Justia Civil Procedure Opinion Summaries

After a woman was injured in a car accident and treated at a hospital, an X-ray suggested a lung nodule, and her medical records recommended a chest CT scan for further investigation. No CT scan was ordered or performed, and she was released. Almost two years later, after suffering a femur fracture, a CT scan at a different hospital revealed cancer, and she subsequently passed away. Her husband and children, representing themselves and her estate, brought a wrongful-death medical malpractice suit against the hospital and multiple providers, alleging failure to properly follow up on the lung nodule.In the Iowa District Court for Scott County, the plaintiffs timely served certificates of merit as required by Iowa Code section 147.140, but these certificates were neither notarized nor included a statement that they were signed under penalty of perjury. Following the Iowa Supreme Court’s decision in Miller v. Catholic Health Initiatives-Iowa, Corp., the defendants moved to dismiss, arguing the certificates did not satisfy statutory requirements. The plaintiffs resisted, providing new expert statements but maintaining these were not amendments. The district court granted the defendants’ motion to dismiss with prejudice. After the death of one of the original plaintiffs, his son was appointed as executor and administrator for the estates. Notices of appeal were filed, initially signed by the non-lawyer administrator.The Supreme Court of Iowa first determined that the estates’ appeal should not be dismissed due to the unauthorized practice of law in filing the notice of appeal, since counsel promptly appeared and continued representation. On the substantive issue, the court was evenly divided on whether the district court correctly dismissed the suit for noncompliance with section 147.140. As a result, the dismissal was affirmed by operation of law. The motion to dismiss the appeal was denied, but the district court judgment was affirmed. View "Willhoite v. Genesis Health System" on Justia Law

The plaintiff, a member of the New Progressive Party and a former System Technician Coordinator for the Municipality of Aguadilla, Puerto Rico, alleged that after a new mayor from the Popular Democratic Party took office, he was subjected to politically motivated adverse employment actions. Specifically, he claimed his server access was revoked, he received a poor employment evaluation, and his work environment became intolerable, all of which led to his constructive resignation. He asserted that these actions were taken because of his political affiliation.Following discovery, several individual defendants moved for summary judgment on the claims against them in their individual capacities, arguing that the plaintiff had not established a prima facie case of political discrimination under the First Amendment and raising a qualified immunity defense. Importantly, they did not address the claims against them in their official capacities, the municipality, or the equal protection and Puerto Rico law claims. The plaintiff opposed the motion, but the district court, adopting a magistrate judge’s report and recommendation, granted summary judgment for the individual defendants and sua sponte dismissed the entire case with prejudice, citing waiver and a lack of evidence.The United States Court of Appeals for the First Circuit reviewed the case and held that the district court erred in granting summary judgment based on waiver alone and in concluding there was no evidence supporting the plaintiff’s claims. The appellate court found that the plaintiff’s deposition testimony created genuine disputes of material fact regarding the involvement and knowledge of the defendants. The court also held that the district court improperly dismissed claims against parties who had not moved for summary judgment without giving the plaintiff notice. The judgment was reversed and the case remanded for further proceedings. View "Arocho-Rodriguez v. Roldan-Concepcion" on Justia Law

The appellant owned a condominium unit in Old Orchard Beach, Maine, subject to the Tidewater Loft Condominium Association’s declaration, which required payment of fees and assessments. After accruing tens of thousands of dollars in unpaid dues, expenses, and legal fees, she received notice of her right to cure the default, but did not do so. The Association initiated foreclosure proceedings. In response, the appellant filed a counterclaim, alleging violations of the Fair Housing Act and the Americans with Disabilities Act, based on the Association’s alleged failure to accommodate her daughter’s disability in connection with snow removal and trash disposal.The Biddeford District Court held a bench trial, at which the appellant appeared pro se. Although pretrial proceedings had identified her counterclaim as an issue for trial, the court ultimately limited the trial to the foreclosure issues and expressly excluded the counterclaim, preventing the appellant from presenting evidence or cross-examining on matters related to her claim. The court then entered judgment of foreclosure and sale for the Association and also entered judgment against the appellant on her counterclaim, concluding she had presented no persuasive evidence, despite not allowing her to do so.On appeal, the Maine Supreme Judicial Court reviewed the procedural due process claim de novo. The court held that the trial court’s failure to permit the appellant to present evidence or be heard on her counterclaim constituted a violation of her procedural due process rights. The Maine Supreme Judicial Court vacated both the foreclosure judgment and the judgment on the counterclaim, remanding for further proceedings to allow the appellant an opportunity to be heard on her counterclaim. View "Tidewater Loft Condominium Association v. Moskal-Kanz" on Justia Law

A state official sought review of a lower court decision concerning an inmate, Joseph Clifton Smith, who was involved in litigation against the Alabama Department of Corrections. The case reached the United States Supreme Court on a writ of certiorari, which is a request for the Supreme Court to review the decision of a lower court.Previously, the United States Court of Appeals for the Eleventh Circuit had reviewed the case and issued a decision regarding Smith’s claims. The party dissatisfied with the Eleventh Circuit’s ruling—the Commissioner of the Alabama Department of Corrections—then sought review in the Supreme Court, prompting the granting of certiorari.Upon consideration, the Supreme Court of the United States dismissed the writ of certiorari as improvidently granted. This means that the Court concluded it should not have agreed to hear the case and, as a result, did not issue a decision on the merits. The effect of this order is that the decision of the Court of Appeals for the Eleventh Circuit remains in place, and the Supreme Court will not provide further review or guidance in this matter. View "Hamm v. Smith" on Justia Law

A woman married a man who was, unbeknownst to her, still legally married to his first wife. After learning of the bigamy, she obtained an annulment of the marriage. Meanwhile, the man's first wife obtained a court judgment against him for unpaid spousal support and an equalization payment, totaling over $1.4 million. To enforce this judgment, the first wife secured a writ of execution and served notices of levy on the man's bank accounts. Relying on a statutory provision allowing a judgment creditor to levy accounts in the name of a judgment debtor’s spouse without a court order if accompanied by an affidavit of spousal status, the first wife provided an affidavit stating that the second woman was the man's spouse. As a result, more than $380,000 was levied from accounts held in the second woman's name, either individually or with her son.The Superior Court of San Diego County denied the second woman’s motion to quash the levies, concluding that the annulment of her marriage did not undermine the validity of the levies. The court found the levies valid, except for a small exemption, and awarded nearly all the seized funds to the first wife. The second woman appealed, arguing that her marriage to the judgment debtor was void from the outset and thus could not form the basis for levying her separate accounts without a court order.The California Court of Appeal, Fourth Appellate District, Division One, held that the trial court erred. The appellate court determined that, under California law, a void marriage is invalid from its inception and its invalidity can be shown in collateral proceedings. Therefore, the affidavit of spousal status was ineffective, and the levies on the second woman's accounts were invalid. The appellate court reversed the trial court’s order, directed that the levies be quashed, and ordered the return of the funds improperly seized. View "Greely v. Greely" on Justia Law

Black Hawk County, Iowa, charges jail inmates daily fees and a booking fee. Rather than pursuing the standard civil reimbursement process, which includes judicial review, the County requires inmates to sign confessions of judgment upon release, acknowledging the debt and agreeing to payment terms. Inmates’ money is seized and applied toward the debt, and the confession allows the County to file for judgment without further judicial review. Leticia Roberts and Calvin Sayers, former inmates who signed these confessions under coercive circumstances, allege that the County’s process deprived them of an opportunity to challenge the jail fees and violated their Fourteenth Amendment due process rights. Roberts made payments out of fear of further enforcement, while Sayers made one payment and had money seized by jail officials.The United States District Court for the Northern District of Iowa dismissed Roberts and Sayers’s claims for lack of standing and failure to state a claim. The district court reasoned that their injury was not traceable to the confession of judgment policy because they would owe jail fees regardless, and any payments were voluntary. The court also denied their motion for a preliminary injunction and leave to amend the complaint.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The Eighth Circuit held that Roberts and Sayers had standing to seek damages and injunctive or declaratory relief, as they plausibly alleged injuries traceable to the County’s policy and a real threat of recurring harm. The appellate court found reasonable inferences that the confessions of judgment were coercive and not voluntary, and that the County’s actions deprived Roberts and Sayers of property without constitutionally adequate process. The Eighth Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "Roberts v. Thompson" on Justia Law

The parties in this case are former spouses who share a minor daughter. Their marriage was dissolved in 2019, and they were awarded joint legal and physical custody. Following the dissolution, both filed numerous motions related to custody, resulting in increased litigation. In 2022 and 2023, each sought sole custody through postjudgment modification motions. The trial court held an evidentiary hearing over several dates to resolve these motions and others. Ultimately, the court awarded the defendant sole legal and primary physical custody, issuing its decision 133 days after the close of evidence.After the decision, the plaintiff moved to void and set aside the custody order, arguing that the decision was untimely under General Statutes § 51-183b, which sets a 120-day deadline for rendering judgment. The Superior Court, Judicial District of Hartford, denied this motion, ruling that postjudgment modification motions are “short calendar matters” governed by Practice Book § 11-19, not § 51-183b. Under § 11-19, the party must file a motion for reassignment within 14 days after the 120-day deadline to preserve a timeliness objection, which the plaintiff did not do. The trial court also did not expressly rule on two contempt motions, and, without prior notice to the parties, it took judicial notice of the plaintiff’s conduct in a prior, unrelated custody proceeding involving a different child.The Connecticut Supreme Court held that the plaintiff had waived her timeliness objection by failing to follow the procedure set forth in Practice Book § 11-19. The court declined to review the claim regarding the unresolved contempt motions, as the plaintiff had not requested a ruling or sought articulation. However, the Supreme Court found that the trial court abused its discretion by sua sponte taking judicial notice of facts from the unrelated custody proceeding without giving the plaintiff notice and an opportunity to respond. This error was harmful because it significantly influenced the custody decision. The Supreme Court reversed the custody award and remanded for further proceedings, affirming the decision in all other respects. View "Hamilton v. Hamilton" on Justia Law

An engineer who had worked for more than two decades at a manufacturing company resigned after a demotion and accepted a leadership position at a competitor. As he was leaving, the company discovered that he had potentially printed several documents containing confidential information about its products. Although forensic analysis could not confirm that he actually printed these documents, the company concluded he had taken trade secrets and sued him and his new employer, alleging breach of a confidentiality agreement and misappropriation of trade secrets. The company sought a preliminary injunction to prevent disclosure of the alleged secrets and to restrict the engineer’s work with the competitor.The United States District Court for the Northern District of Ohio denied the preliminary injunction. The district court ruled that the company failed to meet its burden by not providing “clear and convincing” evidence for each of the four required factors for a preliminary injunction: likelihood of success on the merits, risk of irreparable harm, risk of harm to others, and the public interest. The court treated each factor as a separate prerequisite, each requiring clear and convincing proof.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision for abuse of discretion, clarifying that the district court had committed a legal error. The appellate court held that the correct approach is to weigh all four preliminary injunction factors together in a sliding-scale analysis, not to require clear and convincing evidence for each factor individually. It explained that a heightened standard of proof is not mandated unless required by statute, the Constitution, or in rare cases involving unusually coercive government action, none of which applied here. The Sixth Circuit reversed the district court’s decision and remanded the case for reconsideration under the appropriate standard. View "PCC Airfoils, LLC v. Daugherty" on Justia Law

Carissa Daniels filed a complaint in August 2023 alleging that Patrick R. O’Brien committed timber trespass on her property by cutting trees and bushes. O’Brien’s homeowner’s insurer, MMG Insurance Co., initially defended him under a reservation of rights but later withdrew that reservation and settled the claim with Daniels. Daniels then moved to dismiss her complaint with prejudice as part of the settlement. O’Brien objected to both the settlement and the dismissal, arguing he should have the opportunity to defend against Daniels’s claim and thereby preserve a potential wrongful use of civil process claim against her.The Superior Court (Oxford County) held a hearing on the motions. During the hearing, MMG moved to intervene to support Daniels’s dismissal, while O’Brien moved to keep the matter on the court’s docket. The court granted Daniels’s motion to dismiss with prejudice in February 2025 and denied O’Brien’s motion for further findings of fact and conclusions of law. O’Brien then appealed, raising procedural objections and challenging MMG’s authority to settle over his objection.The Maine Supreme Judicial Court reviewed the case and found no abuse of discretion by the Superior Court in granting the dismissal with prejudice. The Court explained that under Maine Rule of Civil Procedure 41(a)(2), whether to allow a voluntary dismissal is within the trial court’s discretion and does not require a hearing unless evidence is taken. The Court further held that there was no procedural error, and that the merits of the settlement and MMG’s authority to settle were not at issue in this proceeding. The judgment of the Superior Court was affirmed. The main holding is that a trial court does not abuse its discretion by granting a plaintiff’s motion to dismiss with prejudice, even over a defendant’s objection based on potential future claims. View "Daniels v. O'Brien" on Justia Law

After a boat owned by Bryan and Bethea Crabtree was severely damaged by fire while in storage in Florida, the Crabtrees sought coverage under their insurance policy with Great Lakes Insurance. Great Lakes denied their claim, alleging noncompliance with policy conditions, and subsequently filed a declaratory judgment action against the Crabtrees in the United States District Court for the District of Montana, based on the policy’s forum-selection clause and the Crabtrees’ Montana address.The parties agreed that Great Lakes would voluntarily dismiss the Montana case and refile in the United States District Court for the Southern District of Florida (SDFL), with the understanding that the Crabtrees would not contest jurisdiction or venue. Great Lakes dismissed the Montana action and refiled in SDFL. In response, the Crabtrees initiated a state court action and moved to stay or dismiss the SDFL federal suit. Instead of opposing the motion, Great Lakes voluntarily dismissed the SDFL suit as well. That same day, Great Lakes refiled a third action in Montana, which was later transferred back to SDFL at the Crabtrees’ request and with Great Lakes’s consent.Upon return to SDFL, the United States District Court for the Southern District of Florida considered whether, under Federal Rule of Civil Procedure 41(a)(1)(B), Great Lakes’s second voluntary dismissal barred further litigation of the same claim. The court granted summary judgment for the Crabtrees, holding that Rule 41(a)(1)(B) means what it says: a second voluntary dismissal acts as an adjudication on the merits, i.e., a dismissal with prejudice, even if the first dismissal was by agreement. The United States Court of Appeals for the Eleventh Circuit affirmed, concluding that Great Lakes was precluded from relitigating its claim in SDFL. View "Great Lakes Insurance SE v. Crabtree" on Justia Law