Justia Civil Procedure Opinion Summaries

Fire-Dex, a manufacturer of personal protective equipment for firefighters, faced lawsuits from firefighters and their spouses alleging exposure to carcinogens from Fire-Dex's products. These lawsuits were consolidated in multidistrict litigation in South Carolina. Fire-Dex had general commercial liability insurance policies with Admiral Insurance Company and requested Admiral to defend and indemnify it against the lawsuits. Admiral refused, leading to a declaratory judgment action in federal court in Ohio, where the district court declined to exercise jurisdiction.The United States District Court for the Northern District of Ohio initially had diversity jurisdiction over Admiral's declaratory judgment action but chose to abstain from exercising it, a decision affirmed by the Sixth Circuit. Subsequently, Fire-Dex filed a lawsuit in Ohio state court seeking a declaration that Admiral must defend and indemnify it, along with compensatory and punitive damages for breach of contract and bad faith. Admiral removed the case to federal court and filed counterclaims for declaratory judgment. Fire-Dex moved to remand the case to state court.The United States Court of Appeals for the Sixth Circuit reviewed the district court's decision to remand the declaratory claims and stay the damages claims. The Sixth Circuit held that the district court erred in abstaining from the declaratory claims under Thibodaux abstention, as the case did not involve unsettled questions of state law intimately involved with state sovereignty. The court also found that abstaining from the declaratory claims was an abuse of discretion because the declaratory and damages claims were closely intertwined, and no traditional abstention doctrine applied to the damages claims. The Sixth Circuit vacated the district court's order and remanded for further proceedings. View "Fire-Dex, LLC v. Admiral Insurance Co." on Justia Law

A high school student, Eszter Pryor, trained and competed with the Ohio State Diving Club at The Ohio State University (OSU). In the summer of 2014, when she was sixteen, her diving coach, William Bohonyi, sexually abused her. Pryor alleged that OSU was aware of the abuse by August 2014, as they fired Bohonyi following an internal investigation. Pryor filed a Title IX lawsuit against OSU in January 2022, claiming the university was deliberately indifferent to a sexually hostile culture and her abuse.The United States District Court for the Southern District of Ohio dismissed Pryor's claim, ruling it was time-barred by the statute of limitations. OSU had argued that the applicable statute of limitations was two years, as per Ohio Revised Code § 2305.10(A), and the district court agreed, granting summary judgment in favor of OSU based on the expiration of the limitations period.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that the correct statute of limitations for Title IX claims in Ohio is the two-year period for personal injury actions under Ohio Revised Code § 2305.10(A). The court rejected Pryor's argument that a twelve-year limitations period for child sex-abuse claims under Ohio Revised Code § 2305.111(C) should apply. The court emphasized the importance of uniformity and predictability in applying the statute of limitations and noted that Pryor's claim accrued when she turned eighteen in July 2015, giving her until July 2017 to file her lawsuit. Since she filed in January 2022, her claim was indeed time-barred. View "Pryor v. The Ohio State University" on Justia Law

Shawn Agnone subpoenaed third-party witness Kenneth Madick in a marital dissolution action against her former husband, Frank Charles Agnone II. During Madick’s remote deposition, his attorney refused to turn on his webcam, prompting Shawn to file a motion to compel compliance with the subpoena and request sanctions. Before Shawn filed her reply brief, she and Frank settled the dissolution action, rendering the motion to compel moot. Shawn withdrew her motion but argued that sanctions were still warranted due to Madick’s and his counsel’s conduct during the deposition. The trial court granted the request for sanctions in part, ordering Madick to pay Shawn $9,981.The Superior Court of Los Angeles County reviewed the case and imposed sanctions on Madick. The court concluded that sections 2023.010 and 2023.030 did not independently authorize the trial court to impose monetary sanctions for discovery misuses. However, the Supreme Court granted Shawn’s petition for review and deferred further action pending consideration of a related issue in City of Los Angeles v. PricewaterhouseCoopers, LLP (PwC). The Supreme Court held that a trial court may invoke its independent authority to impose monetary sanctions under sections 2023.010 and 2023.030 for unusual forms of discovery abuse not addressed by method-specific sanctions provisions.The California Court of Appeal, Second Appellate District, Division Three, reconsidered the case in light of PwC and concluded that the trial court had the authority to impose sanctions against Madick. The court affirmed the order, holding that the trial court reasonably exercised its discretion to impose sanctions for the unusual form of discovery abuse that frustrated the deposition’s truth-seeking function. The court found that the trial court’s order was supported by substantial evidence and that Madick’s arguments were unconvincing. View "Agnone v. Agnone" on Justia Law

In this case, Whitney Hodges, representing the estate of her late daughter Honestie Hodges, alleges that on December 6, 2017, Grand Rapids Police Department officers detained Honestie, an eleven-year-old African American girl, at gunpoint, handcuffed her, and placed her in a police car. The officers were searching for a stabbing suspect who did not match Honestie’s description. Honestie was not armed, did not pose a threat, and did not attempt to flee. The complaint asserts that the officers lacked probable cause or reasonable suspicion to detain Honestie and used excessive force in doing so.The United States District Court for the Western District of Michigan partially denied the officers' motion to dismiss on qualified-immunity grounds. The district court found that the complaint plausibly alleged violations of Honestie’s Fourth Amendment rights, including unreasonable search and seizure, false imprisonment, and excessive force. The court declined to consider video evidence and police reports provided by the officers, determining that these materials did not blatantly contradict the complaint’s allegations and were subject to reasonable dispute.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. The court affirmed the district court’s order, agreeing that the complaint plausibly alleged that the officers violated Honestie’s clearly established rights. The Sixth Circuit held that the officers’ actions, as alleged, lacked reasonable suspicion or probable cause and involved excessive force. The court dismissed the officers' appeal to the extent it sought to resolve disputed factual issues, emphasizing that such issues should be addressed after discovery. View "Hodges v. City of Grand Rapids, Mich." on Justia Law

In this child abuse and neglect case, the mother, A.L., challenged the circuit court’s failure to rule on her motion for a post-adjudicatory improvement period and the subsequent termination of her parental rights to her four children. She also appealed the denial of post-termination visitation. The case involved prior incidents where Child Protective Services (CPS) intervened due to lack of supervision, including two separate incidents where her children were injured by firearms. Despite services provided by the Department of Human Services (DHS), the mother failed to comply consistently, leading to the filing of a new petition in August 2021 after another gunshot incident involving her child.The Circuit Court of Kanawha County adjudicated the mother as an abusing and neglectful parent and terminated her parental rights. The mother appealed, and the Supreme Court of Appeals of West Virginia vacated the initial dispositional order due to insufficient findings and remanded for a new order addressing the improvement period and providing detailed findings. On remand, the circuit court again terminated her parental rights, citing her failure to rectify the conditions of abuse and neglect despite extensive DHS involvement and services.The Supreme Court of Appeals of West Virginia affirmed the termination of parental rights, finding that the circuit court did not abuse its discretion given the mother’s history of non-compliance and the recurring issues of lack of supervision. However, the court vacated the denial of post-termination visitation, noting that the circuit court failed to consider the children’s best interests and the potential emotional bond with the mother. The case was remanded for further proceedings to determine whether post-termination visitation would be in the best interests of the children. View "In re Z.D.-1" on Justia Law

An employee, Delbert P. Costa, Jr., suffered a workplace injury on May 9, 2012, while employed by the County of Hawai'i, Department of Water Supply. Costa reported the injury, and the County filed an industrial injury claim, contesting compensability pending investigation. The County did not contest that temporary total disability (TTD) benefits would be due if the injury was compensable. The Director of the Department of Labor and Industrial Relations found the injury compensable on June 24, 2013, but the County did not appeal this decision or pay TTD benefits.Costa applied for a hearing to address the nonpayment of TTD benefits, and the Director issued a supplemental decision on April 25, 2014, awarding TTD benefits and imposing a 20% penalty for late payment. The County appealed to the Labor and Industrial Relations Appeals Board (LIRAB), which reversed the Director’s supplemental decision, finding no statutory basis for the penalty as the TTD benefits were not due before the Director’s decision on compensability.The Intermediate Court of Appeals (ICA) affirmed the LIRAB’s decision, although it noted errors in the LIRAB’s application of the evidentiary standard and its characterization of HRS § 386-92 as punitive. The ICA agreed with the LIRAB that the Director’s decision did not order TTD benefits and thus did not support the imposition of a penalty.The Supreme Court of the State of Hawai'i reviewed the case and held that a penalty under HRS § 386-92 is appropriate where an employer fails to make timely TTD benefit payments after a final decision on compensability. The Court vacated the ICA’s judgment and the LIRAB’s decision, remanding the case to the LIRAB to assess the penalty and determine attorneys’ fees and costs. View "Costa v. County of Hawai'i" on Justia Law

The case involves a challenge to a Texas Department of Family and Protective Services (DFPS) rule that authorized state licenses for two residential facilities where the federal government detained mothers and children after their illegal entry into the United States. The plaintiffs, including detained mothers and Grassroots Leadership, Inc., sought to prohibit the detention of children at these facilities, arguing that the rule was invalid under state law. However, by the time the case reached the court of appeals, all the mothers and children had been released from the facilities.The trial court denied the pleas to the jurisdiction filed by the department and the facility operators, eventually ruling in favor of the plaintiffs by declaring the rule invalid and enjoining the department from granting licenses under it. The Third Court of Appeals reversed, holding that the plaintiffs lacked standing and that their claims were moot since they were no longer detained. However, the court of appeals proceeded to address the merits of the case by invoking the "public-interest exception" to mootness and held the rule invalid under the Administrative Procedure Act.The Supreme Court of Texas reviewed the case and held that Texas courts are not constitutionally authorized to adjudicate moot cases, even if they raise questions of considerable public importance. The court emphasized that mootness is a constitutional limitation on judicial power, and there is no "public-interest exception" to mootness in Texas. Consequently, the court reversed the court of appeals' judgment regarding its jurisdiction, vacated the judgment on the merits, and dismissed the case for lack of subject-matter jurisdiction. View "TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES v. GRASSROOTS LEADERSHIP, INC" on Justia Law

Kristina Steets was severely injured in 2017 while working for Celebration Fireworks, Inc. The employer accepted liability for her total disability under the Workers' Compensation Act (WCA) in 2018. In 2019, Steets filed petitions to amend the description of her injuries and sought specific loss benefits. The Workers' Compensation Judge (WCJ) granted her petitions, and the Workers' Compensation Appeal Board (WCAB) and the Commonwealth Court affirmed. However, Steets died from her injuries while the Commonwealth Court's decision was pending.Steets' estate filed petitions seeking payment of the specific loss benefits awarded to her, which were still under appellate review at the time of her death. The WCJ denied the Estate's claims beyond funeral expenses, and the WCAB affirmed. The Commonwealth Court, in a split decision, also affirmed, ruling that specific loss benefits did not survive Steets' work-related death based on the precedent set by Estate of Harris v. WCAB (Sunoco, Inc.).The Supreme Court of Pennsylvania reviewed the case and overruled Estate of Harris and Burns International Security Services, Inc. v. WCAB (Crist), which had held that Section 306(g) of the WCA was the exclusive means by which specific loss benefits survive the death of a worker. The Court held that Section 410 of the WCA applies, which states that if a claimant dies before the final adjudication of their claim, the compensation due to the claimant up to the date of death shall be paid to the dependents or, if there are no dependents, to the estate. Since Steets died before the final adjudication of her specific loss benefits claim, the employer was required to pay those benefits to her estate. The case was remanded to the WCJ to determine the amount of specific loss benefits due to the Estate. View "Steets v. Celebration Fireworks" on Justia Law

A group of appellants, including Firearms Owners Against Crime and two firearms dealers, filed a case against the Pennsylvania State Police (PSP) Commissioner, alleging that PSP was not complying with the Pennsylvania Uniform Firearms Act. The appellants claimed that PSP was intentionally understaffing its Pennsylvania Instant Check System (PICS) Operations Section, leading to significant delays in background checks for firearm purchases, sometimes exceeding seven hours. They argued that these delays violated the statutory requirement for "instantaneous" or "immediate" background checks and caused financial harm to firearms dealers due to canceled transactions.The Commonwealth Court initially issued a preliminary injunction, finding that PSP had a statutory duty to employ sufficient personnel to ensure compliance with the Act and that the delays were causing financial harm to the dealers. However, the court later sustained PSP's preliminary objections, ruling that the statute did not specify a mandatory timeframe for background checks and that the operational decisions regarding staffing were discretionary. The court also dismissed the appellants' request for a refund of the $2.00 background check fee, as the statute did not provide for such refunds.The Supreme Court of Pennsylvania reviewed the case and held that while the statute did not require "instantaneous" responses, it did mandate that PSP provide results as quickly as possible with available resources. The court affirmed the Commonwealth Court's denial of injunctive and mandamus relief, as these would compel affirmative action barred by sovereign immunity. However, the court reversed the denial of declaratory relief, allowing the appellants to seek a judicial declaration of PSP's duties under the Act. The court also vacated the order denying leave to amend the petition, allowing the appellants to include new allegations regarding PSP's response to the preliminary injunction. The case was remanded for further proceedings consistent with these findings. View "Firearms Owners v. Comm'r of PSP" on Justia Law

Numerous plaintiffs filed claims against a law firm and its attorneys who represented them in mass-tort actions. The plaintiffs alleged mishandling and improper distribution of settlement funds obtained from these actions. After years of litigation and jurisdictional conflicts, the cases were brought before the Rankin County Circuit Court.The circuit court referred the cases to a special master who conducted hearings on various motions, including plaintiffs' motions to consolidate, defendants' motions to sever, and defendants' motions to re-open discovery. The special master recommended granting the plaintiffs' motions to consolidate and denying the defendants' motions to sever and re-open discovery. The circuit court adopted these recommendations by order on February 27, 2023. Defendants sought interlocutory appeals on all four cases, which were granted.The Supreme Court of Mississippi reviewed the case and affirmed the decisions of the Rankin County Circuit Court. The court held that the plaintiffs' claims met the requirements for joinder of parties under Rule 20 and consolidation of cases under Rule 42. The court found that the claims arose from a distinct chain of events involving the same defendants, the same mass-tort litigation, and the same settlement funds. The court also determined that consolidating the cases would further judicial economy without prejudicing any party. Additionally, the court upheld the denial of defendants' motions to re-open discovery, noting that the litigation had been pending for years with no restrictions on discovery and much of the requested discovery had already been obtained. The case was remanded to the Rankin County Circuit Court for further proceedings. View "Freese v. Estate of Alford" on Justia Law