Justia Civil Procedure Opinion Summaries

Darian McKinney, a health and physical education teacher, was employed by the District of Columbia Public Schools (DCPS) for four years. During his tenure, he was investigated for sexual harassment, leading to a grievance he filed against DCPS. Both disputes were resolved through a Settlement Agreement, under which McKinney resigned but was allowed to reapply for teaching positions. However, when he reapplied, DCPS blocked his return, citing a failed background check.McKinney sued the District of Columbia, alleging that DCPS breached the Settlement Agreement by not fairly considering his employment applications and deprived him of property and liberty without due process. The United States District Court for the District of Columbia dismissed his complaint for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Settlement Agreement did not obligate DCPS to fairly consider McKinney’s applications, only to allow him to apply. The court found no basis in the contract’s language or law for McKinney’s demand for fair consideration. Additionally, the court ruled that McKinney did not have a constitutionally protected property interest in his original job, the contingent job offers, or his eligibility for DCPS positions. The court also found that McKinney’s claim of deprivation of liberty without due process was forfeited as it was not raised in the lower court.The court affirmed the district court’s dismissal of McKinney’s complaint. View "Darian McKinney v. DC" on Justia Law

Nancy Stark, as the legal guardian and mother of Jill Finley, an incapacitated person, filed a lawsuit against Reliance Standard Life Insurance Company. Finley, who suffered a hypoxic brain injury in 2007, was initially approved for long-term disability benefits by Reliance. However, in 2022, Reliance terminated her benefits, claiming recent testing did not support her total disability. Stark appealed, and Reliance reinstated the benefits in 2023. Stark then sued, seeking a surcharge for financial harm caused by the wrongful termination, claiming breach of fiduciary duty for not providing internal records, and contesting the deduction of social security payments from Finley's disability payments.The United States District Court for the Western District of Oklahoma granted Reliance's motion to dismiss under Rule 12(b)(6) for failure to state a claim. The court found that Stark did not plausibly allege a claim for equitable relief under ERISA, nor did she demonstrate that Reliance's actions violated the terms of the insurance policy or breached fiduciary duties.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that Stark was not entitled to attorney’s fees incurred during the administrative appeal under ERISA’s § 1132(a)(3) or § 1132(g). The court also found that Stark's claims regarding the SSD offset were time-barred and waived due to failure to exhaust administrative remedies. Additionally, the court concluded that Stark did not allege any concrete harm resulting from Reliance's alleged failure to provide requested records during the administrative appeal. Consequently, the Tenth Circuit affirmed the district court's decision to dismiss all of Stark's claims. View "Stark v. Reliance Standard Life Insurance Company" on Justia Law

The case involves a business dispute where ECB USA, Inc. and Atlantic Ventures Corp. (the buyers) sued Savencia Cheese USA, LLC and several individuals (the sellers) after a failed business deal. The buyers, who are foreign nationals, acquired Schratter Foods Incorporated, a Delaware corporation based in New Jersey, after the sellers allegedly misrepresented the company's corporate governance and financial health. The deal was negotiated primarily in France, but the buyers hired a Florida lawyer and moved the company to Florida post-closing.The United States District Court for the Southern District of Florida dismissed the claims against the sellers for lack of personal jurisdiction and dismissed the claims against Savencia Cheese for failure to state a claim. The buyers appealed these dismissals.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court lacked personal jurisdiction over the sellers because the buyers' use of a Florida lawyer did not establish sufficient contacts between the sellers and Florida. The court emphasized that due process requires more than a plaintiff's unilateral conduct to confer jurisdiction in a forum.Regarding the claims against Savencia Cheese, the appellate court agreed with the district court that the buyers failed to plead sufficient facts to state a claim. The court found that the buyers' allegations were conclusory and did not meet the required pleading standards for conspiracy, aiding and abetting breach of fiduciary duty, and tortious interference with a contract.In conclusion, the Eleventh Circuit affirmed the district court's dismissal of the claims against both the sellers and Savencia Cheese. View "ECB USA, Inc. v. Savencia Cheese USA, LLC" on Justia Law

Tammy Livingston, individually and as a beneficiary and co-trustee of the Livingston Music Interest Trust, sued her mother, Travilyn Livingston, over the termination of copyright assignments and associated royalties for songs authored by Jay Livingston. Jay had assigned his copyright interests in several songs to a music publishing company owned by Travilyn. Travilyn later invoked her statutory right to terminate these copyright grants and filed termination notices with the U.S. Copyright Office. Tammy challenged these terminations, claiming her rights as a beneficiary were affected.The United States District Court for the Middle District of Tennessee dismissed Tammy's complaint, holding that it failed to state a claim. Tammy appealed the decision, arguing that the termination notices were ineffective, defective, or invalid, and that she retained a state law right to receive royalties from the songs covered by the terminated agreements.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the 2003 California probate court order, which declared that the Family Trust held no ownership interests in Jay's copyrights, precluded Tammy's claims. The court also found that Jay had validly executed the copyright grants as an individual, not as a trustee, and that Travilyn owned Jay Livingston Music at the time of the assignments. Additionally, the court rejected Tammy's arguments regarding the termination notices' compliance with federal requirements, noting that she failed to plead specific factual allegations for most of the notices. Finally, the court held that Tammy did not identify a state law basis for her claim to royalties, thus failing to meet the pleading standards under Civil Rule 12(b)(6). View "Livingston v. Jay Livingston Music, Inc." on Justia Law

Lester Warren Martin, a renowned pediatric surgeon and successful investor, passed away in 2020, leaving behind a substantial estate. He had created a revocable trust in 1990, which was to be distributed equally among his five children. After one of his daughters, Sarah Stewart, passed away, her share was to be divided between her two children, Daniel Stewart and Rachel Kosoff. In 2018, Lester gave his son, David Martin, power of attorney and made him the trustee of the revocable trust. David distributed $13,930,000 from the trust, mostly to Lester’s four living children, with a smaller portion to Daniel and Rachel.The United States District Court for the Southern District of Ohio held that David breached his fiduciary duties by making distributions without specific written authorization from Lester, as required by the trust. The court granted summary judgment for the plaintiffs on liability and dismissed their remaining claims. A jury trial determined that David owed Daniel and Rachel $2,086,000 in damages. David later filed a motion for relief from judgment, arguing that the court lacked jurisdiction because the plaintiffs did not have a legal right to sue under Ohio law. The district court agreed and dismissed the case.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that Daniel and Rachel had Article III standing, as they alleged a concrete monetary injury traceable to David’s actions and redressable by the court. The appellate court vacated the district court’s order granting relief from judgment and remanded the case for the district court to rule on David’s Rule 50(b) motion for judgment as a matter of law regarding the necessity of expert testimony to prove damages. The appellate court affirmed the denial of David’s motion in limine to exclude the plaintiffs’ damages testimony. View "Stewart v. Martin" on Justia Law

Plaintiffs, representing a class of drivers, alleged that Progressive Specialty Insurance and Progressive Advanced Insurance systematically underestimated the actual cash value (ACV) of their totaled vehicles, thereby breaching their insurance agreements. The plaintiffs claimed that Progressive's method of calculating ACV, which included a "Projected Sold Adjustment" (PSA) to account for the fact that used cars often sell for less than their listed prices, was improper and resulted in underpayment.The United States District Court for the Eastern District of Pennsylvania certified two damages classes, finding that the plaintiffs' claims centered on the legitimacy of the PSAs and that this issue could be resolved on a class-wide basis. The court held that the plaintiffs had standing and rejected Progressive's arguments against commonality, predominance, superiority, and adequacy.The United States Court of Appeals for the Third Circuit reviewed the case and concluded that the District Court had abused its discretion in certifying the classes. The Third Circuit held that proving whether Progressive undercompensated each class member was an individual issue that could not be resolved on a class-wide basis. The court emphasized that the key issue was whether each class member received less than the true ACV of their vehicle, which would require individualized inquiries. As a result, the court found that common issues did not predominate over individual ones, and the District Court's certification of the classes was reversed and remanded for further proceedings. View "Drummond v. Progressive Specialty Insurance Co." on Justia Law

Ruben Santoyo, proceeding without counsel, filed a lawsuit under 42 U.S.C. § 1983 against the City of Chicago and two police officers, challenging the constitutionality of his arrest. Over three years, Santoyo repeatedly filed frivolous motions, many of which attacked the competence and integrity of the district judge. Despite numerous warnings from the judge that further frivolous filings would result in sanctions, Santoyo continued his behavior.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants and denied Santoyo's motions to vacate the judgment. While Santoyo's appeal of the denial was pending, the defendants moved to recover their costs. Instead of addressing the merits of this motion, Santoyo accused the defendants of bad faith and requested disciplinary action against their counsel. The district judge, having lost patience, granted the defendants' motion for costs, imposed a $1,500 sanction on Santoyo, and referred him to the district's Executive Committee, which barred future filings until the sanction was paid.The United States Court of Appeals for the Seventh Circuit reviewed the case. Santoyo argued that the district judge violated his due process rights by not notifying him of the sanction or giving him an opportunity to respond. The appellate court disagreed, noting that Santoyo had been warned multiple times about the consequences of further frivolous filings. The court held that the district judge provided sufficient notice and opportunity for Santoyo to respond, satisfying due process requirements. The Seventh Circuit affirmed the district court's imposition of sanctions. View "Santoyo v. City of Chicago" on Justia Law

Jose Cruz-Muniz and Sandra Cruz were injured in a car accident in 2018 and received treatment from C-Spine Orthopedics, PLLC. They assigned their rights to seek personal protection insurance (PIP) benefits from Progressive Michigan Insurance Company to C-Spine. C-Spine then assigned its accounts receivable, including the claims for unpaid benefits, to several factoring companies. Progressive argued that C-Spine lacked standing to seek payment because it had assigned its rights to the factoring companies. C-Spine countered with signed counter-assignments from the factoring companies, purportedly restoring its right to bring suits. The trial court initially denied Progressive's motion but later granted it, concluding that C-Spine lacked standing when the complaints were filed.In a separate case, Parie Wallace was injured in a bus accident and received treatment from several providers, including C-Spine. Wallace assigned her rights to seek PIP benefits to these providers. She later filed a lawsuit against Suburban Mobility Authority for Regional Transportation (SMART) seeking payment of PIP benefits. SMART argued that Wallace could not bring the action because she had assigned her rights to the providers. The trial court allowed Wallace to obtain revocations of the assignments, which she did, and then denied SMART's motion for summary disposition. The Court of Appeals reversed, holding that Wallace was not the real party in interest when she filed her complaint and that her claims were barred by the one-year-back rule.The Michigan Supreme Court held that both C-Spine and Wallace had standing to file their lawsuits but were not the real parties in interest at the time they filed suit because they had assigned their claims. The Court ruled that defects in real party in interest status could be cured after filing a lawsuit. In C-Spine's case, the Court of Appeals' judgment was affirmed on alternate grounds, and the case was remanded to the trial court for further proceedings. In Wallace's case, the Court of Appeals' judgment was affirmed in part, reversed in part, and vacated in part, and the case was remanded for the trial court to consider whether equitable rescission was warranted and whether the real party in interest defect could be cured. View "C-Spine Orthopedics PLLC v. Progressive Michigan Insurance Company" on Justia Law

C-Spine Orthopedics, PLLC, filed two actions in the Macomb Circuit Court against Progressive Michigan Insurance Company to recover personal protection insurance (PIP) benefits for care provided to Jose Cruz-Muniz and Sandra Cruz, who were injured in a 2018 car accident. Jose and Sandra assigned their rights to seek PIP benefits to C-Spine, which then assigned its accounts receivable, including these claims, to factoring companies. Progressive moved for summary disposition, arguing C-Spine lacked standing as it had assigned its rights. The trial court initially denied but later granted the motion, concluding C-Spine lacked standing when the complaints were filed. The Court of Appeals reversed, holding C-Spine retained its claims for PIP benefits under MCL 500.3112.Parie Wallace filed an action in the Wayne Circuit Court against Suburban Mobility Authority for Regional Transportation (SMART) seeking PIP benefits after being injured in a bus accident. Wallace assigned her rights to PIP benefits to her medical providers. SMART moved for summary disposition, arguing Wallace could not bring the action due to the assignments. The trial court allowed Wallace to obtain revocations of the assignments, which she did, and then denied SMART’s motion. The Court of Appeals reversed, holding Wallace was not the real party in interest when she filed her complaint and that her claims were barred by the one-year-back rule.The Michigan Supreme Court held that both C-Spine and Wallace had standing to file their lawsuits but were not real parties in interest at the time of filing due to their assignments. The Court ruled that defects in real party in interest status could be cured after filing. In C-Spine’s case, the Court of Appeals’ judgment was affirmed on alternate grounds, and the case was remanded to the trial court to consider whether C-Spine could cure the defect. In Wallace’s case, the Court of Appeals’ judgment was affirmed in part, reversed in part, and vacated in part, and the case was remanded for the trial court to consider whether equitable rescission was warranted and whether the real party in interest defect could be cured. View "Wallace v. Smart" on Justia Law

In 2008, the former Attorney General of Mississippi entered into a retention agreement with the Kilborn Firm to sue Entergy Corporation over electricity rates. The Kilborn Firm then agreed to split any compensation with Roedel Parsons, a Louisiana law firm. After years of litigation, the trial judge granted Entergy’s motion for summary judgment, dismissing the case with prejudice. The State did not appeal. Roedel Parsons then sued the State, claiming it was entitled to $34,625,000 as a third-party beneficiary under the retention agreement or, alternatively, for unjust enrichment and quantum meruit recovery.The Hinds County Circuit Court granted the State’s motion to dismiss under Mississippi Rule of Civil Procedure 12(b)(6) for failure to state a claim. The court found that Roedel Parsons was not a third-party beneficiary under the retention agreement, as the agreement specified that any associated attorneys would be at the Kilborn Firm’s expense and at no cost to the State. The court also found that Roedel Parsons failed to state a claim for unjust enrichment and quantum meruit recovery, as the State had no obligation to compensate Roedel Parsons under the terms of the agreement.The Supreme Court of Mississippi reviewed the case and affirmed the lower court’s decision. The court held that Roedel Parsons was not a third-party beneficiary under the retention agreement and had no standing to sue the State for breach of contract. The court also held that Roedel Parsons failed to state a claim for unjust enrichment and quantum meruit recovery, as the State had no reasonable expectation to compensate Roedel Parsons. The court further found that the common-fund doctrine did not apply, as Roedel Parsons failed to identify a specific fund or class of beneficiaries. View "Roedel Parsons Blache Fontana Piontek & Pisano v. State of Mississippi" on Justia Law