Justia Civil Procedure Opinion Summaries

A public hospital in New York contracted with a new parking management company to provide valet services, replacing a previous vendor whose employees were represented by a union and were covered by a collective bargaining agreement (CBA). After winning the contract, the new company considered retaining the existing unionized valet attendants but ultimately did not hire any of them, despite initially recruiting them. Instead, the company posted job listings for the same roles and hired other workers, leaving the former unionized employees without jobs. Evidence suggested that the new company’s refusal to hire was motivated by the employees’ union affiliation.After the union filed an unfair labor practice charge, the Regional Director of the National Labor Relations Board (NLRB) filed a petition with the United States District Court for the Eastern District of New York, seeking a temporary injunction under § 10(j) of the National Labor Relations Act. The requested injunction would have required the company to reinstate the discharged employees, recognize the union, and bargain in good faith. The district court denied the petition in a brief text order, finding no cognizable irreparable harm and noting the delay in seeking relief. Meanwhile, an Administrative Law Judge found that the company violated the Act by refusing to hire the unionized employees and failing to recognize and bargain with the union.The United States Court of Appeals for the Second Circuit reviewed the district court’s denial. The Second Circuit held that the district court’s order violated Rule 52(a)(2) by failing to provide adequate findings and conclusions. The Second Circuit further found that the Regional Director had met all four prongs required for a § 10(j) injunction: likelihood of success on the merits, irreparable harm, balance of equities, and public interest. The court reversed the district court’s order and remanded for entry of the requested injunction. View "Poor v. Parking Systems Plus, Inc." on Justia Law

A Florida resident who worked as an independent contractor driver for an Indiana-based transportation company initiated a lawsuit in the United States District Court for the Northern District of Iowa, alleging violations of Iowa’s business opportunity promotions statutes. The Indiana company, registered to do business in Iowa as a foreign corporation and having appointed an agent for service of process as required by Iowa law, argued that it had no substantial presence or employees in Iowa. The plaintiff asserted that the company’s registration and agent appointment constituted consent to personal jurisdiction, among other arguments.The United States District Court for the Northern District of Iowa denied the Indiana company’s motion to dismiss for lack of personal jurisdiction. It concluded that, under Iowa law, a foreign corporation consents to personal jurisdiction by registering to do business in Iowa and designating an agent for service. However, recognizing the absence of controlling Iowa precedent on this issue, the federal court certified a question of state law to the Iowa Supreme Court for resolution.The Iowa Supreme Court answered the certified question and held that, under Iowa law, a foreign corporation does not consent to personal jurisdiction merely by registering to do business in Iowa, appointing an agent for service of process, or receiving service through that agent. The court determined that Iowa Code chapter 490 does not require foreign corporations to consent to personal jurisdiction as a condition of registration or agent appointment, and declined to interpret the statute as implicitly imposing such consent. The Iowa Supreme Court’s answer was in the negative, clarifying that registration and agent appointment do not constitute consent to personal jurisdiction in Iowa. View "Kelchner v. CRST Expedited, Inc." on Justia Law

A New Mexico insurance company initiated a lawsuit in Nebraska against two insurance companies, asserting claims for contribution and indemnity. One defendant, a New York insurance company, moved to dismiss for lack of personal jurisdiction, while the other defendant, a surplus insurance company, challenged a default judgment and sought to file a responsive pleading. The district court in Douglas County issued separate orders: it dismissed the New York insurer with prejudice and set aside the default judgment against the other defendant, allowing additional proceedings.After the dismissal order concerning the New York insurer, the plaintiff appealed to the Nebraska Court of Appeals, which summarily dismissed the appeal for lack of jurisdiction. The case returned to the district court, where the plaintiff voluntarily dismissed its claims against the remaining defendant without prejudice. This second dismissal order did not reference the prior dismissal of the New York insurer. The plaintiff then filed another appeal, again challenging the earlier dismissal order. The Court of Appeals dismissed this second appeal for lack of appellate jurisdiction, citing the absence of a single judgment resolving all claims against all parties as required by Nebraska statutes and referencing the Nebraska Supreme Court’s decision in Elbert v. Keating, O’Gara. The plaintiff petitioned for further review.The Nebraska Supreme Court reviewed the case and held that, because the district court had not entered a single written judgment adjudicating all claims and all parties, nor certified any order as final under the applicable statute, there was no final, appealable order. Therefore, the Supreme Court determined it lacked appellate jurisdiction and affirmed the dismissal of the appeal by the Court of Appeals. The court emphasized that jurisdiction cannot be created by voluntary dismissal without prejudice of unresolved claims or parties in the absence of a final judgment. View "Continental Indem. Co. v. Starr Indem. & Liab. Co." on Justia Law

The underlying dispute arose after an individual was convicted of a crime in Louisiana, served part of his sentence, and later had his conviction reversed or vacated. Claiming factual innocence, he sought compensation under Louisiana’s wrongful conviction statute, which provides monetary awards to qualifying persons. Prior to filing this petition in state court, he had also initiated a separate federal lawsuit under 42 U.S.C. § 1983, alleging violations of his constitutional rights stemming from the same prosecution and conviction.In the Criminal District Court for the Parish of Orleans, the State requested a stay of the wrongful conviction compensation proceedings, citing Louisiana Code of Civil Procedure article 532. This provision allows a court to stay proceedings when there is a related action in another jurisdiction involving the same parties and occurrence. The State argued that the federal suit should proceed first. The district court denied the motion to stay in open court on March 27, 2025. The State then sought supervisory review from the Louisiana Fourth Circuit Court of Appeal, which also denied relief on April 30, 2025.The Supreme Court of Louisiana reviewed the district court’s denial of the stay. The court examined the statutory differences between the state law compensation claim, which requires proof of factual innocence, and the federal civil rights action, which focuses on constitutional violations by individual actors. Concluding that the district court did not abuse its discretion in refusing to stay the state court proceedings—especially in light of the legislative instruction to decide wrongful conviction claims expeditiously—the Supreme Court of Louisiana affirmed the district court’s decision. The main holding is that denial of the State’s motion to stay the wrongful conviction compensation proceedings was proper under the circumstances. View "Williams v. State" on Justia Law

A motorcyclist attending the Sturgis Motorcycle Rally in South Dakota was injured in a 2017 collision when another driver allegedly pulled out in front of him. The injured party, a resident of Canada, filed a negligence lawsuit against the driver in July 2020. Shortly thereafter, the plaintiff’s counsel granted the defendant’s insurance carrier an open-ended extension to file an answer, due to ongoing medical treatment and uncertainty about the extent of injuries. The parties operated under this informal agreement while the plaintiff continued treatment and sought additional information related to his injuries and damages.Over the next several years, the Meade County clerk of courts issued three notices of intent to dismiss the case for inactivity, to which the plaintiff timely objected, citing the ongoing extension and the need to collect further information. In August 2024, the defendant retained counsel, who acknowledged and reaffirmed the open-ended extension agreement. However, two months later, the defendant moved to dismiss for failure to prosecute. The Circuit Court of the Fourth Judicial Circuit, Meade County, granted the dismissal with prejudice under SDCL 15-11-11 and SDCL 15-6-41(b) (Rule 41(b)), concluding there was unreasonable and unexplained delay.On appeal, the Supreme Court of the State of South Dakota held that dismissal was improper. The Court found that the mutual open-ended extension agreement between the parties constituted good cause for delay under SDCL 15-11-11. Additionally, the Court determined that the plaintiff’s conduct did not rise to the level of egregiousness required for dismissal with prejudice under Rule 41(b), especially given the reaffirmed extension and lack of prejudice to the defendant. The Supreme Court reversed the dismissal and remanded for further proceedings. View "Arrowsmith v. Odle" on Justia Law

Florida PACE Funding Agency initiated a proceeding in the Second Judicial Circuit to validate the issuance of $5 billion in bonds for financing certain property improvements under the PACE Act. The agency complied with statutory notice requirements, and a hearing was held where State Attorneys from the Second, Seventh, and Ninth Circuits were represented. No party objected to the entry of final judgment validating the bonds, and the judgment became final without any appeal. Over a year later, various governmental entities—including state attorneys, counties, and tax collectors (most of whom did not participate in the original proceedings)—filed motions under Florida Rule of Civil Procedure 1.540, seeking relief from the judgment, raising arguments such as lack of jurisdiction, due process violations, and alleged surprise.The circuit court allowed discovery and held an evidentiary hearing, after which it denied all motions for relief from judgment. For the parties who had not appeared previously, the court found that rule 1.540 did not apply to bond validation judgments due to the strict finality requirements of chapter 75, Florida Statutes, and that the motions were untimely and insufficient. For the state attorneys who had participated, the court concluded they were procedurally barred from seeking relief under rule 1.540 because it could not substitute for appellate review.On appeal, the Supreme Court of Florida reviewed whether rule 1.540 applies to final judgments in bond validation proceedings under chapter 75. The court held that chapter 75’s finality language—specifically section 75.09—precludes the use of rule 1.540 to collaterally attack such judgments after the time for appeal has expired. The court concluded that the statutory scheme is exclusive, and the rules of civil procedure do not override the statute. Accordingly, the Supreme Court of Florida affirmed the circuit court’s denial of the motions for relief from judgment. View "State Attorneys for the Second, Seventh and Ninth Judicial Circuits v. Florida Pace Funding Agency" on Justia Law

A South Korean entertainment company that owns trademarks for the popular “Baby Shark” song and related products brought a lawsuit in the United States District Court for the Southern District of New York against dozens of China-based businesses. The company alleged these businesses manufactured or sold counterfeit Baby Shark merchandise, violating trademark, copyright, and unfair competition laws. Seeking to stop the alleged counterfeiting, the company obtained temporary and preliminary injunctions and moved to serve the defendants by email, arguing that this method was appropriate under Federal Rule of Civil Procedure 4(f)(3).After the plaintiff served process by email, most defendants did not respond, leading to default judgments against many of them. However, two defendants appeared and challenged the court’s jurisdiction, arguing that service by email violated the Hague Service Convention, to which both the United States and China are parties. The district court agreed, finding that the Convention did not permit service by email on parties in China, and dismissed the claims against these defendants without prejudice for improper service. The plaintiff appealed to the United States Court of Appeals for the Second Circuit.The United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The appellate court held that the Hague Service Convention does not allow email service on defendants located in China, as China has expressly objected to alternative methods such as those in Article 10 of the Convention. The court further held that neither Federal Rule of Civil Procedure 4(f)(2) nor any purported emergency exception permitted email service in these circumstances. The court also upheld the denial of a default judgment, finding no abuse of discretion. Accordingly, the dismissal of the claims against the two China-based defendants for lack of proper service was affirmed. View "Smart Study Co., LTD v. Shenzhenshixindajixieyouxiangongsi" on Justia Law

Micron Technology and its subsidiaries, along with the State of Idaho, were sued for patent infringement by Katana Silicon Technologies in the United States District Court for the Western District of Texas. The patents at issue related to technology for shrinking semiconductor devices and had expired. In response, Micron asserted a counterclaim under the Idaho Bad Faith Assertions of Patent Infringement Act, alleging that Katana had made bad faith assertions of patent infringement. Katana moved to dismiss the counterclaim, arguing that the Idaho Act was preempted by federal patent law. The case was transferred to the United States District Court for the District of Idaho, where the State of Idaho intervened to defend the statute. Separately, Micron filed suit in Idaho state court against Longhorn IP, alleging similar bad faith assertions and seeking the imposition of a bond. Longhorn removed that case to federal court and also moved to dismiss on preemption grounds.The United States District Court for the District of Idaho denied both motions to dismiss, holding that federal law did not preempt the Idaho statute. The court also imposed an $8 million bond on Longhorn and Katana pursuant to the Act, finding that there was a reasonable likelihood that a bad faith assertion of patent infringement had occurred. Katana and Longhorn appealed these decisions to the United States Court of Appeals for the Federal Circuit.The United States Court of Appeals for the Federal Circuit dismissed the appeal for lack of jurisdiction. The appellate court determined that there was no final judgment from the district court, as the only decisions made were the denial of motions to dismiss and the imposition of a bond, neither of which ended the litigation on the merits. The Federal Circuit also found that none of the exceptions for interlocutory appellate review applied, including those for injunctions, the collateral order doctrine, or mandamus, nor was pendent jurisdiction appropriate. View "Micron Technology, Inc. v. Longhorn IP LLC" on Justia Law

A track and field athlete participated in the 2020 United States Olympic Trials, organized by USA Track & Field, Inc. (USATF), where she signed a waiver and indemnity agreement as part of her application to compete. During the heptathlon event, she suffered heat-related injuries on a day when temperatures were extremely high, preventing her from completing the competition and resulting in her not making the Olympic team. Seeking to pursue tort claims, the athlete first filed a declaratory judgment action in the Marion Superior Court, challenging the enforceability of the waiver agreement and seeking an injunction against its enforcement.The Marion Superior Court granted summary judgment to USATF, holding that the waiver agreement was enforceable and disposing of all claims. After the final judgment, but before the statute of limitations expired, the athlete moved to amend her complaint to add tort claims for negligence, gross negligence, recklessness, and willful misconduct. The trial court denied this motion, concluding that it was untimely because it was filed after entry of final judgment. The athlete appealed, and the Indiana Court of Appeals affirmed the enforceability of the agreement but held that the trial court had abused its discretion in denying the motion to amend, relying on Indiana Trial Rule 15(A).The Indiana Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion, and addressed the procedural issue. The Court held that once final judgment has been entered and all claims have been disposed of, Indiana Trial Rule 15(A) no longer allows for amendment of pleadings. A party may only seek to amend a complaint after final judgment if the judgment is first set aside or vacated under the appropriate rules. Accordingly, the Supreme Court affirmed the trial court’s denial of the motion to amend, clarifying that Rule 15(A) does not apply after final judgment. View "Brooks v. USA Track & Field, Inc." on Justia Law

A motor vehicle accident occurred in Butte, Montana, when a snow grader operated by a city employee backed into a sedan driven by the plaintiff at a very low speed. The grader was engaged in snow removal operations, reversing in the process, and displaying flashing lights and a backup alarm. The plaintiff, after passing the grader, positioned her car behind it and came to a stop. The grader then struck her vehicle. Testimony at trial included differing accounts of whether warning devices were observable and whether the plaintiff was attentive to the grader’s movements. The plaintiff claimed injuries resulting from the collision, though evidence regarding the severity and causation of her injuries was contested.The Second Judicial District Court, Butte-Silver Bow County, conducted a jury trial. The jury found the plaintiff 54% negligent and the city 46% negligent, barring her recovery under Montana’s comparative negligence statute. The plaintiff moved for a new trial, arguing irregularity in the proceedings and insufficient evidence to support the verdict. The District Court granted the motion for a new trial on both grounds, relying on statements made by the city’s counsel during closing arguments and finding the evidence did not support the jury’s comparative negligence finding.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in granting a new trial. The Supreme Court held that the plaintiff had not preserved her objections to alleged irregularities in the proceedings because she failed to object contemporaneously or through a specific motion in limine. The Court also determined that the plaintiff had judicially admitted that comparative negligence was a factual issue for the jury, thereby waiving her right to challenge the sufficiency of the evidence. Furthermore, the Supreme Court found that there was substantial evidence supporting the jury’s verdict. The Supreme Court reversed the District Court’s order granting a new trial and reinstated the jury’s verdict. View "Shahood v. Butte-Silver Bow" on Justia Law