Justia Civil Procedure Opinion Summaries

Linda Ager Coyle, the personal representative of Fred Ager's estate, filed a motion for confirmation of a specific devise related to the proceeds from the sale of storage units Fred had owned. Fred's will directed that the units be given in equal shares to his children, Linda and Jeff, with a life estate interest in half of the net rental income to his wife, Arlene Ager. Arlene filed a petition for supervised administration of the estate, which the circuit court granted. Subsequently, the court denied Linda's motion for confirmation of the specific devise.Linda appealed the circuit court's denial of her motion, and Arlene filed a notice of review seeking to challenge the court's earlier decision denying her motion to remove Linda as the personal representative. The Supreme Court of South Dakota issued an order to show cause, directing the parties to address whether the order denying the motion to confirm a specific devise was appealable. Linda argued that the order was appealable based on the precedent set in In re Estate of Geier, which held that each proceeding in an unsupervised administration is a final order. Arlene contended that the order was not final and not subject to review.The Supreme Court of South Dakota dismissed the appeal for lack of jurisdiction. The court held that a decision made prior to a final order terminating a supervised probate action is not governed by the Geier final order rule. The court emphasized that supervised administration is a single in rem proceeding under SDCL 29A-3-501, which contrasts with the multiple, independent proceedings allowed under SDCL 29A-3-107 for unsupervised administration. Since the order for supervised administration was signed before the denial of Linda's motion, the action had become a supervised administration, and the individual-proceeding rule of finality did not apply. Consequently, the court also dismissed Arlene's notice of review. View "Estate Of Ager" on Justia Law

The case involves a medical negligence claim brought by Janet Hild, the administrator of Scott Boldman's estate, against several medical professionals and entities, including Samaritan Health Partners and Good Samaritan Hospital. Boldman, who had multiple health issues, underwent an emergency appendectomy at Good Samaritan Hospital. Post-surgery, he became combative and removed his breathing tube, after which he soon died. Hild claimed that the anesthesia was improperly handled, causing Boldman's aggressive behavior and subsequent death. The hospital argued that Boldman self-extubated and suffered a cardiac arrest unrelated to the anesthesia.The case proceeded to a jury trial in the Montgomery County Court of Common Pleas. The jury found that Sandra Ward, the Certified Registered Nurse Anesthetist, was negligent in her care of Boldman. However, only the six jurors who found negligence were allowed to vote on whether Ward's negligence proximately caused Boldman's death. They concluded it did not. Hild filed a motion for a new trial, arguing that all jurors should have been allowed to vote on proximate cause. The trial court denied the motion.The Second District Court of Appeals reversed the trial court's decision in part, holding that the trial court erred by not allowing all jurors to vote on proximate cause, and remanded the case for a new trial on specific issues. The hospital appealed to the Supreme Court of Ohio.The Supreme Court of Ohio held that the same-juror rule applies in all negligence cases where the jury answers sequential interrogatories that separate the elements of negligence. This means the same three-fourths of jurors must concur on all elements for a valid verdict. The court reversed the Second District's decision to the extent it ordered a new trial and reinstated the jury's verdict in favor of the hospital. View "Hild v. Samaritan Health Partner" on Justia Law

The plaintiffs, a group of professional models, alleged that the defendant, an adult entertainment nightclub, used their images in social media posts without consent to promote the club between August 2013 and November 2015. The plaintiffs filed a lawsuit in 2021 in the United States District Court for the District of Massachusetts, claiming defamation and related torts. This filing was outside the three-year statute of limitations specified by Massachusetts law. To avoid dismissal, the plaintiffs argued for the application of the "discovery rule," which would delay the start of the limitations period until they knew or reasonably should have known about the harm.The United States District Court for the District of Massachusetts noted that the application of the discovery rule to social media posts was a novel issue in Massachusetts law. The court certified a question to the Supreme Judicial Court of Massachusetts, asking under what circumstances material posted on social media platforms could be considered "inherently unknowable" for the purposes of applying the discovery rule in defamation and related tort claims.The Supreme Judicial Court of Massachusetts held that claims arising from social media posts accrue when a plaintiff knows or reasonably should know they have been harmed by the publication. The court emphasized that the vastness of social media and the variability in access and searchability require a fact-specific inquiry. The court concluded that whether the plaintiffs knew or should have known about the harm must often be determined by the finder of fact. However, if the social media material is widely distributed and readily accessible and searchable, a judge may determine as a matter of law that the discovery rule does not apply. View "Davalos v. Bay Watch, Inc." on Justia Law

Beneficiaries of a family trust sued the co-trustees, alleging mismanagement and the creation of a secret trust to withhold funds. They sought a declaratory judgment, accountings, and damages. The district court excluded all evidence of damages due to the beneficiaries' failure to provide a damages calculation as required by Federal Rule of Civil Procedure 26. Consequently, the district court granted summary judgment in favor of the co-trustees, as the beneficiaries could not prove damages and were not entitled to a declaratory judgment or accountings.The United States District Court for the Western District of Louisiana initially handled the case. The court granted the co-trustees' motion in limine to exclude damages evidence and subsequently granted summary judgment on all claims. The court found that the beneficiaries failed to provide a timely damages calculation and that their claims were time-barred under Louisiana law. The beneficiaries appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision, holding that the district court did not abuse its discretion in excluding the damages evidence. The appellate court applied the "CQ factors" to determine that the exclusion was justified due to the importance of the evidence, the prejudice to the co-trustees, the availability of a continuance, and the beneficiaries' lack of a valid explanation for their delay. Consequently, the court affirmed the summary judgment on all claims, as the beneficiaries could not prove an essential element of their case without the excluded damages evidence. The court also affirmed the dismissal of the beneficiaries' request for a declaratory judgment, as it was remedial in nature and dependent on the underlying claims for recovery. View "King v. King" on Justia Law

Caitlin Julia Weathers, a white woman, was hired by Houston Methodist Hospital as a Patient Transporter in May 2019 and later became a Patient Care Assistant in June 2021. She reported racial harassment and discrimination by her co-workers to her supervisor, Sunila Ali, and Human Resources (HR). HR investigated but found no evidence supporting her claims and instead received negative feedback about her performance. Weathers was placed on a performance improvement plan (PIP) and was eventually terminated on October 4, 2021, for allegedly failing to meet the PIP's expectations. Weathers claimed her termination was retaliatory.Weathers filed an online inquiry with the EEOC on February 11, 2022, but faced difficulties scheduling an interview due to the EEOC's unavailability. After several delays and cancellations, she finally had an interview on August 1, 2022, and filed her charge of discrimination on August 3, 2022, 303 days after her termination. The EEOC issued a Right to Sue letter on August 11, 2022. Weathers then sued Methodist and Ali for discrimination and retaliation under Title VII. The district court dismissed her claims against Ali, citing that employees are not personally liable under Title VII, and dismissed her claims against Methodist as time-barred for not filing within the 300-day deadline.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the dismissal of claims against Ali but found that the district court erred in not applying equitable tolling to Weathers's claims against Methodist. The court noted that the delays were partly due to the EEOC's actions and that Weathers had diligently pursued her claim. The court vacated the district court's judgment for Methodist and remanded the case for further proceedings, allowing Weathers's claims to proceed. View "Weathers v. Houston Methodist Hospital" on Justia Law

Employees of Smith International, Inc. filed a claim for unpaid overtime wages under the Fair Labor Standards Act (FLSA). The employees, known as reamers, supervised the use of Smith’s underreaming tool on offshore drilling rigs. They were paid an annual salary plus daily-rate job bonuses, with their total annual compensation exceeding $100,000. The employees argued that they were misclassified as exempt from overtime requirements and sought to recover unpaid overtime wages, liquidated damages, and attorney fees.The United States District Court for the Western District of Louisiana conditionally certified the action as a collective action. Later, the claims of some plaintiffs were severed into separate individual actions, while others continued as a collective action. The district court consolidated the five proceedings for all purposes except for trial. After discovery, both parties filed cross motions for summary judgment. The district court granted Smith’s motion for summary judgment, finding that the employees were exempt from the FLSA’s overtime pay guarantee as bona fide executives. The employees appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that each employee met the criteria for the bona fide executive exemption under the FLSA. Specifically, the employees satisfied the salary basis test, the salary level test, and the job duties test. The court found that the employees were paid a guaranteed annual salary, which was not subject to reduction based on the quality or quantity of work performed, and that the additional daily-rate compensation did not defeat their qualification for the exemption. The court affirmed the district court’s grant of summary judgment in favor of Smith International, Inc. View "Venable v. Smith International" on Justia Law

Candace Hensley sustained injuries from a trip and fall accident at a Westin Hotel in Indianapolis, Indiana, on May 2, 2017. She and her husband, Timothy Hensley, filed a lawsuit in the State Court of Gwinnett County, Georgia, against Westin Hotel and Westin Hotel Management, L.P. (WHM), alleging negligence and loss of consortium. Merritt Hospitality, LLC (Merritt) and WHM responded, asserting that Merritt was incorrectly named and that Westin Hotel was not a legal entity. The Hensleys amended their complaint to include Merritt and Marriott International, Inc. (Marriott). The case was removed to the United States District Court for the Northern District of Georgia based on diversity jurisdiction.Hartford Casualty Insurance Company, which had paid workers’ compensation benefits to Mrs. Hensley, intervened to protect its subrogation lien. The district court applied Indiana tort law and granted summary judgment in favor of the defendants, concluding that they either did not control the hotel premises or lacked actual knowledge of the hazard. The court also dismissed Hartford’s claim, as it depended on the Hensleys' success. The Hensleys appealed the decision.The United States Court of Appeals for the Eleventh Circuit reviewed the case and determined that the district court lost subject matter jurisdiction when Hartford, an indispensable party, intervened, destroying complete diversity. The appellate court vacated the district court’s summary judgment order and remanded the case with instructions to remand it to the State Court of Gwinnett County, Georgia. The main holding was that Hartford’s intervention as a matter of right and its status as an indispensable party required the case to be remanded to state court due to the lack of complete diversity. View "Hensley v. Westin Hotel" on Justia Law

The relator, Justin Tjaden, sought a writ of mandamus to have his name placed on the November 5, 2024, general-election ballot as an independent candidate for the office of state representative of Ohio House District 99. Tjaden's petition was found to be 124 valid signatures short of the required number. He argued that the boards of elections exceeded their authority by invalidating signatures as "not genuine" and violated his procedural due process and equal protection rights. Tjaden also contended that the statutory requirement for independent candidates to submit a petition with signatures amounting to at least one percent of registered voters who cast ballots for governor in the 2022 general election was unconstitutional.The Geauga County Board of Elections determined that Tjaden's petition contained 371 valid signatures, which was insufficient to qualify for the ballot. Tjaden attempted to challenge this decision in the Geauga County Court of Common Pleas but was unsuccessful due to procedural issues. He then filed a complaint in the same court and a mandamus action in the Supreme Court of Ohio. The Supreme Court dismissed his first mandamus action based on the jurisdictional-priority rule but allowed him to file a second mandamus action after his common-pleas-court case was removed to federal court.The Supreme Court of Ohio denied Tjaden's writ of mandamus. The court held that Tjaden did not have enough valid signatures to qualify for the ballot, even if all contested signatures were deemed valid. The court also found that Tjaden's procedural due process rights were not violated, as the mandamus action provided him with the necessary process. Additionally, the court declined to address Tjaden's equal protection claim, stating that even if the statute were declared unconstitutional, there would be no statutory requirement for an independent candidate to qualify for the ballot. Thus, the court denied the writ. View "State ex rel. Tjaden v. Geauga County Board of Elections" on Justia Law

G.M., a second-grade student with dyslexia and ADHD, was deemed ineligible for special education by Howard County Public Schools (HCPS) under the Individuals with Disabilities Education Act (IDEA). His parents, disagreeing with this determination, pursued the IDEA’s dispute resolution process, which included a state administrative hearing. The administrative law judge (ALJ) sided with HCPS, leading G.M.’s parents to file a lawsuit in federal district court. The district court upheld the ALJ’s decision, prompting an appeal to the United States Court of Appeals for the Fourth Circuit.The ALJ conducted a six-day hearing, considering evidence from both sides. G.M.’s parents presented private evaluations indicating deficiencies in reading and writing, while HCPS provided assessments showing average performance. The ALJ found HCPS’s evidence more persuasive, concluding that G.M. did not exhibit a pattern of strengths and weaknesses necessary to qualify as having a specific learning disability (SLD) under the IDEA. The ALJ also determined that although G.M. had an other health impairment (OHI) due to ADHD, he did not need special education because he was performing adequately relative to grade-level standards.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The court held that the ALJ’s factual findings and credibility determinations were regularly made and thus entitled to deference. The court agreed that G.M. did not qualify as a “child with a disability” under the IDEA because he did not exhibit the necessary pattern of strengths and weaknesses in reading and writing, and his ADHD did not necessitate special education. The court also found that G.M. received a free appropriate public education (FAPE) without special education services, as he was achieving passing marks and advancing from grade to grade. Consequently, HCPS did not substantively violate the IDEA, and G.M. was not entitled to the requested relief. View "G.M. v. Barnes" on Justia Law

Andrew Morgan, a millwright laborer, was employed by Allison Crane & Rigging LLC until his termination on November 18, 2020. Morgan injured his lower back on September 29, 2020, and was diagnosed with a bulged or herniated disc by a chiropractor. He was placed on light duty and given restrictions on bending and lifting. Despite these accommodations, Morgan was terminated, allegedly for failing to follow company policies and not showing up for work on November 17, 2020. Morgan filed a lawsuit claiming disability-based discrimination, retaliation, and failure to accommodate under the ADA and PHRA, as well as wrongful discharge under Pennsylvania common law.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of Allison Crane. The court held that Morgan did not establish an actual or perceived disability under the ADA and PHRA, as his testimony about the chiropractor's diagnosis was inadmissible hearsay and he failed to provide necessary medical evidence. The court also found that Morgan's back pain was transitory and minor, thus not qualifying as a disability. Additionally, the court dismissed Morgan's wrongful discharge claim for lack of prima facie evidence of protected activity.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court applied an incorrect legal standard. The Third Circuit clarified that under the ADA Amendments Act of 2008, temporary impairments can qualify as disabilities if they substantially limit major life activities. The court reversed the District Court's dismissal of Morgan's back pain-based discrimination claims, vacated the dismissal of his retaliation and failure to accommodate claims, and affirmed the dismissal of his wrongful discharge claim. The case was remanded for further proceedings consistent with the Third Circuit's opinion. View "Morgan v. Allison Crane & Rigging LLC" on Justia Law