Justia Civil Procedure Opinion Summaries

M.C. arrived at the Sandra Eskenazi Mental Health Center exhibiting manic behavior. The center sought and obtained an emergency involuntary detention. Subsequently, they petitioned for a temporary commitment. During the hearing, Dr. Jayme Ahmed testified that M.C. had a prior schizophrenia diagnosis, exhibited delusional behavior, and refused medication. M.C. believed he needed to go to Washington, D.C., to broadcast a "state of emergency" and planned to call his father for bus fare. He also reported that his social security benefits had stopped. Dr. Ahmed expressed concern that M.C.'s fixation on Washington, D.C., and lack of stable income would impair his ability to provide for himself.The Marion Superior Court ordered M.C.'s temporary commitment, finding him gravely disabled. M.C. appealed, arguing insufficient evidence of his grave disability and that his case was not moot. The Indiana Court of Appeals dismissed the appeal as moot, stating M.C. failed to demonstrate particularized collateral consequences of his commitment.The Indiana Supreme Court reviewed the case, noting that their recent decision in J.F. v. St. Vincent Hosp. and Health Care Ctr., Inc. established that appeals of temporary commitment orders are not moot unless the appellee shows no collateral consequences. The Court found the Court of Appeals' decision conflicted with J.F. by declaring the appeal moot and improperly placing the burden on M.C. to show collateral consequences. The Indiana Supreme Court vacated the Court of Appeals' decision and affirmed the trial court's temporary commitment order, concluding that sufficient evidence supported M.C.'s commitment. View "In re Commitment of M.C." on Justia Law

In February 2022, a Minneapolis SWAT team executed a no-knock search warrant at an apartment in search of a murder suspect. Inside, they found Amir Locke, the suspect’s cousin, asleep on a couch. Upon entry, officers kicked the couch and commanded Locke to get on the ground. Locke, wrapped in a blanket, fell to the ground and reached for a nearby handgun. Officer Hanneman ordered Locke to show his hands. Locke began to comply by lowering the gun's barrel and raising his left hand, but before he could fully comply, Hanneman shot Locke three times, resulting in Locke's death.Karen Wells and Andre Locke, co-trustees for Locke’s next of kin, filed a lawsuit against Officer Hanneman and the City of Minneapolis under 42 U.S.C. § 1983 and Minnesota’s wrongful death statute. They claimed Hanneman violated Locke’s Fourth Amendment rights and that the City failed to properly train its officers and address unconstitutional practices. Hanneman moved for judgment on the pleadings, asserting qualified immunity, arguing that body camera footage showed Locke posed a threat. The District Court for the District of Minnesota denied the motion, finding the footage did not clearly contradict the complaint’s allegations.The United States Court of Appeals for the Eighth Circuit reviewed the case and determined it lacked jurisdiction to decide the appeal. The court found that the body camera footage did not blatantly contradict the district court’s assumed facts that Locke did not raise the gun in a threatening manner. Consequently, the court dismissed the appeal, stating it could not address Hanneman’s qualified immunity claim or the City’s municipal liability and state-law claims. View "Wells v. Hanneman" on Justia Law

Adam Steele and Krystal Comer, tax return preparers, challenged the IRS's requirement to obtain or renew a Preparer Tax Identification Number (PTIN) by completing Form W-12, which involves paying a fee and disclosing personal information. They initially joined a class action in 2014 contesting the IRS's authority to impose these fees and the amount of information required by Form W-12. However, class counsel later withdrew these claims. Steele and Comer then attempted to revive these claims in a separate lawsuit.The United States District Court for the District of Columbia dismissed their complaint, citing the rule against claim-splitting, which prevents duplicative litigation between the same parties asserting the same claims, even without a final judgment in the first case. The district court found that Steele and Comer had already raised and then withdrawn these claims in the ongoing class action and were denied leave to amend the complaint to reassert them.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the district court's dismissal. The appellate court held that the Paperwork Reduction Act (PRA) does not bar judicial review of the IRS's authority to demand information through Form W-12, but the rule against claim-splitting still precludes the plaintiffs' suit. The court emphasized that claim-splitting bars duplicative litigation filed before final judgment and that Steele and Comer had a fair opportunity to litigate their claims in the earlier class action. The court concluded that the district court's dismissal was proper to prevent strategic end runs around procedural rulings and to preserve the integrity of the adjudicative process. View "Steele v. United States" on Justia Law

Energy Transfer LP, involved in the Dakota Access Pipeline (DAPL) project, filed a lawsuit in North Dakota against Greenpeace International and others, alleging various tort claims related to the 2016 Standing Rock Protests. Unicorn Riot, a Minnesota-based news organization, and its journalist Niko Georgiades, who reported on the protests, were subpoenaed by Energy Transfer for documents and communications related to the protests. Unicorn Riot objected, citing the Minnesota Free Flow of Information Act (MFFIA), which protects newsgatherers from disclosing unpublished information.The Hennepin County District Court denied Energy Transfer's motion to compel Unicorn Riot to produce the requested documents but ordered Unicorn Riot to produce a privilege log. Both parties appealed. The Minnesota Court of Appeals affirmed the denial of the motion to compel but reversed the order requiring a privilege log, concluding that the MFFIA prohibits such an order.The Minnesota Supreme Court reviewed the case. It held that the MFFIA applies to newsgatherers even if they engage in unlawful or tortious conduct, as long as the conduct does not fall within the statutory exceptions of Minn. Stat. §§ 595.024–.025. The court also held that the MFFIA does not prevent district courts from ordering the production of a privilege log, but district courts should consider whether producing such a log would impose an undue burden on the responding party.The Minnesota Supreme Court affirmed the Court of Appeals' decision in part, reversed in part, and remanded the case to the district court to determine the appropriate scope of the privilege log, considering potential undue burdens. View "Energy Transfer LP v. Greenpeace International" on Justia Law

A bank holding company sued two guarantors for breach of their personal guaranties on a $1.5 million loan extended to an entity they were involved with. The guarantors argued that the bank holding company lacked standing to sue because there was no written assignment of the loan documents from the original lender, a bank, to the holding company. The district court admitted the written assignment into evidence and found that the holding company had standing. The court also granted summary judgment in favor of the holding company, finding the guarantors liable under the terms of their guaranties.The guarantors had counterclaimed against the holding company and other parties, alleging fraudulent concealment, fraudulent misrepresentation, civil conspiracy, and breach of the implied covenant of good faith and fair dealing. They argued that the bank and its president conspired with a now-deceased individual to conceal the financial instability of the individual’s entities, which led to the guarantors entering into the guaranties. The district court found no genuine issue of material fact regarding these counterclaims and granted summary judgment for the holding company.The guarantors also attempted to file a document in which the personal representative of the deceased individual’s estate confessed judgment against the estate. The district court ruled this filing a nullity, as the personal representative’s appointment had been terminated before the filing, and he was not authorized to act on behalf of the estate.The Nebraska Supreme Court affirmed the district court’s rulings, holding that the holding company had standing, the guarantors were liable under the guaranties, and the counterclaims were unsupported by evidence. The court also upheld the ruling that the purported confession of judgment was a nullity. View "Henderson State Co. v. Garrelts" on Justia Law

Stacy L. Jones and Joshua Colgrove were in a relationship and had a child, B.C. After their separation, Stacy moved to Lincoln, Nebraska, with B.C. and her other children. Joshua, who was diagnosed with Guillain-Barre syndrome, did not initially seek custody. Stacy was later convicted of felony child abuse and placed on probation, leading to juvenile court proceedings where B.C. was placed in foster care. Joshua's request for B.C.'s placement with him was denied due to his non-compliance with DHHS requests. The juvenile court eventually found Stacy rehabilitated and awarded her custody of B.C., issuing a bridge order transferring jurisdiction to the district court.The district court entered a custody decree consistent with the juvenile court's order. Joshua filed a petition for modification, and the State filed a complaint to establish child and medical support. The district court overruled Joshua's motion to dismiss the State's complaint and required him to pay child support. The court also issued an amended custody decree after the juvenile court corrected minor errors in its bridge order. Joshua's motions to reconsider and strike the amended orders were denied.The Nebraska Supreme Court reviewed the case and affirmed the district court's decision. The court found that the district court's findings, including Stacy's compliance with rehabilitative measures and her ability to protect B.C., were supported by evidence. The court also held that the State's intervention to establish child support was permissible under the relevant statutes. The court determined that the issue of the amended orders was moot and did not warrant further review. The court concluded that the district court did not abuse its discretion in awarding custody to Stacy, requiring Joshua to handle transportation for parenting time, and not awarding Joshua the child tax credit. View "Jones v. Colgrove" on Justia Law

In May 2018, Raynaldo Sampy Jr. was arrested by seven officers from the Lafayette Police Department after driving into an ice cooler. During the arrest, Sampy was forcibly removed from his vehicle, handcuffed, and bent over a police car. He kicked Officer Rabb while being restrained, leading to his conviction for battery of a police officer in Lafayette City Court. Sampy later filed a lawsuit under 42 U.S.C. § 1983, alleging excessive force by the officers and retaliation for his speech.The United States District Court for the Western District of Louisiana dismissed Sampy’s Fourth Amendment excessive force claim, Fourth Amendment bystander liability claim, and First Amendment retaliation claim under Heck v. Humphrey, which bars claims that would imply the invalidity of a conviction. The court did not dismiss a claim regarding a third instance of alleged excessive force, which went to trial, and the jury found for the defendants. Sampy appealed the dismissal of the initial two uses of force.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo. The court held that Sampy’s excessive force claims were barred by Heck because they were not temporally and conceptually distinct from his battery conviction. The court found that the facts in Sampy’s complaint were inconsistent with those adjudicated in the criminal case. The court also held that Sampy’s bystander liability and First Amendment retaliation claims were barred by Heck. Consequently, the Fifth Circuit affirmed the district court’s judgment. View "Sampy v. Rabb" on Justia Law

Clinton Mahoney, the sole member and manager of Mahoney & Associates, LLC, signed an agreement obligating the company to contribute to the Railroad Maintenance and Industrial Health and Welfare Fund, an employee benefit fund. When the Fund could not collect delinquent contributions from Mahoney & Associates, it sued Mahoney personally, citing a personal liability clause in the agreement. The district court granted summary judgment to the Fund, concluding that Mahoney was personally liable based on the clause.The United States District Court for the Central District of Illinois initially entered judgment on July 31, but it did not comply with Federal Rule of Civil Procedure 58. Mahoney filed a notice of appeal on September 26, and the district court later entered a corrected judgment on October 11. Mahoney filed a second notice of appeal the same day. The district court had awarded the Fund attorneys’ fees based on the trust agreement.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that there was a genuine dispute of material fact regarding Mahoney’s intent to be personally bound by the trust agreement, as he signed the memorandum in a representative capacity, which conflicted with the personal liability clause. The court concluded that this issue could not be resolved at summary judgment. The court also addressed Mahoney’s laches defense but found it waived due to his failure to address relevant complications. Consequently, the Seventh Circuit reversed the district court’s grant of summary judgment and vacated the award of attorneys’ fees, remanding the case for further proceedings. View "Railroad Maintenance and Industrial Health & Welfare Fund v. Mahoney" on Justia Law

Eugene Westmoreland, an Illinois inmate who uses a wheelchair, filed a class action lawsuit seeking prospective relief to make the showers at the Northern Reception and Classification Center (NRC) accessible. He claimed the showers were inaccessible to individuals using mobility aids. Westmoreland filed the suit without first using the prison's internal grievance process as required by the Prison Litigation Reform Act (PLRA). Six weeks after filing, he was transferred to a different facility with accessible showers, which led to questions about the mootness of his claim.The United States District Court for the Northern District of Illinois dismissed Westmoreland's suit for lack of subject matter jurisdiction, finding his claim moot due to his transfer. The court also determined that no exception to mootness applied, as Westmoreland had not exhausted the internal grievance process, making him an inadequate class representative.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Westmoreland's transfer rendered his claim moot and that he did not qualify for any exceptions to mootness. The court also found that Westmoreland's failure to exhaust the grievance process as required by the PLRA made him an inadequate class representative, preventing the class action from proceeding. Consequently, the court affirmed the dismissal of the suit. View "Westmoreland v. Hughes" on Justia Law

The case involves a dispute between Peter Lowes and Amy Thompson, formerly Amy Lowes, regarding a nondisparagement clause in their stipulated divorce judgment. Lowes alleged that Thompson breached this clause by describing him as her "abuser" during a political campaign interview. Thompson filed a special motion to strike the breach of contract claim under Oregon’s anti-SLAPP statute, which aims to quickly dismiss nonmeritorious claims arising from protected speech. The trial court granted Thompson’s motion, but the Court of Appeals reversed, concluding that the nondisparagement clause waived Thompson’s right to the anti-SLAPP statute’s protections.The Deschutes County Circuit Court initially granted Thompson’s special motion to strike, finding that her statements were protected under the anti-SLAPP statute and that Lowes failed to show a probability of prevailing on his claim. The Court of Appeals reversed this decision, holding that the nondisparagement clause constituted a waiver of Thompson’s anti-SLAPP protections, thus making it unnecessary to evaluate whether Lowes could prevail on his claim.The Oregon Supreme Court reviewed the case and disagreed with the Court of Appeals. The Supreme Court held that the nondisparagement clause did not clearly indicate an intention to waive the procedural protections of the anti-SLAPP statute. Therefore, the clause alone could not defeat Thompson’s special motion to strike. The Supreme Court reversed the Court of Appeals' decision in part and remanded the case back to the Court of Appeals to determine whether Lowes met his burden of establishing a probability of prevailing on his breach of contract claim. View "Lowes v. Thompson" on Justia Law