Justia Civil Procedure Opinion Summaries

The Association for Accessible Medicines (AAM), representing generic drug manufacturers, challenged a Minnesota law regulating drug prices, Minn. Stat. § 62J.842, arguing it violated the dormant Commerce Clause. The law prohibits manufacturers from imposing excessive price increases on generic or off-patent drugs sold in Minnesota. The district court granted AAM's motion for a preliminary injunction, finding the law likely violated the dormant Commerce Clause.The United States District Court for the District of Minnesota concluded that AAM was likely to succeed on the merits of its claim, faced a threat of irreparable harm, and that the balance of harms and public interest factors were neutral. Minnesota appealed, contesting the likelihood of success on the merits and the balance of harms/public interest.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s ruling for abuse of discretion and its legal conclusions de novo. The court found that the Minnesota law had the impermissible extraterritorial effect of controlling prices outside the state, similar to laws previously struck down by the Supreme Court. The court rejected Minnesota's argument that the law did not control out-of-state prices, noting that it effectively regulated out-of-state transactions if the drugs ended up in Minnesota.The Eighth Circuit affirmed the district court’s decision, agreeing that AAM was likely to succeed on the merits of its dormant Commerce Clause claim. The court also found no abuse of discretion in the district court’s assessment of the balance of harms and public interest, noting that protecting constitutional rights is always in the public interest. The preliminary injunction against the Minnesota law was upheld. View "Ass'n for Accessible Medicines v. Ellison" on Justia Law

The case involves a post-dismissal challenge to a trial court’s order that permanently sealed the petitioners’ actual names and allowed them to be identified by pseudonyms in court records. The petitioners, identified as John Does P, Q, R, and S, sought to prevent Thurston County from releasing unredacted sex offender records in response to a Public Records Act (PRA) request by Donna Zink. The trial court granted the Does’ motion for voluntary dismissal and entered a permanent order to maintain the use of pseudonyms and seal a court record listing their actual names.The trial court initially allowed the Does to proceed in pseudonym to preserve their ability to seek relief in their PRA injunction action. However, over the course of the litigation, nearly all of the Does’ PRA exemption claims were rejected, and Zink received most of the records she requested. The trial court’s preliminary orders allowing pseudonyms were based on the potential harm of being identified as sex offenders. On remand, the trial court granted the Does’ motion for voluntary dismissal and permanently sealed their names, citing compelling privacy and safety concerns.The Washington Supreme Court reviewed the case and held that the trial court abused its discretion in permanently sealing the Disclosure Document and allowing the Does to remain in pseudonym. The court found that the trial court’s findings were insufficient to satisfy GR 15 or the Ishikawa factors, which require specific and compelling reasons to restrict public access to court records. The court noted that the Does’ identities as sex offenders were already publicly available, and the trial court’s order did not articulate new compelling privacy or safety concerns. The Supreme Court remanded the case with instructions to unseal the Disclosure Document, use the Does’ actual names in future proceedings, and replace the pseudonyms in court records with their actual names. View "Doe P v. Thurston County" on Justia Law

In June 2016, Terae Harris, driving an Enterprise rental car, backed out of a parking space and struck James Joplin on his motorcycle. Enterprise offered Joplin a $25,000 settlement in exchange for releasing all claims against both Enterprise and Harris. Joplin did not respond, and in May 2018, he sued Harris for $300,000. In May 2020, Joplin’s new attorney found the signed release and sent it to Enterprise, but it was illegible. Harris filed a plea of accord and satisfaction, claiming the release barred Joplin’s suit.The Circuit Court of Henrico County admitted an unsigned copy of the release as evidence, ruling that the parol evidence rule did not apply because the unsigned release was used to confirm the terms of the illegible signed release. The court granted Harris’ plea of accord and satisfaction, barring Joplin’s suit. Joplin appealed, arguing the unsigned release was improper parol evidence, his attorneys lacked authority to settle, and there was no mutual assent.The Court of Appeals of Virginia reversed the circuit court, holding that the unsigned release was improper parol evidence and that Harris had not met the burden of proof for its admissibility. The court did not address Joplin’s other arguments.The Supreme Court of Virginia reviewed the case and found that the circuit court did not abuse its discretion in admitting the unsigned release. The court held that the parol evidence rule did not apply because the unsigned release was used to verify the terms of the illegible signed release, not to alter them. The court also found that the circuit court’s factual finding linking the two releases was supported by a preponderance of the evidence. Consequently, the Supreme Court of Virginia reversed the Court of Appeals and entered final judgment for Harris. View "Harris v. Joplin" on Justia Law

Alonzo McClanahan, a former employee of DPR Construction, claimed workers' compensation benefits for an injury to his right shoulder that he alleged occurred on July 25, 2017, while moving heavy materials at work. DPR's claims administrator denied the claim, and McClanahan sought adjudication from the Workers' Compensation Appeals Board (WCAB). During the trial, McClanahan testified about the injury, but DPR presented evidence and testimony from employees that contradicted his account. Medical evaluations were conducted by several doctors, including Dr. McGahan, who supported McClanahan's claim of an industrial injury.The Workers' Compensation Judge (WCJ) ruled in favor of McClanahan, finding his testimony credible and supported by medical evidence. DPR filed a petition for reconsideration, which the WCJ recommended denying. The WCAB granted the petition for further review but ultimately affirmed the WCJ's decision in a two-to-one decision, despite acknowledging that the Hanley reports, which were not listed in the pretrial conference statement, were admitted in error. The dissenting board member believed the error warranted a return to the trial level for correction.The California Court of Appeal, Third Appellate District, reviewed the case. The court found that the WCAB did not err in its credibility determination under section 5313, as the WCJ provided sufficient reasons for finding McClanahan credible. However, the court agreed with DPR that the admission of the Hanley reports, which were not listed in the pretrial conference statement, violated section 5502. The court held that this error was not subject to harmless error analysis and annulled the WCAB's decision, remanding the case for reconsideration without reference to the Hanley reports. View "DPR Construction v. Workers' Compensation Appeals Board" on Justia Law

Adetayo Sotade, a defendant in a criminal case in Douglas County, Colorado, is charged with second-degree kidnapping, sexual assault, and unlawful sexual contact. During the investigation, the Colorado Bureau of Investigations (CBI) conducted forensic testing, and it was later discovered that a CBI DNA analyst, Yvonne "Missy" Woods, had tampered with DNA testing in numerous cases. Sotade's defense team requested records related to Woods' misconduct from the CBI under the Colorado Criminal Justice Records Act (CCJRA). The CBI provided some documents but withheld others, prompting Sotade to file an application in the Douglas County District Court to compel the CBI to release the records.The Douglas County District Court held a hearing and concluded it had ancillary jurisdiction to hear the case, despite the CBI's argument that the court lacked jurisdiction because the records were located in Jefferson County. The CBI then filed a petition with the Colorado Supreme Court, arguing that the CCJRA requires such applications to be filed in the district where the records are located and that ancillary jurisdiction was not applicable.The Colorado Supreme Court reviewed the case and concluded that the plain language of the CCJRA requires that a show-cause hearing must take place in the district court where the records are located. The court held that ancillary jurisdiction is not available when a specific statutory provision applies. Therefore, the court made the order to show cause absolute, ruling that the Douglas County District Court did not have jurisdiction to hear the application and that it should have been filed in Jefferson County. View "People v. Sotade" on Justia Law

Ashley Hushen and Alexandra Weary, along with their mothers, reported allegations of sexual harassment by a classmate, Benjamin Gonzales, to their high school administrators. The school conducted a Title IX investigation, resulting in Benjamin's three-day suspension and subsequent juvenile charges for unlawful sexual contact. Benjamin was acquitted of all charges, and the school reopened the investigation, ultimately concluding that Benjamin had not violated school policies. The students involved felt traumatized by the process, and by the time the proceedings concluded, they had graduated.Benjamin later sued Ashley, Alexandra, and their mothers for defamation and intentional infliction of emotional distress based on statements made during the Title IX investigations. The defendants filed a special motion to dismiss under Colorado's anti-SLAPP statute, arguing that their statements were absolutely privileged as they were made during a quasi-judicial proceeding. Both the trial court and the Colorado Court of Appeals ruled that the Title IX proceedings were not quasi-judicial due to procedural shortcomings, allowing Benjamin's lawsuit to proceed.The Supreme Court of Colorado reviewed the case and clarified that the determination of whether a proceeding is quasi-judicial is separate from whether it offers sufficient due process. The court held that a proceeding is quasi-judicial if it involves determining the interests, rights, or duties of specific individuals and applying current law or policy to past or present facts. The court concluded that the Title IX investigation met these criteria and was therefore quasi-judicial. Consequently, the statements made during the investigation were protected by absolute privilege, and the lawsuit against Ashley, Alexandra, and their mothers could not proceed. The court reversed the decision of the court of appeals and remanded the case for further proceedings consistent with this opinion. View "Hushen v. Gonzales" on Justia Law

E.R., the appellant, filed a complaint against the Beaufort County School District, alleging that the district failed to respond appropriately to her reports of sexual abuse and harassment while she was a student. E.R. claimed she was sexually assaulted by three male students and subsequently bullied and harassed by other students. Despite reporting these incidents to school officials, she alleged that no appropriate action was taken.The case was initially filed in South Carolina state court, asserting claims under Title IX and state law for negligence and gross negligence. The school district removed the case to federal court and moved to dismiss it, arguing that the claims were untimely under the South Carolina Tort Claims Act (SCTCA), which has a two-year statute of limitations. The district court agreed, applying the SCTCA's statute of limitations to both the Title IX and state law claims, and dismissed the case as it was filed more than two years after E.R. turned 18.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the appropriate statute of limitations for Title IX claims is the state's general personal injury statute of limitations, not the SCTCA's two-year period. The court reasoned that Title IX claims should borrow the statute of limitations from the most analogous state law cause of action, which in this case is the general personal injury statute. Since South Carolina's general personal injury statute of limitations is three years, E.R.'s claims were timely.The Fourth Circuit vacated the district court's dismissal of E.R.'s complaint and remanded the case for further proceedings consistent with its opinion. View "E.R. v. Beaufort County School District" on Justia Law

The State of New Jersey sued the Dow Chemical Company in state court for the design, manufacture, marketing, and sale of 1,4-dioxane, a substance alleged to be highly toxic and a likely human carcinogen. Dow used 1,4-dioxane to inhibit 1,1,1-trichloroethane (TCA) to create a cleaning agent for metal. New Jersey claims that Dow’s products containing 1,4-dioxane caused substantial environmental harm. The case centers on whether the lawsuit should be heard in state or federal court.The United States District Court for the District of New Jersey remanded the case to state court. The District Court found that Dow was not acting under the United States Government when it produced and sold 1,4-dioxane inhibited TCA. Dow had argued that it acted under the federal government’s direction, citing the federal-officer removal statute, 28 U.S.C. § 1442(a)(1). However, the District Court concluded that Dow’s relationship with the government did not meet the criteria for federal-officer removal, as Dow had independently produced and sold the product before any relevant federal regulations were implemented.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court’s decision. The Third Circuit held that Dow did not satisfy the “acting under” requirement of the federal-officer removal statute. The court explained that Dow’s production and sale of 1,4-dioxane inhibited TCA were not directed, guided, or controlled by the federal government. Dow’s actions were independent and predated the government’s product specifications. Therefore, the case was properly remanded to state court, as Dow could not litigate under the federal-officer removal statute. View "Attorney General New Jersey v. Dow Chemical Company" on Justia Law

The case involves Plaintiff Craig Gabaldon, who was stopped by New Mexico State Police Officer Kevin Smith for multiple traffic violations, including improper merging, speeding, and failing to use a turn signal. During the stop, Officer Smith detected signs of intoxication and arrested Gabaldon after a struggle, during which a loaded gun was found on Gabaldon. Officer Kurtis Ward assisted in the arrest. Gabaldon filed a civil action alleging constitutional violations and state-law claims, asserting that the stop was motivated by his affiliation with the Bandidos Motorcycle Club.The United States District Court for the District of New Mexico granted Defendants' motion for sanctions for spoliation of evidence, as Gabaldon had returned his Bandidos gear to the club, which likely destroyed it. The court also granted summary judgment in favor of Defendants on Gabaldon's Fourth, Fifth, and Fourteenth Amendment claims, citing qualified immunity and finding reasonable suspicion for the traffic stop and probable cause for the arrest. Gabaldon's affidavit, which contradicted his deposition testimony, was struck down as a sham affidavit.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decisions, holding that the district court did not abuse its discretion in granting the spoliation motion or in striking Gabaldon's affidavit. The appellate court agreed that the affidavit was an attempt to create a sham fact issue, as it contradicted Gabaldon's earlier deposition testimony without new evidence. The court also upheld the summary judgment, finding that Officer Smith had reasonable suspicion to stop Gabaldon based on observed traffic violations. The appellate court concluded that the district court's rulings were correct and affirmed the judgment. View "Gabaldon v. New Mexico State Police" on Justia Law

The case involves a workplace accident where the decedent sustained severe head injuries, resulting in a persistent vegetative state and eventual death. The decedent's workers' compensation claim was allowed for several conditions, and he sought scheduled-loss compensation for the loss of use of his bilateral upper and lower extremities. The Industrial Commission of Ohio initially denied this claim, concluding that the loss of use was due to brain injury, not direct injury to the extremities.The decedent filed a mandamus action challenging the denial, but it was dismissed after his death. Subsequently, his surviving spouse, Byk, filed a motion with the commission for scheduled-loss compensation under R.C. 4123.57(B) and 4123.60. The commission denied this motion, stating that the decedent's entitlement to the loss-of-use award had already been determined and denied.Byk then filed a mandamus action in the Tenth District Court of Appeals, which granted a limited writ directing the commission to vacate its order and issue a new order adjudicating the merits of Byk’s claim. The commission and Republic Steel appealed this decision.The Supreme Court of Ohio reviewed the case and reversed the Tenth District's judgment. The court held that Byk was not entitled to scheduled-loss compensation under R.C. 4123.60 because the decedent was not "lawfully entitled to have applied" a second time for the same scheduled-loss compensation that had already been denied. The court emphasized that the statutory language did not authorize an injured worker to reapply for the same compensation after a final denial. Consequently, Byk's request for a writ of mandamus was denied. View "State ex rel. Byk v. Indus. Comm." on Justia Law