Justia Civil Procedure Opinion Summaries

Maxwell Tillinghast, a 13-year-old student, collapsed from sudden cardiac arrest while jogging during a physical education class at Palms Middle School. Although the school had a defibrillator in the main office, the teachers were unaware of its presence. Despite being trained to use a defibrillator, the teachers could not utilize it, leading to Tillinghast's death. His father sued the Los Angeles Unified School District (LAUSD) and several employees, alleging negligence for failing to inform the teachers about the defibrillator.The Superior Court of Los Angeles County heard the case, where the jury focused on whether Tillinghast's latent heart defect would have been fatal even if the teachers had known about the defibrillator. The jury found the school district negligent and awarded Tillinghast's father $15 million in damages. The jury exonerated the school principal, Dr. Derek Moriuchi, from negligence.The LAUSD appealed to the Court of Appeal of the State of California, Second Appellate District, Division Eight, arguing that the trial court erred in giving a specific jury instruction (CACI No. 423) related to public entity liability for failure to perform a mandatory duty. The appellate court found that the school district had forfeited its objections to this instruction by not raising the issue during the trial. Additionally, the court noted that the school district had conceded mistakes were made regarding the defibrillator's availability and training.The Court of Appeal affirmed the judgment, holding that the evidence supported the jury's verdict and that the school district's failure to inform the teachers about the defibrillator constituted negligence. The court awarded costs to the respondent, Tillinghast's father. View "Tillinghast v. L.A. Unified School District" on Justia Law

In January 2023, J.F., a 39-year-old woman with a history of substance abuse, began experiencing severe delusions and paranoia, believing her parents wanted to kill her and her children. After a series of incidents, including living in her car and being admitted to the St. Vincent Stress Center, J.F. was temporarily committed by a trial court for up to ninety days due to her mental illness and inability to keep herself safe.J.F. appealed the commitment, arguing insufficient evidence supported the order. The Court of Appeals dismissed her appeal as moot, stating it did not present a novel issue or particularized harmful consequence. J.F. then petitioned for transfer to the Indiana Supreme Court.The Indiana Supreme Court held that temporary commitment appeals are not moot upon expiration unless the appellee proves no collateral consequences exist. The court emphasized the significant liberty interests and lifelong collateral consequences involved in such commitments, warranting appellate review. The court found sufficient evidence to support J.F.'s commitment, noting her impaired reasoning, inability to function independently, and the danger she posed to herself. Consequently, the court affirmed the trial court's temporary commitment order. View "In re Commitment of J.F." on Justia Law

Anthology, Inc. entered into a 10-year contract with Tarrant County College District (TCCD) in June 2022 to provide Enterprise Resource Planning products and services for approximately $42 million, plus annual fees. In October 2023, TCCD terminated the contract without cause, as permitted by the contract, but refused to pay the early termination fee and demanded a refund of about $1.7 million already paid. Anthology sued TCCD in the United States District Court for the Northern District of Texas, seeking a declaratory judgment and damages for breach of contract.TCCD moved to dismiss the case under Federal Rules 12(b)(1) and 12(b)(6), arguing four grounds: entitlement to immunity from suit under Texas law, state sovereign immunity, lack of diversity jurisdiction, and a statutory bar on recovering damages under Texas law. The district court granted TCCD’s Rule 12(b)(1) motion, dismissing Anthology’s claims without prejudice, based on TCCD’s entitlement to immunity from suit under Texas law, without addressing the other grounds for dismissal. Anthology appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the district court erred in its decision. The appellate court held that state-law immunity cannot limit the jurisdiction of federal courts, which is defined by the Constitution and Congress. Therefore, the district court should not have dismissed the case based on state-law immunity without first addressing the jurisdictional issues of state sovereign immunity and the absence of complete diversity. The Fifth Circuit vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Anthology v. Tarrant County College District" on Justia Law

An executive at a litigation funding company, Signal, resigned to start a competing business and sought legal advice from Signal’s outside counsel, Sugar Felsenthal Grais & Helsinger LLP. Signal sued the law firm and several of its attorneys, alleging legal malpractice, breach of contract, breach of fiduciary duty, and fraud. The district court dismissed some claims and granted summary judgment in favor of the defendants on the remaining claims. Signal appealed these rulings.The United States District Court for the Northern District of Illinois dismissed Signal’s breach of fiduciary duty claim and part of its fraud claim, allowing the legal malpractice, breach of contract, and fraudulent misrepresentation claims to proceed. The court also struck Signal’s request for punitive damages. During discovery, the court denied Signal’s motion to compel production of a memorandum prepared by one of the defendants. The district court later granted summary judgment in favor of the defendants on all remaining claims.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s rulings. The appellate court agreed that Signal failed to establish proximate cause and damages for its legal malpractice and breach of contract claims. The court also found that Signal waived its challenge to the summary judgment ruling on the fraudulent misrepresentation claim by not adequately addressing it on appeal. Additionally, the court upheld the district court’s decision to deny Signal’s motion to compel production of the memorandum, as Signal did not demonstrate that the document influenced the witness’s testimony. The appellate court concluded that the district court’s dismissal of the fraudulent concealment theory was harmless error and denied Signal’s motion to certify a question to the Illinois Supreme Court as moot. View "Signal Funding, LLC v Sugar Felsenthal Grais & Helsinger LLP" on Justia Law

In November 2021, a school shooting occurred at Oxford High School in Michigan, resulting in the deaths of four students and injuries to several others. This event had a profound impact on the local community, leading some families to transfer their children to other schools. Plaintiff C.S., a third-grade student at Robert Kerr Elementary School in Durand, Michigan, wore a hat depicting an AR-15-style rifle and the phrase "COME AND TAKE IT" to school during a "Hat Day" event. School officials, concerned about the potential for disruption given the recent shooting and the presence of transfer students from Oxford, asked C.S. to remove the hat.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the defendants, the school officials, concluding that their actions were justified under the circumstances. The court found that the school officials reasonably forecasted a substantial disruption due to the hat's imagery and message, particularly considering the recent trauma experienced by some students.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the school officials did not violate C.S.'s First Amendment rights by asking her to remove the hat. The court emphasized the unique context of the recent school shooting and the young age of the students, which justified the school officials' concerns about potential disruption. The court also found that the district court did not abuse its discretion in considering the defendants' untimely motion for summary judgment. View "C.S. v. McCrumb" on Justia Law

A man was injured in an accident outside city limits and sued a city and an emergency-responder employee for negligently providing assistance and aggravating his injuries. The city and employee offered the man $7,500 to settle the lawsuit, which he did not accept. They also moved for summary judgment, arguing that they could not be sued because AS 09.65.070(d)(4) does not allow lawsuits based on the “gratuitous extension of municipal services” beyond city limits. The superior court granted summary judgment in their favor, ruling that their actions were gratuitous because they were under no legal obligation to take them. The court also granted attorney’s fees to the city and employee based on a court rule that requires a party to pay the other side’s legal fees if the party rejected an offer of judgment to settle the case that was more favorable than the judgment the party ultimately received.The man appealed, arguing that the city’s emergency response was not gratuitous because he was billed a mileage fee for the ambulance service. He also argued that the city and employee were not entitled to attorney’s fees because their pretrial offer of judgment was invalid.The Supreme Court of the State of Alaska reviewed the case. The court held that AS 09.65.070(d)(4) bars the lawsuit because the city and employee’s actions were gratuitous, meaning they were performed without legal obligation and without charging more than the standard fee. The court also held that the offer of judgment was valid and that the superior court did not err in awarding attorney’s fees to the city and employee. The court affirmed the superior court’s grant of summary judgment and the award of attorney’s fees. View "Rochon v. City of Nome" on Justia Law

Plaintiffs, who are probationers, sued several Pennsylvania judges, probation officers, and the county warden, alleging they were detained without a finding that such detention was necessary to prevent flight or further crimes. They claimed their due process rights were violated as they were held for months without adequate preliminary hearings or credible probable-cause findings.The United States District Court for the Western District of Pennsylvania denied a preliminary injunction and later granted summary judgment for the defendants on both claims. The court held that the plaintiffs' novel claim for a new procedural right conflicted with Supreme Court precedent and found no genuine dispute of material fact regarding the county's adherence to existing constitutional rules in initial hearings.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that probationers do not have a due process right to a finding of necessity before being detained between preliminary and revocation hearings. The Supreme Court's decisions in Morrissey v. Brewer and Gagnon v. Scarpelli established that a finding of probable cause at a preliminary hearing is sufficient to warrant continued detention for a reasonable time until the revocation hearing.However, the Third Circuit found material factual disputes regarding whether the county followed due process rules, particularly concerning the adequacy of notice given to probationers before preliminary hearings. The court reversed and remanded the case in part, allowing plaintiffs to proceed with their claim that the county did not follow established due process procedures. View "Horton v. Rangos" on Justia Law

The case involves the Teachers' Retirement System of Alabama and the Employees' Retirement System of Alabama (collectively "RSA"), which received a land-use certificate from the Baldwin County zoning administrator to construct a five-story structure at The Grand Hotel. The Point Clear Property Owners Association, Inc. (PCPOA), representing around 400 members in the district, appealed the issuance of the certificate to the Baldwin County Board of Adjustment. The Board agreed with PCPOA and rescinded the certificate.RSA appealed the Board's decision to the Baldwin Circuit Court, which affirmed the Board's ruling. RSA then appealed to the Court of Civil Appeals, arguing that PCPOA was not "aggrieved" by the issuance of the certificate and thus lacked standing to appeal. The Court of Civil Appeals held that RSA had waived this argument by not raising it before the Board and cited the precedent set in City of Mobile v. Lee. The court also noted in a footnote that PCPOA did qualify as a "person aggrieved."The Supreme Court of Alabama reviewed the case and affirmed the Court of Civil Appeals' decision. The Supreme Court held that whether PCPOA was "aggrieved" was a waivable issue of capacity, not subject-matter jurisdiction. Therefore, RSA's failure to raise the issue before the Board constituted a waiver. The court did not address whether PCPOA was actually "aggrieved," as it affirmed the lower court's decision based on the waiver. View "Teachers' Retirement System of Alabama and Employees' Retirement System of Alabama v. Baldwin County Planning and Zoning Department" on Justia Law

A state agency, WorkForce West Virginia, and its Acting Commissioner, Scott A. Adkins, sought a writ of prohibition to prevent the enforcement of three orders issued by the Circuit Court of Kanawha County. These orders granted a writ of mandamus to the plaintiffs, denied WorkForce’s motion to dismiss, and allowed the plaintiffs to file a second amended complaint. The plaintiffs, who received unemployment benefits during the COVID-19 pandemic, alleged that WorkForce engaged in illegal collection activities by attempting to recover overpayments beyond the statutory time limits.The Circuit Court of Kanawha County ruled in favor of the plaintiffs, finding that WorkForce’s collection activities were time-barred by West Virginia Code § 21A-10-21, which imposes a two-year statute of limitations for recovering overpayments made due to error. The court also concluded that WorkForce could not determine overpayments due to nondisclosure or misrepresentation through its administrative process and must instead pursue such claims in circuit court. Based on this interpretation, the circuit court granted mandamus and injunctive relief, ordering WorkForce to cease its collection activities and comply with the statutory time limits.The Supreme Court of Appeals of West Virginia reviewed the case and found that the circuit court erred in its interpretation of the relevant statutes. The higher court concluded that the administrative process established by the Legislature allows WorkForce to determine whether overpayments occurred due to error, nondisclosure, or misrepresentation. The court emphasized that claimants must exhaust their administrative remedies before seeking judicial review, as mandated by West Virginia Code § 21A-7-19. Since the plaintiffs did not exhaust their administrative remedies, the circuit court lacked subject matter jurisdiction. Consequently, the Supreme Court of Appeals granted the writ of prohibition and directed the circuit court to dismiss the case. View "Adkins v. Bailey" on Justia Law

Ty Whitehead suffered a serious head injury during a bicycle training ride for a charity fundraiser due to a large pothole on Skyline Boulevard in Oakland. Whitehead alleged that the City of Oakland breached its statutory duty to maintain a safe roadway. Prior to the ride, Whitehead signed a release and waiver of liability, which included a provision discharging the City from any liability for negligence.The Alameda County Superior Court granted summary judgment in favor of the City, holding that the release was valid and enforceable, thus barring Whitehead’s claim. The court reasoned that the release did not affect the public interest, relying on the multifactor test from Tunkl v. Regents of University of California. The Court of Appeal affirmed the trial court’s decision, also relying on the Tunkl framework.The Supreme Court of California reviewed the case and concluded that the release was against public policy under Civil Code section 1668, which prohibits contracts that exempt a party from responsibility for their own fraud, willful injury, or violation of law. The court held that an agreement to exculpate a party for future violations of a statutory duty designed to protect public safety is unenforceable. The court reversed the judgment of the Court of Appeal and remanded the case for further proceedings, allowing the City to argue the doctrine of primary assumption of risk on remand. View "Whitehead v. City of Oakland" on Justia Law