Justia Civil Procedure Opinion Summaries

AllService Plumbing and Maintenance, Inc. is a small, family-owned plumbing company in Baton Rouge, Louisiana. In 2009, a union organizer named Charles LeBlanc began efforts to unionize AllService’s workforce. An employee, Joe Lungrin, opposed the unionization and informed the company’s Vice President, Luke Hall, about LeBlanc’s activities. The union filed a petition with the National Labor Relations Board (NLRB) to hold an election among AllService’s employees. After agreeing on an election date, AllService laid off three employees. The union lost the election, and subsequently filed a complaint with the NLRB alleging that AllService violated the National Labor Relations Act (NLRA) by surveilling, threatening, and interrogating employees, and by laying off employees due to their union activities.An NLRB administrative law judge (ALJ) found in 2011 that AllService violated the NLRA and ordered the reinstatement of the laid-off employees with backpay. AllService did not file timely exceptions, and the NLRB adopted the ALJ’s findings in 2012. A second ALJ calculated damages in 2013, and the NLRB ordered AllService to pay over $100,000. However, the Supreme Court’s decision in NLRB v. Noel Canning in 2014 invalidated the NLRB’s quorum, leading the Board to set aside its decision and dismiss its enforcement petition.In 2022, the NLRB issued a notice to show cause for re-adopting the 2013 ALJ decision, blaming administrative oversight for the delay. AllService objected, citing significant business losses due to floods in 2016 and 2021. The NLRB ignored these objections and adopted the 2013 decision. The NLRB then applied to the United States Court of Appeals for the Fifth Circuit for summary enforcement of its 2022 order.The Fifth Circuit denied the NLRB’s request for summary enforcement, finding that the Board failed to prove that enforcement would be equitable. The court held that the Board’s delay and administrative neglect were extraordinary circumstances excusing AllService’s failure to exhaust specific objections. The court also granted AllService’s petition for review, finding that the Board lacked substantial evidence to attribute Lungrin’s activities to AllService and to find that the pre-election layoffs were related to union activity. View "National Labor Relations Board v. Allservice Plumbing" on Justia Law

An egg farm owned by Rembrandt Enterprises, Inc. experienced a collapse of its poultry cage system in 2020, resulting in significant damage and the death of a farm worker. Rembrandt had contracted with Tecno Poultry Equipment, SpA in 2006 to design and manufacture the cage system, which included a provision for Tecno to supervise its installation. The installation was completed in 2007. Rembrandt sued Tecno in 2021, alleging strict products liability, breach of implied warranties, and negligence. The district court allowed the negligence claim to proceed to trial, where a jury found that Tecno did not breach its duty to supervise the installation.The United States District Court for the Northern District of Iowa granted summary judgment for Tecno on the strict products liability and breach of implied warranties claims. At trial, the jury heard conflicting expert testimony regarding the cause of the collapse. Rembrandt's expert attributed the collapse to missing screws and misplaced bolts, while Tecno's experts blamed improper manure disposal by Rembrandt. The jury ultimately sided with Tecno, and the district court entered judgment in favor of Tecno.The United States Court of Appeals for the Eighth Circuit reviewed the case. Rembrandt argued that the district court erred in denying its motions for judgment as a matter of law and in excluding a screenshot of Tecno's website. The appellate court held that Rembrandt failed to preserve its challenge to the sufficiency of the evidence by not renewing its motion under Rule 50(b) after the jury verdict. The court also found that the district court did not abuse its discretion in excluding the website screenshot, as it was not relevant to the 2006 contract. The Eighth Circuit affirmed the district court's judgment. View "Rembrandt Enterprises, Inc. v. Tecno Poultry Equipment, SpA" on Justia Law

Plaintiff Jana Romanova, a professional photographer, filed a lawsuit against Defendant Amilus Inc. for willful copyright infringement. Romanova alleged that Amilus published her photograph on its website without authorization. Despite being served, Amilus did not respond or appear in court. Romanova moved for a default judgment, but the district court ordered Amilus to show cause why the motion should not be granted. After receiving no response from Amilus, the court then ordered Romanova to show cause why the use of her photograph did not constitute fair use. The district court ultimately dismissed Romanova’s complaint with prejudice, concluding that Amilus’s use of the photograph was fair use.The United States District Court for the Southern District of New York dismissed Romanova’s claim, finding that the fair use defense was clearly established on the face of the complaint. The court reasoned that Amilus’s publication of the photograph communicated a different message than the original, which justified the fair use defense. Romanova appealed the decision, arguing that the court erred in its substantive finding of fair use and in raising the defense sua sponte for a non-appearing defendant.The United States Court of Appeals for the Second Circuit reviewed the case and reversed the district court’s judgment. The appellate court found that the district court misunderstood the fair use doctrine, particularly the requirement for a transformative purpose and justification for copying. The appellate court held that Amilus’s use of the photograph did not communicate a different message and lacked any valid justification for copying. Consequently, the appellate court remanded the case with instructions to enter a default judgment in favor of Romanova. View "Romanova v. Amilus Inc." on Justia Law

Carter W. Page filed a lawsuit against the United States, the Department of Justice (DOJ), the Federal Bureau of Investigation (FBI), and several current and former FBI officials. Page alleged that the FBI unlawfully obtained four warrants to electronically surveil him under the Foreign Intelligence Surveillance Act (FISA) and leaked information obtained from these warrants to the press, causing him reputational harm and lost business opportunities. The district court dismissed Page's claims, finding them either time-barred or insufficiently pleaded.The United States District Court for the District of Columbia dismissed Page's second amended complaint for failure to state a claim. The court found that Page's FISA claims were time-barred by the applicable three-year statute of limitations and that his claims were insufficiently pleaded. The court also dismissed Page's Patriot Act claim against the United States, with the majority concluding it was time-barred and the partial dissent finding it legally insufficient. Additionally, the court dismissed Page's Bivens claim and Privacy Act claims for lack of jurisdiction and failure to state a claim.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's dismissal of Page's FISA and Patriot Act claims as time-barred. The court held that Page had actual or inquiry notice of his FISA claims by April 2017, more than three years before he filed his complaint in November 2020. The court also found that Page's Patriot Act claim was barred because he failed to file his administrative claim with the FBI within two years of its accrual. The court concluded that Page had sufficient information by April 2017 to discover the basis for his claims, making them time-barred. View "Page v. Comey" on Justia Law

A group of neighbors appealed the Environmental Division’s decision affirming the District 4 Environmental Commission’s granting of an Act 250 permit amendment to JAM Golf, LLC for the construction of a housing development on a lot that was formerly part of the Wheeler Nature Park in South Burlington, Vermont. The neighbors argued that the landowner was required to show changed circumstances to amend the permit and that the development did not comply with Act 250 Criteria 8 and 10.The Environmental Division held six days of trial and conducted a site visit. In August 2024, the court affirmed the Act 250 permit amendment with conditions related to noise and safety during the construction period, concluding that the project complied with all relevant Act 250 criteria. The court also determined that the application should not be denied on the grounds of inequitable conduct because the neighbors failed to support assertions that the landowner made material misrepresentations in its application and on appeal.The Vermont Supreme Court reviewed the case and concluded that the permit-amendment argument was not preserved for appeal because it was not included in the statement of questions presented to the Environmental Division. The court also found that the Environmental Division did not err in allowing the landowner to elect to be assessed against the updated 2024 City Plan rather than the 2016 City Plan. The court determined that the evidence supported the Environmental Division’s findings that the project complied with Act 250 Criteria 8 and 10, including visual aesthetics, noise, and compliance with the local or regional plan. The court affirmed the Environmental Division’s decision. View "In re Wheeler Parcel Act 250 Determination" on Justia Law

David W. Cromwell and Anadarko E&P Onshore, LLC are co-tenants in an oil-and-gas lease on land in Loving County, Texas. Cromwell obtained his interests in 2009 through two leases, one with Carmen Ferrer and one with the Tantalo Trust. Both leases contained habendum clauses that extended the lease terms as long as minerals were produced from the land. Anadarko, which already had a working interest and had drilled wells on the land, continued to produce minerals. Cromwell repeatedly sought to participate in production and enter a joint operating agreement with Anadarko, but Anadarko did not respond. Despite this, Anadarko sent Cromwell joint interest invoices and treated him as a working interest owner.The trial court granted summary judgment in favor of Anadarko, ruling that Cromwell's leases terminated at the end of their primary terms because he did not personally cause production. The Court of Appeals for the Eighth District of Texas affirmed, holding that Cromwell was required to take action to cause production to keep his leases alive, based on the court's previous decision in Cimarex Energy Co. v. Anadarko Petroleum Corp.The Supreme Court of Texas reviewed the case and held that the plain language of the habendum clauses did not require Cromwell to personally produce minerals to maintain his interests. The court emphasized that the leases did not specify who must produce the minerals and that production in commercial paying quantities had continuously occurred on the land. Therefore, Cromwell's leases did not terminate. The court disapproved of previous decisions that required lessees to personally produce minerals when the lease language did not explicitly state such a requirement. The judgment of the court of appeals was reversed, and the case was remanded to the trial court to address the parties' remaining arguments. View "CROMWELL v. ANADARKO E&P ONSHORE, LLC" on Justia Law

Bryan and Ami Hauxwell, farmers using ground and surface water for irrigation, were involved in a dispute with the Middle Republican Natural Resources District (NRD) over alleged violations of the NRD’s rules and regulations. The NRD claimed the Hauxwells used ground water to irrigate uncertified acres, failed to install flowmeters, and used non-compliant flowmeters. The NRD issued a cease-and-desist order and penalties after a 2020 hearing, where the NRD’s general manager and counsel participated in the board’s deliberations.The Hauxwells challenged the 2020 findings in the district court for Frontier County, which ruled in their favor, citing due process violations and remanded the case. In 2021, the NRD issued a new complaint and held another hearing, excluding the general manager and counsel from deliberations. The board again found violations but deferred penalties to a later hearing. The district court dismissed the Hauxwells' challenge to the 2021 findings, stating it was not a final order as penalties were not yet determined.In 2022, the NRD held a hearing to determine penalties, resulting in restrictions on the Hauxwells' water use. The Hauxwells filed another petition for review, arguing that the 2020 due process violations tainted the subsequent hearings. The district court agreed, reversing the NRD’s 2022 findings and vacating the penalties.The Nebraska Supreme Court reviewed the case and found that the district court erred in concluding that the 2020 due process violations tainted the 2021 and 2022 hearings. The Supreme Court reversed the district court’s order and remanded the case with directions to address the other claims in the Hauxwells' petition for review. The court emphasized that the NRD’s actions in 2021 and 2022 were separate and not influenced by the 2020 hearing’s procedural issues. View "Hauxwell v. Middle Republican NRD" on Justia Law

John P. Middleton filed a defamation lawsuit against Roy Lee, The Hollywood Reporter LLC, and Gary Baum in the Southern District of Florida. The case stemmed from a professional and personal fallout between Middleton and Lee, which began and ended in California. Middleton had sued Lee in California for millions of dollars, and during the ongoing legal battle, Middleton relocated to Florida. In June 2020, The Hollywood Reporter published an article by Baum that detailed the feud and contained allegedly false statements about Middleton. Middleton claimed these statements were defamatory and filed the lawsuit in June 2022.The district court dismissed Middleton's action, applying California's one-year statute of limitations for defamation claims, which rendered the claims time-barred. The court concluded that Florida's borrowing statute and choice-of-law rules required the application of California law due to the significant relationship factors. The court also denied Middleton's motion to amend the complaint, deeming it futile as the proposed amendments did not alter the determination that California's statute of limitations applied.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that California had the most significant relationship to the defamation claims, considering factors such as the place where the injury and conduct causing the injury occurred, the domicile and residence of the parties, and where the relationship between the parties was centered. Consequently, California's one-year statute of limitations applied, and Middleton's claims were time-barred. The court upheld the dismissal of the action and the denial of the motion to amend the complaint. View "Middleton v. The Hollywood Reporter LLC" on Justia Law

The case involves a dispute over a parcel of land situated at the border of adjoining properties in Owings Mills, Maryland. Dr. Sharon Saunders owns one property, while Steven and Ellen Gilman own the neighboring property. The Gilmans claimed ownership of the disputed land through adverse possession, having maintained and used the land for several decades. In 2018, the Gilmans constructed a fence on the disputed property, prompting Dr. Saunders to commission a property survey and subsequently file a lawsuit to establish the boundary line and seek damages for trespass and other tort claims.The Circuit Court for Baltimore County ruled in favor of the Gilmans, declaring them the absolute owners of the disputed property by adverse possession. The court ordered the Gilmans to prepare and file an amended deed and plat reflecting their ownership. Dr. Saunders appealed the decision, but the Appellate Court dismissed the appeal, stating that the order was not a final judgment and did not fall under any exceptions allowing for an interlocutory appeal.The Supreme Court of Maryland reviewed the case to determine whether the Appellate Court erred in its decision. The Supreme Court held that the Circuit Court's order declaring the Gilmans as owners by adverse possession and directing the preparation of a deed was immediately appealable under Maryland Code, Courts & Judicial Proceedings Article §§ 12-303(1) and 12-303(3)(v). The Supreme Court reversed the Appellate Court's dismissal and remanded the case for further proceedings to address the merits of Dr. Saunders's appeal. View "Saunders v. Gilman" on Justia Law

John Bludworth Shipyard, L.L.C. (JBS) performed nearly $3 million in services to combine three vessels into a single dredging unit for a project along the Gulf Coast. The vessels involved were the Captain Frank Bechtolt, the CIT-103, and the Idler Barge. T.W. LaQuay Marine, L.L.C., which owned the Idler Barge and leased the other two vessels, requested the work without the knowledge or consent of the owners, Manson Construction Company and Caillou Island Towing Company, Inc. JBS asserted maritime liens on each vessel for the services provided.The United States District Court for the Southern District of Texas denied JBS’s motion for interlocutory sale of the three-vessel unit and JBS’s motion for summary judgment to confirm the validity of its maritime liens. The court granted Caillou’s motion to vacate the arrest of the CIT-103, finding that JBS did not provide necessaries to the CIT-103 and that there were fact issues regarding the Bechtolt and the Idler Barge. The district court focused on the CIT-103’s old function, disregarding any new function that JBS’s work might have equipped it to perform.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court erred by considering only the CIT-103’s former function and not its new function after the alterations. The appellate court vacated the district court’s grant of Caillou’s motion to vacate the arrest of the CIT-103 and remanded for further proceedings to determine whether JBS’s work constituted necessaries for the CIT-103’s new function. The court dismissed for lack of jurisdiction the remainder of JBS’s appeal challenging the denial of its motions for summary judgment and interlocutory sale. View "Bludworth v. Manson Construction" on Justia Law