Justia Civil Procedure Opinion Summaries

A group of bondholders sought to recover principal payments owed on defaulted Argentine sovereign bonds. These investors had previously participated in Argentina’s Tax Credit Program, depositing their bonds with an Argentine trustee, Caja de Valores S.A., in exchange for certificates representing principal and interest. After the Republic failed to pay the principal at maturity, the bondholders initially sued in the United States District Court for the Southern District of New York. That court dismissed the case primarily on the ground that, under Argentine law, only the trustee had authority to sue on the bonds, and the Second Circuit affirmed. The bondholders then obtained authorization from an Argentine court to sue and filed a new complaint in New York.The district court again dismissed their claims, mainly for two reasons. First, it found all claims were barred by New York’s six-year statute of limitations for contract actions, holding that the state’s “savings statute” (N.Y. C.P.L.R. § 205(a)) did not apply because the prior dismissal was for lack of personal jurisdiction. It also concluded that tolling provisions in New York’s COVID-era executive orders did not apply absent an equitable showing. Second, the court held that collateral estoppel barred the bondholders from relitigating issues related to standing and jurisdiction previously decided.The United States Court of Appeals for the Second Circuit reviewed the case. It agreed that the savings statute did not apply but held that the COVID-era executive orders tolled the limitations period automatically, without any equitable showing. This made some claims timely (those on the AR16 Bonds) but not others (those on the GD65 Bonds). The Second Circuit further ruled that collateral estoppel did not preclude the bondholders from litigating whether they had authority to sue, and that—under Argentine law, with the new court authorization—they now had such authority. The judgment was affirmed in part, vacated in part, and remanded for further proceedings. View "Bugliotti v. The Republic of Argentina" on Justia Law

The plaintiffs purchased undeveloped property in Westerly, Rhode Island, in 1999. In 2007, they applied to the Rhode Island Department of Environmental Management (DEM) for permission to install an onsite wastewater treatment system (OWTS), a prerequisite for building a residence on their land. DEM denied their application because the groundwater table on the property was only five inches below the surface, while regulations required a minimum of twelve inches. The plaintiffs did not pursue an administrative appeal at that time.In 2020, more than a decade after the denial, the plaintiffs filed suit in Washington County Superior Court, seeking declaratory relief and compensation for an alleged regulatory taking under state and federal law. They also asserted that the regulation violated their rights to equal protection and due process. The state moved to dismiss the action, contending it was time-barred, the plaintiffs failed to exhaust administrative remedies, and they lacked standing. The Superior Court agreed, holding that the claims were barred by the statute of limitations, that administrative remedies had not been exhausted, and that the plaintiffs lacked standing. The court dismissed the case with prejudice.On appeal, the Supreme Court of Rhode Island reviewed whether the lower court’s dismissal was proper. The Court held that the three-year statute of limitations applied to all claims, and the continuing violation doctrine did not toll the limitations period because DEM’s denial of the permit was a discrete act, not a continuing violation. The Court further found the plaintiffs lacked standing for prospective relief because they did not allege an actual or imminent injury, as any future application might not necessarily be denied. The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. View "Majeika v. State of Rhode Island" on Justia Law

A judgment creditor, Green Belt Bank & Trust, sought to collect on a $2.6 million judgment against Mashon Van Mill and others. After initial efforts to collect failed, Green Belt initiated garnishment proceedings against Unverferth Manufacturing Company, alleging that Unverferth owed substantial sums to Mashon for services. Unverferth initially indicated payments were for Mashon’s personal services but later clarified that Mashon worked as an independent contractor, invoicing through “Hill Top Industries,” a name also connected to Mashon. The parties disputed whether funds paid to Hill Top Industries were subject to garnishment and, if so, whether statutory limits applied.The Iowa District Court for Butler County found that Hill Top Industries was not distinct from Mashon, so the funds paid by Unverferth were subject to garnishment. However, the court limited the garnishment amount to 10% of the total payments, applying the cap in Iowa Code section 642.21(1), which restricts garnishment of an employee’s earnings. Green Belt challenged this ruling, arguing that the cap did not apply because Mashon was not an employee, and appealed after the district court denied reconsideration.The Iowa Court of Appeals affirmed the district court’s application of the statutory limit, following its own prior precedent. On further review, the Supreme Court of Iowa held that the statutory garnishment limits in Iowa Code section 642.21(1) apply only to earnings of employees, not independent contractors. The Court reasoned that “employee” has a distinct legal meaning that excludes independent contractors and overruled contrary appellate precedent. The Supreme Court affirmed in part and vacated in part the decision of the Court of Appeals, and reversed in part the district court’s judgment, remanding for entry of a judgment without application of the statutory garnishment cap. View "Green Belt Bank & Trust v. Van Mill" on Justia Law

In the fall of 2025, federal immigration authorities increased enforcement activities in Chicago through “Operation Midway Blitz,” prompting protests near an Immigration and Customs Enforcement (ICE) detention center in Broadview, Illinois. Protesters and journalists alleged that federal officers from ICE, Customs and Border Protection (CBP), and the Department of Homeland Security (DHS) violated their First and Fourth Amendment rights by deploying tear gas and other chemical agents without justification. The plaintiffs described instances of excessive force and sought injunctive relief to stop such practices.The United States District Court for the Northern District of Illinois issued a temporary restraining order and later a broad preliminary injunction that applied districtwide, enjoining all federal law enforcement officers and agencies from using certain crowd control tactics. The court also certified a plaintiff class and required ongoing compliance reporting from DHS officials. The government appealed the preliminary injunction, arguing it was overbroad and infringed on separation of powers principles. The United States Court of Appeals for the Seventh Circuit stayed the injunction, citing its expansive scope and concerns over standing.Subsequently, as the enforcement operation ended and no further constitutional violations were reported, the plaintiffs moved to dismiss the case. The district court dismissed the case without prejudice and decertified the class, contrary to the plaintiffs’ request for dismissal with prejudice. On appeal, the United States Court of Appeals for the Seventh Circuit found that extraordinary circumstances warranted vacating the district court’s preliminary injunction. The Seventh Circuit held that vacatur was appropriate because the case had become moot and to prevent the now-unreviewable injunction from producing adverse legal consequences in future litigation. The court vacated the injunction and dismissed the appeal. View "Chicago Headline Club v. Noem" on Justia Law

A married couple had a child in Las Vegas, Nevada. Shortly after the child’s birth, the mother and child traveled to Canada, initially intending a temporary visit for a funeral. Their stay in Canada was extended unexpectedly due to circumstances including a home repair in Nevada and temporary employment, but the mother continued regular communications with the father and intended to return. During the extended stay, the couple’s relationship deteriorated. The mother filed for custody in a Canadian court, and the father, also in Canada, initiated a Hague Convention proceeding seeking the child’s return to Nevada. The Canadian court determined that the child was a habitual resident of Canada and denied the return request. The father appealed unsuccessfully and participated in the Canadian custody proceedings, contesting jurisdiction.After the failed Hague petition, the father filed for divorce, child custody, and child support in Nevada’s Eighth Judicial District Court. That court denied his motions, determining it lacked jurisdiction since significant proceedings were already underway in Canada and concluding Nevada was not the child’s home state. The father appealed, arguing that the district court wrongly declined jurisdiction.The Supreme Court of Nevada reviewed the matter. It held that under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), the child’s absence from Nevada was temporary; thus, Nevada was the child’s home state for jurisdictional purposes when the custody action was filed. The Supreme Court of Nevada reversed the district court’s order, concluding that Nevada did have home state jurisdiction. However, due to the Canadian court’s pending custody proceedings and the Hague determination, the Nevada court should consider whether to defer jurisdiction to Canada. The Supreme Court of Nevada remanded the case for further proceedings, instructing the district court to attempt communication with the Canadian court and to allow briefing on the most appropriate forum before determining whether to decline jurisdiction. View "Gill v. Gill" on Justia Law

A business agreement was made in early 2020 for the rental of a yacht for an event. The agreement involved a payment of $18,280, which was to cover a deposit and a down payment toward the rental fee. The event was canceled due to the COVID-19 pandemic, and the party that made the payment requested a refund. The yacht provider did not return the funds. The party seeking the refund sued under several theories, including unjust enrichment and breach of contract.After mandatory arbitration resulted in an award for the plaintiff, the defendant requested a trial de novo, and the matter proceeded under Nevada’s Short Trial Program. A short trial judge rendered a proposed judgment in favor of the plaintiff. The defendant objected to this proposed judgment, but the short trial judge, after consulting with the Alternative Dispute Resolution Office, ruled on the objection and later denied the defendant’s NRCP 59 motion to alter or amend the judgment, or for a new trial. The district court then entered judgment in favor of the plaintiff, apparently approving the short trial judge’s proposed judgment.On appeal, the Supreme Court of Nevada considered whether a short trial judge has authority to adjudicate objections to a proposed judgment and post-judgment NRCP 59 motions. The court held that under the plain language of NSTR 3(d), only the district court—not a short trial judge—may review and adjudicate objections to proposed judgments and NRCP 59 motions. The court found that the short trial judge exceeded her authority by ruling on these matters. The Supreme Court of Nevada vacated the district court’s judgment and the short trial judge’s post-judgment orders, remanding the case to the district court for further proceedings consistent with its opinion. View "VEGAS AQUA, LLC VS. JUPITOR CORP." on Justia Law

An individual died from a heroin overdose while incarcerated in a county jail, after another inmate smuggled the drug into the facility and provided it to him. The jail had a known, ongoing issue with inmates smuggling drugs and evading searches, and the person who brought in the drugs had a history of such behavior but was not thoroughly searched. The decedent’s estate sued the county, alleging negligence for failing to prevent the smuggling and resultant death.The Superior Court denied the county’s motion for summary judgment, in which the county sought to invoke two statutory defenses: the felony bar defense (RCW 4.24.420) and the intoxication defense (RCW 5.40.060). The court certified the case for interlocutory review. The Washington Court of Appeals accepted review, focusing on whether the jailer’s special common law duty to protect inmates precluded the county from asserting these statutory defenses. The Court of Appeals concluded that the county could not invoke the statutory defenses, based on prior Washington Supreme Court decisions interpreting the jail’s special duty.The Supreme Court of the State of Washington reviewed the case. It held that the existence of the jailer’s special common law duty to protect incarcerated individuals does not preclude the county from raising the statutory felony and intoxication defenses enacted by the legislature. The court concluded that these statutes do not abrogate the jailer’s duty but create separate affirmative defenses that, if proven, bar liability. The court therefore reversed the Court of Appeals and remanded for further proceedings, holding that the county may assert both statutory defenses. View "Anderson v. Grant County" on Justia Law

Two individuals entered into a loan agreement and mortgage with a bank in Puerto Rico, using their home as collateral. After a decade, they faced financial difficulties and stopped making payments. The bank denied a request to modify the loan but proposed a short sale. The bank then initiated foreclosure proceedings in Puerto Rico’s Court of First Instance, resulting in a judgment against the borrowers. Multiple short sale offers were rejected until one was conditionally accepted, but the sale did not close in time and the home was foreclosed. Subsequently, the bank garnished funds from the borrowers, who then filed for Chapter 13 bankruptcy.The United States Bankruptcy Court for the District of Puerto Rico confirmed the borrowers’ Chapter 13 plan, noting their intent to pursue claims against the bank. The borrowers filed an adversary proceeding seeking damages and other relief. The bank moved to dismiss the adversary complaint, but the bankruptcy court denied this motion, allowing the case to proceed. The borrowers later filed a similar complaint in the United States District Court for the District of Puerto Rico and moved to withdraw the adversary proceeding to the district court. The district court denied the withdrawal as untimely and dismissed the separate federal case. After the borrowers completed their bankruptcy plan and received a discharge, the bankruptcy court dismissed the adversary proceeding for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the First Circuit held that the bankruptcy court erred in finding it automatically lost jurisdiction over the adversary proceeding post-discharge. The appellate court vacated and remanded the case for further proceedings, instructing the lower courts to reassess jurisdiction and properly address the borrowers’ motion for withdrawal and their jury trial request. View "Guallini-Indij v. Banco Popular de Puerto Rico" on Justia Law

A patient was hospitalized after contracting COVID-19 and, as his condition worsened, was transferred between several hospitals in Kentucky and Indiana. During his treatment, he was intubated, placed on a ventilator, and medically immobilized. While under this care, he developed a severe bed sore that progressed to necrotizing fasciitis. Despite ongoing treatment, he ultimately died, with his death certificate listing multiple causes including cardiopulmonary arrest and sepsis. His estate claimed that negligence in the treatment of the bed sore caused his death and filed a proposed medical malpractice complaint against more than eighty healthcare providers.The case began when the estate filed its complaint with the Indiana Department of Insurance, while a medical-review panel was being requested. Before the panel was constituted, the providers moved for summary judgment in Vanderburgh Superior Court, arguing they were immune from liability under Indiana’s Healthcare Immunity Act, Premises Immunity Act, and the federal PREP Act. The trial court granted summary judgment for the providers, finding that statutory immunity applied and that the court, not the medical-review panel, could decide the immunity issue. The estate appealed, and the Indiana Court of Appeals reversed, holding that the question of immunity required expert input from the medical-review panel, especially regarding causation.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ decision. It held that the trial court could make a preliminary determination on statutory immunity without waiting for a medical-review panel’s opinion, since the facts relating to the connection between the patient’s COVID-19 treatment and his injury were undisputed for summary judgment purposes. The court further held that the providers were immune from civil liability under both state and federal law, as the patient’s injuries arose from treatment provided in response to the COVID-19 emergency. The court affirmed summary judgment for the providers. View "Estate of Waggoner v. Anonymous Health System, Inc." on Justia Law

This case arises from multi-district litigation involving claims that certain aqueous film-forming foam products caused injuries, and that Illinois Union Insurance Company issued excess liability policies to BASF Corporation, which allegedly designed and sold components of those products. Plaintiffs, who originally filed their cases in Wisconsin state court, assert that Illinois Union is directly liable under Wisconsin law for BASF’s conduct. After removal to federal court, the cases were consolidated for pretrial proceedings in the United States District Court for the District of South Carolina under the multi-district litigation statute.The District Court for the District of South Carolina, managing the consolidated proceedings, had entered case management orders requiring motions either to be signed by lead counsel or, if not, to be preceded by a motion for leave of court. Illinois Union sought leave to file a motion to stay the proceedings against it pending arbitration, contending that its insurance policies required arbitration of the dispute. The district court denied Illinois Union’s motion for leave, first citing a failure to consult with lead counsel as required, but then acknowledging that consultation had ultimately occurred. The decisive reason for denial was that lead counsel did not consent to Illinois Union’s motion, and the district court ruled that, absent such consent, the motion could not be filed.The United States Court of Appeals for the Fourth Circuit reviewed the district court’s order. It held that, while district courts have broad discretion to manage multi-district litigation, they may not exercise this authority in a way that prevents a party from asserting its statutory right under the Federal Arbitration Act to seek a stay of litigation pending arbitration. Because the district court’s order effectively barred Illinois Union from filing its stay motion based on lack of lead counsel’s consent, the Fourth Circuit vacated the district court’s order and remanded for further proceedings. View "Bouvet v. Illinois Union Insurance Company" on Justia Law