Justia Civil Procedure Opinion Summaries

Florida PACE Funding Agency initiated a proceeding in the Second Judicial Circuit to validate the issuance of $5 billion in bonds for financing certain property improvements under the PACE Act. The agency complied with statutory notice requirements, and a hearing was held where State Attorneys from the Second, Seventh, and Ninth Circuits were represented. No party objected to the entry of final judgment validating the bonds, and the judgment became final without any appeal. Over a year later, various governmental entities—including state attorneys, counties, and tax collectors (most of whom did not participate in the original proceedings)—filed motions under Florida Rule of Civil Procedure 1.540, seeking relief from the judgment, raising arguments such as lack of jurisdiction, due process violations, and alleged surprise.The circuit court allowed discovery and held an evidentiary hearing, after which it denied all motions for relief from judgment. For the parties who had not appeared previously, the court found that rule 1.540 did not apply to bond validation judgments due to the strict finality requirements of chapter 75, Florida Statutes, and that the motions were untimely and insufficient. For the state attorneys who had participated, the court concluded they were procedurally barred from seeking relief under rule 1.540 because it could not substitute for appellate review.On appeal, the Supreme Court of Florida reviewed whether rule 1.540 applies to final judgments in bond validation proceedings under chapter 75. The court held that chapter 75’s finality language—specifically section 75.09—precludes the use of rule 1.540 to collaterally attack such judgments after the time for appeal has expired. The court concluded that the statutory scheme is exclusive, and the rules of civil procedure do not override the statute. Accordingly, the Supreme Court of Florida affirmed the circuit court’s denial of the motions for relief from judgment. View "State Attorneys for the Second, Seventh and Ninth Judicial Circuits v. Florida Pace Funding Agency" on Justia Law

A South Korean entertainment company that owns trademarks for the popular “Baby Shark” song and related products brought a lawsuit in the United States District Court for the Southern District of New York against dozens of China-based businesses. The company alleged these businesses manufactured or sold counterfeit Baby Shark merchandise, violating trademark, copyright, and unfair competition laws. Seeking to stop the alleged counterfeiting, the company obtained temporary and preliminary injunctions and moved to serve the defendants by email, arguing that this method was appropriate under Federal Rule of Civil Procedure 4(f)(3).After the plaintiff served process by email, most defendants did not respond, leading to default judgments against many of them. However, two defendants appeared and challenged the court’s jurisdiction, arguing that service by email violated the Hague Service Convention, to which both the United States and China are parties. The district court agreed, finding that the Convention did not permit service by email on parties in China, and dismissed the claims against these defendants without prejudice for improper service. The plaintiff appealed to the United States Court of Appeals for the Second Circuit.The United States Court of Appeals for the Second Circuit affirmed the district court’s decision. The appellate court held that the Hague Service Convention does not allow email service on defendants located in China, as China has expressly objected to alternative methods such as those in Article 10 of the Convention. The court further held that neither Federal Rule of Civil Procedure 4(f)(2) nor any purported emergency exception permitted email service in these circumstances. The court also upheld the denial of a default judgment, finding no abuse of discretion. Accordingly, the dismissal of the claims against the two China-based defendants for lack of proper service was affirmed. View "Smart Study Co., LTD v. Shenzhenshixindajixieyouxiangongsi" on Justia Law

Micron Technology and its subsidiaries, along with the State of Idaho, were sued for patent infringement by Katana Silicon Technologies in the United States District Court for the Western District of Texas. The patents at issue related to technology for shrinking semiconductor devices and had expired. In response, Micron asserted a counterclaim under the Idaho Bad Faith Assertions of Patent Infringement Act, alleging that Katana had made bad faith assertions of patent infringement. Katana moved to dismiss the counterclaim, arguing that the Idaho Act was preempted by federal patent law. The case was transferred to the United States District Court for the District of Idaho, where the State of Idaho intervened to defend the statute. Separately, Micron filed suit in Idaho state court against Longhorn IP, alleging similar bad faith assertions and seeking the imposition of a bond. Longhorn removed that case to federal court and also moved to dismiss on preemption grounds.The United States District Court for the District of Idaho denied both motions to dismiss, holding that federal law did not preempt the Idaho statute. The court also imposed an $8 million bond on Longhorn and Katana pursuant to the Act, finding that there was a reasonable likelihood that a bad faith assertion of patent infringement had occurred. Katana and Longhorn appealed these decisions to the United States Court of Appeals for the Federal Circuit.The United States Court of Appeals for the Federal Circuit dismissed the appeal for lack of jurisdiction. The appellate court determined that there was no final judgment from the district court, as the only decisions made were the denial of motions to dismiss and the imposition of a bond, neither of which ended the litigation on the merits. The Federal Circuit also found that none of the exceptions for interlocutory appellate review applied, including those for injunctions, the collateral order doctrine, or mandamus, nor was pendent jurisdiction appropriate. View "Micron Technology, Inc. v. Longhorn IP LLC" on Justia Law

A track and field athlete participated in the 2020 United States Olympic Trials, organized by USA Track & Field, Inc. (USATF), where she signed a waiver and indemnity agreement as part of her application to compete. During the heptathlon event, she suffered heat-related injuries on a day when temperatures were extremely high, preventing her from completing the competition and resulting in her not making the Olympic team. Seeking to pursue tort claims, the athlete first filed a declaratory judgment action in the Marion Superior Court, challenging the enforceability of the waiver agreement and seeking an injunction against its enforcement.The Marion Superior Court granted summary judgment to USATF, holding that the waiver agreement was enforceable and disposing of all claims. After the final judgment, but before the statute of limitations expired, the athlete moved to amend her complaint to add tort claims for negligence, gross negligence, recklessness, and willful misconduct. The trial court denied this motion, concluding that it was untimely because it was filed after entry of final judgment. The athlete appealed, and the Indiana Court of Appeals affirmed the enforceability of the agreement but held that the trial court had abused its discretion in denying the motion to amend, relying on Indiana Trial Rule 15(A).The Indiana Supreme Court granted transfer, thereby vacating the Court of Appeals’ opinion, and addressed the procedural issue. The Court held that once final judgment has been entered and all claims have been disposed of, Indiana Trial Rule 15(A) no longer allows for amendment of pleadings. A party may only seek to amend a complaint after final judgment if the judgment is first set aside or vacated under the appropriate rules. Accordingly, the Supreme Court affirmed the trial court’s denial of the motion to amend, clarifying that Rule 15(A) does not apply after final judgment. View "Brooks v. USA Track & Field, Inc." on Justia Law

A motor vehicle accident occurred in Butte, Montana, when a snow grader operated by a city employee backed into a sedan driven by the plaintiff at a very low speed. The grader was engaged in snow removal operations, reversing in the process, and displaying flashing lights and a backup alarm. The plaintiff, after passing the grader, positioned her car behind it and came to a stop. The grader then struck her vehicle. Testimony at trial included differing accounts of whether warning devices were observable and whether the plaintiff was attentive to the grader’s movements. The plaintiff claimed injuries resulting from the collision, though evidence regarding the severity and causation of her injuries was contested.The Second Judicial District Court, Butte-Silver Bow County, conducted a jury trial. The jury found the plaintiff 54% negligent and the city 46% negligent, barring her recovery under Montana’s comparative negligence statute. The plaintiff moved for a new trial, arguing irregularity in the proceedings and insufficient evidence to support the verdict. The District Court granted the motion for a new trial on both grounds, relying on statements made by the city’s counsel during closing arguments and finding the evidence did not support the jury’s comparative negligence finding.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in granting a new trial. The Supreme Court held that the plaintiff had not preserved her objections to alleged irregularities in the proceedings because she failed to object contemporaneously or through a specific motion in limine. The Court also determined that the plaintiff had judicially admitted that comparative negligence was a factual issue for the jury, thereby waiving her right to challenge the sufficiency of the evidence. Furthermore, the Supreme Court found that there was substantial evidence supporting the jury’s verdict. The Supreme Court reversed the District Court’s order granting a new trial and reinstated the jury’s verdict. View "Shahood v. Butte-Silver Bow" on Justia Law

Two individuals worked as delivery drivers for a transportation company for over a decade, primarily out of the company’s New Jersey terminal. Their work mainly involved picking up and delivering goods in New Jersey, with occasional deliveries in neighboring states. Each driver had a contract with the company that included a forum-selection clause requiring any disputes to be litigated in Memphis, Tennessee, and a choice-of-law clause providing that Tennessee law would govern any disputes. The company is incorporated in Delaware, headquartered in Illinois, and has operations nationwide, including in Tennessee, but neither the drivers nor the company’s relevant activities were based in Tennessee.The drivers filed a putative class action in the United States District Court for the District of New Jersey, alleging that the company violated New Jersey wage laws by withholding earnings and failing to pay overtime, among other claims. The case was transferred to the United States District Court for the Western District of Tennessee pursuant to the forum-selection clause. The company then moved to dismiss the complaint, arguing that the Tennessee choice-of-law provision applied and that Tennessee law did not recognize the claims brought under New Jersey statutes. The district court agreed, upheld the choice-of-law provision, and dismissed the case.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the enforceability of the choice-of-law provision under Tennessee’s choice-of-law rules. The court held that the contractual choice-of-law clause was unenforceable because there was no material connection between Tennessee and the transactions or parties. As a result, the Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. The court did not reach the question of whether Tennessee law was contrary to the fundamental policies of New Jersey. View "Andujar v. Hub Group Trucking, Inc." on Justia Law

In this case, a motorist was stopped by state troopers for traffic infractions. The troopers observed signs of intoxication, and after the motorist failed a field sobriety test, he refused to take a chemical breath test, even after being warned multiple times about the consequences. Following his refusal, the troopers completed and signed sworn reports documenting the events, and his driver's license was automatically suspended pending a Department of Motor Vehicles (DMV) hearing to determine if it should be revoked for refusing the chemical test.At the DMV hearing, which was postponed once when the troopers failed to appear, the motorist again properly subpoenaed both troopers for the rescheduled hearing. When the troopers did not attend the second hearing, the Administrative Law Judge (ALJ) acknowledged the validity of the subpoenas but proceeded with the hearing without further adjournment. The ALJ admitted the troopers’ sworn written reports and supporting depositions as evidence and, over the motorist’s objections, found that the elements required for license revocation were met. On administrative appeal, the DMV Appeals Board affirmed, and upon transfer, the Appellate Division confirmed the DMV’s decision, reasoning that the motorist had made a tactical choice not to seek judicial enforcement of the subpoenas or request another adjournment.The New York Court of Appeals reviewed the matter. The court held that when a motorist properly subpoenas officers in a DMV license revocation hearing and the officers fail to appear, due process does not require dismissal of the charge or exclusion of their written reports unless the motorist first seeks judicial enforcement of the subpoenas pursuant to CPLR 2308(b). As the motorist in this case did not pursue enforcement or request an adjournment to do so, his due process rights were not violated. The court affirmed the Appellate Division’s order. View "Monaghan v. Schroeder" on Justia Law

A woman was sexually abused by the defendant when she was fourteen years old, with the abuse occurring in 2009 or 2010. Years later, in 2018, she filed her first petition for a protective order under Pennsylvania’s Protection of Victims of Sexual Violence or Intimidation Act after learning that the defendant was attempting to locate her, contact her through mutual friends, and disrupt her marriage. The court granted a three-year protective order, which expired in January 2021. In June 2022, the woman unexpectedly encountered the defendant at a flea market, which caused her significant fear and anxiety. She subsequently filed a second petition for a protective order in August 2022.The Lebanon County Court of Common Pleas held a hearing and entered a new protective order in her favor, concluding that her right to relief under the Act accrued from the June 2022 encounter, not from the original abuse. The court rejected the defendant’s argument that her claim was barred by the Act’s six-year statute of limitations, reasoning that the statute began to run with the new act that placed her at continued risk. On appeal, a three-judge panel of the Superior Court reversed, holding that the statute of limitations began at the time of the original abuse, and thus the woman’s 2022 petition was untimely. The Superior Court reasoned that the cause of action accrued when the sexual violence occurred, not when a continued risk of harm later manifested.The Supreme Court of Pennsylvania reviewed the case and reversed the Superior Court's decision. The Court held that, consistent with general principles governing statutes of limitations, the six-year period begins to run from the date of the act or circumstance that demonstrates the plaintiff is at a continued risk of harm from the defendant, as this is when the cause of action accrues under the Act. The matter was remanded for further proceedings on the remaining issues. View "Weatherholtz v. McKelvey" on Justia Law

A passenger, after being injured in a hit-and-run rear-end collision while riding in a vehicle arranged through a rideshare application, sought damages for bodily injuries. The passenger alleged that the rideshare company, its subsidiary, and its insurer either provided or were required by law to provide uninsured motorist (UM) coverage, and that their rejection of such coverage violated Louisiana law.The action began in Louisiana state court, initially naming only the insurer as a defendant. The passenger later amended the complaint to add the rideshare company and its subsidiary, arguing that they were not permitted to reject UM coverage. With all defendants’ consent, the insurer removed the case to the United States District Court for the Eastern District of Louisiana, citing diversity jurisdiction. Multiple motions followed, including motions to dismiss by the rideshare entities and a motion for summary judgment by the insurer. The district court found that Louisiana statutes allow transportation network companies to reject UM coverage and that the defendants had properly done so. Accordingly, the district court dismissed all claims with prejudice and denied the passenger’s request to certify a question to the Louisiana Supreme Court.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the statutory interpretation de novo. The court concluded that Louisiana Revised Statute § 45:201.6 incorporates, by general reference, the provisions of § 22:1295, including the right to reject UM coverage. The court found support for this interpretation in state appellate decisions and statutory context. The Fifth Circuit affirmed the district court’s judgment and denied the motion to certify the question to the Louisiana Supreme Court. The holding is that transportation network companies in Louisiana may reject uninsured motorist coverage if they follow the procedures in § 22:1295. View "Guerrera v. United Financial Casualty Co." on Justia Law

Timothy Hale and Sonja Ringen constructed a storage building on their commercially zoned property in Laramie without first obtaining a building permit. When the City of Laramie discovered the construction, it issued a stop work order and a cease-and-desist letter. Despite these notices, Hale and Ringen continued building and subsequently applied for a permit, which the City denied due to deficiencies in the application. After further unsuccessful permit attempts and ongoing disputes over the City’s requirements—including requests for disassembly of the structure—the City sought and obtained a permanent injunction from the District Court of Albany County, restricting use of the building until permitting was complete and compliance was achieved.The District Court of Albany County conducted a bench trial in May 2022 and granted the City’s request for a permanent injunction. The court outlined a process for inspections, identification of code violations, and corrective actions, but continued conflict between the parties hindered progress. Multiple rounds of correspondence, inspections, and motions ensued, with the City insisting on structural disassembly and Hale/Ringen providing documentation to support their position. Hale and Ringen eventually moved to vacate the injunction, arguing it was no longer equitable given their efforts and the City’s refusal to issue a permit. The district court denied their motion, citing only the parties’ lack of agreement, and provided no substantive analysis of the evidence.On appeal, the Supreme Court of Wyoming determined that the district court abused its discretion by failing to consider the evidence and arguments presented before denying the motion to vacate or modify the injunction. The Supreme Court held that a court must exercise discretion and decide motions on their merits, rather than requiring agreement between adversarial parties. Consequently, the Supreme Court reversed the district court’s order and remanded the case for full consideration of Hale/Ringen’s motion in light of all relevant facts and equities. View "Hale v. City of Laramie" on Justia Law