Justia Civil Procedure Opinion Summaries

Seven District of Columbia citizen-voters filed a complaint challenging the constitutionality of the Local Resident Voting Rights Amendment Act of 2022, which allows noncitizens to vote in municipal elections. The plaintiffs argued that this law dilutes their votes, discriminates against U.S. citizens, and violates the constitutional right to citizen self-government. The District of Columbia Board of Elections, responsible for implementing the law, was named as the defendant.The case was initially brought in D.C. Superior Court, but the Board removed it to the United States District Court for the District of Columbia. The Board then moved to dismiss the case, arguing that the plaintiffs lacked standing and failed to state a claim. The district court agreed with the Board, holding that the plaintiffs did not demonstrate any individual disadvantage and thus lacked standing. The court dismissed the complaint, characterizing the plaintiffs' grievances as generalized and insufficient to confer standing.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the plaintiffs had standing to sue because they alleged a concrete and particularized injury: the dilution of their votes due to the expansion of the electorate to include noncitizens. The court distinguished this case from others where plaintiffs failed to show individualized harm. The court found that the plaintiffs' claims were specific to their voting power in D.C. local elections and not merely a generalized grievance. Consequently, the court reversed the district court's dismissal and remanded the case for further proceedings. The Board's cross-appeal was dismissed as moot. View "Hall v. District of Columbia Board of Elections" on Justia Law

In 2012, Bill Simmon, an employee of Vermont Community Access Media, Inc. (VCAM), invited Ciara Kilburn and her minor sister Brona to VCAM’s premises to record a commercial. Simmon secretly recorded the sisters changing clothes using VCAM’s equipment and shared the videos online, where they were viewed millions of times. In 2020, the Kilburns filed a lawsuit against Simmon for invasion of privacy, intentional infliction of emotional distress (IIED), and negligence per se, and against VCAM for vicarious liability, negligence, and negligent infliction of emotional distress (NIED).The Superior Court, Chittenden Unit, Civil Division, dismissed claims against Vermont State Colleges and did not instruct the jury on vicarious liability or NIED. The jury found Simmon liable for invasion of privacy and IIED, and VCAM liable for negligent supervision. Each plaintiff was awarded $1.75 million in compensatory damages against both Simmon and VCAM, and $2 million in punitive damages against Simmon. The court denied VCAM’s motions to exclude evidence, for a new trial, and for remittitur, and also denied plaintiffs’ request to hold VCAM jointly and severally liable for Simmon’s damages.The Vermont Supreme Court affirmed the lower court’s decision. It held that emotional-distress damages were available to plaintiffs for VCAM’s negligent supervision because the claim was based on intentional torts (invasion of privacy and IIED) for which such damages are recoverable. The court found no error in the jury’s award of damages, concluding that the evidence supported the verdict and that the damages were not excessive. The court also ruled that plaintiffs waived their claim for joint and several liability by not objecting to the jury instructions or verdict form before deliberations. View "Kilburn v. Simmon" on Justia Law

The case involves a wrongful-death action brought by the Estate of Jared Shaffer, through Daniel Shaffer as administrator, against Northeast Kingdom Human Services, Inc. Jared Shaffer, a developmentally disabled adult, died on April 18, 2017, from a sudden pulmonary embolism caused by metastatic testicular cancer. The estate claimed that the defendant, responsible for overseeing Jared's Medicaid waiver funds and coordinating his care, was negligent in its duties, leading to Jared's death.Initially, the estate sued Heartbeet Lifesharing, Dr. Peter Sher, and the defendant in federal court, but the case was dismissed for lack of subject matter jurisdiction after a settlement with Dr. Sher’s medical practice. The estate then filed the wrongful-death action in the civil division against the defendant and Heartbeet. Before the trial, the estate settled with Heartbeet, leaving the case to be tried solely against the defendant. The defendant asserted a comparative negligence defense, implicating Daniel Shaffer, Jared's father and co-guardian, in Jared's death.The Vermont Supreme Court reviewed the case after the estate appealed a jury verdict in favor of the defendant. The estate argued that the trial court erred in instructing the jury on comparative negligence, providing misleading jury instructions, and sustaining objections to certain questions posed to the defendant’s corporate representative. The estate also contended that the jury deliberated too quickly and that the evidence overwhelmingly supported its claim of negligence.The Vermont Supreme Court found that while the trial court erred in conflating the identity of the plaintiff with Daniel Shaffer, the estate was not prejudiced because the jury never reached the question of comparative negligence, having found no negligence on the defendant's part. The court also upheld the trial court's evidentiary rulings and found no error in the jury's deliberation process. The jury's verdict in favor of the defendant was affirmed. View "Shaffer v. Northeast Kingdom Human Services, Inc." on Justia Law

Johari Powell suffered serious injuries when her 2009 Hyundai Elantra stalled in traffic and was rear-ended. Powell alleged that the car stalled due to a fuel pump failure. Paul Swacina, on behalf of Powell and her minor children, sued multiple defendants in Texas state court, including Hyundam Industrial Company, Ltd., the manufacturer of the fuel pump. Hyundam, a South Korean company, filed a special appearance under Texas Rule of Civil Procedure 120a, requesting dismissal for lack of personal jurisdiction. Hyundam argued it had no business operations or direct sales in Texas and no control over where its products were sold.The trial court overruled Swacina’s objections to an affidavit by Hyundam’s Managing Director and denied Hyundam’s special appearance. The court of appeals affirmed, holding that Hyundam purposefully availed itself of the Texas market by designing fuel pumps for the North American region, which includes Texas. The court of appeals found that Hyundam’s actions were sufficient to establish personal jurisdiction in Texas.The Supreme Court of Texas reviewed the case and reversed the court of appeals' decision. The court held that there was no evidence Hyundam specifically targeted Texas. Designing a product for the North American region, which includes Texas, does not constitute purposeful availment of the Texas market. The court emphasized that mere foreseeability of a product ending up in Texas is insufficient for personal jurisdiction. The court concluded that Hyundam did not engage in any conduct specifically targeting Texas and thus did not purposefully avail itself of the Texas market. The Supreme Court of Texas rendered judgment dismissing the case against Hyundam. View "Hyundam Industrial Co. Ltd. v. Swacina" on Justia Law

Cesar Posada sued Osvanis Lozada and his employer, TELS, Inc., after a collision between their tractor-trailers. Posada claimed negligence and negligence per se against Lozada and sought to hold TELS vicariously liable. Lozada's tire unexpectedly lost air, causing his truck to jackknife and block the highway, leading to Posada crashing into it. Lozada and TELS filed no-evidence motions for summary judgment, which the trial court granted.The trial court in El Paso County granted the no-evidence motions for summary judgment filed by Lozada and TELS, dismissing Posada's claims. Posada's motions for a new trial were denied. The Court of Appeals for the Eighth District of Texas reversed the trial court's decision, holding that a reasonable jury could find that Lozada breached his duty of care and that his actions were the proximate cause of the collision. The court of appeals also reversed the summary judgment in favor of TELS, as their liability was predicated on Lozada's liability.The Supreme Court of Texas reviewed the case and concluded that Posada failed to produce summary-judgment evidence raising a genuine issue of material fact regarding whether Lozada breached his duty of care. The court noted that the evidence showed Lozada was driving under the speed limit when his tire rapidly lost air, causing the accident. There was no evidence Lozada acted negligently in response to the tire failure. Consequently, the Supreme Court of Texas reversed the court of appeals' judgment and reinstated the trial court's judgment, dismissing Posada's claims against Lozada and TELS with prejudice. View "Lozada v. Posada" on Justia Law

A Piper Light Sport Aircraft lost engine power and crashed on a runway in Addison, Texas, causing severe injuries to Sheema Shaik, a passenger, and emotional distress to her husband, Touseef Siddiqui. The Shaiks, Texas residents, filed a lawsuit in Dallas County against multiple parties, including BRP-Rotax GmbH & Co. KG (Rotax), the Austrian manufacturer of the aircraft engine. They claimed that Texas courts had specific personal jurisdiction over Rotax because it intentionally placed the defective engine into the stream of commerce, leading to its arrival in Texas.The trial court denied Rotax's special appearance motion to dismiss for lack of personal jurisdiction. The Court of Appeals for the Fifth District of Texas affirmed this decision, concluding that Rotax purposefully availed itself of the Texas market under the "stream-of-commerce-plus" test. The court of appeals cited Rotax's distribution agreement with Kodiak, its website, a repair center in Texas, and the number of Rotax engines registered in Texas as evidence of purposeful availment.The Supreme Court of Texas reviewed the case and reversed the lower court's decision. The court held that Rotax did not purposefully avail itself of the Texas market. The evidence showed that Rotax's engines reached Texas through the unilateral actions of third parties, not through any direct targeting or control by Rotax. The court emphasized that mere foreseeability of a product ending up in Texas is insufficient for establishing specific personal jurisdiction. Therefore, the case against Rotax was dismissed for lack of personal jurisdiction. View "BRP-Rotax GmbH & Co. KG v. Shaik" on Justia Law

Eric Jackson, a commercial tractor-trailer driver, was injured in a motor-vehicle collision in Morgan County, Alabama, on December 20, 2020. Jackson's personal vehicles were insured by State Farm Mutual Automobile Insurance Company under policies issued in Kentucky, which included uninsured/underinsured-motorist (UIM) coverage. In April 2022, Jackson sued the alleged at-fault driver in the Morgan Circuit Court. Later, he sought to amend his complaint to add State Farm as a defendant to recover UIM benefits. State Farm denied the claim, asserting that Jackson failed to file his UIM claim within the two-year period required by Kentucky law, as stipulated in the insurance policies.The Morgan Circuit Court granted State Farm's motion for judgment on the pleadings, concluding that Kentucky law governed the claim and that Jackson did not file his complaint within the required two-year period. Jackson appealed, arguing that Alabama's six-year statute of limitations should apply and that any contractual provision shortening this period was void under Alabama law.The Supreme Court of Alabama reviewed the case de novo. The court noted that Alabama enforces choice-of-law provisions in contracts unless they violate public policy. Jackson's policies explicitly incorporated Kentucky's two-year statute of limitations for filing accident-related tort claims. The court found that the policies were clear and unambiguous in this regard and that Kentucky law, which allows such contractual limitations, applied. The court distinguished this case from others where no specific choice-of-law provision was present or where the provision did not explicitly include procedural laws like statutes of limitations.The Supreme Court of Alabama affirmed the lower court's judgment, holding that the contractual provision incorporating Kentucky's two-year statute of limitations was valid and enforceable, thus barring Jackson's UIM claim. View "Jackson v. State Farm Mutual Automobile Insurance Co." on Justia Law

The case involves a dispute where Pranay Bajjuri and others (appellees) sued Anand Karney, Sudha Karney (appellants), and others for unjust enrichment, fraud, and civil conspiracy. The appellees alleged that the appellants fraudulently induced them to invest in various limited liability companies (LLCs) for purchasing and operating rental properties, but the appellants diverted the investments for personal gain. The appellants failed to produce financial and organizational documents related to the LLCs during discovery, leading to the current appeal.The District Court for Douglas County issued a scheduling order for discovery and trial. Despite repeated requests and a court order to compel, the appellants did not produce the required documents. The appellees filed a motion for sanctions, seeking default judgment and attorney fees. The district court found that the appellants had repeatedly violated discovery rules and had been previously warned of sanctions. The court granted the motion for sanctions, entering a default judgment of $2,201,385.82 and awarding attorney fees of $180,645.68 against the appellants.The Nebraska Supreme Court reviewed the case and upheld the district court's decision. The court found that the appellants had frustrated the discovery process and failed to comply with the court's order to compel. The court determined that the appellants, as members and managers of the LLCs, had the ability to obtain and produce the required documents but did not do so. The court concluded that the sanctions of default judgment and attorney fees were appropriate given the appellants' inexcusable recalcitrance and history of discovery abuse. The Nebraska Supreme Court affirmed the district court's orders, finding no abuse of discretion. View "Bajjuri v. Karney" on Justia Law

An adoptive mother, J.S., declined to take her teenage son, E.K., back into her home due to his history of violent behavior towards her and his siblings. The Indiana Department of Child Services (DCS) sought a CHINS 1 adjudication, alleging that the mother failed to provide necessary shelter. At the fact-finding hearing, the mother requested alternative CHINS adjudications based on the child endangering himself or others (CHINS 6) or his fetal alcohol syndrome diagnosis (CHINS 10). The trial court deferred to DCS’s filing decision and entered a CHINS 1 adjudication.The Whitley Circuit Court initially awarded DCS emergency custody of E.K. and later adjudicated him under CHINS 1 after the father admitted to the allegations. The mother contested the CHINS 1 adjudication, leading to a fact-finding hearing. The trial court found that E.K. posed a danger to himself and others but still adjudicated him under CHINS 1, citing the mother’s refusal to provide necessary shelter. The Indiana Court of Appeals affirmed the trial court’s decision.The Indiana Supreme Court reviewed the case and vacated the CHINS 1 adjudication, finding insufficient evidence that the mother either had the financial means to provide a safe home or failed to seek other reasonable means to do so. The court held that the trial court should have independently assessed whether a CHINS 6 or 10 adjudication was appropriate, rather than deferring to DCS. Due to procedural shortcomings, including the lack of proper notice and participation for E.K., the Supreme Court remanded the case for further proceedings consistent with its opinion. View "J.S. v. Department of Child Services" on Justia Law

The case involves a representative action under the Fair Labor Standards Act (FLSA) filed by Mamadou Bah against Enterprise Rent-A-Car Company of Boston, LLC, and Enterprise Holdings, Inc. Bah alleged that the defendants failed to pay overtime wages to assistant branch managers before November 27, 2016. Bah sought conditional certification of a class of similarly situated employees and requested the issuance of notice to potential opt-in plaintiffs. The defendants moved to stay the issuance of notice pending a motion to dismiss, which the district court granted. The district court later dismissed Bah's claims against Enterprise Holdings, Inc. for failure to state a claim, leading to further amendments to the complaint.The United States District Court for the District of Massachusetts initially dismissed Bah's claims against Enterprise Holdings, Inc. without prejudice, leading to the filing of an amended complaint. The district court eventually denied a motion to dismiss the second amended complaint, but by then, the statute of limitations had expired for potential opt-in plaintiffs. The district court conditionally certified a class and authorized notice, but the claims of the opt-in plaintiffs were dismissed as untimely. Bah requested equitable tolling of the statute of limitations due to the delay in issuing notice, which the district court denied.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying equitable tolling. The court found that the delay in issuing notice was attributable to Bah's own pleading errors and that the opt-in plaintiffs did not demonstrate the requisite diligence. The court affirmed the district court's decision to deny equitable tolling and dismiss the claims of the opt-in plaintiffs as untimely. View "Kwoka v. Enterprise Rent-A-Car Company of Boston, LLC" on Justia Law