Justia Civil Procedure Opinion Summaries

Plaintiff Tidrick purchased a vehicle from FCA US LLC (FCA) and experienced transmission issues, leading her to request FCA repurchase the vehicle under the Song-Beverly Consumer Warranty Act. FCA initially declined, prompting Tidrick to file a lawsuit in Orange County Superior Court. The parties eventually settled, with FCA agreeing to repurchase the vehicle, pay restitution, and cover attorney fees and costs. Tidrick sought $82,719.33 in attorney fees and costs, but the trial court awarded her only $15,000, a significant reduction.The Orange County Superior Court, where the case was initially filed, awarded Tidrick $15,000 in attorney fees and costs, applying hourly rates prevailing in Fresno County, where Tidrick resided and purchased the vehicle. The court justified this by referencing Code of Civil Procedure section 395, subdivision (b), which it interpreted as mandating venue in Fresno County. The court also criticized the number of hours billed and the lack of a settlement agreement copy, suggesting the litigation was unnecessarily prolonged.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. It held that the trial court erred in applying Fresno County rates instead of Orange County rates, as venue was proper in Orange County where FCA's principal place of business is located. The appellate court also found that the trial court abused its discretion by not properly applying the lodestar method to calculate attorney fees and failing to specify the amount of costs awarded. The appellate court reversed the trial court's award and remanded the case with directions to recalculate the attorney fees using Orange County rates and to clarify the costs awarded. View "Tidrick v. FCA US LLC" on Justia Law

CPI Security Systems, Inc. filed a lawsuit against Vivint Smart Home, Inc., alleging that Vivint engaged in deceptive practices to lure away CPI’s customers. Vivint sales representatives falsely claimed that Vivint had acquired CPI, that CPI was going out of business, or that Vivint needed to upgrade CPI’s equipment. These tactics led many CPI customers to switch to Vivint, causing significant losses for CPI. A jury found Vivint liable for violating the Lanham Act, the North Carolina Unfair and Deceptive Trade Practices Act (UDTPA), and for committing the common-law torts of unfair competition and tortious interference with contracts. The jury awarded CPI $49.7 million in compensatory damages and $140 million in punitive damages.The United States District Court for the Western District of North Carolina upheld the jury’s verdict. Vivint appealed, raising several issues, including the requirement of CPI’s reliance on false statements for the UDTPA claim, the sufficiency of evidence supporting the damages award, the application of North Carolina’s cap on punitive damages, and the admission of prejudicial evidence.The United States Court of Appeals for the Fourth Circuit reviewed the case and found no reversible error. The court held that CPI was not required to prove its own reliance on Vivint’s false statements to establish a UDTPA claim, as the claim was based on unfair competition rather than fraud. The court also found that the evidence presented by CPI was sufficient to support the jury’s damages award. Additionally, the court ruled that the district court correctly applied North Carolina’s cap on punitive damages by considering the total compensatory damages awarded. The court further held that the district court did not abuse its discretion in denying Vivint’s motion to bifurcate the trial or in its evidentiary rulings. The reassignment of the trial judge post-trial did not warrant a new trial. Consequently, the Fourth Circuit affirmed the district court’s judgment. View "CPI Security Systems, Inc. v. Vivint Smart Home, Inc." on Justia Law

Jane Doe attended high school in City View Independent School District from 2016 to 2020, where she was allegedly sexually abused by her teacher, Robert Morris. The abuse reportedly began when Doe was a fifteen-year-old freshman and continued until she graduated. Doe claims that she reported the abuse to school officials in 2018, but they threatened her with retaliation and did not report the abuse to law enforcement. In 2022, after public outcry over Morris being named coach of the year, Doe publicly stated her experiences, leading to further threats from school officials.Doe filed a lawsuit against City View ISD and several school officials in the United States District Court for the Northern District of Texas on April 4, 2023. The district court dismissed her second amended complaint with prejudice, concluding that her claims were barred by the statute of limitations. Doe appealed the dismissal of her Title IX claims, arguing that her claims were timely due to the continuing violation doctrine or equitable tolling.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Doe's Title IX claims were barred by the statute of limitations, as they accrued no later than May 2020 when she graduated. The court also found that Doe's arguments for equitable tolling and the continuing violation doctrine were unavailing. Additionally, the court determined that Doe could not convert her First Amendment retaliation claim, based on a 2022 letter from a school official, into a Title IX retaliation claim. The court concluded that the district court did not abuse its discretion in denying Doe leave to amend her complaint. View "Doe v. City View Independent School District" on Justia Law

Capital Video Corporation (CVC) obtained a judgment against Joseph A. Bevilacqua in 2002 for $178,000 plus interest. CVC requested and received an original execution in December 2002, which lapsed. In 2004, CVC obtained an alias execution, recorded it against property jointly owned by Bevilacqua and his wife, Donna Bevilacqua. In 2005, CVC obtained another alias execution, recorded it against another jointly owned property, and later partially discharged it. In 2020, CVC requested a replacement execution, which was issued and recorded against a property in North Providence. This property was later transferred to Donna Bevilacqua and then to her trust. In 2022, CVC obtained another pluries execution and scheduled a constable’s sale of the property. Donna Bevilacqua intervened, seeking to prevent the sale.The Superior Court invalidated the 2020 and 2022 pluries executions, finding that they were not issued within the six-year limitation period set by § 9-25-3. The court determined that the 2020 execution was not issued within six years of the 2005 alias execution and that the 2022 execution was invalid because it assumed the validity of the 2020 execution.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's decision. The Court held that the 2020 and 2022 pluries executions were invalid because they were not issued within the six-year period required by § 9-25-3. Additionally, CVC failed to properly apply for a replacement execution and did not provide proof that the 2005 alias execution was lost or destroyed. The Court concluded that the trial justice did not err in ordering the release and discharge of the 2020 and 2022 pluries executions. View "Capital Video Corp. v. Bevilacqua" on Justia Law

Ryan Vanicek was killed in a traffic accident when a tractor-trailer driven by Kenneth Kratt, on behalf of Sandair Corporation, collided with his pickup truck. Jessica Vanicek, Ryan's wife, filed a wrongful death and survival action against Kratt and Sandair. Lyman-Richey Corporation, Ryan's employer, intervened under Nebraska's worker's compensation statute. A magistrate judge struck Jessica's claim for punitive damages and denied her leave to amend her complaint. The district court later compelled a settlement over Jessica's objection and ordered the funds to be deposited without post-judgment interest.The United States District Court for the District of Nebraska initially referred the issue of punitive damages to a magistrate judge, who struck the claim, applying Nebraska law. The district court overruled Jessica's objection to this order. The district court also granted summary judgment to the defendants on the claims for negligent infliction of emotional distress and denied a motion for partial summary judgment on pre- and post-impact damages. The district court approved a $5 million settlement proposed by Lyman-Richey, finding it fair and reasonable based on expert reports and the defendants' insurance policy limits. Jessica appealed the denial of her motion to amend and the settlement approval.The United States Court of Appeals for the Eighth Circuit dismissed Jessica's appeal regarding the denial of her motion to amend for lack of jurisdiction, as she failed to object to the magistrate judge's order in the district court. The court affirmed the district court's approval of the settlement, finding no abuse of discretion in its evaluation of damages and the defendants' ability to satisfy the judgment. The court also upheld the district court's decision to deny post-judgment interest, concluding that Jessica was estopped from claiming it due to her attorney's dilatory conduct. View "Vanicek v. Lyman-Richey Corp." on Justia Law

Linda Martin filed a class action lawsuit against the FBI, alleging that the Notice of Seizure provided to property owners did not meet the Due Process requirements under the Fifth Amendment. The FBI had seized $40,200 from Martin's safe deposit box and issued a Notice of Seizure, which Martin claimed lacked specific legal or factual bases for the seizure, thus denying her a meaningful opportunity to respond. Martin sought declaratory and injunctive relief for herself and a proposed nationwide class of individuals who had received similar notices.The United States District Court for the District of Columbia dismissed Martin's individual claim as moot after the FBI returned her seized property. The court also dismissed the class action for failure to exhaust administrative remedies and for failure to state a plausible Due Process claim. The court found that Martin had an adequate opportunity to present her Due Process challenge during the administrative proceedings and that her claim was moot because the FBI had returned her property.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court affirmed the district court's dismissal of Martin's individual claim as moot, as the FBI had returned her property. The court also dismissed the appeal of the class certification judgment for lack of jurisdiction, noting that Martin had not challenged the denial of class certification in her appellate briefs. The court concluded that without a certified class, it lacked jurisdiction to review the district court's merits rulings on the Due Process and exhaustion claims. View "Martin v. FBI" on Justia Law

Eight citizens of Mali alleged that, as children, they were trafficked to Côte d’Ivoire and forced to work without pay on small, remote cocoa farms. After eventually returning to Mali, they brought a putative class action in the United States against seven major cocoa importers, claiming the companies violated the Trafficking Victims Protection Reauthorization Act (TVPRA) by knowingly benefiting from a supply chain that relied on forced child labor. The plaintiffs asserted that the importers orchestrated and controlled a cocoa supply chain “venture” and delayed meaningful action against child labor through their leadership of the World Cocoa Foundation.The United States District Court for the District of Columbia dismissed the complaint for lack of standing. The court found that the plaintiffs failed to connect the defendants to any specific cocoa plantations, including those where the plaintiffs had worked. The court concluded that the plaintiffs’ general, industry-wide allegations lacked the specificity required to establish causation under Article III of the Constitution. The plaintiffs appealed, and the United States Court of Appeals for the District of Columbia Circuit held the appeal in abeyance pending resolution of a similar case, Doe 1 v. Apple Inc.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiffs lacked Article III standing because they did not plausibly allege facts showing a causal connection between their forced labor and the importers’ conduct. Specifically, the complaint failed to allege that the importers sourced cocoa, directly or through intermediaries, from the specific farms where the plaintiffs worked. The court distinguished this case from Doe 1 v. Apple Inc., where plaintiffs had plausibly traced their injuries to the defendants’ suppliers. The dismissal was affirmed. View "Coubaly v. Cargill Incorporated" on Justia Law

Jonathan Yu filed a petition for a civil harassment restraining order against Lorain Pozniak-Rice on October 27, 2023, alleging harassment by Pozniak-Rice and her daughter following the end of his relationship with the daughter. Yu claimed that the harassment included phone calls, trespassing, threats, and false statements to authorities. The court issued a temporary restraining order and set a hearing date, requiring Yu to personally serve Pozniak-Rice with the petition and other documents.At the initial hearing on November 21, 2023, Yu reported unsuccessful attempts to serve Pozniak-Rice, leading the court to continue the hearing to December 19, 2023, and extend the temporary restraining order. Yu again failed to serve Pozniak-Rice personally and requested authorization for alternative service methods. The court granted this request based on a declaration from a service provider, allowing service by email and mail. Yu filed proofs of service indicating partial compliance with the court's order.Pozniak-Rice did not appear at the January 8, 2024, hearing, and the court granted Yu a five-year restraining order, finding clear and convincing evidence of harassment. Pozniak-Rice later filed a motion to set aside the restraining order, claiming she was never served, but the court denied the motion as procedurally defective.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case and found that substantial evidence did not support the trial court's finding that Yu made a diligent effort to personally serve Pozniak-Rice. The appellate court reversed the restraining order, reinstated the temporary restraining order, and directed the trial court to give Yu another opportunity to serve Pozniak-Rice and conduct further proceedings on the petition. The appeal from the order denying the motion to set aside the restraining order was dismissed as moot. View "Yu v. Pozniak-Rice" on Justia Law

In this case, the plaintiffs, David Boniface, Nissandère Martyr, and Juders Ysemé, brought claims against Jean Morose Viliena under the Torture Victim Protection Act (TVPA) for events that occurred in Haiti in 2007-08. The claims included the extrajudicial killing of Boniface's brother, Eclesiaste Boniface, the attempted extrajudicial killings of Martyr and Ysemé, and the torture of Martyr and Ysemé. The jury in the U.S. District Court for the District of Massachusetts found Viliena liable and awarded compensatory and punitive damages.Viliena appealed, challenging the findings of liability and the damages awards. He argued that federal courts lacked subject-matter jurisdiction and that Congress did not have the power to authorize causes of action under the TVPA for conduct occurring abroad between foreign nationals. He also contended that the TVPA does not provide for attempted extrajudicial killing and raised various specific challenges to the trial and damages awards.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed that it had subject-matter jurisdiction over the TVPA claims. However, it vacated the denial of the motion for reconsideration and remanded for the district court to address whether Congress had the power to provide any cause of action under the TVPA for conduct occurring outside the United States between foreign citizens. The court also agreed with Viliena that the TVPA does not provide a cause of action for attempted extrajudicial killing.The court found sufficient evidence to support the jury's findings of liability for the extrajudicial killing and torture claims. However, it determined that a new trial on damages was necessary due to the erroneous inclusion of the attempted extrajudicial killing claims. The case was remanded for further proceedings consistent with the opinion. View "Boniface v. Viliena" on Justia Law

The case involves a dispute between the former owner-operator of a professional baseball franchise in Puerto Rico and the league, its president, and other franchise owners. The plaintiffs allege that the defendants conspired to force the former owner to relinquish control of the franchise, violating the Sherman Act, a federal civil rights statute, and various Puerto Rico laws. The plaintiffs claim that the defendants' actions were in retaliation for the former owner's public criticism of the conditions at the team's stadium and his proposal to move the team to another municipality.The United States District Court for the District of Puerto Rico dismissed the plaintiffs' Sherman Act claims, citing the "business of baseball" exemption. The court also ruled that the plaintiffs' claims under Puerto Rico's antitrust and fair competition laws were preempted by federal law. Additionally, the court dismissed the plaintiffs' federal civil rights claim on res judicata grounds, based on a prior judgment from the Superior Court of San Juan. The court then declined to exercise supplemental jurisdiction over the remaining Puerto Rico law claim.The United States Court of Appeals for the First Circuit affirmed the dismissal of the Sherman Act claims, agreeing that the "business of baseball" exemption applied to the Puerto Rico professional baseball league. However, the court vacated the District Court's dismissal of the Puerto Rico antitrust and fair competition claims, finding that the District Court had incorrectly applied the Supremacy Clause. The court also reversed the dismissal of the federal civil rights claim, concluding that the District Court had misapplied the doctrine of res judicata. Consequently, the court reversed the dismissal of the remaining Puerto Rico law claim, as a federal claim remained in the case. View "Cangrejeros de Santurce Baseball Club, LLC v. Liga de Beisbol Profesional de Puerto Rico, Inc." on Justia Law