Justia Civil Procedure Opinion Summaries

The United States government brought suit against several defendants, including EZ Lynk, SEZC, Thomas Wood, and Bradley Gintz, alleging that their product, the EZ Lynk System, violated the Clean Air Act by enabling vehicle owners to bypass or disable emissions controls. The EZ Lynk System consists of a physical device that connects to a vehicle’s diagnostics port, a smartphone app, and a cloud-based service. Through this system, users can download and install “tunes” created by third-party technicians, including “delete tunes” that defeat emissions controls. The complaint detailed how EZ Lynk collaborated with tune creators, provided technical support, and maintained an online forum where users discussed using the system to delete emissions controls.The United States District Court for the Southern District of New York found that the government’s complaint sufficiently alleged that the EZ Lynk System was a “defeat device” under the Clean Air Act. However, the district court dismissed the complaint, holding that EZ Lynk and its principals were immune from liability under Section 230 of the Communications Decency Act. The court reasoned that EZ Lynk merely published third-party information (the delete tunes) and did not create them, thus qualifying for Section 230 immunity.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s dismissal de novo. The Second Circuit agreed that the complaint adequately alleged the EZ Lynk System was a defeat device. However, it held that the complaint also sufficiently alleged that EZ Lynk, Wood, and Gintz directly and materially contributed to the creation of the unlawful delete tunes, making them ineligible for Section 230 immunity. The Second Circuit vacated the district court’s dismissal and remanded the case for further proceedings. The main holding is that Section 230 immunity does not apply where a defendant directly and materially contributes to the creation of unlawful content. View "United States v. EZ Lynk" on Justia Law

Robert Miller was arrested on July 31, 2019, and died the next day while in custody at the Tarrant County Jail. His wife, Shanelle Jenkins, was not notified by authorities of his death but learned about it several days later through a newspaper article. Jenkins alleges that, despite making several direct requests, she was unable to obtain information from Tarrant County or the Texas Rangers about the circumstances of her husband’s death. Nearly two years after Miller’s death, Jenkins filed a lawsuit against the Tarrant County Sheriff’s Office and Sheriff, alleging wrongful death and excessive force, but her complaint lacked specific factual allegations about how Miller died.The United States District Court for the Northern District of Texas dismissed Jenkins’s federal claims with prejudice due to insufficient factual allegations and declined to exercise supplemental jurisdiction over her state law claims. After the dismissal, Jenkins received documents from Tarrant County and the Texas Department of Public Safety that provided more details about Miller’s death. She sought relief from the judgment under Federal Rule of Civil Procedure 60(b), but the district court denied her motion, and the United States Court of Appeals for the Fifth Circuit affirmed, finding that Jenkins had not exercised due diligence in investigating her claims and that the evidence was not intentionally withheld.Jenkins then filed a new lawsuit on November 30, 2023, against ten individual defendants, asserting similar claims but with more detailed factual allegations. The district court again dismissed her claims, holding they were barred by Texas’s two-year statute of limitations and that equitable tolling did not apply because Jenkins failed to allege fraudulent concealment by the named defendants and did not exercise due diligence. The United States Court of Appeals for the Fifth Circuit affirmed, holding that Jenkins’s claims accrued in August 2019 and were time-barred, and that equitable tolling was not warranted. View "Jenkins v. Tahmahkera" on Justia Law

A married couple, who wed in 2020 and share a young child, purchased an engineering business together using loans secured by the wife’s premarital home. After their separation in 2023, the wife petitioned for divorce. The parties entered into interim agreements regarding custody, child support, and business management, but the husband repeatedly violated these orders by failing to make required payments, misusing business funds, and withholding financial disclosures. The wife raised concerns about the husband’s substance abuse and erratic behavior, providing evidence of his alcohol and marijuana use, as well as incidents of intoxication during child exchanges and at work. The husband denied these allegations but admitted to some problematic behavior in written communications.The Thirteenth Judicial District Court, Yellowstone County, held multiple hearings, finding the husband in contempt several times for violating court orders. At trial, the court heard testimony and reviewed evidence regarding the husband’s parenting, financial conduct, and the parties’ competing proposals for the business. The court found the wife more credible, sanctioned the husband for discovery violations, and ultimately awarded her primary custody of the child, with the husband’s parenting time to be phased in only after he completed chemical dependency and mental health evaluations. The court also awarded the wife sole ownership of the business and her premarital home, requiring her to assume all related debts.The Supreme Court of the State of Montana affirmed the District Court’s decisions. It held that the finding regarding the husband’s failure to make full financial disclosures was supported by substantial evidence and not clearly erroneous. The Supreme Court also found no abuse of discretion in conditioning the husband’s parenting time on completion of evaluations or in awarding the business to the wife, as these decisions were equitable and consistent with Montana law. View "In re Marriage of Boeshans" on Justia Law

A resident of a memory-care facility in Massachusetts alleged that the facility’s court-appointed receiver, KCP Advisory Group, LLC, conspired with others to unlawfully evict residents, including herself, by falsely claiming that the local fire department had ordered an emergency evacuation. The resident, after being transferred to another facility, filed suit in the United States District Court for the District of Massachusetts, asserting several state-law claims against KCP and other defendants. The complaint alleged that KCP’s actions violated statutory and contractual notice requirements and were carried out in bad faith.KCP moved to dismiss the claims against it, arguing that as a court-appointed receiver, it was entitled to absolute quasi-judicial immunity. The district court granted the motion in part and denied it in part, holding that while quasi-judicial immunity barred claims based on negligent performance of receivership duties, it did not bar claims alleging that KCP acted without jurisdiction, contrary to law and contract, or in bad faith. The court thus denied KCP’s motion to dismiss several counts, including those for violation of the Massachusetts Consumer Protection Act, intentional infliction of emotional distress, civil conspiracy, fraud, and breach of fiduciary duty. KCP appealed the denial of immunity as to these counts.The United States Court of Appeals for the First Circuit reviewed the district court’s denial of absolute quasi-judicial immunity de novo. The appellate court held that KCP’s alleged acts—removing residents from the facility—were judicial in nature and within the scope of its authority as receiver. Because KCP did not act in the absence of all jurisdiction, the court concluded that quasi-judicial immunity barred all of the resident’s claims against KCP. The First Circuit therefore reversed the district court’s denial of KCP’s motion to dismiss the specified counts. View "Suny v. KCP Advisory Group, LLC" on Justia Law

The dispute centers on approximately 930 acres of agricultural land owned by two trusts near Pocatello, Idaho. The trusts entered into a purchase and sales agreement with a developer, Millennial Development Partners, to sell a strip of land for a new road, Northgate Parkway, which was to provide access to their property. The trusts allege that Millennial and its partners, along with the City of Pocatello, failed to construct promised access points and infrastructure, and that the developers and city officials conspired to devalue the trusts’ property, interfere with potential sales, and ultimately force a sale below market value. The trusts claim these actions diminished their property’s value and constituted breach of contract, fraud, interference with economic advantage, regulatory taking, and civil conspiracy.After the trusts filed suit in the District Court of the Sixth Judicial District, Bannock County, the defendants moved for summary judgment. The trusts sought to delay the proceedings to complete additional discovery, arguing that the defendants had not adequately responded to discovery requests. The district court denied both of the trusts’ motions to continue, struck their late response to the summary judgment motions as untimely, and granted summary judgment in favor of the defendants, dismissing the case with prejudice and awarding attorney fees to the defendants. The trusts appealed these decisions.The Supreme Court of the State of Idaho affirmed the district court’s denial of the trusts’ motions to continue, finding no abuse of discretion. However, it reversed the grant of summary judgment, holding that the district court erred by failing to analyze whether the defendants had met their burden under the summary judgment standard and appeared to have granted summary judgment as a sanction for the trusts’ untimely response. The Supreme Court vacated the judgment and remanded the case for further proceedings, and declined to award attorney fees on appeal. View "Rupp v. City of Pocatello" on Justia Law

Michael Rivera, a prisoner, filed a complaint alleging that his constitutional rights were violated by police officers during a traffic stop and subsequent search. Initially, Rivera named the New Castle County Police Department and several unidentified “John Doe” officers as defendants. After the police department identified the officers involved, Rivera amended his complaint to name them specifically.The United States District Court for the District of Delaware screened Rivera’s complaint, dismissed the claim against the police department as frivolous, but allowed the claims against the Doe defendants to proceed. The court ordered the police department to identify the officers, which it did. Rivera then amended his complaint to add the identified officers. The officers moved to dismiss, arguing that the amendment was untimely and did not relate back to the original complaint under Federal Rule of Civil Procedure 15(c), because Rivera allegedly knew their identities when he filed the original complaint. The District Court agreed, finding that Rivera “indisputably knew” the officers’ names and thus the amendment did not relate back, rendering the claims untimely. Rivera’s motion for reconsideration was denied, and he appealed.The United States Court of Appeals for the Third Circuit reviewed the District Court’s decision de novo. The Third Circuit held that the District Court applied the wrong legal standard by focusing on Rivera’s knowledge rather than on what the officers knew or should have known, as required by Rule 15(c) and the Supreme Court’s decision in Krupski v. Costa Crociere S.p.A. The Third Circuit also found that the District Court improperly resolved factual disputes against Rivera at the motion to dismiss stage. The Third Circuit vacated the District Court’s dismissal and remanded for further proceedings consistent with its opinion. View "Rivera v. New Castle County Police Department" on Justia Law

The State of Vermont brought a lawsuit in state court against 3M Company, alleging that 3M’s production of per- and polyfluoroalkyl substances (PFAS), known as “forever chemicals,” had contaminated Vermont’s natural resources, including water, wildlife, soil, and sediment. The case focused on contamination at the Rutland City landfill and a former 3M manufacturing facility in Rutland, Vermont. In 2023, Vermont’s Department of Environmental Conservation sent 3M a letter identifying it as a potentially responsible party for PFAS contamination, and Vermont’s counsel later forwarded this letter to 3M’s counsel in the context of the ongoing litigation.After receiving the letter, 3M conducted an internal investigation and determined that, during its ownership of the Rutland facility, it had manufactured copper-clad laminates in accordance with military specifications that required the use of PFAS. On January 3, 2024, 3M removed the case to federal court under the federal officer removal statute, 28 U.S.C. § 1442(a)(1), asserting a federal defense based on its compliance with military requirements. The United States District Court for the District of Vermont found that 3M’s removal was untimely under 28 U.S.C. § 1446(b)(3), reasoning that the thirty-day removal period began when 3M received Vermont’s email with the DEC letter, and remanded the case to state court.The United States Court of Appeals for the Second Circuit reviewed the District Court’s remand order de novo. The Second Circuit held that Vermont’s correspondence did not provide sufficient information for 3M to ascertain that the case was removable under the federal officer removal statute, and thus the thirty-day removal period had not begun when 3M received the email. The court vacated the District Court’s order and remanded the case for further proceedings. View "Vermont v. 3M Co." on Justia Law

A student organization at West Texas A&M University, focused on supporting LGBT+ students, planned a charity drag show to raise funds for a suicide prevention initiative. The event was to be held in a university venue that had previously hosted a wide range of student and community events, including a prior drag show. The organizers took steps to ensure the show would be appropriate for a general audience, restricting lewd content and requiring minors to be accompanied by adults. Shortly before the event, the university president canceled the show, citing concerns that drag performances were discriminatory against women and did not align with the university’s values.Following the cancellation, the student group and two of its officers filed suit in the United States District Court for the Northern District of Texas, seeking a preliminary injunction to allow future drag shows on campus. The district court denied the injunction, holding that drag shows were not inherently expressive conduct protected by the First Amendment and that the university president was entitled to qualified immunity. The court also found that the plaintiffs had standing against certain university officials but not others, and rejected the claim of irreparable harm.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of the preliminary injunction de novo. The Fifth Circuit held that the planned drag show was expressive conduct protected by the First Amendment, as it conveyed a clear message of support for the LGBT+ community in its context. The court determined that the university venue was a designated public forum, making the content-based restriction on the drag show subject to strict scrutiny, which the university did not attempt to justify. The court found the plaintiffs faced irreparable harm from the ongoing ban and that the balance of equities and public interest favored an injunction. The Fifth Circuit reversed the district court’s denial of a preliminary injunction against the university president and a vice president, affirmed the denial as to the chancellor for lack of standing, and remanded for entry of the injunction. View "Spectrum WT v. Wendler" on Justia Law

William Cannon was convicted of assault with intent to commit rape and dissuading a witness, after attacking a 16-year-old girl and confessing to other attempted sexual assaults. Near the end of his prison sentence, the district attorney petitioned to commit him under the Sexually Violent Predator Act (SVPA), which allows for the civil commitment of certain sex offenders after their sentences if they are found to be sexually violent predators. During pretrial proceedings, Cannon’s attorney, without Cannon’s personal attendance or express waiver, waived his right to a jury trial. The trial court did not advise Cannon of his jury trial rights or seek his personal waiver, as the SVPA does not require these steps. Following a bench trial, Cannon was found to be a sexually violent predator and was committed.On appeal, Cannon argued for the first time that the SVPA’s procedures violated his state and federal equal protection rights because, unlike other civil commitment schemes for individuals found not guilty by reason of insanity (NGI) or those with mental health disorders (OMHD), the SVPA does not require a judicial advisement of the right to a jury trial or a personal waiver from the defendant. The Court of Appeal considered the equal protection claim despite it not being raised below, found that rational basis review was the appropriate standard, and remanded the case to the trial court to allow the parties to develop a fuller record and litigate the equal protection issue.The Supreme Court of California reviewed the case to determine the appropriate standard of scrutiny for Cannon’s equal protection challenge. The court held that rational basis review, not strict scrutiny, applies to the SVPA’s jury trial demand and waiver procedures. The court affirmed the Court of Appeal’s remand order, directing the trial court to determine whether the legislative choice of procedures is constitutionally justified under rational basis review and whether Cannon knowingly waived his right to a jury trial. The order of commitment is conditionally affirmed pending the outcome of those proceedings. View "P. v. Cannon" on Justia Law

Ferdinand E. Marcos, former President of the Philippines, deposited approximately $2 million in a New York Merrill Lynch account in 1972, which grew to over $40 million. These funds, known as the Arelma Assets, were proceeds of Marcos’s criminal activities. After Marcos’s ouster, multiple parties—including the Republic of the Philippines, a class of nearly 10,000 human rights victims, and the estate of Roger Roxas (from whom Marcos had stolen treasure)—asserted competing claims to these assets. The Republic obtained a forfeiture judgment from a Philippine court and requested the U.S. Attorney General to enforce it under 28 U.S.C. § 2467.The United States District Court for the Southern District of New York reviewed the enforcement application. The court rejected the class’s affirmative defenses, which included arguments based on statute of limitations, subject matter jurisdiction, lack of notice, and fraud. The court also found that Roxas lacked Article III standing because she failed to show a sufficient interest in the Arelma Assets, and denied her leave to amend her answer. The court entered judgment for the Government, allowing the assets to be returned to the Republic of the Philippines.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s judgment. The Second Circuit held that the class failed to create a genuine dispute of material fact as to any of its affirmative defenses and that Roxas lacked standing to participate as a respondent. The court also upheld the denial of intervention by Golden Budha Corporation, finding its interests adequately represented and lacking standing. The main holding is that the Government’s application to enforce the Philippine forfeiture judgment was timely and proper, and that neither the class nor Roxas could block enforcement or claim the assets. View "In re: Enforcement of Philippine Forfeiture Judgment" on Justia Law