Justia Civil Procedure Opinion Summaries

Articles Posted in Civil Procedure
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In 2019, Navient Solutions, LLC, a student loan servicer, filed a civil action alleging that a group of lawyers, marketers, and debt-relief businesses conspired to defraud Navient out of millions of dollars in unpaid student debt. Navient claimed that the defendants lured student borrowers into filing sham lawsuits against Navient under the Telephone Consumer Protection Act (TCPA), which regulates abusive telemarketing practices. The case proceeded to trial, and a jury found in favor of Navient. However, the district court later granted the defendants' renewed motions for judgment as a matter of law, ruling that the TCPA suits were not sham litigation and setting aside the jury's verdicts.The United States District Court for the Eastern District of Virginia initially rejected the defendants' argument that their litigation activities were protected under the Noerr–Pennington doctrine, which safeguards the First Amendment right to petition the government. After the jury returned verdicts against each defendant, the district court vacated the verdicts, concluding that the TCPA litigation was not sham litigation and that Navient's damages were directly related to the TCPA litigation.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that the TCPA actions were not sham litigation and were protected under the Noerr–Pennington doctrine. The court found that the defendants' actions were based on a legitimate question of statutory interpretation regarding the definition of an automatic telephone dialing system (ATDS) under the TCPA. The court also noted that Navient had conceded the merits of the TCPA cases and had only sought damages related to the litigation costs. As a result, the court concluded that the defendants' petitioning activity was protected by the First Amendment, and the district court's judgment as a matter of law was appropriate. View "Navient Solutions, LLC v. Lohman" on Justia Law

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The case involves the Public Interest Legal Foundation (PILF) filing a two-count complaint against Jocelyn Benson, the Michigan Secretary of State, alleging non-compliance with the National Voter Registration Act of 1993 (NVRA). PILF claimed that Michigan failed to conduct proper maintenance of voter registration lists by not removing deceased registrants and did not allow inspection of public records related to voter rolls. PILF's requests for records and subsequent correspondence with the Secretary of State's office did not yield the desired information, leading to the lawsuit.The United States District Court for the Western District of Michigan granted summary judgment in favor of Secretary Benson. The court found that Michigan's efforts to maintain voter registration lists, including using state and federal death records and collaborating with the Electronic Registration Information Center (ERIC), constituted a reasonable effort under the NVRA. The court also found that PILF's claim regarding the failure to allow inspection of records was moot.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's summary judgment, agreeing that Michigan's program for removing deceased registrants was reasonable under the NVRA. The court noted that the NVRA requires a reasonable effort, not a perfect one, and that Michigan's multi-layered approach met this standard. The court also found that PILF lacked standing to assert its claim regarding the inspection of records, as it failed to demonstrate concrete downstream consequences from the alleged NVRA violation.In conclusion, the Sixth Circuit affirmed the district court's judgment, holding that Michigan's efforts to maintain accurate voter registration lists were reasonable and that PILF did not have standing to pursue its claim regarding the inspection of records. View "Public Interest Legal Foundation v. Benson" on Justia Law

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Loretta Mauldin, an employee at the McAlester Army Ammunition Plant (MCAAP) since 1991, filed a lawsuit against the Secretary of the United States Department of the Army. Mauldin, who was born in 1958, claimed retaliation and discrimination based on age under the Age Discrimination in Employment Act (ADEA) and sex discrimination under Title VII of the Civil Rights Act. The case arose after Mauldin was not selected for a promotion to a Grade 9 Explosives Operator Supervisor position in 2018. She alleged that her non-selection was due to her age, sex, and prior Equal Employment Opportunity (EEO) activity, including supporting a co-worker's age discrimination complaint.The United States District Court for the Eastern District of Oklahoma granted summary judgment in favor of the Army, dismissing Mauldin's claims. The court found that Mauldin failed to establish a prima facie case of retaliation and discrimination. It concluded that the Army provided legitimate, nondiscriminatory reasons for selecting another candidate, Scott Harkey, who performed better in the interview process. The court also determined that Mauldin did not provide sufficient evidence to show that the Army's reasons were pretextual.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court correctly considered the Army's evidence, including testimony from the interview panelists and Mauldin's supervisor, Buckner. The court found that Mauldin did not demonstrate a genuine issue of material fact regarding pretext. The court emphasized that the interview process was neutral and that Mauldin's lower interview scores were a legitimate reason for her non-selection. Consequently, the Tenth Circuit upheld the summary judgment in favor of the Army, concluding that Mauldin's claims of retaliation and discrimination were not supported by sufficient evidence. View "Mauldin v. Wormuth" on Justia Law

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An inmate at the Lebanon Correctional Institution filed a mandamus action against the Ohio Department of Rehabilitation and Correction (DRC) to compel the production of records in response to his public-records requests. He also sought statutory damages and court costs. The inmate requested a memorandum regarding "Legal Dockets," a ViaPath memorandum, and commissary receipts and price lists.The inmate initially sent his request for the "Legal Dockets" memorandum to the warden’s assistant, who asked for a ten-cent payment. The inmate claimed to have submitted the payment, but the assistant stated she never received it. The inmate later received the requested memorandum after filing the mandamus action. For the ViaPath memorandum, the inmate sent his request to the prison’s mailroom department, which directed him to the warden’s assistant. The inmate did not follow up with the assistant. Similarly, for the commissary receipts and price lists, the inmate sent his request to a commissary supervisor, who also directed him to the warden’s assistant, but the inmate did not follow up.The Supreme Court of Ohio reviewed the case. The court denied the writ as moot regarding the "Legal Dockets" memorandum since the inmate received it after filing the action. The court denied the writ for the other requests because the inmate failed to show a violation of the Public Records Act, as he did not direct his requests to the appropriate person responsible for public records. The court also denied the inmate’s requests for statutory damages and court costs, finding that the evidence was evenly balanced on whether the assistant received the payment for the "Legal Dockets" memorandum, and the inmate had filed an affidavit of indigency, meaning there were no costs to award. View "State ex rel. Clark v. Ohio Dept. of Rehab. & Corr." on Justia Law

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The case involves a dispute arising from alleged breaches of a partnership agreement between PNC Bank, N.A., Columbia Housing SLP Corporation (collectively, the "PNC Parties"), and Rene O. Campos, along with 2013 Travis Creek GP, LLC, as general partner. The partnership was formed to acquire, construct, develop, and operate an affordable housing apartment complex in Austin, Texas, with anticipated federal tax credits. A mechanic’s lien was placed on the property, leading to a default on the construction loan. The PNC Parties sought to remove the general partner and replace it with Columbia, resulting in a lawsuit.The PNC Parties filed the lawsuit in the United States District Court for the Western District of Texas, invoking diversity jurisdiction. The district court retained supplemental jurisdiction over the enforcement of the settlement agreement that resolved the 2017 lawsuit. In 2021, the Eureka Parties moved to re-open the case to enforce the settlement agreement, leading to competing motions to enforce. The district court severed the motions from the original lawsuit, creating a new case, and granted each motion in part, offsetting the balance owed. The Eureka Parties and the Partnership appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the parties failed to establish an independent jurisdictional basis for the severed motions. The court noted that severed claims must have an independent jurisdictional basis and that the record lacked sufficient evidence to establish diversity of citizenship. Consequently, the court remanded the case to the district court for the limited purpose of determining whether such jurisdiction exists. The panel retained jurisdiction over the limited remand. View "PNC Bank v. 2013 Travis Oak Creek" on Justia Law

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Maxwell Tillinghast, a 13-year-old student, collapsed from sudden cardiac arrest while jogging during a physical education class at Palms Middle School. Although the school had a defibrillator in the main office, the teachers were unaware of its presence. Despite being trained to use a defibrillator, the teachers could not utilize it, leading to Tillinghast's death. His father sued the Los Angeles Unified School District (LAUSD) and several employees, alleging negligence for failing to inform the teachers about the defibrillator.The Superior Court of Los Angeles County heard the case, where the jury focused on whether Tillinghast's latent heart defect would have been fatal even if the teachers had known about the defibrillator. The jury found the school district negligent and awarded Tillinghast's father $15 million in damages. The jury exonerated the school principal, Dr. Derek Moriuchi, from negligence.The LAUSD appealed to the Court of Appeal of the State of California, Second Appellate District, Division Eight, arguing that the trial court erred in giving a specific jury instruction (CACI No. 423) related to public entity liability for failure to perform a mandatory duty. The appellate court found that the school district had forfeited its objections to this instruction by not raising the issue during the trial. Additionally, the court noted that the school district had conceded mistakes were made regarding the defibrillator's availability and training.The Court of Appeal affirmed the judgment, holding that the evidence supported the jury's verdict and that the school district's failure to inform the teachers about the defibrillator constituted negligence. The court awarded costs to the respondent, Tillinghast's father. View "Tillinghast v. L.A. Unified School District" on Justia Law

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In January 2023, J.F., a 39-year-old woman with a history of substance abuse, began experiencing severe delusions and paranoia, believing her parents wanted to kill her and her children. After a series of incidents, including living in her car and being admitted to the St. Vincent Stress Center, J.F. was temporarily committed by a trial court for up to ninety days due to her mental illness and inability to keep herself safe.J.F. appealed the commitment, arguing insufficient evidence supported the order. The Court of Appeals dismissed her appeal as moot, stating it did not present a novel issue or particularized harmful consequence. J.F. then petitioned for transfer to the Indiana Supreme Court.The Indiana Supreme Court held that temporary commitment appeals are not moot upon expiration unless the appellee proves no collateral consequences exist. The court emphasized the significant liberty interests and lifelong collateral consequences involved in such commitments, warranting appellate review. The court found sufficient evidence to support J.F.'s commitment, noting her impaired reasoning, inability to function independently, and the danger she posed to herself. Consequently, the court affirmed the trial court's temporary commitment order. View "In re Commitment of J.F." on Justia Law

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Anthology, Inc. entered into a 10-year contract with Tarrant County College District (TCCD) in June 2022 to provide Enterprise Resource Planning products and services for approximately $42 million, plus annual fees. In October 2023, TCCD terminated the contract without cause, as permitted by the contract, but refused to pay the early termination fee and demanded a refund of about $1.7 million already paid. Anthology sued TCCD in the United States District Court for the Northern District of Texas, seeking a declaratory judgment and damages for breach of contract.TCCD moved to dismiss the case under Federal Rules 12(b)(1) and 12(b)(6), arguing four grounds: entitlement to immunity from suit under Texas law, state sovereign immunity, lack of diversity jurisdiction, and a statutory bar on recovering damages under Texas law. The district court granted TCCD’s Rule 12(b)(1) motion, dismissing Anthology’s claims without prejudice, based on TCCD’s entitlement to immunity from suit under Texas law, without addressing the other grounds for dismissal. Anthology appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the district court erred in its decision. The appellate court held that state-law immunity cannot limit the jurisdiction of federal courts, which is defined by the Constitution and Congress. Therefore, the district court should not have dismissed the case based on state-law immunity without first addressing the jurisdictional issues of state sovereign immunity and the absence of complete diversity. The Fifth Circuit vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Anthology v. Tarrant County College District" on Justia Law

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An executive at a litigation funding company, Signal, resigned to start a competing business and sought legal advice from Signal’s outside counsel, Sugar Felsenthal Grais & Helsinger LLP. Signal sued the law firm and several of its attorneys, alleging legal malpractice, breach of contract, breach of fiduciary duty, and fraud. The district court dismissed some claims and granted summary judgment in favor of the defendants on the remaining claims. Signal appealed these rulings.The United States District Court for the Northern District of Illinois dismissed Signal’s breach of fiduciary duty claim and part of its fraud claim, allowing the legal malpractice, breach of contract, and fraudulent misrepresentation claims to proceed. The court also struck Signal’s request for punitive damages. During discovery, the court denied Signal’s motion to compel production of a memorandum prepared by one of the defendants. The district court later granted summary judgment in favor of the defendants on all remaining claims.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court agreed that Signal failed to establish proximate cause and damages for its legal malpractice and breach of contract claims. The court also found that Signal waived its challenge to the summary judgment ruling on the fraudulent misrepresentation claim by not adequately addressing it on appeal. Additionally, the court upheld the district court’s decision to deny Signal’s motion to compel production of the memorandum, as Signal did not demonstrate that the document influenced the witness’s testimony. The appellate court concluded that the district court’s dismissal of the fraudulent concealment theory was harmless error and denied Signal’s motion to certify a question to the Illinois Supreme Court as moot. View "Signal Funding, LLC v Sugar Felsenthal Grais & Helsinger LLP" on Justia Law

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In November 2021, a school shooting occurred at Oxford High School in Michigan, resulting in the deaths of four students and injuries to several others. This event had a profound impact on the local community, leading some families to transfer their children to other schools. Plaintiff C.S., a third-grade student at Robert Kerr Elementary School in Durand, Michigan, wore a hat depicting an AR-15-style rifle and the phrase "COME AND TAKE IT" to school during a "Hat Day" event. School officials, concerned about the potential for disruption given the recent shooting and the presence of transfer students from Oxford, asked C.S. to remove the hat.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the defendants, the school officials, concluding that their actions were justified under the circumstances. The court found that the school officials reasonably forecasted a substantial disruption due to the hat's imagery and message, particularly considering the recent trauma experienced by some students.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the school officials did not violate C.S.'s First Amendment rights by asking her to remove the hat. The court emphasized the unique context of the recent school shooting and the young age of the students, which justified the school officials' concerns about potential disruption. The court also found that the district court did not abuse its discretion in considering the defendants' untimely motion for summary judgment. View "C.S. v. McCrumb" on Justia Law