Justia Civil Procedure Opinion Summaries

Brian Farabee, who suffers from borderline personality disorder, has spent his adult life in hospitals or prison for crimes committed while hospitalized. He filed a lawsuit under 42 U.S.C. § 1983 against Dr. Robert Gardella, Dr. Christy McFarland, and Daniel Herr, alleging violations of his constitutional rights and the Americans with Disabilities Act. Farabee claimed that the defendants denied him clinically recommended treatment, unnecessarily restrained and isolated him, forcibly medicated him, and discriminated against him.The United States District Court for the Western District of Virginia granted summary judgment in favor of the defendants without allowing Farabee to conduct discovery or ensuring he was informed of Federal Rule of Civil Procedure Rule 56’s requirements. The court concluded that there was no material dispute of fact and that the defendants were entitled to summary judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that the district court erred in granting summary judgment before allowing Farabee to conduct discovery. The appellate court emphasized that summary judgment should only be granted after adequate time for discovery and that the district court should have provided Farabee, a pro se litigant, with an opportunity to gather evidence. The Fourth Circuit reversed and vacated the district court’s summary judgment decision and remanded the case for further proceedings. The appellate court also recommended that the district court appoint counsel to assist Farabee in litigating the case due to its complexity and Farabee’s limited ability to conduct discovery on his own. View "Farabee v. Gardella" on Justia Law

Tracy Langiano alleged that he was shot and injured by Officer Landon Rollins in violation of the Fourth Amendment and that the City of Fort Worth’s policies contributed to this violation. Langiano was accused of sexually abusing his step-granddaughters and left his home after writing a suicide note. He checked into a motel with a loaded handgun, intending to kill himself. His son informed the police about the suicide note and the handgun. Police located Langiano at the motel, and Officer Rollins, without knocking, entered the room. Rollins claimed Langiano pointed a gun at him, prompting Rollins to shoot Langiano multiple times. Langiano disputed pointing the gun at Rollins but admitted holding it.The United States District Court for the Northern District of Texas denied Langiano’s motion to stay the civil suit while criminal charges were pending. The court granted summary judgment in favor of Officer Rollins and the City of Fort Worth, dismissing Langiano’s civil suit. Langiano appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying the stay, as Langiano did not demonstrate substantial and irreparable prejudice. The court also affirmed the summary judgment in favor of Officer Rollins, finding that Rollins’ use of force was reasonable given the circumstances and that Langiano’s Fourth Amendment rights were not violated. Additionally, the court held that the warrantless entry into the motel room was justified due to the exigent circumstances of Langiano being armed and suicidal. The court also affirmed the summary judgment in favor of the City, as there was no constitutional violation to support a Monell claim. The district court’s judgment was affirmed. View "Langiano v. City of Fort Worth" on Justia Law

Peyman Roshan, a lawyer and real estate broker, had his law license suspended by the California Supreme Court in 2021 for misconduct. Following this, the California Department of Real Estate (DRE) initiated a reciprocal disciplinary proceeding against his real estate license. Roshan filed a federal lawsuit against the DRE, alleging constitutional violations and seeking to enjoin the DRE's disciplinary action.The United States District Court for the Northern District of California dismissed Roshan's lawsuit, citing the Younger abstention doctrine, which prevents federal courts from interfering with certain ongoing state proceedings. The district court held that the DRE's disciplinary proceeding was quasi-criminal in nature and that Roshan could raise his federal claims during the judicial review of the DRE action.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The Ninth Circuit held that the district court correctly applied the Younger abstention doctrine. The court noted that the state proceedings were ongoing, involved important state interests, and allowed Roshan to raise his federal claims. The court also determined that the DRE proceeding was quasi-criminal because it was initiated by a state agency following an investigation, involved formal charges, and aimed to determine whether Roshan should be sanctioned by suspending or revoking his real estate license.The Ninth Circuit concluded that all the requirements for Younger abstention were met and that Roshan had not demonstrated any bad faith, harassment, or extraordinary circumstances that would make abstention inappropriate. Therefore, the district court's decision to abstain from hearing the case was proper, and the dismissal of Roshan's lawsuit was affirmed. View "ROSHAN V. MCCAULEY" on Justia Law

The plaintiffs, Michael R. and Christine O. McElroy, claimed an express or implied easement to access Seaweed Beach in Narragansett, Rhode Island, and to traverse certain private properties to reach the beach. The private properties in question are owned by Marilyn O. Stephens, Paul G. and Nancy L. Anthony, and Vivian H. Lacroix. The dispute arose when the Stephenses blocked access to their driveway, which the McElroys used to reach Seaweed Beach.In the Superior Court, the McElroys sought to quiet title to the easement, a declaration of their rights, and injunctive relief. The court initially granted summary judgment in favor of the McElroys, but the Rhode Island Supreme Court vacated this judgment, citing unresolved factual issues. Upon remand, a bench trial was conducted, and the trial justice found that the McElroys had an express easement upon Seaweed Beach and an implied easement over the Stephens property. However, the court ruled that the McElroys did not have easements over the Anthony or Lacroix properties.The Rhode Island Supreme Court reviewed the case and affirmed the trial justice's findings. The court held that the 1986 warranty deed clearly incorporated the 1929 express easement upon Seaweed Beach. The court also upheld the trial justice's determination that the McElroys had an implied easement over the Stephens property, as it was necessary for the enjoyment of their express easement on Seaweed Beach. The court found no error in the trial justice's admission of the 1986 purchase and sales agreement as extrinsic evidence to establish the implied easement. Finally, the court concluded that the trial justice did not err in denying the motion to amend the judgment, as the alleged inconsistencies did not constitute a manifest error of law. View "McElroy v. Stephens" on Justia Law

Kattie Boline sustained injuries from a car accident and sued JKC Trucking and driver Jerzy Syrzyna for negligence. During her jury trial, Boline violated a stipulated order in limine by mentioning insurance, which led the district court to declare a mistrial. The court found her violation intentional and sanctioned her by ordering her to pay $62,074.95 in defense attorneys’ fees and costs. The court also ruled that no new jury trial would be held until the sanction was paid. When Boline failed to pay, the district court dismissed her case with prejudice and entered judgment against her for the sanction amount.The district court of Sweetwater County initially handled the case, where Boline filed her complaint in 2018. The case experienced several delays before being set for trial in August 2022. During the trial, Boline’s mention of insurance, despite a pretrial order prohibiting such testimony, led to the mistrial. The district court then sanctioned her and conditioned a new trial on the payment of the sanction. Boline’s inability to pay the sanction led to the dismissal of her case with prejudice.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The Supreme Court held that the district court did not abuse its discretion in sanctioning Boline and dismissing her case with prejudice. The court found that the district court properly considered Boline’s mental health condition, financial situation, and the reasonableness of the attorneys’ fees and costs. The Supreme Court also held that the district court did not violate Boline’s right to open access to the courts under the Wyoming Constitution, as the sanction and subsequent dismissal were appropriate responses to her intentional violation of the court’s order. View "Boline v. JKC Trucking" on Justia Law

Juanita and Stephen Clark, Linda and Cliff Trebilcock, and Dan Gurney reside on Fuller Mountain Road in the Town of Phippsburg. Gurney has operated a firewood business from his property for thirty years. In September 2020, the Clarks and the Trebilcocks complained to the Town’s Code Enforcement Officer (CEO) that Gurney’s business was a nuisance under the Town’s Land Use Ordinance (LUO). The CEO found no violation, but the Clarks and the Trebilcocks appealed to the Board of Appeals (BOA), which found the business to be a nuisance. The Board of Selectmen (BOS) later found that Gurney had abated the nuisance.The Clarks and the Trebilcocks challenged the BOS’s decision in the Superior Court (Sagadahoc County), arguing that the BOS lacked authority to conduct a de novo review and that there were due process violations. The Superior Court affirmed the BOS’s decision, leading to the Clarks’ appeal to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court concluded that the BOA’s findings were outside the scope of the current appeal but found that the BOS exceeded its authority and violated due process in its review. The Court held that the BOS did not have the authority to review the CEO’s decision and that the BOS’s role was limited to deciding whether a consent agreement could be achieved or if court action was necessary. The Court also found procedural due process violations due to the conduct of BOS Chair Julia House, who exhibited bias and engaged in ex parte communications.The Court vacated the judgment and remanded the case to the Superior Court with instructions to remand to the BOS for new proceedings without the participation of Chair Julia House. View "Clark v. Town of Phippsburg" on Justia Law

In 2020, the Vermont Superior Court transitioned to electronic filing and adopted a policy that delayed public access to newly filed civil complaints until a court clerk reviewed them for compliance with technical requirements and the absence of unredacted confidential information. Plaintiffs, consisting of news and media organizations, challenged this practice, claiming it violated their First Amendment right of access to court documents.The United States District Court for the District of Vermont held a bench trial and ruled in favor of the Plaintiffs. The court found that Vermont’s pre-access review process violated the First Amendment and issued a permanent injunction preventing the Defendants from withholding complaints until the completion of the review process. The Defendants, administrators and clerks of the Vermont Superior Court, appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the district court that Vermont’s practice, as reviewed, violated the Plaintiffs’ First Amendment rights. However, the appellate court found that the terms of the permanent injunction were not supported by the court’s findings. The Second Circuit affirmed the district court’s judgment to the extent it found the practice violated the First Amendment but vacated the permanent injunction. The case was remanded for further proceedings to reconsider the terms of an appropriate injunction. The court also addressed and rejected the Defendants' arguments regarding abstention and mootness. View "Courthouse News Service v. Corsones" on Justia Law

Crystal Walcott Spill's estate and beneficiaries filed a wrongful death suit against several doctors, including Dr. Steven Paganessi and his medical group, alleging negligence during a surgical procedure that led to Spill's death. Spill, who had lupus, was under the care of Dr. Jenny Diep, a New York-based rheumatologist, and Dr. Jacob Markovitz, a New Jersey-based gynecologist. Before the surgery, Dr. Diep increased Spill's blood pressure medication dosage and recommended she see a nephrologist. Spill saw Dr. Holly Koncicki, a New York-based nephrologist, who conducted lab tests but did not receive the results before the surgery. Spill suffered a cardiac event during the procedure and died the same day. The lab results, available after her death, showed critically elevated creatinine and potassium levels.The trial court dismissed Dr. Diep from the case due to lack of personal jurisdiction and denied the defendants' motion to include her on the verdict form for fault allocation. The Appellate Division affirmed, holding that an out-of-state individual over whom New Jersey courts lack personal jurisdiction cannot be included for fault allocation.The Supreme Court of New Jersey reviewed the case and affirmed the Appellate Division's decision, with modifications. The Court held that an individual outside New Jersey's jurisdiction is not a "party" under the Comparative Negligence Act (CNA) for fault allocation purposes. However, such an individual may be considered a joint tortfeasor under the Joint Tortfeasors Contribution Law (JTCL), allowing defendants to seek contribution in a relevant jurisdiction if a judgment is rendered against them. The Court did not agree with the Appellate Division's view that the model civil jury instruction on causation mitigates any unfairness to the defendants. View "Estate of Spill v. Markovitz" on Justia Law

Kafi, Inc. ("Kafi") owns a residential property in League City, Texas, which it purchased from Joe and Kelly Richardson in September 2020. The Richardsons had financed the property with a loan from Sand Canyon Corporation in 2006, secured by an Adjustable Rate Note and a Deed of Trust. Sand Canyon transferred its interest in the loan to Wells Fargo Bank, N.A. ("Wells Fargo") in October 2006. Kafi challenged Wells Fargo's right to foreclose on the property, claiming the assignment of the Deed of Trust was forged. Kafi also sought equitable redemption, arguing it should be allowed to pay off any valid liens before foreclosure.The case was initially filed in Texas state court and then removed to the United States District Court for the Southern District of Texas. The district court dismissed Kafi's claims against Sand Canyon and Nationwide Title Clearing, Inc., and dismissed Kafi's standalone forgery claim and claim for exemplary damages. The court allowed Kafi's claims for declaratory relief, quiet title, and equitable redemption to proceed. Wells Fargo and PHH Mortgage Corporation filed a motion for summary judgment, which the district court granted, dismissing Kafi's remaining claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that Wells Fargo, as the holder of the Note, had standing to foreclose on the property under Texas law, regardless of the alleged forgery in the assignment of the Deed of Trust. The court also upheld the dismissal of Kafi's equitable redemption claim, noting that Kafi failed to provide sufficient evidence that it was ready, willing, and able to pay the redemption amount. The court emphasized that Kafi's declaration, which stated it was ready, able, or willing to redeem the property, was insufficient to meet the conjunctive requirement of being ready, willing, and able. Thus, the Fifth Circuit affirmed the district court's summary judgment in favor of Wells Fargo. View "Kafi, Inc. v. Wells Fargo Bank" on Justia Law

Plaintiffs Clifford Osborne and Deborah Olsen sued their former landlord, Kevin Belton, for disability discrimination and retaliation under the Fair Housing Act (FHA) and the Louisiana Equal Housing Opportunity Act (LEHOA). The dispute arose when Belton, who initially allowed the plaintiffs to keep a dog temporarily, later prohibited the dog and threatened eviction. Despite Osborne providing a letter from his physician stating the need for a service dog due to mental health issues, Belton refused to accept it and proceeded with eviction, which was granted by a Louisiana justice of the peace court.In early 2020, Osborne and Olsen filed a lawsuit in the United States District Court for the Western District of Louisiana. They moved for summary judgment, which Belton did not oppose, leading the district court to grant the motion in August 2022. Belton subsequently filed a Rule 60(b) motion for relief from the judgment nearly a year later, which the district court denied. He then filed a Rule 59(e) motion for reconsideration of the denial of his Rule 60(b) motion, which was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it had jurisdiction to review only the order denying Belton’s Rule 60(b) motion, as the notice of appeal was timely for this order but not for the underlying summary judgment. The Fifth Circuit held that the district court did not abuse its discretion in denying the Rule 60(b) motion, as Belton failed to establish grounds for relief such as excusable neglect, newly discovered evidence, fraud, or a void judgment. Consequently, the Fifth Circuit affirmed the district court’s denial of Belton’s Rule 60(b) motion. View "Osborne v. Belton" on Justia Law