Justia Civil Procedure Opinion Summaries

Two individuals worked as delivery drivers for a transportation company for over a decade, primarily out of the company’s New Jersey terminal. Their work mainly involved picking up and delivering goods in New Jersey, with occasional deliveries in neighboring states. Each driver had a contract with the company that included a forum-selection clause requiring any disputes to be litigated in Memphis, Tennessee, and a choice-of-law clause providing that Tennessee law would govern any disputes. The company is incorporated in Delaware, headquartered in Illinois, and has operations nationwide, including in Tennessee, but neither the drivers nor the company’s relevant activities were based in Tennessee.The drivers filed a putative class action in the United States District Court for the District of New Jersey, alleging that the company violated New Jersey wage laws by withholding earnings and failing to pay overtime, among other claims. The case was transferred to the United States District Court for the Western District of Tennessee pursuant to the forum-selection clause. The company then moved to dismiss the complaint, arguing that the Tennessee choice-of-law provision applied and that Tennessee law did not recognize the claims brought under New Jersey statutes. The district court agreed, upheld the choice-of-law provision, and dismissed the case.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the enforceability of the choice-of-law provision under Tennessee’s choice-of-law rules. The court held that the contractual choice-of-law clause was unenforceable because there was no material connection between Tennessee and the transactions or parties. As a result, the Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. The court did not reach the question of whether Tennessee law was contrary to the fundamental policies of New Jersey. View "Andujar v. Hub Group Trucking, Inc." on Justia Law

In this case, a motorist was stopped by state troopers for traffic infractions. The troopers observed signs of intoxication, and after the motorist failed a field sobriety test, he refused to take a chemical breath test, even after being warned multiple times about the consequences. Following his refusal, the troopers completed and signed sworn reports documenting the events, and his driver's license was automatically suspended pending a Department of Motor Vehicles (DMV) hearing to determine if it should be revoked for refusing the chemical test.At the DMV hearing, which was postponed once when the troopers failed to appear, the motorist again properly subpoenaed both troopers for the rescheduled hearing. When the troopers did not attend the second hearing, the Administrative Law Judge (ALJ) acknowledged the validity of the subpoenas but proceeded with the hearing without further adjournment. The ALJ admitted the troopers’ sworn written reports and supporting depositions as evidence and, over the motorist’s objections, found that the elements required for license revocation were met. On administrative appeal, the DMV Appeals Board affirmed, and upon transfer, the Appellate Division confirmed the DMV’s decision, reasoning that the motorist had made a tactical choice not to seek judicial enforcement of the subpoenas or request another adjournment.The New York Court of Appeals reviewed the matter. The court held that when a motorist properly subpoenas officers in a DMV license revocation hearing and the officers fail to appear, due process does not require dismissal of the charge or exclusion of their written reports unless the motorist first seeks judicial enforcement of the subpoenas pursuant to CPLR 2308(b). As the motorist in this case did not pursue enforcement or request an adjournment to do so, his due process rights were not violated. The court affirmed the Appellate Division’s order. View "Monaghan v. Schroeder" on Justia Law

A woman was sexually abused by the defendant when she was fourteen years old, with the abuse occurring in 2009 or 2010. Years later, in 2018, she filed her first petition for a protective order under Pennsylvania’s Protection of Victims of Sexual Violence or Intimidation Act after learning that the defendant was attempting to locate her, contact her through mutual friends, and disrupt her marriage. The court granted a three-year protective order, which expired in January 2021. In June 2022, the woman unexpectedly encountered the defendant at a flea market, which caused her significant fear and anxiety. She subsequently filed a second petition for a protective order in August 2022.The Lebanon County Court of Common Pleas held a hearing and entered a new protective order in her favor, concluding that her right to relief under the Act accrued from the June 2022 encounter, not from the original abuse. The court rejected the defendant’s argument that her claim was barred by the Act’s six-year statute of limitations, reasoning that the statute began to run with the new act that placed her at continued risk. On appeal, a three-judge panel of the Superior Court reversed, holding that the statute of limitations began at the time of the original abuse, and thus the woman’s 2022 petition was untimely. The Superior Court reasoned that the cause of action accrued when the sexual violence occurred, not when a continued risk of harm later manifested.The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court's decision. The Court held that, consistent with general principles governing statutes of limitations, the six-year period begins to run from the date of the act or circumstance that demonstrates the plaintiff is at a continued risk of harm from the defendant, as this is when the cause of action accrues under the Act. The matter was remanded for further proceedings on the remaining issues. View "Weatherholtz v. McKelvey" on Justia Law

A passenger, after being injured in a hit-and-run rear-end collision while riding in a vehicle arranged through a rideshare application, sought damages for bodily injuries. The passenger alleged that the rideshare company, its subsidiary, and its insurer either provided or were required by law to provide uninsured motorist (UM) coverage, and that their rejection of such coverage violated Louisiana law.The action began in Louisiana state court, initially naming only the insurer as a defendant. The passenger later amended the complaint to add the rideshare company and its subsidiary, arguing that they were not permitted to reject UM coverage. With all defendants’ consent, the insurer removed the case to the United States District Court for the Eastern District of Louisiana, citing diversity jurisdiction. Multiple motions followed, including motions to dismiss by the rideshare entities and a motion for summary judgment by the insurer. The district court found that Louisiana statutes allow transportation network companies to reject UM coverage and that the defendants had properly done so. Accordingly, the district court dismissed all claims with prejudice and denied the passenger’s request to certify a question to the Louisiana Supreme Court.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the statutory interpretation de novo. The court concluded that Louisiana Revised Statute § 45:201.6 incorporates, by general reference, the provisions of § 22:1295, including the right to reject UM coverage. The court found support for this interpretation in state appellate decisions and statutory context. The Fifth Circuit affirmed the district court’s judgment and denied the motion to certify the question to the Louisiana Supreme Court. The holding is that transportation network companies in Louisiana may reject uninsured motorist coverage if they follow the procedures in § 22:1295. View "Guerrera v. United Financial Casualty Co." on Justia Law

Timothy Hale and Sonja Ringen constructed a storage building on their commercially zoned property in Laramie without first obtaining a building permit. When the City of Laramie discovered the construction, it issued a stop work order and a cease-and-desist letter. Despite these notices, Hale and Ringen continued building and subsequently applied for a permit, which the City denied due to deficiencies in the application. After further unsuccessful permit attempts and ongoing disputes over the City’s requirements—including requests for disassembly of the structure—the City sought and obtained a permanent injunction from the District Court of Albany County, restricting use of the building until permitting was complete and compliance was achieved.The District Court of Albany County conducted a bench trial in May 2022 and granted the City’s request for a permanent injunction. The court outlined a process for inspections, identification of code violations, and corrective actions, but continued conflict between the parties hindered progress. Multiple rounds of correspondence, inspections, and motions ensued, with the City insisting on structural disassembly and Hale/Ringen providing documentation to support their position. Hale and Ringen eventually moved to vacate the injunction, arguing it was no longer equitable given their efforts and the City’s refusal to issue a permit. The district court denied their motion, citing only the parties’ lack of agreement, and provided no substantive analysis of the evidence.On appeal, the Supreme Court of Wyoming determined that the district court abused its discretion by failing to consider the evidence and arguments presented before denying the motion to vacate or modify the injunction. The Supreme Court held that a court must exercise discretion and decide motions on their merits, rather than requiring agreement between adversarial parties. Consequently, the Supreme Court reversed the district court’s order and remanded the case for full consideration of Hale/Ringen’s motion in light of all relevant facts and equities. View "Hale v. City of Laramie" on Justia Law

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

A young child, Alice, made several allegations of sexual misconduct against her father over the course of multiple years, beginning in 2021. These allegations were investigated on several occasions by county departments of social services, but none found substantiating evidence, and some investigators suspected that Alice’s mother coached her to fabricate accusations. The parents, who never married, were engaged in an ongoing custody dispute. The Carteret County District Court ultimately awarded primary custody to Alice’s father, finding the mother’s denials of visitation willful and her testimony untruthful. Additional reports of abuse were made thereafter, including by Alice’s school counselor and a therapist. These led to further investigations and court actions, but again no evidence of abuse was substantiated.The District Court in Carteret County dismissed a subsequent juvenile petition alleging abuse, neglect, and dependency, relying on the doctrines of res judicata and collateral estoppel, finding the issues had already been litigated. The Court of Appeals vacated this order, holding that collateral estoppel precluded relitigation of the previously adjudicated abuse allegations but not new allegations arising after the prior custody and interference proceedings. The appellate court remanded for further proceedings on the new allegations.The Supreme Court of North Carolina reviewed the case to clarify the application of collateral estoppel. The Supreme Court held that collateral estoppel did not bar the Department of Social Services’ juvenile petition because the Department was neither a party nor in privity with a party to the prior child custody or interference proceedings. Additionally, the prior court findings did not “actually determine” the relevant abuse issues for collateral estoppel purposes. The Supreme Court reversed the decision of the Court of Appeals and remanded for further proceedings, also noting the Department’s conflict of interest in this matter. View "In re A.D.H" on Justia Law

The plaintiff owned a large tract of land in Cumberland County, North Carolina. In 1992 and 2006, the North Carolina Department of Transportation (NCDOT) filed official corridor maps under the Map Act, which imposed restrictions on portions of the plaintiff’s property, limiting development and affecting value. In 2002 and 2010, NCDOT initiated two direct condemnation actions to acquire parts of the plaintiff’s land—some of which overlapped with the previously restricted areas—resulting in two settlements and consent judgments. After the 2010 settlement, 28.041 acres of the plaintiff’s property remained subject to Map Act restrictions until the maps were repealed in 2016.Following the repeal and a 2016 North Carolina Supreme Court decision in Kirby v. North Carolina Department of Transportation, which held that Map Act restrictions constituted a taking, the plaintiff filed an inverse condemnation action in Cumberland County Superior Court in 2018. The plaintiff sought compensation specifically for the Map Act restrictions not addressed in prior settlements. The Superior Court dismissed some claims but allowed the action to proceed for the remaining 28.041 acres. The North Carolina Court of Appeals affirmed, holding that the plaintiff’s claims regarding the Map Act restrictions were not barred and could proceed as an independent interest not covered by the earlier condemnation actions.The Supreme Court of North Carolina reversed the Court of Appeals. It held that, under North Carolina’s eminent domain statutes, the plaintiff was required to raise claims related to the Map Act restrictions as part of the answer in NCDOT’s 2010 direct condemnation action, since those restrictions were pertinent to determining just compensation for the partial taking. Because the plaintiff failed to do so, he could not pursue a separate inverse condemnation claim for those restrictions under N.C.G.S. § 136-111. The Court’s disposition was to reverse the judgment of the Court of Appeals. View "Sanders v. N.C. Dep't of Transp" on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

A dispute arose from a business relationship between an individual and a contracting company, resulting in complex litigation in Texas. In 2012, the company sued the individual in Texas for fraud, and after a jury trial, a judgment was entered against the individual, awarding substantial compensatory and punitive damages, attorney fees, and interest. While the individual appealed the Texas judgment, the company initiated proceedings in Alabama to domesticate the Texas judgment under the Uniform Enforcement of Foreign Judgments Act. The Baldwin Circuit Clerk issued a certificate of judgment, and the individual unsuccessfully sought to stay enforcement of the domesticated judgment pending the Texas appeal.The Texas intermediate appellate court affirmed the judgment, but in April 2024, the Supreme Court of Texas reversed the judgment and remanded for determination of a settlement credit and entry of a new judgment. In November 2024, the individual filed a motion under Rule 60(b)(5), Alabama Rules of Civil Procedure, in Baldwin Circuit Court, seeking relief from the domesticated judgment on the basis that the underlying Texas judgment had been reversed. The circuit court denied the motion without a hearing, finding that Rule 60(b)(5) was not the appropriate procedural mechanism because it requires two separate judgments, and domestication does not create a second judgment independent of the foreign judgment.On appeal, the Supreme Court of Alabama reviewed whether the circuit court exceeded its discretion in denying relief. The court held that the circuit court did not abuse its discretion, finding that Rule 60(b)(5) does not apply to a domesticated foreign judgment based solely on the reversal of the underlying foreign judgment, and the individual failed to show entitlement to relief under any other subsection of Rule 60(b). The Supreme Court of Alabama affirmed the order of the circuit court. View "Shumate v. Berry Contracting L.P." on Justia Law