Justia Civil Procedure Opinion Summaries

George Martens filed a complaint in the Third District Court of Appeals for a writ of mandamus against various judges and courts in Hancock County, alleging that they lacked jurisdiction to decide certain tax cases. Martens did not allege that he was a party to any tax case pending before those courts when he filed this action. The judges and courts filed a motion to dismiss, arguing that Martens lacked standing and had not stated a cognizable mandamus claim.The Third District Court of Appeals dismissed the case, concluding that Martens lacked standing to bring the complaint and had failed to state a claim for mandamus relief. Martens appealed to the Supreme Court of Ohio, arguing that he did not need to meet the traditional standing requirement based on the public-right doctrine recognized in State ex rel. Ohio Academy of Trial Lawyers v. Sheward. Alternatively, he claimed taxpayer standing.The Supreme Court of Ohio rejected Martens's reliance on Sheward, overruling the public-right doctrine established in that case. The court held that Sheward was contrary to the deeply rooted standing requirement and the Ohio Constitution. The court also found that Martens could not establish taxpayer standing, as he had not shown any special interest in the public funds at issue or cited statutory authority authorizing him to bring a taxpayer suit. Consequently, the Supreme Court of Ohio affirmed the Third District's dismissal of Martens's complaint for lack of standing. View "State ex rel. Martens v. Findlay Municipal Court" on Justia Law

The City of Rittman filed an original action in prohibition against Judge Corey E. Spitler of the Wayne County Common Pleas Court. Rittman sought to prevent Judge Spitler from exercising jurisdiction over a class-action lawsuit in which Rittman was named as a defendant. The lawsuit, filed by Tara Boler and Trista Bise, alleged that Rittman had illegally collected a 0.5 percent income tax increase beyond its authorized period and sought refunds for the overcharged taxes from 2008 to 2022.In the Wayne County Common Pleas Court, Judge Spitler denied Rittman’s motion to dismiss and motion to stay discovery, and he established a case-management schedule. Rittman then sought a writ of prohibition from the Supreme Court of Ohio to stop Judge Spitler from proceeding with the case, arguing that the lawsuit was an impermissible attempt to bypass the statutory process for obtaining tax refunds.The Supreme Court of Ohio reviewed the case and determined that Judge Spitler had jurisdiction and statutory authority under R.C. 2723.01 to hear the case. The court found that the plaintiffs' claims were substantively governed by R.C. 2723.01, which allows common pleas courts to enjoin the illegal levy or collection of taxes and entertain actions to recover them when collected. The court concluded that although the plaintiffs did not explicitly invoke R.C. 2723, their claims fit within its scope. Therefore, the Supreme Court of Ohio denied the writ of prohibition, allowing Judge Spitler to continue exercising jurisdiction over the underlying case. View "State ex rel. Rittman v. Spitler" on Justia Law

AMW Investments, Inc. and Midwest Entertainment Ventures, Inc. (collectively, AMW) owned and operated an adult-entertainment venue called Theatre X. The Town of Clarksville revoked AMW’s adult-entertainment license in early 2019 due to violations of local ordinances against lewd conduct. AMW sought judicial review of the revocation in the Clark Circuit Court, which led to the Town filing counterclaims and seeking a preliminary injunction to bar AMW from operating Theatre X. The trial court issued the injunction and deferred ruling on fines pending AMW’s appeal of the injunction.The Clark Circuit Court ordered AMW to respond to the Town’s discovery requests, but AMW only objected on jurisdictional grounds, claiming the trial court lacked jurisdiction during the appeal. The trial court found AMW’s objections inexcusable and ordered compliance. AMW continued to object and withhold documents, leading the trial court to find AMW in contempt and impose a $30,000 sanction. AMW appealed the sanction, and the Indiana Court of Appeals reversed, holding that AMW’s objections were not waived.The Indiana Supreme Court reviewed the case and held that AMW’s objections were untimely and thus waived. The Court affirmed the trial court’s discovery order and sanction, stating that the trial court did not lose jurisdiction during the appeal and no stay was issued. The Court emphasized that untimely objections are presumptively waived under the trial rules, and the trial court did not abuse its discretion in refusing to excuse the waiver or in sanctioning AMW for non-compliance. The case was remanded for further proceedings consistent with the opinion. View "AMW Investments Inc. v. The Town of Clarksville" on Justia Law

Lake County sought reimbursement from the State of Montana for costs incurred in enforcing state criminal jurisdiction on the Flathead Indian Reservation under Public Law 280 (P.L. 280). The County argued that the State was obligated to cover these costs, citing financial strain and the diversion of resources from other services.The District Court of the Twentieth Judicial District dismissed Lake County’s claims for unfunded mandate and unjust enrichment, ruling that the statutes of limitations had expired. The court determined that the claims accrued in January 2017, when the County expressed its inability to continue bearing the financial burden of P.L. 280. The court also ruled that the continuing tort and equitable tolling doctrines did not apply to toll the statutes of limitations. The court denied the State’s motion to dismiss the declaratory judgment claim but later granted summary judgment in favor of the State, ruling that the State was not obligated to appropriate any specific amount to reimburse the County.The Supreme Court of the State of Montana affirmed the District Court’s rulings. It held that Lake County’s claims were justiciable but that the continuing tort doctrine did not apply because the County sought monetary damages, not abatement. The Court also ruled that the equitable tolling doctrine did not apply as the County did not pursue a legal remedy within the doctrine’s scope. Finally, the Court held that § 2-1-301(2), MCA, only required the State to reimburse the County to the extent funds were appropriated by the Legislature, which retained discretion over such appropriations. The Court affirmed the dismissal of the unfunded mandate and unjust enrichment claims and the summary judgment on the declaratory judgment claim. View "Lake County v. State" on Justia Law

Erin Hughes, the plaintiff, obtained two homeowner’s insurance policies for her property in Malibu. One policy, through the California FAIR Plan Association (FAIR Plan), covered fire loss, while the other, issued by Farmers Insurance Exchange (Farmers), did not. After a fire caused significant damage to her property, Hughes filed a lawsuit against Farmers, alleging it was vicariously liable for the negligence of its agent, Maritza Hartnett, who assisted her in obtaining the FAIR Plan policy, resulting in underinsurance for fire loss.The Superior Court of Los Angeles County granted Farmers’ motion for summary judgment, concluding that Hartnett was not acting within the scope of her agency with Farmers when she assisted Hughes in obtaining the FAIR Plan policy. The court also denied Hughes’s motion for leave to amend her complaint.The Court of Appeal of the State of California, Second Appellate District, reviewed the case. The court affirmed the lower court’s decision, holding that Hartnett was not acting as Farmers’ actual or ostensible agent when she helped Hughes obtain the FAIR Plan policy. The court found that Hartnett was acting as an independent broker for the FAIR Plan policy and not on behalf of Farmers. Additionally, the court determined that Hughes failed to present evidence that could establish a triable issue regarding Farmers’ vicarious liability for Hartnett’s actions.The court also upheld the trial court’s denial of Hughes’s motion for leave to amend her complaint, noting that Hughes offered no explanation for the delay in filing the motion and that allowing the amendment would have prejudiced Farmers and Hartnett. The judgment in favor of Farmers was affirmed, and Farmers was entitled to recover its costs on appeal. View "Hughes v. Farmers Insurance Exchange" on Justia Law

R.L., a sheriff’s deputy, was charged with driving while intoxicated, but the charges were later dropped. The Indiana Law Enforcement Training Board initiated proceedings to revoke R.L.'s basic-training certificate, which is necessary for his employment as an officer. R.L. sought and obtained a court declaration and injunction preventing the board from disciplining him before the board issued a final decision.The Martin Circuit Court granted R.L.'s request for declaratory and injunctive relief, barring the board from using facts from R.L.'s expunged arrest to revoke his certificate. The board intervened and moved to vacate the order, arguing procedural errors and lack of merit. The trial court vacated its initial order but issued a second similar order. The board appealed, and the Indiana Court of Appeals reversed the trial court's decision, allowing the board to consider independent evidence of the facts underlying the expunged arrest records.The Indiana Supreme Court reviewed the case and held that the trial court erred in granting R.L.'s request for declaratory and injunctive relief. The court emphasized that R.L. must follow the Administrative Orders and Procedures Act (AOPA) to challenge the board's decisions and that he failed to exhaust administrative remedies before seeking judicial intervention. The court reversed the trial court's judgment and remanded with instructions to dismiss R.L.'s declaratory-judgment action, reinforcing the necessity of exhausting administrative remedies before seeking judicial review. View "Indiana Law Enforcement Training Board v. R L" on Justia Law

R.A. filed a lawsuit against her son G.A.'s special education teacher, Robin Johnson, and several school officials, alleging that Johnson mistreated G.A. during the first and second grades. The complaint claimed that Johnson subjected G.A. to physical and emotional abuse and that the school officials negligently failed to intervene despite knowing about the abuse. The school officials moved to dismiss the negligence claims, arguing they were protected by public official immunity. The district court denied the motion, and the school officials filed an interlocutory appeal.The United States District Court for the Western District of North Carolina initially denied the school officials' motion to dismiss the state law claims, leading to an appeal. The Fourth Circuit Court of Appeals previously ruled that the school officials were entitled to public official immunity and that the state law claims against them should be dismissed. Despite this, the district court allowed R.A. to file an amended complaint with additional details from new evidence, which the school officials again moved to dismiss. The district court denied this motion, interpreting the appellate mandate as allowing dismissal without prejudice.The Fourth Circuit Court of Appeals reviewed the case again and held that the district court violated the mandate rule by not dismissing the claims with prejudice as instructed. The appellate court emphasized that its prior decision required dismissal with prejudice and that the district court's interpretation was incorrect. The court reiterated that the mandate rule requires lower courts to follow the appellate court's instructions precisely and that no exceptions to the mandate rule applied in this case. Consequently, the Fourth Circuit reversed the district court's decision, reaffirming that the state law claims against the school officials must be dismissed with prejudice. View "R.A. v. McClenahan" on Justia Law

Derrick A. Davis sued the City of Little Rock, the chief of police, and three detectives for Fourth Amendment violations under 42 U.S.C. § 1983 after a no-knock warrant was executed on his residence. The warrant was based on an email about drug activity, a controlled buy using a confidential informant (CI), and Detective Bell's affidavit. The SWAT team executed the warrant, finding marijuana inside Davis's home.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants. Davis appealed, arguing that there were genuine disputes of material fact regarding the detectives' responsibility for the SWAT team's actions, the veracity of statements in the warrant affidavit, and the existence of a conspiracy to violate his Fourth Amendment rights. He also challenged the district court's handling of evidence and the imposition of sanctions for his failure to attend a deposition.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that Detectives Bell and Ison were entitled to qualified immunity because the right in question was not clearly established at the time of the warrant's execution. The court also found no Franks violation, as Davis failed to show that any false statements in the affidavit were made knowingly or with reckless disregard for the truth. Additionally, the court ruled that Davis's § 1983 conspiracy claim failed because the underlying Fourth Amendment claims were properly dismissed.The court also determined that the district court did not err in considering Detective Bell's affidavit or in disregarding Davis's expert opinions. Finally, the court concluded that it lacked jurisdiction to review the sanctions award because the district court had not yet fixed the amount. The judgment was affirmed. View "Davis v. City of Little Rock" on Justia Law

JHVS Group, LLC and its members, Jasanjot Singh and Harshana Kaur, purchased a 66.4-acre pistachio orchard from Shawn Slate and Dina Slate for approximately $2.6 million. The Slates agreed to carry a loan for $1,889,600, and JHVS made a $700,000 down payment. The agreement included interest payments and additional payments tied to crop yields. JHVS alleged that the Slates and their brokers, Randy Hayer and SVN Executive Commercial Advisors, misrepresented critical information about water rights and crop values, leading to financial losses and a notice of default filed by the Slates.The Superior Court of Madera County issued a preliminary injunction to prevent the foreclosure sale of the property, based on JHVS's claims of fraud and misrepresentation. The court granted the injunction after the defendants failed to appear or respond to the motion. The order was intended to preserve JHVS's right to rescind the contract.The California Court of Appeal, Fifth Appellate District, reviewed the case and found that the trial court lacked fundamental jurisdiction over the Slates because they were never properly served with the summons and complaint. The appellate court determined that the preliminary injunction was void as to the Slates due to this lack of jurisdiction. Consequently, the appellate court reversed the trial court's order granting the preliminary injunction against the Slates and remanded the case for further proceedings consistent with its opinion. The appellate court awarded costs to the Slates. View "JHVS Group, LLC v. Slate" on Justia Law

A state prisoner, Chance Blackman, filed a federal habeas petition over a year after the federal statute of limitations had expired. Blackman argued that he was entitled to equitable tolling due to severe mental and physical impairments that prevented him from filing on time. Despite his claims, Blackman had managed to file multiple state habeas petitions before and after the federal deadline.The United States District Court for the Central District of California dismissed Blackman's federal habeas petition as untimely. The court found that Blackman did not meet the requirements for equitable tolling because he had access to legal assistance and was able to file cogent state habeas petitions during the relevant period. The court concluded that Blackman’s impairments were not the but-for cause of his delay in filing the federal petition.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s judgment. The Ninth Circuit held that Blackman did not satisfy the second prong of the Bills v. Clark test, which requires showing that the impairment was a but-for cause of the delay. The court noted that Blackman’s ability to file multiple state petitions indicated that his impairments did not make it impossible for him to meet the federal filing deadline. Consequently, the court did not need to address the first prong of the Bills test or Blackman’s statutory tolling argument, as his federal habeas petition would have been untimely even with the statutory tolling he claimed. The court also denied Blackman’s request for an evidentiary hearing, finding no further factual development was necessary. View "BLACKMAN V. CISNEROS" on Justia Law