Justia Civil Procedure Opinion Summaries

Phhhoto Inc. filed a lawsuit against Meta Platforms, Inc., alleging that Meta engaged in anticompetitive practices that harmed Phhhoto's business. Phhhoto claimed that Meta's introduction of an algorithmic feed on Instagram in March 2016 suppressed Phhhoto's content, leading to a significant decline in user engagement and new registrations. Phhhoto argued that Meta's actions, including withdrawing access to Instagram's Find Friends API, terminating a joint project, and releasing a competing app called Boomerang, were part of a scheme to monopolize the market and eliminate Phhhoto as a competitor.The United States District Court for the Eastern District of New York dismissed Phhhoto's claim under Federal Rule of Civil Procedure 12(b)(6), ruling that it was time-barred by the four-year statute of limitations under the Sherman Act. The court found that Phhhoto's claim accrued outside the limitations period and that equitable tolling did not apply because Phhhoto failed to demonstrate fraudulent concealment by Meta.On appeal, the United States Court of Appeals for the Second Circuit reviewed the case de novo and concluded that Phhhoto sufficiently alleged that the statute of limitations should be equitably tolled due to Meta's fraudulent concealment. The court found that Meta's public statements about the algorithmic feed were misleading and constituted affirmative acts of concealment. The court also determined that Phhhoto did not have actual or inquiry notice of its antitrust claim until October 25, 2017, when it discovered evidence suggesting Meta's anticompetitive behavior. The court held that Phhhoto's continued ignorance of the claim was not due to a lack of diligence.The Second Circuit vacated the district court's judgment and remanded the case for further proceedings, allowing Phhhoto's antitrust claim to proceed. View "Phhhoto Inc. v. Meta Platforms, Inc." on Justia Law

Matt Roane was involved in litigation with the Archuleta County Board of Commissioners when he submitted a Colorado Open Records Act (CORA) request to Archuleta County Clerk and Recorder, Kristy Archuleta, seeking a recording of a recent Board meeting. Archuleta denied the request, claiming it circumvented the Colorado Rules of Civil Procedure. Roane had not sought any records through discovery in his civil action against the Board. Roane then sued Archuleta, alleging a violation of CORA.The district court granted Roane's motion to show cause, rejecting Archuleta's argument that the Colorado Rules of Civil Procedure prohibited Roane from obtaining evidence outside of discovery procedures. The court ordered Archuleta to produce the recording. Archuleta appealed, arguing that the district court allowed Roane to bypass discovery rules. The Colorado Court of Appeals affirmed the district court's order, holding that CORA allows litigants to inspect public records even if they are relevant to pending litigation.The Supreme Court of Colorado reviewed the case and held that a litigant may obtain records under CORA even if those records are relevant to pending litigation and the litigant has not made document requests under the Rules of Civil Procedure. The court emphasized that CORA and the Rules of Civil Procedure are distinct legal regimes and that CORA does not limit inspection rights simply because the requester is involved in litigation with the public entity. The court affirmed the judgment of the court of appeals. View "Archuleta v. Roane" on Justia Law

An inmate at the Trumbull Correctional Institution (TCI) submitted 17 public-records requests to various TCI departments and employees in August 2023. The requests included documents such as the current bank statement for TCI’s industrial and entertainment fund, the recreation music-room schedule, TCI’s list of approved vendors, and body-camera footage from a specific corrections officer. The inmate claimed that all his requests were initially denied and sought a writ of mandamus to compel the production of the records, as well as statutory damages and reimbursement for postage and photocopying.The case was reviewed by the Supreme Court of Ohio. The court found that many of the inmate’s requests had been rendered moot because the requested documents were provided to him after he filed his complaint. The court also determined that the inmate did not meet his burden of proof for some requests, as he failed to show that he properly requested the records from the appropriate public office or person responsible for public records. Additionally, the court found that the delay in responding to the inmate’s requests was not unreasonable given the number of requests.The Supreme Court of Ohio denied the inmate’s request for a writ of mandamus, statutory damages, and reimbursement for expenses. The court also denied the inmate’s motion to compel the clerk to accept his untimely response and the respondents’ motion for sanctions. The court concluded that there was no evidence that the inmate acted falsely or fraudulently in bringing the action. View "State ex rel. Berry v. Booth" on Justia Law

A group of city and county governments, Indian tribes, and other entities filed actions against opioid manufacturers, distributors, and pharmacies, alleging they misled medical professionals and the public, leading to widespread addiction. Two Ohio counties, Trumbull and Lake, claimed that national pharmaceutical chains, including Walgreens, CVS, and Walmart, contributed to the opioid epidemic by filling prescriptions without proper controls. They filed a common-law absolute public-nuisance claim seeking equitable relief.The United States District Court for the Northern District of Ohio denied the pharmacies' motion to dismiss, which argued that the Ohio Product Liability Act (OPLA) abrogated the public-nuisance claims. The court based its decision on a prior ruling in a related case, concluding that the OPLA did not abrogate public-nuisance claims seeking non-compensatory damages. After a jury verdict in favor of the counties, the pharmacies' motion for judgment as a matter of law was also denied. The pharmacies appealed, and the Sixth Circuit certified a question to the Supreme Court of Ohio regarding the OPLA's scope.The Supreme Court of Ohio held that the OPLA abrogates all common-law public-nuisance claims arising from the sale of a product, including those seeking equitable relief. The court determined that the statutory definition of "product liability claim" includes public-nuisance claims related to the design, manufacture, supply, marketing, distribution, promotion, advertising, labeling, or sale of a product. The court rejected the argument that the OPLA only abrogates claims seeking compensatory damages or involving defective products. The court concluded that the counties' claims, based on the pharmacies' dispensing of opioids, fall within the scope of the OPLA and are therefore abrogated. View "In re Natl. Prescription Opiate Litigation" on Justia Law

Phoenix Lighting Group, L.L.C. (Phoenix) sued Genlyte Thomas Group, L.L.C. (DCO) and obtained a jury verdict for tortious interference, misappropriation of trade secrets, and civil conspiracy. The jury awarded Phoenix compensatory and punitive damages, as well as reasonable attorney fees. The trial court awarded additional punitive damages for the misappropriation claim and enhanced the attorney fees by a multiplier of two.The Ninth District Court of Appeals affirmed the trial court's decision in part but reversed the application of the punitive-damages cap for the conspiracy claim, remanding the case for further proceedings. Phoenix requested postjudgment attorney fees, which the Ninth District did not specifically address but remanded the case for further proceedings consistent with its opinion.The Supreme Court of Ohio accepted jurisdiction over DCO's challenge to the enhancement of the attorney-fee award. The court reversed the Ninth District's affirmation of the enhanced attorney fees and remanded the case to the trial court to issue a final judgment granting Phoenix attorney fees in the amount of $1,991,507.On remand, the trial court awarded Phoenix postjudgment attorney fees and expenses. The Ninth District affirmed this award, concluding that the trial court had jurisdiction to consider postjudgment attorney fees and did not exceed its authority.The Supreme Court of Ohio reviewed the case and held that the trial court exceeded its authority by considering and granting Phoenix's motion for postjudgment attorney fees and expenses. The court reversed the Ninth District's judgment and remanded the case to the trial court with instructions to vacate its award of postjudgment attorney fees and expenses and to enter final judgment. View "Phoenix Lighting Group, L.L.C. v. Genlyte Thomas Group, L.L.C." on Justia Law

An inmate at the Pickaway Correctional Institution, Trevor J. Teagarden, requested various public records from prison staff between June and August 2023. These requests included medical protocols, recreation schedules, policy indexes, and a sign-in sheet for LexisNexis computer terminals. The prison staff responded by directing him to where some of the requested documents were posted or available for review in the library, and denied access to the sign-in sheet, stating it was library property.Teagarden filed a complaint for a writ of mandamus in December 2023, seeking to compel the prison staff to provide the requested records, along with statutory damages and court costs. The Supreme Court of Ohio reviewed the case after denying the respondents' motion to dismiss and ordering them to file an answer.The Supreme Court of Ohio held that Teagarden's requests for the recreation schedules and medical protocols were either not directed to the proper records custodian or were too vague. However, the court found that the sign-in sheet for the LexisNexis computer terminals was a public record maintained by the library staff, and their refusal to provide it violated the Public Records Act. Consequently, the court granted a writ of mandamus ordering the prison staff to provide Teagarden with the sign-in sheet for August 24 and 25, 2023.The court awarded Teagarden $1,000 in statutory damages for the failure to provide the sign-in sheet but denied his request for court costs due to his affidavit of indigency. The court denied the writ for the other records requested, as the responses from the prison staff were deemed appropriate under the circumstances. View "State ex rel. Teagarden v. Igwe" on Justia Law

In 2015, Michael Shields, a mechanic for the Greater Cleveland Regional Transit Authority (RTA), injured his left shoulder. The Bureau of Workers’ Compensation approved his claim for left shoulder strain. In 2017, Shields sought benefits for a related right shoulder injury, which the bureau denied. Shields then sued in the Cuyahoga County Court of Common Pleas, and in May 2022, a jury found him entitled to benefits for the right shoulder injury. The RTA appealed, and the Eighth District Court of Appeals affirmed the decision on April 27, 2023.Following the appellate court's decision, Shields filed a motion on May 8, 2023, seeking $26,221 in appellate attorney fees or a remand to the trial court to determine the fees. The RTA opposed, arguing the motion was untimely and that Shields had waived the issue by not seeking fees earlier. The appellate court ruled in favor of Shields, allowing him to recover appellate attorney fees and remanded the case to the trial court to determine the amount.The Supreme Court of Ohio reviewed the case and affirmed the appellate court's decision. The court held that a worker who prevails at trial in a workers’ compensation action may request attorney fees after obtaining an appellate judgment on the merits. The court emphasized that the workers’ compensation statute should be liberally construed in favor of employees and found no statutory requirement for the timing of such a request. The court dismissed the RTA's arguments regarding the timing and jurisdiction of the fee request and did not address the issue of fee caps, as it was not ripe for review. View "Shields v. Bureau of Workers’ Compensation" on Justia Law

A medical-malpractice action was filed by Kalvyn Stull and his family against Summa Health System and associated parties, alleging that improper medical treatment following a car accident caused severe brain damage to Kalvyn. During discovery, the plaintiffs requested the residency file of Dr. Mazen Elashi, a resident physician involved in the treatment. Summa Health System claimed the file was protected by the peer-review privilege under Ohio law, supported by an affidavit from Dr. Erika Laipply, which stated that the file was used exclusively for peer-review purposes.The trial court in Summit County held that Summa had not sufficiently demonstrated that the peer-review privilege applied, as the affidavit contained ambiguities and lacked specific details. The court granted the motion to compel the production of the residency file. Summa appealed, and the Ninth District Court of Appeals affirmed the trial court's decision, agreeing that the affidavit was insufficient to establish the privilege due to its ambiguities and incomplete information.The Supreme Court of Ohio reviewed the case and held that the presence of factual ambiguities in affidavit testimony does not alone determine whether the peer-review privilege applies. The court emphasized that the trial court has the authority to conduct further inquiry, including in camera review, to resolve the factual disputes and determine the applicability of the privilege. The Supreme Court reversed the judgment of the Ninth District Court of Appeals and remanded the case to the trial court for an in camera review of the residency file and any other necessary factual inquiry to resolve the legal question of whether the file is privileged. View "Stull v. Summa Health System" on Justia Law

The decedent, Marc F. Thurrell, executed a will in 1997, leaving his estate to his father and, if his father predeceased him, to his uncle. Both the father and the uncle died before the decedent. At the time of the decedent's death, the uncle's children and the decedent's sister (the respondent) were alive. The respondent argued that the estate should pass to her under New Hampshire's anti-lapse statute, RSA 551:12, as the sole surviving lineal descendant of the father, or alternatively, through intestacy.The Circuit Court (Moran, J.) granted a petition for estate administration, listing the uncle's children as beneficiaries and appointing the petitioner as executor. The respondent objected, arguing that the estate should pass to her under the anti-lapse statute or through intestacy. The trial court ruled that the bequest to the father lapsed due to a survivorship requirement, but the bequest to the uncle did not lapse, applying the anti-lapse statute to pass the estate to the uncle's children. The respondent's motion for reconsideration and subsequent motion to determine heirs were denied.The Supreme Court of New Hampshire reviewed the case and affirmed the trial court's decision. The court held that the decedent's will did not express an intention for the will to lapse or for the anti-lapse statute to be inapplicable to the uncle's bequest. The will's language indicated that the decedent intended for the anti-lapse statute to apply to the uncle's bequest, allowing the uncle's children to inherit. The court also found that the intentional omission clause in the will did not preclude the uncle's children from inheriting, as they were provided for in the will through the anti-lapse statute. The court concluded that the trial court did not err in applying RSA 551:12 to the residual bequest to the uncle and properly denied the respondent's motion to determine heirs. View "In re Estate of Thurrell" on Justia Law

Christina Peterson, representing herself, challenged the qualifications of Valerie Vie as a candidate for probate court judge in Douglas County, Georgia. Peterson claimed that Vie had not been a resident of Douglas County for the required time to run for the office. Peterson initially filed a challenge with the local Board of Elections, which was denied. She then filed a petition for review in superior court, which was also denied. After the primary election, which Vie won, Peterson filed a second petition in superior court challenging the election results on the same grounds.The local Board of Elections held a hearing and denied Peterson's challenge. Peterson then filed a petition for review in the superior court, which was also denied. Peterson did not seek to stay the primary election and filed an application for discretionary appeal with the Supreme Court of Georgia, which was denied. Subsequently, Peterson filed a post-primary petition in superior court, which was dismissed on the grounds of collateral estoppel, res judicata, and mootness due to her failure to seek a stay of the primary election.The Supreme Court of Georgia reviewed the case and dismissed Peterson's appeal. The court held that parties seeking to challenge election results must act with dispatch to resolve disputes before the election occurs. Peterson failed to expedite her challenges and did not seek a stay of the primary election. The court emphasized the importance of resolving election disputes promptly to avoid unnecessary expenses and ensure the finality of election results. Consequently, the court dismissed the appeal without addressing the merits of Peterson's claims. View "Peterson v. Vie" on Justia Law