Justia Civil Procedure Opinion Summaries

CEZ Prior, LLC ("CEZ") entered into a purchase agreement with 755 N Prior Ave., LLC ("Prior") to buy a property for $26 million. The agreement required Prior to cooperate in obtaining tenant estoppel certificates. Errors in square footage measurements led to rent discrepancies, prompting an amendment to reduce the purchase price to $15.1 million and the cash required at closing to $3.8 million. CEZ later requested to delay closing due to financial issues, but Prior did not agree. Prior sent estoppel certificates that did not address rate increases, and CEZ proposed edits that Prior rejected. CEZ demanded satisfactory certificates on the closing date, but Prior terminated the agreement, alleging CEZ failed to tender cash.CEZ sued Prior for breach of contract in Minnesota state court and sought to enjoin the termination. Prior removed the case to federal court and counterclaimed for breach of contract. The district court stayed the matter and later denied CEZ's motion for a preliminary injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court's denial of the preliminary injunction. The court found that CEZ was unlikely to succeed on the merits of its breach of contract claim, as Prior had reasonably cooperated in obtaining the estoppel certificates. The balance of harms favored Prior, given CEZ's insufficient evidence of its ability to pay. The public interest did not favor CEZ due to its low probability of success on the merits.The court also addressed CEZ's argument under Minnesota law, finding that the district court's stay order was not an injunction and did not extend statutory deadlines. Consequently, CEZ was not entitled to additional time to close under Minnesota statutes. The Eighth Circuit affirmed the district court's judgment. View "CEZ Prior, LLC v. 755 N Prior Ave. LLC" on Justia Law

John Doe filed a putative class action against SSM Health Care Corporation in Missouri state court, alleging that SSM shared private health information with third-party marketing services without authorization, violating Missouri law. Doe claimed that SSM's MyChart patient portal transmitted personal health data to third-party websites like Facebook. The lawsuit included nine state law claims, such as violations of the Missouri Wiretap Statute and the Computer Tampering Act.SSM removed the case to federal court, citing the federal officer removal statute and the Class Action Fairness Act (CAFA). Doe moved to remand the case to state court. The United States District Court for the Eastern District of Missouri rejected SSM's arguments, ruling that SSM was not "acting under" a federal officer and that Doe's proposed class was limited to Missouri citizens, thus lacking the minimal diversity required under CAFA. The district court remanded the case to state court.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that SSM did not meet the criteria for federal officer removal because it was not acting under the direction of a federal officer. The court also held that the proposed class was limited to Missouri citizens, which destroyed the minimal diversity necessary for CAFA jurisdiction. Consequently, the Eighth Circuit affirmed the district court's remand order. View "Doe v. SSM Health Care Corporation" on Justia Law

The Human Rights Defense Center (HRDC), a non-profit organization, filed a Freedom of Information Act (FOIA) request with the United States Park Police for information about legal actions against the agency. After the Park Police failed to respond within the statutory period, HRDC filed a FOIA lawsuit. The Park Police eventually produced documents but withheld the names of officers involved in three tort settlements, citing FOIA Exemption 6, which protects against unwarranted invasions of personal privacy. Additionally, the Park Police inadvertently disclosed names in some documents and sought to prevent HRDC from using or disseminating this information.The United States District Court for the District of Columbia ruled that the Park Police correctly withheld the officer names under Exemption 6 and issued a clawback order for the inadvertently disclosed names, invoking its inherent authority to manage judicial proceedings.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Park Police failed to meet its burden under Exemption 6 to show that releasing the officer names would constitute a substantial invasion of privacy. The court found the agency's justifications to be generic and conclusory, lacking specific details. Consequently, the court did not need to balance the privacy interest against the public interest in disclosure.The court also determined that the district court's clawback order was not a valid exercise of inherent judicial authority, as it aimed to fill a perceived gap in the FOIA statute rather than protect core judicial functions. The court reversed the district court's summary judgment in favor of the Park Police, vacated the clawback order, and remanded the case for the release of the non-exempt officer names. View "Human Rights Defense Center v. United States Park Police" on Justia Law

Rodney Martin worked for B.F. Goodrich Company from 1966 to 2012 and was exposed to vinyl chloride monomer until 1974. He was diagnosed with angiosarcoma of the liver in December 2019 and died in July 2020. His widow, Candice Martin, filed a civil action in November 2021, alleging that Rodney’s occupational exposure caused his illness and death. She invoked the exception in section 1.1 of the Workers’ Occupational Diseases Act to avoid its exclusivity provisions.PolyOne filed a motion to dismiss for lack of personal jurisdiction, and Goodrich filed a motion to dismiss under the exclusivity provisions, arguing that section 1.1 did not apply and that using it would infringe on their due process rights. The district court denied these motions and certified two questions for interlocutory appeal to the United States Court of Appeals for the Seventh Circuit, which then certified three related questions to the Illinois Supreme Court.The Illinois Supreme Court reviewed the case and answered the certified questions. The court held that section 1(f) of the Workers’ Occupational Diseases Act is a period of repose for purposes of section 1.1. The court also determined that section 1.1 applies prospectively under section 4 of the Statute on Statutes, meaning it applies to new actions filed after the amendment was enacted. Finally, the court found that applying section 1.1 prospectively does not violate Illinois’s due process guarantee, as defendants did not have a vested right in an exclusivity defense before the employee’s injury was discovered. View "Martin v. Goodrich Corp." on Justia Law

Rebecca Petta filed a class-action complaint in the circuit court of Champaign County against Christie Business Holdings Company, P.C., doing business as Christie Clinic. Petta alleged that Christie negligently failed to prevent unauthorized access to its business email account, which potentially exposed patients' private personal data, including Social Security numbers and health insurance information. Christie moved to dismiss the complaint, and the trial court granted the motion.The trial court found that Petta had standing due to an inference of injury from unauthorized use of her phone number and city in a loan application. However, the court dismissed the complaint for failing to state a valid claim under existing law and due to the economic loss doctrine. The appellate court affirmed the dismissal but on the grounds that Petta lacked standing, as the alleged increased risk of identity theft was too speculative and the unauthorized loan application did not involve her private personal data.The Supreme Court of Illinois reviewed the case and agreed with the appellate court. The court held that Petta's allegations of increased risk of harm were insufficient to confer standing in a complaint seeking monetary damages. The court also found that the unauthorized loan application, which used only Petta's publicly available phone number and city, was not fairly traceable to Christie's alleged misconduct. Consequently, the court affirmed the appellate court's judgment, concluding that Petta lacked standing to bring her claims. View "Petta v. Christie Business Holding Co., P.C." on Justia Law

In June 2019, the Illinois General Assembly amended the Illinois Gambling Act to authorize the Illinois Gaming Board to issue six new casino licenses, including one in Waukegan. Waukegan Potawatomi Casino, LLC (Potawatomi Casino) submitted a proposal, but the City of Waukegan certified three other applicants and not Potawatomi Casino. Potawatomi Casino filed a complaint seeking to prohibit the Board from issuing a casino license due to the City's alleged noncompliance with the statute. The Cook County circuit court dismissed the complaint for lack of standing.The appellate court reversed the circuit court's decision, finding that Potawatomi Casino had standing to bring the action. The appellate court concluded that Potawatomi Casino had a legally cognizable interest in competing in a fair and lawful certification process and that the alleged injury was distinct and traceable to the City's actions. The appellate court also rejected the argument that the absence of a private right of action under the Act provided a basis to affirm the dismissal.The Illinois Supreme Court reviewed the case and reversed the appellate court's decision. The court held that the Board had jurisdiction to consider the applications once the City certified the applicants, and the license issued to Full House was not void. The court found that no effectual relief could be granted to Potawatomi Casino, rendering the appeal moot. Additionally, the court determined that Potawatomi Casino lacked standing to bring the suit because it did not have a legally cognizable interest in the casino licensing process when it filed the action. The court affirmed the circuit court's dismissal of the complaint. View "Waukegan Potawatomi Casino, LLC v. Illinois Gaming Board" on Justia Law

The case involves D.H.E., the biological father of V.S., a minor. The Cook County circuit court found V.S. neglected due to an injurious environment and dependent due to his mother's disability. Consequently, V.S. was adjudged a ward of the court, and guardianship was granted to the Department of Children and Family Services (DCFS). D.H.E. appealed, arguing that the neglect finding violated his due process rights, was against the manifest weight of the evidence, and that the court failed to provide a factual basis for its disposition.The appellate court affirmed the circuit court's adjudication and disposition orders. It found that D.H.E.'s challenges related to the neglect finding were moot because he did not also challenge the dependency finding. The appellate court also upheld the disposition order, which granted guardianship and custody to DCFS based on the finding that D.H.E. was unable to care for V.S.The Illinois Supreme Court reviewed the case and affirmed the appellate court's judgment. The court held that D.H.E.'s appeal was moot because he failed to challenge the dependency finding, which alone was sufficient to support the wardship and disposition orders. The court also found that the collateral consequences exception to mootness did not apply, as no significant collateral consequences specifically tied to the neglect finding were identified. Therefore, the court did not address the remaining issues on appeal. View "In re V.S." on Justia Law

Steuben Foods, Inc. (Steuben) filed a complaint in 2010 in the United States District Court for the Western District of New York, alleging that Shibuya Hoppmann Corp. infringed claims of U.S. Patent Nos. 6,209,591, 6,536,188, and 6,702,985. Shibuya Kogyo Co., Ltd. was added as a defendant in 2012, and a similar complaint was filed against HP Hood LLC. The cases were consolidated and later transferred to the District of Delaware in 2019. The district court issued a claim construction order in 2020 and denied cross-motions for summary judgment in 2021. A five-day jury trial resulted in a verdict that the asserted patents were valid and infringed, awarding Steuben $38,322,283.78 in damages.The district court granted Shibuya’s motion for judgment as a matter of law (JMOL) of noninfringement for all asserted patents, found the invalidity arguments waived, and conditionally granted a new trial. Steuben appealed the JMOL and the conditional grant of a new trial.The United States Court of Appeals for the Federal Circuit reviewed the case. The court reversed the JMOL of noninfringement for the ’591 and ’188 patents, finding substantial evidence supported the jury’s verdict of infringement. The court affirmed the JMOL of noninfringement for the ’985 patent, holding that the continuous addition of sterilant could not be equivalent to the claim’s requirement of intermittent addition. The court also reversed the conditional grant of a new trial on noninfringement and vacated the conditional grant of a new trial on invalidity and damages, remanding for further proceedings.The main holdings were: reversing the JMOL of noninfringement for the ’591 and ’188 patents, affirming the JMOL of noninfringement for the ’985 patent, reversing the conditional grant of a new trial on noninfringement, and vacating the conditional grant of a new trial on invalidity and damages. View "STEUBEN FOODS, INC. v. SHIBUYA HOPPMANN CORPORATION " on Justia Law

Clover Boykin filed a lawsuit against Greenwood Leflore Hospital (GLH) under 42 U.S.C. § 1983, alleging that GLH intentionally withheld her medical records, preventing her from filing a medical malpractice suit. Boykin claimed that GLH's actions violated her constitutional right of access to the courts. GLH responded with a motion to dismiss, arguing that Boykin's claims failed as a matter of law, the employee was immune from suit, GLH was never served, and the suit was time-barred.The Leflore County Circuit Court denied GLH's motion to dismiss and granted Boykin additional time to serve GLH. GLH then sought an interlocutory appeal, which the Supreme Court of Mississippi granted. Boykin did not file a brief in response to the appeal.The Supreme Court of Mississippi accepted Boykin's failure to file a brief as a confession of error and found that Boykin's claims failed as a matter of law. The court held that HIPAA does not provide a private right of action and that Boykin could not use § 1983 to enforce a federal statute that does not give her an individual right. The court reversed the trial judge's denial of the motion to dismiss and rendered judgment in favor of GLH. View "Greenwood Leflore Hospital v. Boykin" on Justia Law

The City of New Orleans filed a lawsuit against several pipeline operators and Entergy New Orleans LLC, alleging that their oil and gas production and transportation activities caused damage to the City's coastal zone. The City claimed that Entergy allowed its pipeline canals to widen and erode, threatening the City's storm buffer. The lawsuit was filed under Louisiana’s State and Local Coastal Resources Management Act of 1978 (SLCRMA).The defendants removed the case to federal court, arguing that Entergy, the only in-state defendant, was improperly joined to defeat diversity jurisdiction. Entergy consented to the removal and argued that it was exempt from SLCRMA’s permit requirements because its activities commenced before the statute's effective date. The City moved to remand the case to state court, but the United States District Court for the Eastern District of Louisiana denied the motion, dismissed Entergy as a party, and stayed the case pending appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that Entergy was improperly joined because its activities were exempt under SLCRMA’s Historical-Use Exception, which applies to uses legally commenced before the statute's effective date. The court found no reasonable basis for the City to recover against Entergy, thus disregarding Entergy's citizenship and establishing complete diversity among the parties. The court also rejected the City's argument that it was merely a nominal party representing Louisiana, concluding that the City filed the suit on its own behalf and stood to benefit from a favorable ruling. Consequently, the appellate court affirmed the district court's denial of the City's motion to remand. View "New Orleans City v. Aspect Energy" on Justia Law