Justia Civil Procedure Opinion Summaries

Petitioners sought review of the Federal Energy Regulatory Commission's (FERC) grant of an abandonment incentive to ITC Midwest, LLC (ITC). This incentive allows ITC to recover 100% of its prudently incurred costs if a planned transmission project is abandoned for reasons beyond its control. Petitioners, a group of organizations whose members purchase electricity, argued that ITC's ownership of the project was uncertain due to ongoing litigation challenging the Iowa Right of First Refusal statute.The Federal Energy Regulatory Commission approved ITC's request for the abandonment incentive, finding that the project met the necessary criteria, including enhancing reliability and reducing congestion. Petitioners filed a protest, which FERC rejected, stating that regulatory or litigation uncertainty does not preclude granting an abandonment incentive. Petitioners then sought rehearing, which FERC also denied, reiterating that the approval was consistent with its precedent.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court determined that petitioners lacked Article III standing because they failed to show imminent injury from FERC's orders. The court noted that petitioners' claims of potential future higher rates were speculative and not concrete or imminent. The court also found that petitioners' interest in the proper application of the law and potential collateral estoppel effects did not constitute a cognizable injury. Consequently, the court dismissed the petition for lack of jurisdiction. View "Industrial Energy Consumers of America v. FERC" on Justia Law

Mark Nelson, operating North Country Weatherization Technologies, provided ice removal services to Pine View First Addition Association, a Minnesota non-profit homeowners' association, in spring 2023. Pine View's property manager, a North Dakota LLC, contacted Nelson for urgent ice removal due to water damage. Nelson completed the work and invoiced Pine View, but payment was delayed, allegedly due to Pine View's attempt to have insurance cover the costs. Nelson filed a lawsuit in North Dakota for breach of contract and unjust enrichment, seeking $79,695 plus interest and attorney’s fees.The District Court of Cass County, East Central Judicial District, granted Pine View's motion to dismiss for lack of personal jurisdiction, concluding that North Dakota did not have jurisdiction over Pine View, as it is a Minnesota entity and the services were performed in Minnesota. The court also denied Pine View's motion for Rule 11 sanctions against Nelson and his attorney, as well as Nelson's request for prevailing party attorney’s fees.The Supreme Court of North Dakota reviewed the case and reversed the district court's decision. The Supreme Court held that North Dakota has specific personal jurisdiction over Pine View because Pine View, through its North Dakota-based property manager, initiated contact with Nelson for the ice removal services. The court found that Pine View's contacts with North Dakota were sufficient to satisfy the state's long-arm provision and due process requirements. The Supreme Court also determined that the district court abused its discretion in denying Nelson's request for prevailing party attorney’s fees under Rule 11(c)(2), as Pine View's motion for sanctions against Nelson violated Rule 11(c)(5)(A). The case was remanded for further proceedings and to determine the amount of attorney’s fees Nelson is owed. View "Nelson v. Pine View First Addition Association" on Justia Law

Jacob Hollingsworth filed for divorce from Katie Hollingsworth after nearly five years of marriage. They had one child and stipulated to a parenting plan, leaving the division of marital property, spousal support, and attorney’s fees as the issues for trial. Katie entered the marriage with significant debt and a house, while Jacob had a house, personal assets, and business interests. They kept separate finances except for a joint account for shared expenses. Jacob paid off much of Katie’s debt during the marriage.The District Court of Morton County, South Central Judicial District, heard testimony from both parties, two valuation experts, and Jacob’s father. The court awarded Jacob 92% and Katie 8% of the marital assets, denied Katie’s requests for spousal support and attorney’s fees, and allowed Jacob’s valuation expert to testify despite a late report disclosure. Katie appealed the decisions.The North Dakota Supreme Court reviewed the case. It upheld the district court’s decision to allow the expert testimony, noting that the court offered a continuance, which Katie declined. The court found no abuse of discretion in the district court’s handling of the late disclosure.The Supreme Court also affirmed the district court’s valuation and division of the marital estate, finding the valuations were within the range of evidence presented and the unequal distribution was justified by the parties’ financial contributions and spending habits. The court upheld the use of the agreed valuation date for assets and found no error in including interim order funds in the marital estate.The court found no clear error in denying spousal support, as both parties were capable of self-support. It also upheld the denial of attorney’s fees, noting Katie’s sufficient income and excessive spending habits. The district court’s judgment was affirmed in all respects. View "Hollingsworth v. Hollingsworth" on Justia Law

Michael Gifford, a beneficiary of the Operating Engineers 139 Health Benefit Fund, sought reimbursement for out-of-network medical expenses incurred during his treatment for a stroke and subsequent brain aneurysm surgery. The Fund denied the claim, stating the services were not provided in an emergency and were not medically necessary. Gifford's wife, Suzanne, appealed the decision, but the Fund upheld the denial after consulting two independent medical reviewers who concluded the surgery was not an emergency and not medically necessary.The United States District Court for the Eastern District of Wisconsin granted the Fund's motion for summary judgment, agreeing that the Fund's decision was not arbitrary and capricious. The court also granted the Fund's motion for a protective order, limiting discovery to the administrative record. The Estate of Michael Gifford, represented by Suzanne, appealed the decision, arguing that the Fund failed to conduct a full and fair review by not considering a surgical note from Dr. Ahuja, which was not included in the administrative record.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that the Fund's denial of benefits was not arbitrary and capricious, as the Fund reasonably relied on the independent medical reviewers' reports and the administrative record. The court also found that the Fund was not required to seek out additional information not provided by the claimant. Additionally, the court upheld the district court's grant of the protective order, finding no abuse of discretion in limiting discovery to the administrative record. The court concluded that the Fund provided a full and fair review of the claim, and the denial of benefits was reasonable. View "Estate of Gifford v Operating Engineers 139 Health Benefit Fund" on Justia Law

Alice Guan and her homeowners association (HOA), Ellingsworth Residential Community Association, Inc., were involved in a dispute after Guan failed to conform her yard to the HOA’s covenants. Ellingsworth sued Guan in state court, and Guan countersued for various state-law claims. The state court awarded Guan costs and fees, but before she could collect, Ellingsworth filed for subchapter V bankruptcy.In the Bankruptcy Court, Guan filed several motions, including objections to Ellingsworth’s subchapter V eligibility and reorganization plan, and a motion for relief from the automatic stay. The Bankruptcy Court overruled Guan’s objections, confirming Ellingsworth’s subchapter V status and reorganization plan, and denied her motion for relief from the stay. Guan appealed these decisions to the District Court.The District Court affirmed the Bankruptcy Court’s orders, finding that Ellingsworth was eligible for subchapter V as it was engaged in business activities, and that the reorganization plan was fair and equitable. The court also upheld the denial of Guan’s motion for relief from the stay, concluding that the Bankruptcy Court did not abuse its discretion and had jurisdiction over Guan’s claims.Guan also appealed the Bankruptcy Court’s denial of her motion to abstain from ruling on state law issues. The District Court dismissed this appeal for lack of jurisdiction, stating that the abstention order was not a final appealable order.The United States Court of Appeals for the Eleventh Circuit affirmed the District Court’s decisions on subchapter V eligibility, the reorganization plan, and the denial of stay relief. However, it vacated the dismissal of Guan’s abstention appeal, remanding it to the District Court for further consideration, as the denial of mandatory abstention is immediately appealable. View "Guan v. Ellingsworth Residential Community Association, Inc." on Justia Law

Robert Gallagher borrowed money from Santander Consumer USA to purchase a car. After making the final payment via electronic funds transfer, Santander, following its standard practice, waited 15 days before sending the car title. Missouri law requires lienholders to release their lien within five business days after receiving full payment, including electronic funds transfers, or pay liquidated damages. Gallagher filed a lawsuit in Missouri state court on behalf of a potential class of borrowers affected by Santander's 15-day policy.The case was removed to the United States District Court for the Eastern District of Missouri, which granted summary judgment in favor of Santander. Gallagher appealed the decision, seeking to reverse the summary judgment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on whether Gallagher had standing to bring the case in federal court, specifically whether he had suffered an injury-in-fact. The court determined that Gallagher had not identified a concrete harm resulting from the delay in receiving the car title. The court noted that a statutory violation alone is insufficient for standing; there must be a concrete harm related to the violation. Gallagher did not demonstrate any monetary harm, such as a failed sale or impaired credit rating, nor did he show any ongoing injury to his property rights.The Eighth Circuit concluded that Gallagher lacked standing because he did not suffer a concrete injury. As a result, the court vacated the district court's judgment and instructed the district court to remand the case to state court. View "Gallagher v. Santander Consumer USA, Inc." on Justia Law

While incarcerated at Woodborne Correctional Facility, Antonio Mallet sought medical care for urinary obstruction and painful urination, symptoms indicative of prostate cancer. Despite a cystoscopy revealing concerning results, prison doctors did not conduct further tests for prostate cancer, instead prescribing medication for a benign enlarged prostate. Mallet was released on parole in January 2019 and was diagnosed with late-stage prostate cancer in May 2021. He filed a lawsuit on February 25, 2022, against the State of New York, the New York State Department of Corrections and Community Supervision (DOCCS), its acting commissioner, and three medical providers, alleging deliberate indifference to his medical needs and other constitutional violations, as well as state law claims for malpractice and negligence.The United States District Court for the Southern District of New York dismissed Mallet’s constitutional claims as untimely, reasoning that the claims accrued by the time he was released from custody in January 2019, thus falling outside the three-year statute of limitations for Section 1983 claims in New York. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Second Circuit found it plausible that Mallet’s deliberate indifference claim had not accrued by February 25, 2019, making his complaint potentially timely. The court reversed the district court’s dismissal of the deliberate indifference claims against Dr. Makram and Dr. Stellato, finding them plausible, but affirmed the dismissal of the claim against Professor Ritaccio and the constitutional claims against New York State, DOCCS, and Annucci due to sovereign immunity. The court vacated the dismissal of the remaining constitutional claims and state law claims, remanding the case for further proceedings. View "Mallet v. New York State Department of Corrections and Community Supervision" on Justia Law

Deborah Jane Clapp, a Minneapolis homeowner and taxpayer, filed a declaratory judgment action against the Minneapolis Public Schools and its officials. Clapp challenged the constitutionality of racial and ethnic preference provisions in a collective bargaining agreement between the school district and its teachers' union. She sought to stop the school district from implementing and spending public money on these provisions, alleging they violated the Minnesota Constitution's Equal Protection Guarantee.The district court dismissed Clapp's complaint, ruling that she lacked standing and that her claims were not ripe. Clapp appealed, and the Minnesota Court of Appeals reversed the district court's decision, concluding that Clapp had taxpayer standing and that her claims were ripe for judicial review. The school district then petitioned for review by the Minnesota Supreme Court.The Minnesota Supreme Court reviewed the case and focused on the issue of taxpayer standing. The court held that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. In this case, the court found that the alleged unlawful disbursements were merely incidental to the central dispute, which was the constitutionality of the racial and ethnic preference provisions in the collective bargaining agreement. Therefore, Clapp lacked taxpayer standing to bring her claims. The court reversed the decision of the court of appeals, upholding the district court's dismissal of Clapp's complaint. View "Clapp vs. Sayles-Adams" on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely for payments going back five years under Kansas’s statute of limitations. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, interpreting the policy against Kansas City Life. The conversion claim was dismissed. A jury awarded over $5 million in damages, which was reduced to $908,075 due to the statute of limitations. Both parties appealed.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s class certification, finding that common questions of law and fact predominated. The court also upheld the application of Kansas law for both the conversion claim and the statute of limitations. The court agreed with the district court’s interpretation of the insurance policy, concluding that the cost of insurance should not include profits and expenses. The court found that the jury’s damages award was supported by reasonable evidence and did not warrant an increase.The Eighth Circuit affirmed the district court’s judgment, including the class certification, the application of Kansas law, the partial summary judgment in favor of Meek, and the damages award. View "Meek v. Kansas City Life Ins. Company" on Justia Law

Betty Callens, an 81-year-old woman, underwent left-hip-replacement surgery on September 23, 2019, at Grandview Medical Center. After her discharge on September 27, 2019, she was transferred to Brookdale Skilled Nursing Facility for rehabilitation. Callens alleged that she received poor nursing care at Brookdale, leading to a fall on October 3, 2019, which resulted in another fracture of her left hip and a fractured left femur. She was readmitted to Grandview for further surgeries and was later diagnosed with Clostridioides difficile. On October 15, 2019, Callens was transferred to St. Martin's for rehabilitation. On October 21, 2019, while being bathed by a nurse at St. Martin's, Callens alleged that the nurse applied excessive pressure to her healing hip, causing another dislocation.The Jefferson Circuit Court granted summary judgment in favor of St. Martin's, concluding that Callens failed to provide medical-expert testimony to establish a breach of the standard of care or causation of her injuries. Callens's motion to strike the affidavit of St. Martin's expert, Michael Britton, R.N., was denied. The court found that Britton was qualified as a similarly situated health-care provider.The Supreme Court of Alabama reviewed the case and affirmed the lower court's decision. The court held that Callens's case did not fall under the "layman" exception, which allows for the absence of expert testimony in cases where the lack of skill is apparent to a layperson. The court determined that the care provided to Callens involved complex medical procedures beyond the understanding of an average layperson, thus requiring expert testimony. The court also upheld the qualification of Britton as a similarly situated health-care provider, noting that he had provided hands-on care in the relevant field during the year preceding Callens's injuries. Consequently, the summary judgment in favor of St. Martin's was affirmed. View "Callens v. Episcopal Foundation of Jefferson County" on Justia Law