Justia Civil Procedure Opinion Summaries

The plaintiff, a Belgian company, agreed to ship car parts made in Mexico to a Mexican plant operated by the defendants, a Delaware LLC and a Delaware corporation. The initial contract documents included a forum-selection clause pointing to a Mexican venue. However, the plaintiff later sued in Michigan, alleging that the parties had switched to a Michigan forum-selection clause during their transactions. The defendants moved to dismiss the suit under Federal Rule of Civil Procedure 12(b)(6) and the forum non conveniens doctrine, arguing that the Mexican forum-selection clause applied.The United States District Court for the Eastern District of Michigan granted the defendants' Rule 12(b)(6) motion, dismissing the suit without conducting a forum non conveniens analysis. The court found that the forum-selection clause in the initial contract documents, which pointed to a Mexican venue, was controlling.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the complaint plausibly alleged that the parties had switched to a Michigan forum-selection clause. The court noted that a factual dispute existed over which forum-selection clause applied to the plaintiff’s breach-of-contract claims. The court held that this venue issue could not be resolved on the pleadings under Rule 12(b)(6) or under the forum non conveniens doctrine without factual findings. Therefore, the Sixth Circuit reversed the district court's decision and remanded the case for further proceedings to resolve the factual disputes regarding the applicable forum-selection clause. View "VCST Int'l B.V. v. BorgWarner Noblesville, LLC" on Justia Law

Power Rental Op Co, LLC ("Power Rental") is a Florida-based company providing water and energy services. The Virgin Islands Water and Power Authority ("WAPA") is a municipal corporation in the U.S. Virgin Islands. In 2012, WAPA entered into a rental agreement with General Electric International, which Power Rental later acquired. By 2019, WAPA owed Power Rental over $14 million, which was reduced to approximately $9.3 million through a promissory note governed by New York law. WAPA defaulted on the note in 2020, leading Power Rental to sue in Florida state court for breach of the note and other claims.The case was removed to the Middle District of Florida, which dissolved pre-judgment writs of garnishment issued by the state court, granted partial summary judgment in favor of Power Rental, and ordered WAPA to complete a fact information sheet. The court found that WAPA waived its sovereign immunity defenses under the terms of the note. WAPA's appeal to the Eleventh Circuit was voluntarily dismissed.Power Rental registered the judgment in the U.S. District Court for the District of Puerto Rico, which issued a writ of execution served on WAPA's account at FirstBank in Puerto Rico. WAPA filed an emergency motion to quash the writ, arguing that the funds were exempt under Virgin Islands law and that the Puerto Rico court lacked jurisdiction. The District of Puerto Rico denied the motion, finding that the separate entity rule did not apply and that it had jurisdiction to issue the writ.The United States Court of Appeals for the First Circuit affirmed the District of Puerto Rico's order. The court held that the separate entity rule was outdated and did not apply, allowing the Puerto Rico court to have jurisdiction over the writ. The court also upheld the lower court's finding that WAPA had waived its statutory immunity defenses. View "Power Rental OP CO, LLC v. Virgin Islands Water and Power Authority" on Justia Law

Zayn Al-Abidin Muhammad Husayn, also known as Abu Zubaydah, was captured in Pakistan in March 2002, suspected of being an Al Qaeda leader. He was transferred to a CIA-operated secret prison where he was subjected to "enhanced interrogation techniques" by James Mitchell and John Jessen, psychologists contracted by the CIA. These techniques included waterboarding, sleep deprivation, and confinement in small boxes, which Zubaydah alleges amounted to torture. He was later transferred to Guantanamo Bay, where he remains detained as an enemy combatant.Zubaydah filed a lawsuit under the Alien Tort Statute seeking damages for the injuries he suffered during his detention and interrogations. The United States District Court for the Eastern District of Washington dismissed the case, citing lack of jurisdiction under the Military Commissions Act (MCA) of 2006, which denies federal courts jurisdiction over certain actions relating to the detention and treatment of enemy combatants by the United States and its agents.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The Ninth Circuit held that the MCA deprived the district court of jurisdiction because Zubaydah's claims related to his detention and treatment by the defendants, who were considered agents of the United States. The court found that the CIA had authorized, controlled, and ratified the defendants' actions, thereby establishing an agency relationship. Consequently, the MCA barred the court from hearing Zubaydah's claims. The decision was affirmed. View "HUSAYN V. MITCHELL" on Justia Law

South Hill Meat Lockers Incorporated (South Hill) alleged that the Idaho Transportation Department (ITD) caused damage to its building during a road construction project on U.S. Highway 95 in Bonners Ferry, Idaho. South Hill claimed ITD was liable under seven different causes of action, including negligence and constitutional violations. ITD moved for summary judgment, asserting "plan or design immunity" under Idaho Code section 6-904(7). The district court initially denied ITD's first motion for summary judgment but later granted ITD's second motion for partial summary judgment, dismissing four of South Hill's claims. After a change in judges, the new judge granted ITD's motion for reconsideration, dismissing South Hill's complaint with prejudice.The district court's rulings were mixed. Judge Buchanan initially denied ITD's first motion for summary judgment, finding genuine disputes of material fact. However, she later granted ITD's second motion for partial summary judgment, dismissing several of South Hill's claims. Upon Judge Buchanan's retirement, Judge Berecz reconsidered and granted ITD's first motion for summary judgment, dismissing all of South Hill's claims.The Idaho Supreme Court reviewed the case and vacated the district court's judgment. The court affirmed in part and reversed in part the district court's summary judgment rulings. The Supreme Court found that there were genuine issues of material fact regarding whether ITD's change orders and the gas line relocation were meaningfully reviewed, which precluded summary judgment on the basis of plan or design immunity. The court also reversed the dismissal of South Hill's nuisance claim, holding that a nuisance claim for damages can persist even after the nuisance has abated. The court affirmed the district court's rulings on other claims, including the determination that Idaho Code section 55-310 does not impose strict liability. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "South Hill Meat Lockers Incorp. v. Idaho Transportation Dept." on Justia Law

Mary Ann Arnold worked for United Airlines from 1994 to 2020. She alleged age discrimination, retaliation, hostile work environment, and constructive discharge after experiencing changes in her job responsibilities and being placed on a Performance Improvement Plan (PIP). Arnold claimed these actions were due to her age and previous complaints about discrimination and harassment.The United States District Court for the Northern District of Illinois granted summary judgment in favor of United Airlines on Arnold's claims of discrimination, retaliation, and hostile work environment. The court dismissed her constructive discharge claim without prejudice, citing failure to exhaust administrative remedies.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Arnold did not provide sufficient evidence to show that she suffered adverse employment actions due to age discrimination. The court also found that her retaliation claim failed because the actions taken by United were not materially adverse and were not shown to be causally connected to her complaints. Additionally, the court held that Arnold did not demonstrate a hostile work environment based on age, as the incidents she described were not severe or pervasive enough to meet the legal standard. The court also upheld the dismissal of her constructive discharge claim due to failure to exhaust administrative remedies. View "Arnold v. United Airlines, Inc." on Justia Law

Sheila Prato, the plaintiff, and her company, Prato Properties, LLC, filed a civil complaint against Thomas John Gioia and Lee & Associates Commercial Real Estate Services, Inc. (the Lee Firm) for breach of fiduciary duty and intentional interference with contract. The case was dismissed without prejudice due to the plaintiffs' failure to appear at trial. At the time of the trial, Prato's attorney, Timothy McFarlin, had been rendered inactive and ineligible to practice law by the State Bar of California due to pending disciplinary proceedings. Prato was unaware of her attorney's status, but the defendants and their counsel were aware and did not inform her or the court.The Superior Court of Orange County dismissed the case without prejudice and subsequently awarded over $70,000 in attorney fees against Prato and her company. The trial court granted the defendants' motions for attorney fees despite Prato's opposition, which argued that the defendants failed to provide the required notice under section 286 of the Code of Civil Procedure, which mandates that a party whose attorney has been removed or suspended must be given written notice to appoint another attorney or appear in person before further proceedings can be taken against them.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court found that the defendants' counsel failed to provide the required notice under section 286 before the trial, which prejudiced Prato. The court held that an attorney who has been rendered inactive and ineligible to practice law meets the definition of an attorney who has been "removed or suspended" for purposes of section 286. The court concluded that the trial court abused its discretion in awarding attorney fees to the defendants without considering the lack of notice and the circumstances surrounding Prato's unrepresented status.The Court of Appeal reversed the judgment and remanded the case to the trial court to reconsider the defendants' motions for attorney fees in light of section 286. View "Prato v. Gioia" on Justia Law

Plaintiffs, employees and independent contractors of White Oak Radiator Service, Inc., were injured while performing work at Enable Midstream Partners, LP's natural gas processing plant. The work involved removing and replacing amine and glycol coolers. During the work, a glycol surge tank ruptured, causing injuries. Plaintiffs filed a lawsuit seeking damages for their injuries.The trial court found that the claims of Joey Miller and Davy Dowdy against Enable sounded in tort rather than workers' compensation. The court awarded damages to Mr. Dowdy for injuries to his cervical spine and hearing loss, but found that White Oak bore a greater percentage of fault than assigned by the trial court. The trial court assigned 90 percent fault to Enable and 10 percent to White Oak. Enable appealed, arguing that the plaintiffs' exclusive remedy was under the Louisiana workers' compensation laws and challenging the allocation of fault and damages.The Supreme Court of Louisiana reviewed the case and held that the manual labor exception under La. R.S. 23:1021 (7) does not apply to the employees and independent contractors of an independent contractor. Therefore, plaintiffs' claims against Enable sound in tort. The court found no manifest error in the trial court's award of damages to Mr. Dowdy for his cervical spine injuries and hearing loss. However, the court found that the trial court erred in the apportionment of fault and amended the judgment to assign 70 percent fault to Enable and 30 percent fault to White Oak. The trial court's judgment was affirmed as amended. View "McBride v. Old Republic Insurance Co." on Justia Law

A general contractor, Keluco General Contractors, Inc., secured a workers’ compensation and employers’ liability policy through Travelers Property Casualty Company of America. The policy was set to last one year, expiring on March 5, 2017. After the policy expired, a Keluco employee was injured at work. Keluco attempted to make a claim on its workers’ compensation policy and discovered it had expired. Travelers claimed to have sent a notice of nonrenewal to Keluco and its insurance agent, Gretchen Santerre, but Keluco claimed it never received the notice.Keluco sued Santerre and her employer, Country Mutual Insurance Company, for failing to inform it of the nonrenewal notice. Santerre filed a third-party complaint against Travelers. The Superior Court of Alaska granted partial summary judgment against Travelers, ruling that it failed to send the nonrenewal notice in the manner required by statute, specifically by not obtaining a certificate of mailing from the United States Postal Service (USPS). The court found that Travelers breached its contract with Keluco.The Supreme Court of the State of Alaska reviewed the case. The court affirmed the Superior Court’s rulings on summary judgment, agreeing that Travelers violated AS 21.36.260 by not obtaining a certificate of mailing from USPS and thus breached its contract with Keluco. The court also affirmed the dismissal of Travelers’ contribution claim against Santerre, noting that Alaska law allows for the allocation of fault to a party who has settled out of a case.However, the Supreme Court reversed the Superior Court’s determination of when prejudgment interest began to accrue. The Supreme Court held that prejudgment interest should begin to accrue on September 20, 2017, the date the Keluco employee was injured and entitled to workers’ compensation benefits, rather than January 9, 2017. The case was remanded for recalculation of prejudgment interest. View "Travelers Property Casualty Company of America v. Keluco General Contractors" on Justia Law

The case involves three separate lawsuits filed by individuals, organizations, and states to prevent the enforcement of President Trump's Executive Order No. 14160. This order specifies conditions under which a person born in the United States is not considered a citizen. The plaintiffs argue that the order violates the Fourteenth Amendment's Citizenship Clause and the Nationality Act of 1940. District Courts in each case issued universal injunctions, preventing the order's enforcement against anyone, not just the plaintiffs. The Government sought to limit these injunctions to the plaintiffs, arguing that the courts lacked the authority to issue such broad relief.The District Courts concluded that the Executive Order was likely unlawful and issued universal preliminary injunctions. The Courts of Appeals denied the Government's requests to stay these injunctions. The Government then filed emergency applications with the Supreme Court, seeking partial stays to limit the injunctions to the plaintiffs.The Supreme Court of the United States reviewed the case and held that universal injunctions likely exceed the equitable authority granted to federal courts by Congress. The Court granted the Government's applications for partial stays, limiting the injunctions to the extent necessary to provide complete relief to each plaintiff with standing to sue. The Court emphasized that federal courts' equitable authority is confined to traditional remedies available at the time of the Judiciary Act of 1789, and universal injunctions do not have a historical precedent. The Court directed the lower courts to determine whether narrower injunctions would be appropriate. View "Trump v. CASA, Inc." on Justia Law

N.S. was arrested for robbery and destruction of property and was released on his own recognizance by a Magistrate Judge. However, before he could leave the courthouse, U.S. Marshals detained him based on an ICE detainer. N.S. filed a class complaint alleging that the Marshals acted beyond their statutory authority by making a civil immigration arrest, violating the Administrative Procedure Act.The United States District Court for the District of Columbia certified the proposed class and granted N.S.'s request for a permanent injunction, prohibiting Marshal Dixon and his agents from arresting and detaining criminal defendants in the Superior Court for suspected civil immigration violations. The court held that the Marshals were not authorized to make civil immigration arrests as they had not undergone the required training. The court also found that the 2002 Order delegating authority to the Marshals lacked sufficient legal support.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Marshals were not authorized to make civil immigration arrests due to the lack of required training. However, the court found that the class-wide injunction issued by the district court was barred by 8 U.S.C. § 1252(f)(1), which prohibits lower courts from enjoining the operation of certain immigration provisions. The court vacated the injunction and remanded the case to the district court to reconsider the appropriate remedy. View "N.S. v. Dixon" on Justia Law