UIM coverage because she was not driving a "covered auto" as defined by the policy.Roberge filed a lawsuit in Providence County Superior Court, asserting claims for breach of contract, declaratory judgment, and bad faith. Travelers removed the case to the United States District Court for the District of Rhode Island. The district court granted summary judgment in favor of Travelers, concluding that Roberge was not entitled to UM/UIM coverage under the policy's terms and that neither the Rhode Island Supreme Court's decision in Martinelli v. Travelers Insurance Companies nor the Rhode Island Uninsured Motorist Statute required such coverage.On appeal, the United States Court of Appeals for the First Circuit reviewed the case. The court noted that the policy's language clearly excluded Roberge from UM/UIM coverage because she was not driving a "covered auto." However, the court found that the case raised unresolved questions of Rhode Island insurance law, particularly regarding the applicability of the Martinelli exception and the requirements of the Rhode Island Uninsured Motorist Statute. The First Circuit decided to certify two questions to the Rhode Island Supreme Court: whether an employee must be considered a named insured under an employer's auto insurance policy when operating a personal vehicle in the scope of employment, and whether it violates Rhode Island law and public policy for an employer's policy to provide liability but not UM/UIM coverage to employees in such circumstances. The case was stayed pending the Rhode Island Supreme Court's response. View "Roberge v. Travelers Property Casualty Co. of America" on Justia Law

Overwell Harvest, Ltd. invested millions in Neurensic, Inc., which soon faced severe financial difficulties. Neurensic's management, led by CEO David Widerhorn and COO Paul Giedraitis, sought to sell the company. Trading Technologies International, Inc. emerged as a potential buyer. Before the shareholders' vote on the sale, Overwell made a competing offer, prompting Trading Technologies to increase its offer, which Neurensic's board accepted. The shareholders approved the sale to Trading Technologies. Overwell then sued Trading Technologies, alleging it aided and abetted breaches of fiduciary duties by Neurensic's management.The United States District Court for the Northern District of Illinois rejected Overwell's jury demand, ruling that its aiding and abetting claim was equitable, despite seeking legal relief. After a bench trial, the court found in favor of Trading Technologies, concluding that Overwell failed to prove any fiduciary breaches by Widerhorn and Giedraitis that Trading Technologies could have aided and abetted. Overwell appealed, arguing that the district court erred in denying a jury trial.The United States Court of Appeals for the Seventh Circuit reviewed the case and agreed with Overwell that it had a right to a jury trial because it sought legal relief. However, the court found that the district court's error was harmless. The appellate court concluded that Trading Technologies would have been entitled to a directed verdict because Overwell failed to establish that Trading Technologies knowingly participated in any fiduciary breaches by Neurensic's management. Consequently, the Seventh Circuit affirmed the district court's judgment. View "Overwell Harvest, Limited v. Trading Technologies International, Inc." on Justia Law

Next Millennium Telecom Co. (Nextel), a Saudi Arabian corporation, was contracted by the Saudi Arabian government to install an emergency siren system. Nextel paid American Signal Corporation, a Wisconsin corporation, approximately $11 million for the sirens and related components. After installation, the sirens failed to operate correctly, and American Signal refused to repair or replace the defective parts or refund the payment. Consequently, Nextel sued American Signal in federal court for breach of contract, among other claims.The case was heard in the United States District Court for the Eastern District of Wisconsin. The litigation was marked by Nextel's uncooperative behavior, which hindered the discovery process. At the final pretrial conference, the district court noted the lack of progress on key factual issues and ordered Nextel to take specific steps, including obtaining local counsel, conferring with American Signal, and filing a plan for testing the sirens and securing visas for witnesses. Nextel's failure to comply with these orders led the district court to dismiss the case for failure to prosecute.The United States Court of Appeals for the Seventh Circuit reviewed the dismissal. The court held that the district court did not abuse its discretion in dismissing the case. The appellate court found that Nextel's conduct, including its failure to facilitate inspections, schedule depositions, adhere to local rules, and comply with the court's pretrial order, justified the dismissal. The court emphasized that the responsibility to move the case forward rested with Nextel, and its pattern of delay and non-compliance supported the district court's decision. The Seventh Circuit affirmed the dismissal and did not address Nextel's argument regarding remote testimony for its witnesses. View "Next Millennium Telecom Co. v. American Signal Corporation" on Justia Law