Justia Civil Procedure Opinion Summaries

A property owner purchased a lot in a Wyoming subdivision governed by two homeowners’ associations, each enforcing its own set of covenants. The owner sought to demolish an existing structure and build a new residence with an attached hangar, submitting construction plans for approval as required. Disputes arose over whether his application was complete and whether the associations unreasonably delayed or withheld approval, resulting in increased construction costs due to inflation. Complicating matters, one association (AVR I) had been dissolved years earlier, but its board continued to act as if it existed, later forming a new entity (AVR II) that purported to enforce covenants recorded after AVR I’s dissolution but before AVR II’s formal creation.The property owner initially sued AVR I, believing it to be the proper party, and later sued the other association, AAA. During discovery, he learned that AVR I had been defunct and that AVR II was the actual entity acting as the homeowners’ association. He moved to amend his complaint to add AVR II and assert new claims, including that the covenants were invalid. The District Court of Lincoln County denied the motion to amend, finding the amendments would be futile, and granted summary judgment to AVR I, reasoning that the covenants automatically approved the owner’s plans by default and any delay was self-imposed.The Supreme Court of Wyoming reviewed the case and held that the district court abused its discretion in denying leave to amend the complaint. The Supreme Court found that the proposed claims against AVR II were not futile, as there were unresolved factual and legal questions regarding the validity and enforceability of the covenants and AVR II’s authority. The court also held that summary judgment for AVR I was premature. The orders denying amendment and granting summary judgment were reversed, and the case was remanded for further proceedings. View "Conger v. AVR Homeowner's Association, Inc." on Justia Law

Several individuals with developmental disabilities, along with Disability Rights New York (DRNY), an advocacy organization, alleged that New York State agencies responsible for services to people with developmental disabilities caused them to remain in restrictive institutional settings for extended periods, despite being eligible for community-based residential placements. The individual plaintiffs claimed they waited from nine months to six years for such placements, resulting in physical and psychological harm. DRNY, as the state’s designated Protection and Advocacy System, joined the suit, asserting authority to represent the interests of individuals with disabilities under federal law.The United States District Court for the Southern District of New York first addressed the defendants’ motion to dismiss DRNY’s claims for lack of standing, agreeing that DRNY had not suffered an injury in fact and rejecting its argument that federal statutes conferred “congressionally authorized representational standing.” The district court also dismissed the individual plaintiffs’ claims as moot, based on pre-motion letters from the defendants indicating that all individual plaintiffs had since been moved out of institutional facilities. Additionally, the court denied a motion by other individuals seeking to intervene as plaintiffs, finding the motion untimely.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s dismissal of DRNY’s claims, holding that DRNY lacked standing because it had not suffered a concrete injury and that Congress could not override Article III’s standing requirements by statute. The Second Circuit also affirmed the denial of the motion to intervene, finding no abuse of discretion in the district court’s timeliness determination. However, the Second Circuit vacated the dismissal of the individual plaintiffs’ claims as moot, holding that the district court erred by dismissing those claims based solely on pre-motion letters without full briefing or a hearing. The case was remanded for further proceedings on the individual plaintiffs’ claims. View "A.H. v. N.Y. State Dep't of Health" on Justia Law

Two drivers, McGee and Hudgins, were involved in a road-rage incident that ended with McGee crashing into Green’s vehicle, causing her injuries. Green and her husband sued both drivers. Before filing suit, Green received $100,000 from McGee’s insurer in exchange for a covenant not to execute judgment against McGee. Green’s underinsured motorist (UIM) carrier, Progressive, defended the suit in McGee’s name. The jury found McGee 60% at fault and Hudgins 40% at fault, and determined both acted recklessly, willfully, and wantonly. The jury awarded Green $88,546.78 in actual damages and $35,000 in punitive damages against each defendant.The Circuit Court for Spartanburg County combined the actual and punitive damages for a total of $158,546.78, subtracted the $100,000 payment from McGee’s insurer, and allocated the remaining $58,546.78 between McGee and Hudgins based on their respective percentages of fault. On appeal, the South Carolina Court of Appeals altered the setoff calculation, allocating the $100,000 payment first to McGee’s share, then applying any remainder to Hudgins’ share, resulting in a net judgment of $58,546.78 against Hudgins and $0 against McGee.The Supreme Court of South Carolina reviewed the setoff calculation. It held that, because the jury found both defendants acted recklessly, willfully, and wantonly, joint and several liability applied to the actual damages, making the percentage allocation of fault irrelevant. The court further held that the $100,000 payment could only be set off against the actual damages, not the punitive damages, as punitive damages are not for the “same injury.” The court reversed the Court of Appeals, holding Green is entitled to a net judgment of $23,546.78 against McGee and $35,000 against Hudgins, and remanded for entry of judgment in those amounts. View "Green v. McGee" on Justia Law

Kevin Rhodes, a former employee of the Missouri Highways and Transportation Commission, was terminated in December 2019 following an investigation into allegations of workplace misconduct, including the use of a racial slur. Rhodes filed grievances about his treatment during the investigation and, after his termination, brought charges of discrimination with the Missouri Commission on Human Rights. He subsequently received notices of right to sue and filed a lawsuit in circuit court alleging sex discrimination, retaliation, and hostile work environment under the Missouri Human Rights Act.A jury in the Circuit Court of Jackson County found in favor of the commission on the sex discrimination claim but ruled for Rhodes on his retaliation and hostile work environment claims, awarding him various damages. The circuit court applied a statutory damages cap and entered judgment accordingly. The commission moved for judgment notwithstanding the verdict, which the circuit court denied. Both parties appealed: Rhodes challenged the constitutionality of the damages cap, while the commission argued that Rhodes had not made a submissible case. The case was transferred to the Supreme Court of Missouri due to the constitutional issues raised.The Supreme Court of Missouri determined that the circuit court’s judgment was not final because it failed to address Rhodes’s requests for equitable relief and prejudgment interest. The court explained that a final judgment must dispose of all claims and forms of relief sought. Because the judgment did not resolve all aspects of Rhodes’s claims, the Supreme Court of Missouri dismissed the appeal for lack of a final judgment, declining to address the merits of the parties’ arguments. View "Rhodes v. Missouri Highways and Transportation Commission" on Justia Law

After Missouri voters approved a constitutional amendment in November 2024 protecting the right to make decisions about reproductive healthcare, Planned Parenthood filed a lawsuit in the Circuit Court of Jackson County. The organization sought a declaration that various state abortion laws and regulations were unconstitutional under the new amendment and requested a preliminary injunction to prevent their enforcement while the case was pending. The circuit court initially granted a preliminary injunction enjoining several abortion-related statutes and regulations, and later expanded the injunction to include additional licensing requirements after a motion for reconsideration.The State of Missouri challenged the preliminary injunction, arguing that the circuit court applied the wrong legal standard. The Supreme Court of Missouri issued a peremptory writ directing the circuit court to vacate its orders and reconsider the injunction under a more rigorous standard, requiring a threshold finding that the party seeking the injunction is likely to prevail on the merits. The circuit court complied, reevaluated the request, and again issued a preliminary injunction enjoining the same statutes and regulations. The State then appealed directly to the Supreme Court of Missouri, raising multiple points of error and seeking a stay and expedited review.The Supreme Court of Missouri determined that it lacked exclusive appellate jurisdiction over the appeal because the circuit court had not yet ruled on the constitutional validity of the challenged statutes. The Court explained that its exclusive jurisdiction is only invoked when a claim that a statute is unconstitutional has been properly raised, preserved, and ruled upon in the lower court. Since the appeal concerned only the issuance of a preliminary injunction and not a final determination on the statutes’ validity, the Supreme Court of Missouri transferred the case to the Missouri Court of Appeals, Western District, for further proceedings. View "Comprehensive Health of Planned Parenthood Great Plains v. State" on Justia Law

A group of institutional investors brought a class action lawsuit against a pharmaceutical company and several of its officers, alleging violations of federal securities laws after the company’s share price dropped significantly following the rejection of a takeover bid and subsequent negative financial disclosures. One large investor, Sculptor, intended to pursue its own individual lawsuit rather than participate in the class action. The District Court certified the class and issued a notice specifying the procedure and deadline for class members to opt out. Although Sculptor intended to opt out, its counsel failed to submit the required exclusion request by the deadline. Both Sculptor and the company proceeded for years as if Sculptor had opted out, litigating the individual action and treating Sculptor as an opt-out plaintiff.The United States District Court for the District of New Jersey later approved a class settlement, which prompted the discovery that Sculptor had never formally opted out. Sculptor then sought to be excluded from the class after the deadline, arguing that its conduct showed a reasonable intent to opt out, that its failure was due to excusable neglect, and that the class notice was inadequate. The District Court rejected these arguments, finding that only compliance with the court’s specified opt-out procedure sufficed, that Sculptor’s neglect was not excusable under the relevant legal standard, and that the notice met due process requirements.The United States Court of Appeals for the Third Circuit affirmed the District Court’s judgment. The Third Circuit held that a class member must follow the opt-out procedures established by the district court under Rule 23; a mere “reasonable indication” of intent to opt out is insufficient. The court also found no abuse of discretion in denying Sculptor’s late opt-out request and concluded that the class notice satisfied due process. View "Perrigo Institutional Investor Group v. Papa" on Justia Law

A Luxembourg-based investment fund and its former General Partner became embroiled in a complex dispute following a contentious split among the fund’s founders. The fund, originally managed by Novalpina Capital Partners I GP S.À.R.L. (Novalpina), saw its General Partner position transferred to Treo NOAL GP S.à.r.l. (Treo) after a vote by limited partners, including the Oregon Public Employees Retirement Fund (OPERF). The fund’s structure involved multiple entities and significant investments, with allegations of improper conduct and maneuvers by both sides during the transition. Novalpina and Treo subsequently initiated several lawsuits in Luxembourg, including actions over control of the fund and claims for financial entitlements.Novalpina filed an ex parte petition in the United States District Court for the District of Oregon under 28 U.S.C. § 1782, seeking discovery from Oregon officials for use in foreign proceedings, specifically the Veto Right Litigation and a contemplated fraud claim. Treo, Langdon, and Read intervened, and the district court granted the petition, finding statutory and discretionary factors favored Novalpina. The parties negotiated a protective order, which allowed use of the documents in litigation related to the events described in the petition. After Novalpina used the documents in additional foreign proceedings, Treo moved for reconsideration of the discovery grant and to modify the protective order, arguing misuse and misrepresentation.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of Treo’s motions. The Ninth Circuit held that documents produced under § 1782 for use in specified foreign proceedings may be used in other proceedings unless the district court orders otherwise. The court found no abuse of discretion in the district court’s denial of Treo’s motion for reconsideration or its request to modify the protective order, affirming the district court’s rulings. View "NOVALPINA CAPITAL PARTNERS I GP S.A.R.L V. READ" on Justia Law

Quintara Biosciences, Inc. and Ruifeng Biztech, Inc. are both DNA-sequencing-analysis companies that had a business relationship from 2013 to 2019. In 2019, the relationship deteriorated, with Quintara alleging that Ruifeng locked it out of its office, took its equipment, and hired away its employees. Quintara then filed suit, asserting a claim under the federal Defend Trade Secrets Act (DTSA), alleging misappropriation of nine specific trade secrets, including customer and vendor databases, marketing plans, and proprietary technology.The United States District Court for the Northern District of California, referencing a California state law rule, ordered Quintara to disclose its alleged trade secrets with “reasonable particularity” at the outset of discovery. Dissatisfied with the specificity of Quintara’s disclosures, Ruifeng moved to strike most of the trade secrets under Federal Rule of Civil Procedure 12(f). The district court granted the motion, striking all but two of the trade secrets and effectively dismissing Quintara’s claims as to the others. The case proceeded to trial on the remaining trade secrets, and a jury found in favor of Ruifeng.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s actions. The appellate court held that the district court abused its discretion by striking Quintara’s trade secrets at the discovery stage. The Ninth Circuit clarified that, under the DTSA, whether a trade secret is identified with sufficient particularity is a question of fact to be resolved at summary judgment or trial, not at the outset of discovery. The court reversed the district court’s order striking the trade secrets, affirmed the denial of a mistrial, and remanded the case for further proceedings. The main holding is that DTSA claims should not be dismissed at the discovery stage for lack of particularity except in extreme circumstances, and Rule 12(f) does not authorize striking trade secrets in this context. View "QUINTARA BIOSCIENCES, INC. V. RUIFENG BIZTECH, INC." on Justia Law

Terri R. Winnon, a former executive assistant and controller for a group of skilled nursing facilities (SNFs) in Texas, alleged that her former employers and associated entities engaged in fraudulent schemes to obtain improper reimbursements from Medicare and Texas Medicaid. She claimed that the defendants paid unlawful kickbacks to doctors and hospital discharge planners for patient referrals and inflated therapy service bills to maximize government reimbursements. Winnon’s allegations included specific practices such as employee bonuses tied to Medicare census targets, “sham” medical directorships, and “marketing gifts” to hospital staff, as well as systematic upcoding of therapy services by a contracted provider, RehabCare.After Winnon filed her qui tam action under the False Claims Act (FCA) and related Texas statutes, the United States District Court for the District of Columbia dismissed her claims. The court found that her allegations against RehabCare were barred by the FCA’s public disclosure provision, as similar claims had already been made public in a prior lawsuit, United States ex rel. Halpin & Fahey v. Kindred Healthcare, Inc. The district court also determined that Winnon’s claims against the SNF Defendants did not meet the heightened pleading requirements of Federal Rule of Civil Procedure 9(b), as they lacked sufficient particularity regarding the alleged fraudulent conduct.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s dismissals. The appellate court held that Winnon’s claims against RehabCare were precluded by the public disclosure bar because her allegations were substantially similar to those previously disclosed and she did not qualify as an “original source” under the FCA. Regarding the SNF Defendants, the court concluded that Winnon’s allegations failed to satisfy Rule 9(b)’s requirement for particularity, as she did not provide enough specific details to support a strong inference that false claims were actually submitted. The court affirmed the district court’s judgments in full. View "USA v. Lozano" on Justia Law

P&J Beverage Corporation filed a lawsuit against the City of Columbus, seeking to prevent the city from issuing an alcoholic beverage license to The Bottle Shop, LLC, and later sought to revoke the license after it was issued. P&J argued that The Bottle Shop’s location was too close to a daycare, which it claimed qualified as a “school” under city ordinances. The trial court granted summary judgment to P&J, invalidating The Bottle Shop’s license and enjoining its operation. The Bottle Shop’s attorney then emailed P&J’s attorney, referencing a potential claim for wrongful injunction if the appellate court reversed the trial court’s order, and requested a stay of the injunction pending appeal. P&J declined, and The Bottle Shop’s motion for a stay was denied by the trial court but later granted by the Court of Appeals, which ultimately reversed the trial court’s decision on the merits.Subsequently, The Bottle Shop sued P&J for both abusive litigation and wrongful injunction, seeking damages, attorney fees, and punitive damages. At trial, The Bottle Shop presented evidence of lost revenue, overhead costs, and attorney fees incurred during the period it was closed. The jury awarded substantial damages, attorney fees, and punitive damages. The trial court entered judgment accordingly. P&J moved for a directed verdict and for judgment notwithstanding the verdict, arguing, among other things, that The Bottle Shop failed to provide the statutory notice required for an abusive litigation claim. The trial court denied these motions, and the Court of Appeals affirmed, holding that the email satisfied the statutory notice requirement.The Supreme Court of Georgia reviewed the case and held that the email sent by The Bottle Shop did not satisfy the statutory notice requirement under OCGA § 51-7-84 (a) for an abusive litigation claim, as it failed to identify the civil proceeding as abusive litigation. The Court vacated the trial court’s judgment and remanded the case for further proceedings to determine what portion of the damages, if any, remain valid. View "P& J BEVERAGE CORPORATION v. THE BOTTLE SHOP, LLC" on Justia Law