Justia Civil Procedure Opinion Summaries

An elderly plaintiff with significant disabilities inherited her home and, facing a tax sale due to unpaid property taxes, responded to a flyer offering help. She met with the defendant, who had her sign documents that transferred ownership of her home to him, allegedly under the pretense of providing a loan. The documents did not provide for any payment to the plaintiff, only that the defendant would pay the back taxes. The plaintiff later attempted to cancel the transaction, believing it had been voided when the defendant returned her documents and she received no loan. Several years later, the defendant served her with an eviction notice, prompting her to file suit alleging fraud, undue influence, financial elder abuse, and other claims, seeking cancellation of the transfer and damages.The case was heard in the Superior Court of Los Angeles County. The defendant, representing himself, filed an answer and a cross-complaint, asserting that he had purchased the property and that the plaintiff had lived rent-free for years. The litigation was marked by extensive discovery disputes, with the plaintiff filing nine motions to compel and for sanctions due to the defendant’s repeated failures to provide timely and adequate discovery responses, appear for depositions, and pay court-ordered sanctions. The court issued incremental sanctions, including monetary and issue sanctions, before ultimately imposing terminating sanctions by striking the defendant’s answer and cross-complaint, leading to a default judgment in favor of the plaintiff.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. It held that the trial court did not abuse its discretion in imposing terminating sanctions after the defendant’s persistent and willful noncompliance with discovery orders. The court also found that the plaintiff’s complaint provided sufficient notice of damages, and that the award of damages and attorney fees was supported by substantial evidence. The judgment of the trial court was affirmed in all respects. View "Atlas v. Davidyan" on Justia Law

A pretrial detainee in the St. Tammany Parish Jail, who has had a prosthetic eye for decades, reported his chronic condition to jail medical staff upon intake. In June 2022, a jail doctor prescribed antibiotics and twice-weekly wound care for an infection in the detainee’s eye socket. Although the detainee was initially scheduled for wound care, he was not taken to his appointments, and his infection worsened over several weeks. The detainee filed multiple grievances, alleging that a deputy failed to escort him to medical care and that a refusal-of-treatment form was falsely completed without his knowledge or signature. After further investigation, jail officials determined that the medical records inaccurately reflected wound care visits, which were actually medication distributions, and ultimately found the detainee’s grievance substantiated.The detainee filed a pro se civil rights action under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Louisiana, naming jail officials and medical staff as defendants. The district court, through a magistrate judge, granted a motion to dismiss for some defendants and summary judgment for others, entering final judgment against the detainee and dismissing his claims with prejudice. The court denied the detainee’s motions to compel discovery and to amend his complaint, and did not address some discovery requests before entering judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the magistrate judge committed plain error by treating a report and recommendation as a final judgment before it was formally adopted, thereby denying the detainee a full and fair opportunity for discovery. The appellate court reversed the grant of summary judgment for the doctor-defendants, affirmed the dismissal of claims against most jail officials, but found that dismissal should have been without prejudice to allow for amendment. The case was remanded for further proceedings consistent with these holdings. View "James v. Smith" on Justia Law

In 2022, a Colorado town enacted an ordinance restricting most vehicles from entering its pedestrian malls, with certain exceptions, including one for high-volume commercial carriers making frequent deliveries. In 2023, the town amended the ordinance to remove this exception, leaving only a provision allowing a town-approved contractor to deliver goods in the pedestrian areas. The Colorado Motor Carriers Association, representing trucking companies, challenged the amended ordinance, arguing it was preempted by federal law, and sought a preliminary injunction to halt its enforcement.The United States District Court for the District of Colorado granted a preliminary injunction against the amended ordinance, finding the Association was likely to succeed on the merits and would suffer irreparable harm. However, the court declined to enjoin the original ordinance, reasoning that the Association had not demonstrated irreparable injury, particularly given its delay in bringing suit after the original ordinance had been in effect for over a year. Both parties appealed: the town challenged the injunction against the amended ordinance, while the Association cross-appealed the denial of relief against the original ordinance.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s decisions. It held that the amended ordinance likely fell within the federal statutory safety exceptions, as it regulated with respect to motor vehicles and was genuinely responsive to safety concerns, based on legislative intent and a logical nexus to pedestrian safety. The court found the district court had erred in concluding the Association was likely to succeed on the merits and thus abused its discretion in granting the preliminary injunction. Regarding the original ordinance, the Tenth Circuit affirmed the district court’s denial of a preliminary injunction, holding that the Association’s delay in seeking relief undercut its claim of irreparable harm. The court reversed the injunction against the amended ordinance and remanded with instructions to dissolve it, while affirming the denial of relief as to the original ordinance. View "Colorado Motor v. Town of Vail" on Justia Law

The plaintiff purchased a life insurance policy for her son and consistently paid the required premiums. She alleges that the insurer failed to provide the statutory notices and protections mandated by California law before terminating her policy for nonpayment. After missing a payment in 2016, her policy lapsed, and following reinstatement, it was terminated again in 2018 after another missed payment. The plaintiff contends that the insurer’s failure to comply with statutory notice requirements rendered the termination ineffective and that her experience was representative of many other policyholders in California.The United States District Court for the Eastern District of California granted in part the plaintiff’s motion for class certification. The court found that the prerequisites of Federal Rule of Civil Procedure 23(a) were met and certified a class under Rule 23(b)(2) for declaratory and injunctive relief. The certified class included all policy owners or beneficiaries whose policies lapsed for nonpayment without the required statutory notice. The court appointed the plaintiff as class representative but denied, without prejudice, certification for monetary relief under Rule 23(b)(3).The United States Court of Appeals for the Ninth Circuit reviewed the district court’s class-certification order. Relying on its intervening decision in Small v. Allianz Life Insurance Co. of North America, the Ninth Circuit held that to recover for violations of the relevant California statutes, plaintiffs must show not only a statutory violation but also that the violation caused them harm. The court found that the plaintiff was not an adequate class representative for beneficiaries and that her claims were not typical of class members who intentionally allowed their policies to lapse. The Ninth Circuit reversed the district court’s class-certification order and remanded the case for further proceedings. View "Farley v. Lincoln Benefit Life Co." on Justia Law

After failing to pay property taxes on her home in Maricopa County, Arizona, the plaintiff’s tax liens were sold to a private entity, which later foreclosed on the property. The plaintiff did not respond to the foreclosure action, resulting in a default judgment that extinguished her rights to the property. The property was then deeded to the private purchaser, who transferred it to another private party. The plaintiff subsequently challenged the foreclosure, the retention of surplus equity from the sale, and the constitutionality of the Arizona statute that allowed private parties to enforce tax liens without providing just compensation.The United States District Court for the District of Arizona dismissed the plaintiff’s claims, finding that the Rooker-Feldman doctrine deprived it of subject matter jurisdiction. The court reasoned that the plaintiff’s injuries stemmed from the state court’s foreclosure judgment, which had already extinguished her property rights, and thus her federal claims amounted to an impermissible appeal of a state court decision. The court also dismissed her state law claims, except for one over which it declined supplemental jurisdiction.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed in part and reversed in part. The Ninth Circuit held that the Rooker-Feldman doctrine barred the plaintiff’s claims that directly attacked the state court foreclosure judgment, such as those alleging the foreclosure was an unconstitutional taking or excessive fine. However, the court held that claims challenging the defendants’ post-judgment retention of surplus equity were not barred, in light of the Supreme Court’s decision in Tyler v. Hennepin County, which recognized a property owner’s right to excess equity after a tax foreclosure. The court also found that the plaintiff’s facial challenge to the statute was not barred by Rooker-Feldman but was moot due to legislative amendments. The case was remanded for further proceedings on the surviving claims. View "SEARLE V. ALLEN" on Justia Law

A family leased a home within military housing at the Naval Amphibious Base Coronado in California. Shortly after moving in, they experienced persistent water intrusion and mold contamination, which they alleged damaged their property and affected their health. The family reported these issues to the property manager and the public-private entity responsible for the housing, but claimed that remediation efforts were inadequate and that their concerns were dismissed. After further testing confirmed hazardous mold, the family vacated the property and brought state law claims, including negligence and breach of contract, against the property manager, the public-private housing entity, and a mold remediation company.The defendants removed the case from California state court to the United States District Court for the Southern District of California, asserting federal enclave, federal officer, and federal agency jurisdiction. The district court denied the defendants’ motion to dismiss based on derivative sovereign immunity and, after further proceedings, found that it lacked subject matter jurisdiction on all asserted grounds. Specifically, the court determined there was no evidence that the United States had accepted exclusive jurisdiction over the property, that the defendants failed to show a causal nexus between their actions and federal direction, and that the public-private entity was not a federal agency. The district court remanded the case to state court.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the remand order under an exception allowing appellate review when federal officer removal is asserted. The Ninth Circuit held that the district court correctly found no federal enclave jurisdiction because there was no evidence of federal acceptance of exclusive jurisdiction over the property. The court also held that the defendants did not meet the requirements for federal officer or agency jurisdiction. The Ninth Circuit affirmed the district court’s remand to state court. View "CHILDS V. SAN DIEGO FAMILY HOUSING, LLC" on Justia Law

A teacher at a public charter school in Utah was terminated after a series of events involving a student and the student's parent. The teacher, a former Air Force veteran, reprimanded the student for disruptive behavior, leading the student to quit the team and report the incident to his father. The parent, dissatisfied with the teacher's conduct, began raising concerns about the teacher's alleged inappropriate behavior, including claims of physical and verbal abuse, to school administrators and at a school board meeting. The parent also communicated these concerns to the school superintendent and, according to the teacher, made a report to local police. Investigations by both the police and the Division of Child and Family Services found no evidence of abuse, and the teacher was ultimately terminated without a stated reason.The teacher filed suit in the Third District Court, Salt Lake County, alleging defamation, intentional infliction of emotional distress (IIED), abuse of process, and tortious interference with economic relations. The parent moved for early dismissal under Utah’s Uniform Public Expression Protection Act (UPEPA), arguing the statute protected his speech and actions. The district court denied the motion, finding UPEPA inapplicable and concluding that the teacher had stated prima facie cases for all claims.On direct appeal, the Supreme Court of the State of Utah held that the district court erred in finding UPEPA did not apply, as the parent’s statements concerned a matter of public concern. The Supreme Court also found that the teacher failed to state prima facie cases for IIED and abuse of process, requiring dismissal of those claims. The court vacated the denial of the special motion as to defamation and tortious interference, remanding for further consideration of whether the teacher could establish a prima facie case, particularly regarding privilege. The court ordered costs and fees related to the motion be awarded as provided by UPEPA. View "Mackey v. Krause" on Justia Law

In 2021, a plaintiff filed a complaint against a public school district, alleging that she was repeatedly sexually assaulted by a teacher while attending middle and high school. The complaint asserted that the teacher’s abusive conduct was widely known within the school and that the district either knew or should have known about the abuse but failed to act, allowing the teacher to remain employed. The plaintiff brought claims for negligence and negligent hiring, retention, and supervision, relying on statutory provisions that exempt certain childhood sexual assault claims from the usual requirement to present a claim to the public entity before filing suit.The Superior Court of Los Angeles County reviewed the case after the school district moved for judgment on the pleadings. The district argued that the plaintiff’s claims were only possible due to Assembly Bill 218 (AB 218), which retroactively eliminated the claims presentation requirement for childhood sexual assault claims against public entities. The district contended that AB 218 violated the gift clause of the California Constitution by imposing liability for past acts where no enforceable claim previously existed. The trial court agreed, finding that AB 218 retroactively created liability and constituted an unconstitutional gift of public funds, and dismissed the complaint with prejudice.The California Court of Appeal, Second Appellate District, Division One, reviewed the trial court’s decision de novo. The appellate court held that AB 218 does not violate the gift clause because it did not create new substantive liability; rather, it removed a procedural barrier to enforcing pre-existing liability for negligence and negligent hiring, retention, and supervision. The court reversed the trial court’s order and remanded with directions to deny the school district’s motion for judgment on the pleadings. View "O.B. v. L.A. Unified School Dist." on Justia Law

Two business compliance companies entered into a partnership to develop a software product, with one company providing “white-label” services to the other. The partnership was formalized in a written agreement, but disputes arose over performance, payment for out-of-scope work, and the functionality of the software integration. As the relationship deteriorated, the company that had sought the services began developing its own infrastructure, ultimately terminating the partnership and launching a competing product. The service provider alleged that its trade secrets and proprietary information were misappropriated in the process.The United States District Court for the Eastern District of Pennsylvania presided over a jury trial in which the service provider brought claims for breach of contract, trade secret misappropriation under both state and federal law, and unfair competition. The jury found in favor of the service provider, awarding compensatory and punitive damages across the claims. The jury specifically found that six of eight alleged trade secrets were misappropriated. The defendant company filed post-trial motions for judgment as a matter of law, a new trial, and remittitur, arguing insufficient evidence, improper expert testimony, and duplicative damages. The District Court denied these motions.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s rulings. The Third Circuit held that the defendant had forfeited its argument regarding the protectability of the trade secrets by not raising it with sufficient specificity at trial, and thus assumed protectability for purposes of appeal. The court found sufficient evidence supported the jury’s finding of misappropriation by use, and that the verdict was not against the weight of the evidence. The court also found no reversible error in the admission of expert testimony. However, the Third Circuit determined that the damages awarded for trade secret misappropriation and unfair competition were duplicative, and conditionally remanded for remittitur of $11,068,044, allowing the plaintiff to accept the reduced award or seek a new trial on damages. View "Harbor Business Compliance Corp v. Firstbase IO Inc" on Justia Law

Dr. Padma Rao brought a defamation suit against JP Morgan Chase Bank and its employee, Keifer Krause, after Krause informed the administrator of her late mother’s estate that Rao, acting under a power of attorney, had designated herself as the payable on death (POD) beneficiary of her mother’s accounts. This statement led the estate administrator to accuse Rao of fraud and breach of fiduciary duty in probate court. The dispute centered on whether Rao had improperly used her authority to benefit herself, which would be illegal under Illinois law.The case was initially filed in Illinois state court, but Chase removed it to the United States District Court for the Northern District of Illinois before any defendant was served, invoking “snap removal.” The district court dismissed all claims except for defamation per se. On summary judgment, the court ruled in favor of the defendants, finding that Krause’s statements were not defamatory, could be innocently construed, and were protected by qualified privilege. Rao appealed both the dismissal of her consumer fraud claim and the grant of summary judgment on her defamation claim.The United States Court of Appeals for the Seventh Circuit first addressed jurisdiction, dismissing Krause as a party to preserve diversity jurisdiction. The court affirmed the dismissal of Rao’s consumer fraud claim, finding she had not alleged unauthorized disclosure of personal information. However, it reversed the summary judgment on the defamation per se claim against Chase, holding that Krause’s statements could not be innocently construed and that a qualified privilege did not apply, given evidence of possible recklessness. The case was remanded for a jury to determine whether the statements were understood as defamatory. View "Padma Rao v J.P. Morgan Chase Bank, N.A." on Justia Law