Justia Civil Procedure Opinion Summaries

After separating from his wife Monique in 2016, Brett, a sculptor, was ordered in a dissolution proceeding to pay spousal and child support. Brett accumulated approximately $2 million in unpaid support obligations and, according to his own testimony, held no assets apart from a copyright in certain works associated with Michael Jackson. Monique moved to have a receiver appointed and to compel Brett to assign the copyright to the receiver for purposes of monetization to satisfy the outstanding support debt.The Superior Court of Los Angeles County granted Monique’s request, appointing a receiver and ordering Brett to assign his copyright to that receiver. Brett did not dispute his debt or the fact that his copyright was his only asset but argued that existing law did not authorize courts to compel the assignment of a copyright, contending that such authority existed only for patents. He timely appealed from this order.The California Court of Appeal, Second Appellate District, Division One, reviewed the case. The court held that, under Code of Civil Procedure section 695.010, subdivision (a), all property of a judgment debtor, including copyrights, is subject to enforcement of a money judgment unless a specific exception applies. The court found no exception for copyrights. It further reasoned that although no published California case had previously addressed forced assignment of copyrights, statutes and past cases regarding other intellectual property, such as patents, supported the trial court’s authority. The court also found persuasive support in analogous federal and out-of-state decisions. Consequently, the Court of Appeal affirmed the trial court’s order compelling Brett to assign his copyright to the receiver and denied Monique’s request for appellate sanctions. Respondent was awarded costs on appeal. View "In re Marriage of Strong" on Justia Law

An attorney who chaired the Davidson County Election Commission was also employed at a law firm that represented the Metropolitan Government of Nashville and Davidson County. The Election Commission became involved in a dispute over whether a citizen-initiated tax-repeal referendum should be placed on the ballot, a measure opposed by the city government and certain city council members. The attorney, acting as commission chair, supported certifying the referendum. Following pressure from city officials, including a council member who threatened to withdraw city business from the law firm if the attorney continued supporting the referendum, the law firm terminated the attorney’s employment after he refused to change his position.The attorney filed suit in the United States District Court for the Middle District of Tennessee, asserting violations of his First Amendment rights under 42 U.S.C. § 1983, among other claims. The district court denied motions to dismiss based on qualified immunity filed by both the council member and the law firm. The court concluded that the council member’s alleged conduct violated clearly established First Amendment law and that the law firm, as a private entity, was not entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit determined that both the council member and the law firm were eligible to assert qualified immunity due to their public functions in this context. The court held that the council member was not entitled to qualified immunity because the complaint plausibly alleged he violated clearly established First Amendment rights by causing the attorney’s firing due to protected speech. However, the court found that the law firm was entitled to qualified immunity, as there was no clearly established law prohibiting a law firm from firing an employee in response to client pressure under these circumstances. Accordingly, the Sixth Circuit affirmed the denial of qualified immunity for the council member, reversed as to the law firm, and remanded for further proceedings. View "DeLanis v. Metropolitan Government of Nashville" on Justia Law

After a car accident in Prince George’s County, Maryland, George Bowens, who was injured by the clear negligence of another driver, sought to recover compensation for his injuries. The at-fault driver had $30,000 in liability insurance, which was offered to Bowens in settlement. Bowens, however, had a $50,000 underinsured motorist (UIM) policy with his own insurer, State Farm. After accepting the $30,000 from the at-fault driver’s insurer (with State Farm’s consent and waiver of subrogation rights), Bowens sought the remaining $20,000 from State Farm under his UIM policy, claiming breach of contract when State Farm denied the claim.Bowens filed his action in the District Court of Maryland, which has jurisdiction over contract claims not exceeding $30,000. State Farm moved to dismiss, arguing that to recover the $20,000, Bowens would have to prove total damages of $50,000—an amount above the District Court’s jurisdictional cap. The District Court granted the motion to dismiss for lack of subject matter jurisdiction, and the Circuit Court for Prince George’s County affirmed, reasoning that the court would need to find Bowens’ damages exceeded $30,000, thus exceeding the District Court's authority.The Supreme Court of Maryland reviewed the case and reversed the lower courts. It held that, for purposes of determining the District Court’s jurisdiction under § 4-401(1) of the Courts and Judicial Proceedings Article, the relevant amount is the “debt or damages claimed” in the pleadings—that is, the net recovery sought from the defendant in the action—not the plaintiff’s total damages. Because Bowens sought only $20,000 from State Farm, the District Court had jurisdiction to hear the case. The Supreme Court of Maryland remanded the case for further proceedings consistent with this opinion. View "Bowens v. State Farm Mutual Automobile Insurance Co." on Justia Law

Mike Dennis developed mycosis fungoides, a subtype of non-Hodgkin’s lymphoma, after regularly applying Roundup, a glyphosate-based herbicide manufactured by Monsanto, for approximately 20 years. Dennis claimed his cancer resulted from exposure to Roundup, which he alleged was sold and marketed without adequate warnings about its carcinogenic risks, despite Monsanto’s knowledge of the potential danger. He brought claims for design defect, failure to warn (under both negligence and strict liability), and negligence. At trial, the jury found that Monsanto was liable for failing to warn about the cancer risk, determining Monsanto knew or should have known of the risk, failed to provide adequate warnings, and acted with malice or oppression. The jury awarded Dennis $7 million in economic damages and $325 million in punitive damages.Following the verdict, Monsanto moved for a new trial and for judgment notwithstanding the verdict (JNOV). The Superior Court of San Diego County denied Monsanto’s requests to overturn the liability findings but reduced the punitive damages award from $325 million to $21 million, finding the original award disproportionate to the compensatory damages. Monsanto timely appealed, arguing that Dennis’s failure to warn claims were preempted by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and that the punitive damages were excessive and unconstitutional.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that FIFRA does not preempt state law failure to warn claims that parallel federal misbranding requirements, in line with United States Supreme Court precedent and California decisions. The court also found that the punitive damages award, as reduced by the trial court, did not violate due process, as it was based on highly reprehensible conduct directly related to Dennis’s harm. The Court of Appeal affirmed the judgment in full. View "Dennis v. Monsanto Co." on Justia Law

A nonprofit religious organization operates several Zen Buddhist temples in California, providing residential training programs where participants, known as Work Practice Apprentices (WPAs), live and work at the temples. Participants perform various tasks, including cleaning, cooking, and guest services, as part of their Zen training. Upon completing the WPA program, individuals may become staff members, continuing similar duties while residing at the temple. The plaintiff participated as a WPA and later as a staff member, performing duties such as guest services, food preparation, and facility maintenance. She received modest monthly stipends and room and board, but ultimately challenged the compensation as inadequate under California wage-and-hour laws.After her affiliation with the organization ended, the plaintiff filed a wage claim with the Labor Commissioner, seeking unpaid regular and overtime wages, meal period premium wages, and liquidated damages. The Labor Commissioner ruled in her favor against the organization and two individual leaders, holding the individuals personally liable as employers under Labor Code section 558.1, and awarded her $149,177.15. The defendants appealed to the Superior Court of San Francisco, posting an undertaking only on behalf of the organization, not the individual defendants. The trial court denied the plaintiff’s motion to dismiss the appeals by the individuals for lack of undertakings and granted summary judgment for all defendants, finding the ministerial exception under the First Amendment barred the wage-and-hour claims.The California Court of Appeal, First Appellate District, Division Five, reversed. It held that the ministerial exception does not bar wage-and-hour claims by ministers unless such claims would require judicial inquiry into ecclesiastical matters or religious doctrine. Because there was no evidence that adjudicating the plaintiff’s wage claims would entangle the court in religious concerns, the exception did not apply. The court also held that the trial court lacked jurisdiction over the individual defendants’ appeals due to their failure to post the required undertakings. View "Lorenzo v. San Francisco Zen Center" on Justia Law

A dispute arose between a manufacturer of construction equipment and its distributor over a 2012 distribution agreement. The distributor alleged that the manufacturer breached the agreement by selling covered equipment directly to third parties, bypassing the distributor. The manufacturer, in turn, counterclaimed that the distributor failed to pay amounts due under a 2016 rental agreement and for various purchases made between 2016 and 2017. Both parties sought damages and prejudgment interest related to their respective claims and counterclaims.The United States District Court for the Southern District of New York, after the completion of discovery, granted summary judgment for the distributor on liability for its breach-of-contract claim, leaving damages to be determined by a jury. The court also granted summary judgment for the manufacturer as to both liability and damages on its breach-of-contract counterclaim. A jury awarded the distributor substantial damages for the manufacturer’s breach. The district court denied the manufacturer’s post-trial motions for judgment as a matter of law and for a new trial or remittitur, and later awarded prejudgment interest to the distributor, despite the manufacturer’s objection that the request was untimely under Federal Rule of Civil Procedure 59(e).On appeal, the United States Court of Appeals for the Second Circuit addressed whether the distributor’s motion for prejudgment interest was timely. The court held that the initial judgment entered by the district court was not sufficiently final, as it omitted reference to the manufacturer’s successful counterclaim and the award of prejudgment interest. As a result, the 28-day deadline for a Rule 59(e) motion was not triggered until a later, comprehensive, final judgment was entered. The Second Circuit affirmed the district court’s award of prejudgment interest to the distributor. View "Alessi Equip., Inc. v. Am. Piledriving Equip., Inc." on Justia Law

The case concerns three heirs of Paul von Mendelssohn-Bartholdy, a Jewish German art collector persecuted by the Nazi regime, who seek to recover Vincent van Gogh’s painting “Sunflowers.” Mendelssohn-Bartholdy was forced to liquidate his art collection in the 1930s due to Nazi policies. The painting was sold through a Parisian dealer, later purchased at auction in London in 1987 by Yasuda Fire and Marine Insurance Company, which subsequently became Sompo Japan Insurance. The painting was exhibited briefly in Chicago and Amsterdam in 2001–2002 before returning to Japan, where it remains on display.The plaintiffs filed suit in the United States District Court for the Northern District of Illinois against Sompo Holdings and its affiliates, seeking the painting’s return or compensation, alleging various state and federal claims. The district court found it lacked subject matter jurisdiction over the federal claims because the Holocaust Expropriated Art Recovery Act (HEAR Act) does not create a federal cause of action, and the plaintiffs had not shown a conflict between state law and federal policy to justify federal common law claims. For the state law claims, the district court held (following a Pennsylvania district court’s reasoning in Holtzman) that the HEAR Act’s extension of limitations periods could confer federal question jurisdiction, but ultimately dismissed these claims for lack of personal jurisdiction over the defendants, finding insufficient connection to Illinois.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed. The court held that the federal claims failed for lack of a federal cause of action or basis for federal common law. As for the state law claims, the Seventh Circuit declined to address subject matter jurisdiction and instead affirmed the dismissal for lack of personal jurisdiction, concluding the defendants’ contacts with Illinois were unrelated to the plaintiffs’ claims. The court also found no abuse of discretion in denying leave to file a further amended complaint. View "Schoeps v. Sompo Holdings, Inc." on Justia Law

An incarcerated individual at Corcoran State Prison hired an attorney to file a petition for writ of habeas corpus, both in state and potentially federal court, for a total fee of $35,000. The attorney did not file the petition as agreed, leading the client to sue for breach of contract. Throughout the proceedings, the plaintiff notified the Superior Court of Orange County multiple times that he was incarcerated, requested remote appearances, and actively participated by filing necessary court documents, including a case management statement and fee waiver application. Despite these efforts, the plaintiff failed to appear for the scheduled trial, and the attorney attended and testified that the plaintiff was incarcerated.After the plaintiff's failure to appear at trial, the Superior Court of Orange County dismissed the lawsuit without prejudice, stating it was unaware of the plaintiff’s incarceration until the day of trial. The plaintiff appealed this dismissal, arguing that the court should have recognized his incarceration and taken additional steps before terminating the case.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the dismissal. The appellate court found that the trial court abused its discretion by dismissing the lawsuit without first issuing an order to show cause or ensuring that the plaintiff had meaningful access to the court. The court emphasized that incarcerated, indigent litigants must be afforded meaningful access to civil courts, and that dismissal is a drastic remedy reserved for rare circumstances. The appellate court reversed the judgment of dismissal and remanded the case, instructing the trial court to provide the plaintiff with meaningful access to the court and to communicate with prison officials as necessary. The plaintiff may recover costs on appeal, subject to further determination by the trial court. View "Park v. Guisti" on Justia Law

Riverdale Mills Corporation operates a wire mesh manufacturing facility in Northbridge, Massachusetts. In 2019, the Occupational Safety and Health Administration (OSHA) conducted two investigations at Riverdale’s facility, which resulted in citations alleging violations of safety and health standards under the Occupational Safety and Health Act. Riverdale contested these citations, and after a consolidated hearing before an Administrative Law Judge (ALJ) of the Occupational Safety and Health Review Commission (OSHRC) in 2021, the ALJ affirmed three citation items while vacating or withdrawing the others.Subsequently, in December 2023, Riverdale applied to the ALJ for recovery of attorney’s fees and costs under the Equal Access to Justice Act (EAJA). To establish eligibility for this recovery, Riverdale submitted its 2019 balance sheet as evidence, along with a motion to seal the document due to alleged confidential business information. The Secretary of Labor opposed the motion, arguing Riverdale had not demonstrated sufficient grounds for sealing. After considering submissions from both parties, the ALJ denied Riverdale’s motion to seal, applying balancing tests from D.C. Circuit and First Circuit case law and concluding Riverdale had not shown compelling reasons to overcome the presumption of public access. Riverdale attempted to appeal this denial to the OSHRC Commission, but the Commission automatically dismissed the appeal for lack of quorum.Riverdale then sought interlocutory review from the United States Court of Appeals for the First Circuit. The First Circuit assumed interlocutory jurisdiction under the collateral order doctrine and reviewed the ALJ’s denial for abuse of discretion. It held that Riverdale had waived certain arguments by not raising them earlier and determined the ALJ did not abuse her discretion in denying the motion to seal, finding Riverdale failed to meet its burden to justify sealing the balance sheet. The petition for review was denied. View "Riverdale Mills Corp. v. Chavez-DeRemer" on Justia Law

OneTaste, Inc., a company founded in 2004 that promoted “orgasmic meditation,” sued Netflix for defamation in 2023. The lawsuit was based on a Netflix documentary that featured allegations from former employee Ayries Blanck, who claimed she was sexually assaulted and abused in connection with her employment and participation in OneTaste’s activities. The documentary included statements from Blanck’s sister and other former associates, as well as references to earlier media investigations and reports about alleged exploitative and abusive practices at OneTaste. OneTaste asserted that Netflix published false statements with actual malice, despite being provided with information it claimed disproved the allegations.The Superior Court of Los Angeles County reviewed Netflix’s special motion to strike under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16). Netflix argued its conduct was protected activity and that OneTaste could not demonstrate a probability of prevailing, especially on the element of actual malice. After considering the pleadings and both parties’ evidence, the trial court concluded that OneTaste failed to present sufficient evidence that Netflix published the challenged statements with actual malice. The court also found OneTaste’s additional evidence did not establish that Netflix was aware of probable falsity or recklessly disregarded the truth. As a result, the court granted Netflix’s motion to strike the complaint.On appeal, the California Court of Appeal, Second Appellate District, Division Three, affirmed the trial court’s order. The appellate court held that OneTaste did not meet its burden to show a probability of prevailing on the defamation claim because it failed to produce evidence of actual malice by Netflix. The court also rejected OneTaste’s constitutional and public policy challenges to the anti-SLAPP statute and denied its requests for judicial notice of materials not considered by the trial court. View "Onetaste Incorporated v. Netflix, Inc." on Justia Law