Justia Civil Procedure Opinion Summaries

Donna Christensen, a twenty-year-old inmate at Vilas County Jail, died by suicide after twenty-five days in confinement. She had a history of substance abuse and mental illness and had previously reported suicidal thoughts and hallucinations. During her incarceration, she exhibited withdrawal symptoms and had an altercation with jail staff, leading to her placement on suicide watch. Despite her initial suicidal ideations, she was removed from suicide watch after a brief assessment by a social worker. She was later placed in solitary confinement, where she remained until her death.The Christensens, Donna's parents, sued Vilas County, the jail's medical service provider, and various employees, alleging that Donna's death resulted from inadequate medical treatment, excessive force, and due process violations. The United States District Court for the Western District of Wisconsin granted summary judgment in favor of the defendants, ruling against the Christensens. The court also denied the Christensens' requests to amend their complaint and extend deadlines for additional discovery.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the Christensens failed to present sufficient evidence to establish that the defendants were deliberately indifferent to Donna's serious medical condition under the Eighth Amendment. The court found no genuine dispute of material fact regarding the defendants' conduct and concluded that no reasonable jury could find in favor of the Christensens. The court also upheld the district court's denial of the Christensens' motions for additional discovery and to amend their complaint, finding no abuse of discretion in the lower court's case management decisions. View "Christensen v Weiss" on Justia Law

In 2011, Deutsche Bank filed a breach-of-contract action against Walter M. Potenza and Carmela Natale, alleging default on a promissory note and loan modification agreement. Deutsche Bank obtained a judgment for $1,662,837.12 in 2017. In 2021, the plaintiffs filed an independent action in equity, claiming Deutsche Bank committed fraud on the court by falsely asserting it was the holder of the note, despite knowing the note had not been properly endorsed.The Superior Court granted Deutsche Bank's motion for judgment on the pleadings, finding no credible evidence of fraud and determining that the plaintiffs' failure to obtain the deposition earlier was due to their attorneys' negligence. The plaintiffs appealed this decision.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's decision. The Court held that the plaintiffs could not establish all the elements required for relief under Rule 60(b). Specifically, the plaintiffs admitted Deutsche Bank was the holder of the note in their 2011 answer and did not present evidence or seek a continuance during the 2017 summary judgment hearing. The Court concluded that the plaintiffs' failure to challenge the validity of the note or the knowledge of Deutsche Bank's affiant precluded them from obtaining relief. The judgment in favor of Deutsche Bank was affirmed, and the case was remanded to the Superior Court. View "Potenza v. Deutsche Bank National Trust Company" on Justia Law

Absolute Pediatric Therapy, owned by Anthony Christopher, hired LaDonna Humphrey in May 2018 but terminated her four months later. In October 2018, Absolute and Christopher sued Humphrey in Arkansas state court, alleging various tort claims and accusing her of stealing information and making false accusations. Humphrey counterclaimed under the False Claims Act, alleging her termination was for reporting illegal activities. The litigation was contentious, and in August 2019, the state court found Humphrey in contempt and liable on all counts, awarding $3.57 million in damages to the plaintiffs.Following the state court's decision, Humphrey filed for Chapter 7 bankruptcy in September 2019. The Trustee of her bankruptcy estate proposed selling her claims, including her counterclaim and defensive appellate rights, to Absolute for $12,500. Humphrey objected to the sale of her defensive appellate rights. The bankruptcy court approved the sale, finding it reasonable and negotiated at arm's length. Humphrey did not obtain a stay of the sale but did secure a stay of the state court appeal.Humphrey appealed the bankruptcy court's order to the United States District Court for the Western District of Arkansas, which reversed the bankruptcy court's decision. The district court held that defensive appellate rights are not property of the estate under Arkansas law and found the sale not in the best interest of the estate. The district court also rejected the argument that the appeal was moot under 11 U.S.C. § 363(m) because Humphrey had obtained a stay of the state court proceedings.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the absence of a stay of the sale itself rendered the appeal statutorily moot under 11 U.S.C. § 363(m). The court vacated the district court's order and dismissed Humphrey's appeal from the bankruptcy court. View "Humphrey v. Christopher" on Justia Law

Deborah A. Chatfield filed for divorce from Frederick H. Chatfield Jr. on July 14, 2021. Frederick initially had legal representation, but his attorney withdrew in December 2021, leaving him to represent himself. A final hearing was held on August 23, 2024, which Frederick did not attend. The court granted the divorce and classified certain real estate in Rockport as marital property, ordering its sale. Frederick did not appeal the divorce judgment or request further findings of fact.Frederick later retained counsel and filed a motion for relief from judgment under M.R. Civ. P. 60(b), arguing that the property was nonmarital, the court lacked jurisdiction, and Deborah's belief that the property was marital was a mistake. The District Court (Rockland) denied the motion, finding that Frederick had not protected his interests during the original proceedings and had not provided justification for his absence. The court also found no credible evidence to support Frederick's claims.The Estate of Frederick H. Chatfield Jr. appealed the denial to the Maine Supreme Judicial Court. The court reviewed the denial for abuse of discretion, considering whether the lower court's findings were supported by the record, whether the court understood the applicable law, and whether the court's decisions were reasonable. The Supreme Judicial Court affirmed the lower court's decision, finding no abuse of discretion or clear error. The court noted that Frederick failed to protect his interests by not attending the hearing, not filing for further findings, and not appealing the original judgment. The court also found that the lower court had jurisdiction over the property and that Frederick did not meet the burden of proof required for relief under Rule 60(b). View "Chatfield v. Estate of Chatfield" on Justia Law

Everett Robinson was transferred to Canton Harbor Healthcare Center, a skilled nursing facility, for follow-up care after a stroke. During his stay, he developed pressure ulcers, which allegedly worsened after his transfer to other facilities, leading to his death. Felicia Robinson, his widow, and his surviving children filed a complaint against Canton Harbor, alleging negligence in allowing the pressure ulcers to develop and worsen, causing his wrongful death. They submitted a certificate of a qualified expert, signed by registered nurse Anjanette Jones-Singh, attesting that Canton Harbor breached the standard of care, causing the pressure ulcers.The Circuit Court for Baltimore City dismissed the complaint, ruling that as a registered nurse, Jones-Singh was not qualified to attest to the proximate cause of Robinson's pressure ulcers. The Robinsons appealed, and the Appellate Court of Maryland vacated the dismissal, holding that a registered nurse is not disqualified per se from attesting that a breach of nursing standards proximately caused pressure ulcers. The case was remanded for further proceedings.The Supreme Court of Maryland affirmed the Appellate Court's judgment. The court held that a registered nurse may attest in a certificate that a breach of nursing care standards at a skilled nursing facility proximately caused a pressure ulcer, provided the nurse relies on a pre-existing diagnosis and does not make a medical diagnosis. The court also held that a registered nurse meets the peer-to-peer requirement to attest to breaches of nursing care standards but not to the standards applicable to physicians. The case was allowed to proceed based on the certificate provided by Nurse Jones-Singh. View "Canton Harbor Healthcare v. Robinson" on Justia Law

The New Jersey Coalition of Automotive Retailers (NJCAR), a trade association representing franchised new car and truck retailers in New Jersey, sued Ford Motor Company. NJCAR alleged that Ford's Lincoln Commitment Program (LCP) violated the Franchise Practices Act (FPA) by creating price differentials among franchisees. NJCAR is not a franchisee itself but represents franchisee members, including Lincoln dealerships.The trial court granted summary judgment in favor of Ford, ruling that NJCAR lacked statutory standing to sue under the FPA because the statute limits the right to sue to franchisees. NJCAR appealed, arguing that it had associational standing to represent its members. The Appellate Division reversed the trial court's decision, holding that NJCAR had associational standing and that New Jersey's liberal standing doctrine did not preclude NJCAR from bringing the suit.The Supreme Court of New Jersey reviewed the case and reversed the Appellate Division's decision. The Court held that the FPA explicitly limits the right to bring a lawsuit to franchisees, as indicated by the statute's language stating that "any franchisee may bring an action against its franchisor." The Court emphasized that the Legislature's intent was clear in restricting the right to sue to franchisees only, and NJCAR, not being a franchisee, lacked statutory standing to bring the suit under the FPA. The Court did not address whether NJCAR would have associational standing under a different cause of action, limiting its holding solely to the FPA. View "New Jersey Coalition of Automotive Retailers, Inc. v. Ford Motor Company" on Justia Law

In 2020, the Maryland General Assembly passed the Housing Opportunities Made Equal (HOME) Act, which added "source of income" to the list of prohibited considerations in housing rental or sale. The appellant, a housing voucher recipient, applied to rent an apartment in the appellee's complex. The appellee applied a minimum-income requirement, combining all sources of income to determine if the total exceeded 2.5 times the full gross rent. The appellant's combined income, including her voucher, did not meet this threshold, leading to the rejection of her application. The appellant sued, claiming the minimum-income requirement constituted source-of-income discrimination under § 20-705.The Circuit Court for Baltimore County granted summary judgment to the appellee, finding that the appellee's policy did not discriminate based on the source of income but rather on the amount of income. The court ruled that the appellee neutrally applied its income qualification criteria and rejected the appellant based on the amount of her income, not its source.The Supreme Court of Maryland reviewed the case and held that the appellee's counting of voucher income in the same manner as other income sources did not entitle it to summary judgment. The court found that this approach did not resolve the appellant's disparate impact claim, which asserts that a facially neutral policy has a disparate impact on a protected group without a legitimate, nondiscriminatory reason. The court vacated the judgment of the circuit court and remanded the case for further proceedings consistent with its opinion, emphasizing the need to address the disparate impact analysis. View "Hare v. David S. Brown Enterprises" on Justia Law

Edward Snukis was stopped by Officers Matthew Taylor and Trevor Koontz after a report of an impaired man refusing to leave a parking lot. The encounter escalated when Snukis resisted commands and struck Officer Koontz. Officer Taylor tased Snukis twice, and both officers pinned him to the ground, with Taylor striking Snukis in the head six times. After securing Snukis in handcuffs, the officers noticed he had lost consciousness and provided emergency assistance, but Snukis died later that evening. Snukis’s children, as co-administrators of his estate, sued the officers and the City of Evansville under 42 U.S.C. § 1983.The United States District Court for the Southern District of Indiana granted summary judgment in favor of the defendants. The estate appealed the decision, focusing on claims against the officers for excessive force, failure to intervene, and failure to render medical aid.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court held that the officers' use of force was reasonable given Snukis’s resistance and the threat he posed. The court found that Officer Taylor’s use of the taser and subsequent strikes were justified due to Snukis’s active resistance. The court also determined that the officers provided prompt and appropriate medical care once Snukis lost consciousness. Consequently, the court affirmed the district court’s grant of summary judgment in favor of the officers. View "Snukis v. Taylor" on Justia Law

A stockholder of Amazon.com, Inc. sent a letter to the company demanding to inspect its books and records under Section 220 of the Delaware General Corporation Law. The stockholder aimed to investigate potential wrongdoing and mismanagement by Amazon, believing the company engaged in anticompetitive activities in the U.S. and Europe. When the stockholder and Amazon could not agree on certain conditions for producing the records, the stockholder filed an action in the Court of Chancery.A Magistrate in Chancery conducted a one-day trial and concluded that the stockholder did not meet its burden to prove a "credible basis" for inferring possible wrongdoing by Amazon. The stockholder took exceptions to the final report. A Vice Chancellor adopted the final report's conclusion but did not reach its credible basis analysis, instead finding the scope of the stockholder's stated purpose to be "facially improper" and not "lucid."On appeal, the Supreme Court of the State of Delaware found that the Vice Chancellor erred in interpreting the scope of the stockholder's purpose and was required to engage with the evidence presented. The court determined that the evidence, including a complaint filed by the Federal Trade Commission against Amazon for alleged antitrust violations that largely survived a motion to dismiss, established a credible basis from which a court could infer possible wrongdoing by Amazon. The Supreme Court reversed the judgment of the Court of Chancery and remanded for further proceedings to determine the scope and conditions of production consistent with its decision. View "Roberta Ann K.W. Wong Leung Revocable Trust v. Amazon.com, Inc." on Justia Law

Christopher Pable, a software engineer with the Chicago Transit Authority (CTA), discovered a cybersecurity vulnerability in the BusTime system, which was developed by Clever Devices, Ltd. Pable reported the vulnerability to his supervisor, Mike Haynes, who tested it on another city's transit system. Clever Devices, which had a significant contract with the CTA, alerted the CTA about the incident, leading to the termination of Pable and Haynes. Pable then sued the CTA and Clever Devices under the National Transit Systems Security Act, alleging retaliation for whistleblowing.The United States District Court for the Northern District of Illinois dismissed Pable's complaint during the discovery phase, citing the deletion of evidence and misconduct by Pable's attorney, Timothy Duffy. The court also imposed monetary sanctions on both Pable and Duffy. The court found that Pable and Duffy had failed to preserve relevant electronically stored information (ESI) and had made misrepresentations during the discovery process.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court did not abuse its discretion in dismissing Pable's complaint under Federal Rule of Civil Procedure 37(e) due to the intentional spoliation of evidence. The court also upheld the monetary sanctions imposed under Rule 37(e), Rule 37(a)(5), and 28 U.S.C. § 1927, finding that Duffy's conduct unreasonably and vexatiously multiplied the proceedings. The appellate court declined to impose additional sanctions on appeal, concluding that the appeal was substantially justified. View "Christopher Pable v CTA" on Justia Law