Justia Civil Procedure Opinion Summaries

In several Minnesota cities, only members of a pre-approved union can work on municipal construction jobs. Multiple contractors, a carpenter, and a union objected to this requirement, alleging it violated the First Amendment. The contractors, Kaski, Inc.; Nordic Group, Inc.; and Roen Salvage Co., claimed they missed out on lucrative work due to these project-labor agreements. Luke Krhin, a carpenter, and the Christian Labor Association, which has a local chapter in Minnesota, also joined the lawsuit.The United States District Court for the District of Minnesota determined that none of the plaintiffs had standing to sue. The court found that the contractors, Krhin, and the Christian Labor Association could not succeed on their First Amendment claim. The plaintiffs appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on the issue of standing, a jurisdictional requirement. The court found that the contractors did not have standing because the relevant constitutional claims belonged to their employees, not to them. The court also found that Krhin, who opposed joining a pre-approved union, was exempt from the requirement as a supervisor, thus lacking standing. The Christian Labor Association also lacked standing because it failed to identify any members who would have standing to sue in their own right.The Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss based on a lack of standing. View "Christian Labor Association v. City of Duluth" on Justia Law

A widow, Lori Olson, individually and as the personal representative of her deceased husband Scott Olson's estate, filed a lawsuit against Huron Regional Medical Center (HRMC), Dr. William Miner, and Thomas Miner, a physician’s assistant, alleging negligence, wrongful death, loss of consortium, intentional infliction of emotional distress, civil conspiracy, and fraudulent concealment. Scott Olson died at HRMC in January 2020 under the care of Dr. Miner and Thomas Miner. Lori Olson initiated the lawsuit in September 2021.The Circuit Court of the Third Judicial Circuit in Beadle County, South Dakota, denied Dr. Miner’s motion to dismiss for insufficient service of process but later granted the defendants' motions to dismiss for failure to prosecute. Lori Olson appealed the dismissal, and Dr. Miner filed a notice of review challenging the denial of his motion to dismiss for insufficient service.The Supreme Court of South Dakota reviewed the case and found that there was verifiable record activity within the year prior to the defendants’ motion to dismiss, including efforts to compile medical records and communication between the parties. The court concluded that the Circuit Court erred in dismissing the case under SDCL 15-11-11 for lack of prosecution, as there was sufficient activity to move the case forward. Additionally, the court found that the delays in the case did not rise to the level of egregiousness required for dismissal under Rule 41(b) and that the Circuit Court did not consider less severe sanctions before dismissing the case.The Supreme Court of South Dakota reversed the Circuit Court’s decision to dismiss the case for failure to prosecute and affirmed the denial of Dr. Miner’s motion to dismiss for insufficient service of process, concluding that Dr. Miner was properly served. View "Olson v. Huron Regional Medical Center, Inc." on Justia Law

Pamela J. (Tower) Weinle appealed a divorce judgment from the District Court (Skowhegan), which divided marital property and awarded Alan R. Tower spousal support and attorney fees. Weinle contested the spousal support, property distribution, and attorney fees. Tower died after the judgment and during the appeal process.The District Court awarded Tower $2,000 per month in general spousal support, $500 per month in reimbursement spousal support, and $12,325 in attorney fees. The court found that Weinle had engaged in economic misconduct by purchasing and selling property without Tower's knowledge and failing to comply with discovery obligations, which increased litigation costs. The court also noted that Weinle had a substantial income and financial resources, while Tower had limited income and poor health.The Maine Supreme Judicial Court overruled its previous decision in Panter v. Panter, which required dismissal of an appeal if a party died during its pendency. The court held that the death of a party does not moot the appeal regarding property rights. The court affirmed the District Court's judgment, finding no error in the spousal support award, property distribution, or attorney fees. The court noted that the spousal support obligation ceased upon Tower's death, as the divorce judgment did not specify that the support survived the death of either party. View "Weinle v. Estate of Tower" on Justia Law

Valderra Land Holdings, LLC owns real property encumbered by a performance trust deed held for the benefit of Jenco, LC and others. After Valderra defaulted on its obligations, Jenco sought judicial foreclosure. Valderra counterclaimed, asserting a right to cure its default and requested the court to determine the amount owed. The district court set the payoff amount and directed Jenco to instruct the trustee to reconvey the property upon Valderra’s tender of funds.Valderra tendered the payoff amount, but Jenco did not instruct the trustee to release the trust deed. Instead, Jenco appealed the judgment and moved for a stay of the obligation to reconvey the property under rule 62(b) of the Utah Rules of Civil Procedure. The district court granted the stay over Valderra’s objection, which argued that the order was injunctive and should be governed by rule 62(c), not 62(b).The Supreme Court of Utah reviewed the case and agreed with Valderra that the district court erred in granting the stay under rule 62(b). The court held that rule 62(b) applies only to stays of orders or judgments to pay money, not injunctive orders, which are governed by rule 62(c). The court found that the order requiring Jenco to instruct the trustee to reconvey the property was injunctive in nature. Consequently, the district court should have considered the motion under rule 62(c), which requires the court to determine whether the conditions for the security of the rights of the adverse party are just.The Supreme Court of Utah reversed the district court’s decision to grant the stay under rule 62(b) and vacated the order rejecting Valderra’s rule 62(i) objection. The court also denied Valderra’s request for appellate attorney fees, as Valderra was not awarded fees in the lower court. View "Jenco v. Valderra Land Holdings" on Justia Law

AST & Science LLC, a company in the satellite technology and communications business, hired Delclaux Partners SA to introduce it to registered broker-dealers for investment purposes. Delclaux introduced AST to LionTree Advisors LLC, which handled AST's Series A financing. Two contracts were involved: a Finder’s Fee Agreement between AST and Delclaux, and a separate agreement between AST and LionTree. After the Series B financing, Delclaux claimed it was owed fees from four transactions, which AST refused to pay, leading to AST suing Delclaux for breach of contract, alleging Delclaux acted as an unregistered broker-dealer.The United States District Court for the Southern District of Florida denied summary judgment on AST’s complaint and granted summary judgment to AST on Delclaux’s counterclaim. Delclaux appealed, but the appeal was voluntarily dismissed due to jurisdictional questions. The district court later held that it lacked diversity jurisdiction but claimed federal-question jurisdiction, asserting that the case involved a federal issue regarding the Securities Exchange Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s assertion of federal-question jurisdiction. The appellate court held that the breach-of-contract claim was governed by state law and did not meet the criteria for federal-question jurisdiction under the Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing test. The court found that the federal issue was not substantial enough to warrant federal jurisdiction. Consequently, the Eleventh Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss it for lack of subject-matter jurisdiction. View "AST & Science LLC v. Delclaux Partners SA" on Justia Law

Plaintiff Karim Codrington was subjected to an unlawful traffic stop, search, and arrest by Louisville Metro Police Department officers. During the criminal proceedings, a Kentucky state court suppressed the evidence seized from his vehicle and dismissed the charges. Over three years later, Codrington filed a 42 U.S.C. § 1983 lawsuit, alleging that the officers planted drugs on him, provided those drugs to prosecutors, and stole thousands of dollars from him.The United States District Court for the Western District of Kentucky granted summary judgment in favor of the defendants on all claims, finding that Codrington’s claims were either barred by the statute of limitations or failed on their merits. Specifically, the court found that the unlawful search and seizure, selective enforcement, and false arrest/imprisonment claims were time-barred. The court also found that Codrington failed to provide sufficient evidence to support his fabrication-of-evidence and malicious-prosecution claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment on the unlawful search and seizure, selective enforcement, false arrest/imprisonment, malicious prosecution, and state-law conversion claims. However, the court reversed the district court’s grant of summary judgment on the fabrication-of-evidence claim, finding that there was a genuine dispute of material fact regarding whether the officers fabricated evidence. The court also vacated the district court’s judgment on Codrington’s Monell claims and remanded for further proceedings. View "Codrington v. Dolak" on Justia Law

A minor, B.D., through his guardian, sued Samsung SDI, a South Korean battery manufacturer, after one of its batteries exploded in his pocket in Indiana. Samsung SDI moved to dismiss the complaint for lack of personal jurisdiction, which the district court granted. The court found that Samsung SDI had not purposefully availed itself of the Indiana forum through sales of individual batteries, as the battery was purchased through an unauthorized transaction.The United States District Court for the Southern District of Indiana initially denied Samsung SDI's motion to dismiss, concluding that B.D. made a prima facie case for personal jurisdiction. However, upon remand for further jurisdictional discovery, the district court granted Samsung SDI's renewed motion to dismiss, reasoning that B.D. failed to show that Samsung SDI purposefully availed itself of the Indiana forum.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that Samsung SDI purposefully availed itself of the Indiana forum through an end-product stream of commerce by selling batteries to sophisticated customers, who then incorporated them into products available in Indiana. However, the court found a disconnect between Samsung SDI's purposeful contacts with Indiana and B.D.'s lawsuit, which stemmed from a consumer purchase of an individual battery. This disconnect precluded the exercise of specific personal jurisdiction over Samsung SDI. The court emphasized that the unilateral actions of third parties made individual batteries available to Indiana consumers, not Samsung SDI's deliberate actions. Thus, the court affirmed the dismissal of the lawsuit for lack of personal jurisdiction. View "B.D. v. Samsung SDI Co., Ltd." on Justia Law

Sysco Machinery Corporation, a Taiwanese company, accused DCS USA Corporation, a North Carolina company, of business torts related to their manufacturer-distributor relationship. Sysco alleged that after some of its employees left to form a competitor, Cymtek Solutions, Inc., DCS sold machines made by Cymtek using Sysco's confidential information. Sysco claimed these diverted contracts were worth millions of dollars.Sysco first filed suit in Taiwan, where it claims to have won a preliminary injunction against Cymtek. Sysco then filed a suit in the Eastern District of North Carolina, which it voluntarily dismissed, followed by a suit in the District of Massachusetts, which was dismissed. Finally, Sysco returned to the Eastern District of North Carolina, where it brought claims for trade secret misappropriation, copyright infringement, unfair and deceptive trade practices, and tortious interference with prospective economic advantage. The district court dismissed all claims under Rule 12(b)(6) for failure to state a claim and denied Sysco's post-judgment leave to amend its complaint.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Sysco's trade secret misappropriation claim, finding that Sysco did not plausibly allege the existence of a valid trade secret or that DCS misappropriated it. The court also affirmed the dismissal of Sysco's other claims, noting that Sysco did not sufficiently develop its arguments for copyright infringement, unfair and deceptive trade practices, and tortious interference with prospective economic advantage. Finally, the court upheld the district court's denial of Sysco's motion to alter or amend the judgment and for leave to amend the complaint, citing Sysco's repeated failure to state a claim and the potential prejudice to DCS. View "Sysco Machinery Corp. v. DCS USA Corp." on Justia Law

A mother appealed the dismissal of a neglect case brought against her by the State of Wyoming. The case involved her two children, AB and JC. The mother was arrested for drug-related charges, and the children were placed in protective custody. JC was released to his father, who had primary custody, while AB was released to his paternal grandfather and later to his father, who lived in Texas. The State filed a neglect petition, and the juvenile court held hearings, during which the mother denied the allegations. The court initially placed AB with his paternal grandfather and later with his father.The juvenile court found the children had been neglected and ordered continued placement with their fathers while the mother completed a case plan. The State moved to dismiss the neglect petition after the mother made progress on her case plan and AB's father sought custody. The juvenile court initially dismissed the petition but vacated the dismissal after the mother objected. The court later set a permanency review hearing and maintained the status quo, allowing the mother to continue working on her case plan.The State again moved to dismiss the case, noting the mother’s progress and the existence of custody agreements for both children. The juvenile court dismissed the neglect petition, and the mother appealed. The Wyoming Supreme Court found the appeal moot because the State had dismissed the neglect action, and the mother had physical custody of AB. The court concluded that any judgment would have no practical effect on the existing controversy and dismissed the appeal. The court also determined that none of the exceptions to the mootness doctrine applied in this case. View "In the Interest Of: AB and JC" on Justia Law

Ian Elliot, Cindy Elliot, and their mother, Ada Elliot, were partners in StarFire, a limited partnership owning property in Gallatin County. Cindy managed StarFire and sought to remove Ian as a general partner. Ian was appointed Ada’s guardian, and Joyce Wuertz was appointed as Ada’s conservator. Ian sued Cindy for misappropriation of funds and sought to remove Wuertz as conservator, but his motions were denied. Ada’s will divided her estate equally between Ian and Cindy, but due to their strained relationship, a special administrator was appointed instead of Ian. Ian’s subsequent motions to disqualify the special administrator were also denied.The Thirteenth Judicial District Court, Yellowstone County, appointed Andrew Billstein as the special administrator of Ian’s estate. The Objectors (Jenny Jing, Alice Carpenter, and Mike Bolenbaugh) filed an untimely appeal against this appointment, which was declined. The Objectors also opposed the settlement agreements proposed by the Special Administrator, which aimed to resolve ongoing litigation involving Ian’s estate. The District Court approved the settlements, finding them reasonable under the Pallister factors, and denied the Objectors’ motion for relief under M. R. Civ. P. 59 and 60.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decisions. The court held that the District Court had subject matter jurisdiction to approve the settlement agreements and did not abuse its discretion in doing so. The court found that the settlements were reasonable, considering the strength of the cases, the risk and expense of further litigation, and the views of experienced counsel. The court also upheld the District Court’s denial of the Objectors’ post-judgment relief motions. View "In re Estate of Elliot" on Justia Law