Justia Civil Procedure Opinion Summaries

An inmate at the Richland Correctional Institution, Kimani E. Ware, sought a writ of mandamus to compel Richland County Sheriff Steve Sheldon to provide public records he requested, including a booking report, use-of-force reports, and policies on inmate grievances and use of force. Ware also sought statutory damages and court costs.Ware sent his public-records request in October 2022, and the sheriff's office responded in November 2022. However, there was conflicting evidence regarding the completeness of the sheriff's response. Ware claimed that the sheriff did not provide the inmate-grievance policy and use-of-force policy, and that the sheriff provided incident reports instead of the requested use-of-force reports. Ware filed his mandamus complaint in December 2023, and the sheriff moved to dismiss, which was denied by the court. Both parties submitted evidence, but only Ware filed a timely merit brief.The Supreme Court of Ohio reviewed the case and found discrepancies in the evidence provided by Ware, suggesting that Ware may have altered the response letter from the sheriff's office. The court determined that Ware did not prove by clear and convincing evidence that the sheriff failed to provide the requested records. Consequently, the court denied Ware's claim for a writ of mandamus and his requests for statutory damages and court costs. The court also denied motions from both parties for leave to file additional evidence. View "State ex rel. Ware v. Sheldon" on Justia Law

Two children in the custody of the Department of Children and Families (DCF) appealed the dismissal of guardianship petitions filed by their great-aunt and great-uncle, who reside in Pennsylvania. The Juvenile Court dismissed the petitions, citing the Interstate Compact on the Placement of Children (ICPC), as Pennsylvania had denied the placement due to the great-uncle's felony convictions from the 1990s. The children argued that the ICPC does not apply to out-of-state relatives seeking guardianship, while DCF contended that the appeal should be dismissed because the great-aunt and great-uncle, who are indispensable parties, did not appeal the dismissal.The Juvenile Court granted DCF's motion to dismiss the guardianship petitions, concluding that allowing the guardianship would violate the ICPC. The court noted that Pennsylvania's denial was based on the great-uncle's ineligibility to work or volunteer with children due to his felony convictions. The children filed a motion for reconsideration, which was denied. They then filed timely notices of appeal, but the great-aunt and great-uncle did not.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that the absence of the great-aunt and great-uncle, who are indispensable parties, compelled the dismissal of the appeal. The court emphasized that it could not proceed without the relatives, whose rights would be affected by the decision. Consequently, the appeal was dismissed. View "Guardianship of Wilson" on Justia Law

The plaintiffs, Boyang Song and Travis McCune, own a unit at The 903 condominium complex in Providence, Rhode Island. They filed a lawsuit against Evan Lemoine and Stephen Rodio, the president and secretary of The 903 Condominium Owner’s Association, respectively. The dispute arose when the defendants failed to include the plaintiffs' specific agenda items in a special-meeting petition regarding gas metering and billing issues at the complex. The plaintiffs sought to address the malfunctioning gas timers and the board's decision to switch to a ratio utility billing system, which they argued conflicted with the complex’s governing documents and the Rhode Island Condominium Act.The Superior Court consolidated the plaintiffs' motion for a preliminary injunction with a trial on the merits. After a three-day nonjury trial, the Superior Court found in favor of the defendants. The trial justice determined that the notice of the special meeting sent by the board was insufficient but concluded that the plaintiffs' proposed meeting notice was improper because it did not set forth valid transactable business within the association’s authority. The court found for the defendants on count I of the verified complaint and later entered judgment in favor of the defendants on all counts of the plaintiffs' complaint, while dismissing the defendants' counterclaims.The Rhode Island Supreme Court reviewed the case and vacated the part of the Superior Court's judgment finding in favor of the defendants. The Supreme Court held that the plaintiffs had satisfied their obligation to obtain the requisite number of signatures for the special meeting and that their proposed notice complied with the statutory requirements. The court found that the trial justice overstepped by evaluating the merits of the plaintiffs' motions individually and granting relief not sought by the parties. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Song v. Lemoine" on Justia Law

Eugene Kritter, an experienced helicopter pilot, owned and operated Kritter Cropdusting. While crop dusting over a farm in North Carolina, his helicopter collided with a low-hanging steel wire, resulting in his death. Kritter Cropdusting and Kritter’s estate filed a negligence lawsuit against the farm owners and operators, as well as Nutrien, the pesticide company that hired Kritter Cropdusting for the job.The United States District Court for the Eastern District of North Carolina granted summary judgment in favor of the defendants. The court concluded that the farm owners and operators owed no duty of care to Kritter to remove or warn about the wire, as the risk was not reasonably foreseeable to them. The court also found that neither Nutrien nor its employee, Elmore, owed Kritter a duty of care. Additionally, the court rejected the argument that Kritter was contributorily negligent and found that the wire was not an open and obvious condition.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that summary judgment was inappropriate because material questions of fact remained regarding whether the defendants owed a duty of care to Kritter. The court noted that under North Carolina law, issues of negligence are generally for the jury to decide, especially when facts are disputed or multiple reasonable inferences can be drawn. The court also found that the district court erred in concluding that the risk posed by the wire was not foreseeable and that Kritter’s death was incident to his work. The Fourth Circuit vacated the district court’s summary judgment and remanded the case for further proceedings. View "Kritter v. Mooring" on Justia Law

In August 2021, the Cook County Health and Hospitals System implemented a policy requiring all personnel to be fully vaccinated against infectious diseases, including COVID-19. Exemptions were allowed for disability, medical conditions, or sincerely held religious beliefs. Plaintiffs, who are healthcare employees or contractors, requested religious exemptions, which were granted. However, the accommodation provided was a transfer to unpaid status pending termination, with a limited time to find a non-existent remote position. Plaintiffs argued this was religious discrimination violating the Free Exercise Clause of the First Amendment.The United States District Court for the Northern District of Illinois previously denied plaintiffs' motions for preliminary injunctions against the vaccine mandates, including Cook County’s. The Seventh Circuit affirmed this denial, rejecting the plaintiffs' facial challenge to the mandate. On remand, plaintiffs amended their complaint but were denied permission to add a claim under the Illinois Religious Freedom Restoration Act until after the court ruled on the County’s motion to dismiss. The district court dismissed the second amended complaint, considering it a facial challenge, which had already been ruled upon.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the plaintiffs waived their as-applied challenge by not raising it in the district court or their opening brief on appeal. The court also noted that plaintiffs conceded they no longer sought injunctive relief and did not pursue a facial challenge. Consequently, the court affirmed the district court’s dismissal of the constitutional claim. Additionally, the court found no abuse of discretion in the district court’s denial of leave to amend the complaint to include the Illinois RFRA claim. The court criticized the plaintiffs' counsel for poor advocacy and procedural errors. View "Lukaszczyk v Cook County" on Justia Law

In April 2021, David Browne visited Billy Jack’s Saloon and Grill in Dewey-Humboldt, Arizona. After leaving the bar, Browne, with a blood alcohol content nearly four times the legal limit, caused a multi-vehicle collision on State Route 69. Victor Sanchez-Ravuelta, Janette Dodge, and their two minor children, Elijah and Amelia, were injured in the crash. The plaintiffs alleged that the Arizona Department of Liquor Licenses and Control (the Department) was negligent in failing to prevent Billy Jack’s from overserving its patrons.The plaintiffs filed a lawsuit against the State of Arizona, the Town of Dewey-Humboldt, and Yavapai County. The Superior Court in Maricopa County dismissed the claims against all defendants. The court found that the plaintiffs’ notice of claim to the County and Town was insufficient and that the Department did not have a legal duty to protect the plaintiffs from the harm caused by Browne’s actions. The court dismissed the minor plaintiffs’ claims without prejudice and the adult plaintiffs’ claims with prejudice.The Arizona Court of Appeals held that the Department owed a statute-based duty of care to the plaintiffs. However, the Arizona Supreme Court reviewed the case and concluded that the Department did not owe a duty of care to the plaintiffs. The court found that the statutes cited by the plaintiffs did not impose a mandatory duty on the Department to prevent the overserving of patrons. The Supreme Court vacated parts of the Court of Appeals' opinion and affirmed the Superior Court’s dismissal of the adult plaintiffs’ claims against the State with prejudice. The case was remanded to the Court of Appeals to consider the Town’s cross-appeal. View "SANCHEZ-RAVUELTA v YAVAPAI" on Justia Law

The President invoked the Alien Enemies Act (AEA) to remove Venezuelan nationals identified as members of the Tren de Aragua (TdA), a designated foreign terrorist organization. Two detainees, along with a putative class of similarly situated detainees in the Northern District of Texas, sought injunctive relief against their summary removal under the AEA. The detainees were being held in U.S. detention facilities and were notified of their imminent removal.The District Court denied the detainees' motion for a temporary restraining order (TRO) against their removal. The detainees then moved for an emergency TRO, which was not promptly addressed by the District Court. Consequently, they appealed to the Fifth Circuit, which dismissed their appeal for lack of jurisdiction and denied their motion for an injunction pending appeal, citing insufficient time given to the district court to act. The detainees also applied to the Supreme Court for a temporary injunction.The Supreme Court of the United States reviewed the case and found that the Fifth Circuit erred in dismissing the detainees' appeal for lack of jurisdiction. The Court held that the District Court's inaction had the practical effect of refusing an injunction, given the extreme urgency and high risk of irreparable harm faced by the detainees. The Supreme Court vacated the judgment of the Fifth Circuit and remanded the case for further proceedings. The Court emphasized that due process requires adequate notice and time for detainees to seek habeas relief before removal. The Government was enjoined from removing the detainees under the AEA pending further proceedings and disposition of the petition for a writ of certiorari. View "A.A.R.P. v. Trump" on Justia Law

A creditor and a debtor’s law firm both claimed settlement funds held by the superior court. The creditor had a charging order against the debtor’s distributions from a limited liability company (LLC), while the law firm had an attorney’s lien on the funds. In a previous appeal, the attorney’s lien was deemed valid, but the case was remanded to determine if the funds were LLC distributions subject to the charging order and the value of the attorney’s lien.The superior court ruled that the funds were LLC distributions and subject to the charging order. It also found that the debtor failed to prove any money was owed to the law firm for work performed, thus invalidating the attorney’s lien. The court mistakenly released the funds to the creditor, who returned them within two days, but was sanctioned with attorney’s fees for temporarily keeping the funds.The debtor appealed, and the creditor cross-appealed the attorney’s fee award. The Supreme Court of Alaska affirmed the superior court’s rulings on the merits but reversed the attorney’s fee award. The court held that the funds were indeed LLC distributions subject to the charging order and that the debtor and law firm failed to prove the value of the attorney’s lien. The court also vacated the second final judgment and the attorney’s fee award against the creditor, finding no rule violation by the creditor. View "Baker v. Duffus" on Justia Law

Erna Rousey transferred five real properties and nearly $225,000 in cash assets to her son, James “Jimmy” Rousey, Jr., in the last few years of her life. After her death, her estate sought recission of these transfers, alleging undue influence. The estate argued that Erna lacked the mental capacity to make the transfers and that they were the product of fraud, undue influence, or coercion. Jimmy contended that the transfers were valid gifts and that Erna had sufficient mental capacity.The Superior Court of the State of Alaska, Third Judicial District, Anchorage, found that Jimmy maintained a confidential relationship with Erna and that the property transfers were the result of undue influence. The court concluded that the estate was entitled to recission of the property transfers and awarded attorney’s fees to the estate. Jimmy, representing himself, appealed the recission and attorney’s fee award, arguing that the transfers were valid gifts and that the court erred in its findings.The Supreme Court of the State of Alaska reviewed the case and affirmed the recission of the property transfers. The court held that the estate provided clear and convincing evidence that Jimmy exerted undue influence over Erna, who was susceptible due to her diminished mental capacity, isolation, and reliance on Jimmy. The court found that Jimmy failed to rebut the presumption of undue influence and that the transfers were not gifts. However, the Supreme Court vacated and remanded the enhanced attorney’s fee award for reconsideration, noting that the superior court may have improperly relied on Jimmy’s actions before the litigation started and did not sufficiently explain why Jimmy’s opposition to the petition was in bad faith. The Supreme Court instructed the lower court to reconsider the attorney’s fee award based on appropriate factors. View "In re Estate of Rousey" on Justia Law

A couple, the Marons, alleged that Florida's Disposition of Unclaimed Property Act violated the Takings Clause of the Fifth Amendment. They claimed that the Act allowed the state to take their unclaimed property without compensating them for the earnings accrued while the property was in the state's custody. The Act requires holders of unclaimed property to deliver it to the state's Department of Financial Services, which then uses the property for public purposes, including investing it. The Marons argued that they were entitled to these earnings.The United States District Court for the Northern District of Florida dismissed the Marons' suit. The court reasoned that the state could constitutionally escheat the property altogether, so it could also keep the property in its custody without compensating for the earnings. The court also addressed jurisdictional issues, concluding that the Marons had standing and that their claim was not fully barred by sovereign immunity, but ultimately found that the Marons failed to state a claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court concluded that the district court had jurisdiction over the Marons' takings claim, as the Marons had standing, the claim was ripe, and it was not barred by sovereign immunity. However, the appellate court disagreed with the district court's analysis on the merits. The appellate court held that the Act did not transfer title of the unclaimed property to the state, but merely placed it in the state's custody. The court vacated the district court's judgment and remanded the case for further proceedings to determine whether the Marons' property was directly appropriated by the state and whether the Act provided just compensation. View "Maron v. Chief Financial Officer of Florida" on Justia Law