Justia Civil Procedure Opinion Summaries

A company serving as the project administrator for several partially income-restricted apartment complexes operated with the aim of providing affordable housing for middle-income tenants maintained constructive possession and control over the properties, which are owned by a local Joint Powers Authority (JPA) and thus exempt from ad valorem property taxation under the California Constitution. The company received significant fees and bond revenues from its administration of the complexes. The county assessor determined that the company’s exclusive control and financial benefits met the statutory criteria for a taxable “possessory interest,” and assessed property taxes accordingly. The company initially contested the tax assessments before the Orange County Assessment Appeals Board but filed a separate action for declaratory relief in superior court before the administrative proceedings concluded, seeking a declaration that neither it nor its tenants were liable for these taxes.The Superior Court of Orange County denied the county’s special motion to strike the complaint under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16), finding that the company’s declaratory relief claim did not arise from the county assessor’s protected activity under the statute’s first prong. The court did not reach the question of whether the company could show a likelihood of success on the merits under the statute’s second prong.The California Court of Appeal, Fourth Appellate District, Division Three, conducted a de novo review and held that the claim for declaratory relief did arise from the assessor’s protected speech, petitioning, and advocacy activities under section 425.16. The appellate court reversed the order denying the anti-SLAPP motion and remanded the matter with instructions for the trial court to determine whether the company can demonstrate a probability of prevailing on the merits under the second prong of the anti-SLAPP statute. View "Waterford Property Co. v. County of Orange" on Justia Law

Two Georgia voters, William T. Quinn and David Cross, independently analyzed Georgia’s voter registration list by comparing it with the United States Postal Service’s National Change of Address database. Believing they had found evidence that the Secretary of State was not properly maintaining the voter rolls as required by the National Voter Registration Act of 1993 (NVRA) and state law, they notified the Secretary, requesting that potentially ineligible voters be flagged and notified. When the Secretary did not respond, the plaintiffs filed suit, asserting that this alleged failure undermined their confidence in the election process and risked diluting their votes.The United States District Court for the Northern District of Georgia dismissed the case for lack of Article III standing. The district court found that the plaintiffs’ claimed injuries—undermined confidence in elections and risk of vote dilution—were generalized grievances common to all Georgia voters, not injuries particularized to the plaintiffs themselves. The court reasoned that any voter could express similar concerns based on the state’s alleged noncompliance with the NVRA, and that such concerns were too speculative to confer standing.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s dismissal. The Eleventh Circuit held that the plaintiffs’ alleged injuries were not particularized, as the supposed harm—loss of confidence in the electoral process—equally affected all Georgia voters. The court concluded that merely discovering or believing in government error, even after personal investigation, does not transform a generalized grievance into a particularized injury sufficient for federal court standing. Thus, the plaintiffs lacked standing, and the dismissal was affirmed. View "Quinn v. Secretary of State, State of Georgia" on Justia Law

A company providing paratransit and microtransit services under contract with a regional public transportation authority subcontracted another company to supply vehicles and drivers. After several months, the subcontractor terminated the agreement and brought suit against the transportation company and the authority, asserting claims including breach of contract, quantum meruit, tortious interference, fraud, and negligent misrepresentation. The fraud claim centered on alleged false representations made to induce the subcontract.The trial court (Texas District Court) ruled on a motion to dismiss under Texas Rule of Civil Procedure 91a, which allows dismissal if pleadings show no legal or factual basis for relief. The court dismissed the fraud and other tort claims against all defendants, as well as the breach of contract claim against the transportation authority and its primary contractor. It limited potential contract damages as to the contractor’s subsidiary and severed and abated remaining claims. The subcontractor appealed the dismissal of its claims against the main transportation company.The Court of Appeals for the Fifth District of Texas reversed in part, finding that the breach of contract and fraud claims against the main transportation company had a basis in law and that its statutory immunity under Texas Transportation Code § 452.056(d) was not conclusively established. The Supreme Court of Texas, reviewing only the fraud claim, held that the statutory immunity did apply. Because the pleadings showed the transportation company was contractually performing the authority’s function, and the authority itself would be immune from a fraud claim (an intentional tort), the company was likewise immune from liability for fraud. Accordingly, the Supreme Court of Texas reversed the Court of Appeals’ judgment and reinstated the trial court’s dismissal of the fraud claim. The case was remanded for further proceedings on any remaining claims. View "MV TRANSPORTATION, INC. v. GDS TRANSPORT, LLC" on Justia Law

A catastrophic storm in March 2016 caused unprecedented rainfall in the Sabine River basin, leading the operators of the Toledo Bend Dam—jointly managed by the Sabine River Authority of Texas and the Sabine River Authority, State of Louisiana—to open nine spillway gates. This action released significant amounts of water into the Sabine River over several weeks. Downriver landowners experienced extensive flooding and property damage. More than 700 landowners brought suit, alleging that the dam operators’ actions constituted a compensable taking of their property under the Fifth Amendment.The case began in the United States District Court for the Eastern District of Texas, where the defendants raised several defenses, including sovereign immunity, which was litigated and ultimately denied. Discovery disputes arose over the admissibility and timeliness of the plaintiffs’ expert affidavits and reports, which were found to rely heavily on an untested graduate thesis. The magistrate judge struck the challenged affidavits as untimely, and the plaintiffs did not object. Later, the district court granted summary judgment for the defendants, finding the plaintiffs had not produced sufficient admissible evidence to create a genuine dispute of material fact as to whether the dam’s operation caused the flooding, nor that a taking had occurred. The court also found the necessity doctrine might shield the defendants but did not decide the case on that ground.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the lower court’s decisions. It held that the district court did not abuse its discretion in excluding the untimely expert affidavits. Affirming summary judgment, the Fifth Circuit found that the plaintiffs had failed to present sufficient evidence of causation—specifically, that the dam’s operation, rather than the unprecedented storm itself, caused additional flooding beyond what would have occurred without the dam. The judgment of the district court was affirmed. View "Bonin v. Sabine River Authority" on Justia Law

Two plaintiffs obtained significant monetary judgments against a defendant, Deutsch, relating to a failed real estate project. Over the next several years, the plaintiffs attempted to enforce these judgments by seeking information about alleged fraudulent transfers from Deutsch to his wife, Baird, and their children. Multiple lawsuits and post-judgment discovery proceedings in Minnesota and New York courts ensued, including actions alleging Baird and her children received valuable assets as fraudulent conveyances. Repeated discovery efforts were largely unsuccessful, with courts in New York and during bankruptcy proceedings consistently finding no evidence justifying further inquiry into Baird’s finances. Despite these setbacks, the plaintiffs continued to pursue information about Baird’s assets, including through federal court subpoenas after a default judgment recognized the original state court awards.In the United States District Court for the District of Minnesota, a magistrate judge had previously limited discovery into Baird’s finances, explicitly stating that further discovery would only be permitted if the plaintiffs produced new evidence of fraudulent or voidable transactions. Ignoring this warning, the plaintiffs sought leave to depose their former counsel, the Scher Law Firm, regarding its prior investigations into the alleged fraudulent transfers. The magistrate judge denied the motion, finding that the requested discovery concerned Baird’s finances and that the plaintiffs had not presented any new evidence as required. The judge also imposed sanctions, ordering the plaintiffs to pay Baird’s costs and fees for responding to the motion, citing their willful disregard of court orders and ongoing harassment.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s decisions. The Eighth Circuit held that denying the motion for leave to depose the Scher Law Firm was not an abuse of discretion, as the plaintiffs failed to meet the court’s condition for further discovery. The appellate court also upheld the imposition of sanctions, finding the plaintiffs’ conduct justified penalties and that the district court acted within its inherent authority. View "Lupe Development Partners, LLC v. Baird" on Justia Law

A group of affiliated energy companies brought a civil case in North Dakota against several environmental organizations and individuals, alleging a coordinated campaign—sometimes involving unlawful acts—targeted at their pipeline operations. After six years of litigation, a three-week jury trial resulted in a unanimous verdict for the energy companies, awarding over $130 million in compensatory and exemplary damages against one defendant, Greenpeace International, and over $666 million against all Greenpeace entities combined. The jury found Greenpeace International liable for conspiracy, defamation, defamation per se, and tortious interference, but not for property-related torts.While the North Dakota case was pending, Greenpeace International initiated legal proceedings in the Netherlands, seeking relief under Dutch and European anti-SLAPP (Strategic Litigation Against Public Participation) laws. The Dutch action alleged, among other things, that the North Dakota suit was a SLAPP case and sought to declare it “manifestly unfounded,” potentially undermining the North Dakota verdict. The energy companies sought an antisuit injunction in North Dakota District Court to prevent Greenpeace International from proceeding with the Dutch litigation. The district court denied the motion, reasoning that the Dutch and North Dakota cases involved different issues because anti-SLAPP actions are not recognized under North Dakota law, and thus did not meet the threshold for an antisuit injunction. The district court also found that the Dutch action was not vexatious, did not threaten North Dakota policy, and did not implicate comity concerns.On review, the Supreme Court of North Dakota determined that the district court abused its discretion by misapplying the legal framework for antisuit injunctions. The Supreme Court held that the issues in both cases were substantially similar, as the Dutch action, as pleaded, would require relitigating questions already decided by the North Dakota jury. The Court adopted a “conservative” approach to comity, weighing respect for foreign tribunals against the need to protect the integrity of state proceedings. The Supreme Court granted the petition for a supervisory writ and remanded the case, directing the district court to enter a narrowly tailored antisuit injunction preventing Greenpeace International from pursuing any Dutch claims that would require a finding that the North Dakota case lacked legal foundation, while permitting claims based on matters not adjudicated in North Dakota. View "Energy Transfer v. Gion" on Justia Law

A group of pharmacy benefit managers and related companies, including both benefit managers and mail-order pharmacies, were sued by the State of Arkansas in state court. The State alleged that these companies contributed to the opioid epidemic by facilitating and encouraging the misuse, abuse, and over-prescription of opioids, particularly through their negotiations with drug manufacturers for placement of opioid drugs on insurance formularies in exchange for rebates and fees. The State’s complaint asserted claims for public nuisance, negligence, and unjust enrichment under state law, and included allegations that the companies prioritized profits from rebates over public health concerns.After being sued, the defendant companies removed the case to the United States District Court for the Eastern District of Arkansas, citing the federal officer removal statute, 28 U.S.C. § 1442(a)(1), as well as the general removal statute. They argued that their actions were taken under the direction of federal officers, particularly in their roles administering federal health care programs, such as those governed by the Federal Employees Health Benefits Act (FEHBA). The State moved to remand, asserting that the complaint disclaimed any claims against federal officers or persons acting under them. The district court found the disclaimers sufficient and remanded the case to state court.On appeal, the United States Court of Appeals for the Eighth Circuit held that removal was proper under the federal officer removal statute. The court concluded that the defendant companies acted under the direction of federal officers when administering federal health plans and negotiating drug rebates, and that these actions were sufficiently related to the claims in the complaint. The court determined that the State’s disclaimers could not sever the connection between the challenged conduct and federal duties, given the indivisibility of negotiations on behalf of both federal and private clients. The Eighth Circuit therefore reversed the district court’s remand order. View "Griffin v. OptumRx, Inc." on Justia Law

The case involves a dispute between an individual and two defendants whom he sued for breach of contract, fraud, intentional infliction of emotional distress, and defamation. After a bench trial, the trial court entered judgment in favor of the defendants on all claims. The plaintiff then filed multiple post-trial and post-judgment motions, alleging, among other things, that new evidence showed interference in the case by the Federal Bureau of Investigation. All of these motions were denied. Subsequently, the plaintiff filed several motions seeking to disqualify the presiding judge for alleged bias and misconduct, each of which was also denied.Following these filings, the trial court judge issued an order declaring the plaintiff a vexatious litigant and enjoining him from filing further pleadings without first obtaining the court’s permission. The plaintiff appealed, raising issues about the vexatious litigant order, the denial of his motions to disqualify the judge, and the completeness of the record on appeal.The Supreme Court of the State of Montana reviewed the case. It held that the trial court abused its discretion by declaring the plaintiff a vexatious litigant and issuing a pre-filing order without first providing notice and an opportunity to be heard. The court vacated the vexatious litigant order and remanded for further proceedings, requiring the trial court to allow the plaintiff a chance to be heard and then, if warranted, issue a substantive order with adequate analysis. The Supreme Court affirmed the denial of the plaintiff’s motions for judicial disqualification, finding the motions procedurally deficient, and concluded that the trial court transmitted a sufficient record on appeal. The judgment was affirmed in part, reversed in part, and remanded for further proceedings. View "Heaven v. Weber" on Justia Law

Robert Toothman was initially employed by Apex Life Sciences, LLC, a temporary employment agency, which placed him at Redwood Toxicology Laboratory, Inc. During his employment with Apex, Toothman signed an arbitration agreement that required him to arbitrate employment disputes with Apex and its defined affiliates, subsidiaries, and parent companies. In April 2018, Toothman’s employment with Apex ended, after which he was hired directly by Redwood and worked there until June 2022. Toothman and Redwood did not sign an arbitration agreement. Several months after leaving Redwood, Toothman filed a class action alleging Labor Code violations based solely on his direct employment with Redwood, not his prior period as an Apex employee.The Sonoma County Superior Court reviewed Redwood’s motion to compel arbitration and to dismiss the class claims. Redwood argued that it was either a party to the Apex arbitration agreement as an affiliate, a third-party beneficiary, or entitled to enforce the agreement under equitable estoppel. Redwood also claimed that Toothman’s class claims should be dismissed based on the arbitration agreement. The trial court denied Redwood’s motion, finding that Redwood was not a signatory to the arbitration agreement, was not an affiliate as defined by the agreement, and could not compel arbitration under any alternative theory.The California Court of Appeal, First Appellate District, Division Four, reviewed the trial court’s order de novo. It held that Redwood was not a party to the arbitration agreement and did not qualify as an affiliate or third-party beneficiary. The court further determined that Toothman’s claims were not sufficiently intertwined with the arbitration agreement to justify equitable estoppel. The appellate court affirmed the trial court’s order denying Redwood’s motion to compel arbitration and to dismiss the class claims. View "Toothman v. Redwood Toxicology Laboratory" on Justia Law

In June 2020, following the murder of George Floyd, protestors established the Capitol Hill Occupied Protest (CHOP), occupying a sixteen-block area in Seattle’s Capitol Hill neighborhood. In response, the Seattle Police Department abandoned its East Precinct and significantly reduced police presence in the affected area, including Cal Anderson Park. The protests and encampments continued to cause disruption, vandalism, and crime for months, with CHOP forcibly disbanded on July 1, 2020, but neighborhood disturbances persisting until December 2020. Two businesses located near Cal Anderson Park, one a restaurant and the other a property owner, claimed that the City’s actions and inaction led to severe economic losses, including lost revenue, property damage, and tenant departures.Previously, these businesses were absent putative class members in the Hunters Capital, LLC v. City of Seattle class action in the United States District Court for the Western District of Washington, which raised similar claims. After class certification was denied and the case settled, the businesses filed individual lawsuits in April and June 2023, consolidated in the district court. The district court dismissed the state-created danger and Takings Clause claims, and found their nuisance claims untimely under the applicable two-year statute of limitations, but did not initially decide on equitable tolling pending further guidance from the Washington Supreme Court. After the Campeau v. Yakima HMA, LLC decision, the district court dismissed the nuisance claims and entered final judgment.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the dismissal of the state-created danger and Takings Clause claims, holding that the state-created danger doctrine does not extend to purely economic harm and that the cessation of police services did not constitute a compensable taking. However, the appellate court reversed the dismissal of the nuisance claims, holding that equitable tolling under American Pipe is available under Washington law, and remanded for further proceedings on those claims. View "3PAK LLC V. CITY OF SEATTLE" on Justia Law