Justia Civil Procedure Opinion Summaries

David Katleski, an experienced golfer, was struck by an errant golf ball while participating in a tournament at Cazenovia Golf Club. The accident occurred during a "shotgun start" tournament, where players tee off simultaneously from different holes. Katleski was hit while searching for a ball on the seventh fairway by a ball hit from the third hole. He sued the golf club, alleging negligent design and operation of the course, particularly the placement of tee box A on the third hole.The Supreme Court denied the club's motion for summary judgment, finding a triable issue of fact regarding whether the course's design unreasonably enhanced the risk. The Appellate Division reversed, granting summary judgment to the club, emphasizing Katleski's experience and awareness of the course layout. The court found no evidence that the course design exposed Katleski to risks beyond those inherent in golf. Katleski appealed to the Court of Appeals.The New York Court of Appeals affirmed the Appellate Division's decision, holding that the primary assumption of risk doctrine precluded Katleski's negligence claim. The court found that being struck by a mishit golf ball is an inherent risk of the sport, and there was no evidence that the course design unreasonably enhanced this risk.Mary Galante was injured in a separate incident at Elma Meadows Golf Course when she collided with a car while driving a golf cart in the parking lot. The Appellate Division denied her motion to strike the County's primary assumption of risk defense and granted summary judgment to the County. The Court of Appeals reversed, holding that the primary assumption of risk doctrine did not apply as Galante was not participating in a protected athletic or recreational activity at the time of her injury. The case was remitted to the Appellate Division for further consideration. View "Katleski v Cazenovia Golf Club, Inc." on Justia Law

Two former employees sued Zen Nails Studio LLC and its owners for violating the Fair Labor Standards Act (FLSA) and a similar Maryland state law. After a five-day bench trial, the plaintiffs won and were awarded approximately 60% of their requested damages. The plaintiffs then sought $343,189.85 in attorney’s fees, but the district court awarded them $167,115.49, which was less than half of what they requested. The plaintiffs appealed the district court’s decision regarding the hourly rates used to calculate the attorney’s fees.The United States District Court for the District of Maryland, at Greenbelt, initially reviewed the case. The district court set the hourly rates for the plaintiffs’ attorneys, paralegals, and paraprofessionals based on the local rules' guidelines, which it treated as presumptively reasonable. The court then calculated the hours reasonably worked and reduced the total by 35% due to the plaintiffs achieving a moderately successful outcome. The plaintiffs challenged the district court’s reliance on the local rules' guidelines for setting the hourly rates.The United States Court of Appeals for the Fourth Circuit reviewed the case. The appellate court held that the district court erred by treating the hourly rates in the local rules as presumptively correct and requiring special justification for higher rates. The Fourth Circuit emphasized that while fee matrices can be a useful starting point, they should not be treated as setting a baseline that requires special justification to deviate from. The appellate court vacated the fee award and remanded the case for further proceedings, instructing the district court to consider all relevant evidence to determine the prevailing market rates without giving undue weight to the local rules' guidelines. View "De Paredes v. Zen Nails Studio LLC" on Justia Law

Plaintiffs alleged that an automobile manufacturer designed, manufactured, and sold defective vehicles, specifically Dodge "muscle" cars with defective rear differentials. They filed a complaint asserting state and federal causes of action based on fraud and breach of warranty. The District Court dismissed the fraud counts and some warranty counts, allowing plaintiffs to amend their complaint. After amending, the District Court dismissed the fraud counts again and some warranty counts, but allowed two warranty counts to proceed.The United States District Court for the District of Delaware initially dismissed the complaint without prejudice, allowing plaintiffs to amend it. After the plaintiffs amended their complaint, the District Court dismissed the fraud counts and some warranty counts with prejudice, but allowed two warranty counts to proceed. The plaintiffs then moved to certify the dismissal of their fraud counts for appeal under 28 U.S.C. § 1292(b) or for final judgment under Rule 54(b). The District Court denied the request for certification under § 1292(b) but granted the request for final judgment under Rule 54(b) for the fraud counts.The United States Court of Appeals for the Third Circuit reviewed the case and determined that the District Court's Rule 54(b) judgment was not final. The Court of Appeals held that the fraud and warranty counts constituted a single claim for purposes of Rule 54(b) because they were alternative theories of recovery based on the same factual situation. As a result, the judgment did not dispose of all the rights or liabilities of one or more of the parties. Consequently, the Court of Appeals dismissed the appeal for lack of jurisdiction and instructed the District Court to vacate its order directing the entry of a partial final judgment. View "Diaz v. FCA US LLC" on Justia Law

Jina Garcia received treatment from St. Anthony North Hospital, operated by Centura Health Corporation, following a motor vehicle accident. Garcia informed the hospital that she had Medicare and Medicaid coverage and that her automobile insurance carrier was Progressive Insurance. Centura asserted a hospital lien against Garcia for $2,170.35 without billing Medicare first. Garcia filed a class action lawsuit against Centura, alleging violations of the hospital lien statute by filing liens before billing Medicare, seeking damages of twice the amount of the asserted liens.The District Court of the City and County of Denver certified a class and ordered Garcia to respond to substantial discovery requests from Centura. Garcia objected, arguing the requests were irrelevant, overbroad, and violated her privacy. The district court required Garcia to provide much of the requested discovery. Garcia sought relief from the Colorado Supreme Court, which issued an order to show cause and remanded the case for further proceedings, instructing the district court to determine the relevance and proportionality of the discovery requests.The Colorado Supreme Court reviewed the case again and concluded that the district court abused its discretion in ordering Garcia to respond to the discovery requests. The court found that the discovery sought by Centura was not relevant to the claims or defenses in the case and was not proportional to the needs of the case. The court emphasized that the principal factual issues were whether Centura asserted liens without billing Medicare and the amount of those liens. The court made its order to show cause absolute and remanded the case to the district court for further proceedings consistent with its opinion. View "Garcia v. Centura Health Corp." on Justia Law

An inmate at the Hancock County Jail, Monica J. Johnson, died by suicide after being incarcerated from September 21 to September 29, 2018. Her estate and surviving spouse filed a medical malpractice notice of claim against Hancock County and several county officials and employees, alleging negligence in her care. The County and its employees, along with Jail Housing Officer Kayla Dumond, appealed the Superior Court's denial of their motions for summary judgment.The Superior Court (Penobscot County) denied the motions for summary judgment, determining that it lacked jurisdiction to decide whether the Maine Health Security Act (MHSA) applied to the defendants and that the defendants had not demonstrated immunity under the Maine Tort Claims Act (MTCA). The Maine Supreme Judicial Court reviewed the interlocutory appeal.The court concluded that the issue of whether the defendants are "health care providers" under the MHSA is not immediately appealable. Additionally, the court decided to defer to the federal court on the issue of immunity under the MTCA, as the federal court is handling a related case involving the same parties and facts. Consequently, the appeal was dismissed, allowing the MHSA screening process to proceed, with the understanding that the federal court will continue with the litigation once the screening process is completed. View "Carney v. Hancock County" on Justia Law

James and David Hart were involved in a real estate transaction with Millennial Development Partners, LLC, from 2016 to 2022. The Harts filed a complaint in September 2021 seeking a declaratory judgment that future purchases would be unenforceable. The district court set a trial date for July 12, 2022, with a backup date of October 11, 2022, and required discovery to be completed sixty days before trial. Millennial answered the complaint on June 7, 2022, asserting eleven affirmative defenses and counterclaimed for declaratory relief. The Harts' counsel requested a trial continuance due to an undisclosed conflict of interest with previous counsel. The district court continued the trial to October and ordered the Harts to file a motion and brief establishing good cause to amend the scheduling order. The Harts failed to comply with this order.The district court of the Sixth Judicial District of Idaho struck the Harts' pleadings and dismissed the case without prejudice as a sanction for failing to follow the court’s scheduling order. Millennial moved for attorney fees, which the district court awarded on two grounds: as a sanction for disobeying the scheduling order and under Idaho Code section 12-121, finding the Harts pursued the case unreasonably. The district court calculated the award considering Idaho Rule of Civil Procedure 54(e)(3) factors and awarded Millennial $9,592.46 in attorney fees and costs. The Harts moved to reconsider, arguing the district court incorrectly applied Idaho Rule of Civil Procedure 37(d)(3) and prematurely applied Idaho Code section 12-121. The district court clarified its sanction under Rule 16(e) and upheld the award.The Supreme Court of Idaho affirmed the district court’s decision, holding that the district court did not abuse its discretion in sanctioning the Harts under Idaho Rule of Civil Procedure 16(e) and awarding attorney fees under Idaho Code section 12-121. The court also affirmed the calculation of attorney fees and awarded Millennial attorney fees on appeal under Idaho Code section 12-120(3). View "Petersen v. Millennial Development Partners, LLC" on Justia Law

David Katleski, an experienced golfer, was struck by an errant golf ball while competing in a tournament at Cazenovia Golf Club. The accident occurred during a "shotgun start" tournament, where players tee off simultaneously from different holes. Katleski was hit in the eye by a ball from another player teeing off from a nearby hole. He filed a negligence action against the golf club, claiming the course was negligently designed and operated, particularly pointing to the placement of a tee box that increased the risk of such accidents.The Supreme Court denied the golf club's motion for summary judgment, finding that there was a triable issue of fact regarding whether the course's design unreasonably enhanced the risk of being struck by a golf ball. However, the Appellate Division reversed this decision, granting summary judgment to the golf club. The court emphasized Katleski's experience and awareness of the course layout, concluding that the design did not expose him to risks beyond those inherent in the sport of golf. Katleski appealed to the Court of Appeals.The New York Court of Appeals affirmed the Appellate Division's decision, holding that the primary assumption of risk doctrine precluded Katleski's negligence claim. The court found that being struck by a mishit golf ball is an inherent risk of the game, and there was no evidence that the course's design unreasonably enhanced this risk.In a related case, Mary Galante was injured in a parking lot at a golf course before she began playing. The Appellate Division had applied the primary assumption of risk doctrine to dismiss her claim. However, the Court of Appeals reversed this decision, holding that the doctrine did not apply because Galante was not participating in a protected athletic or recreational activity at the time of her injury. The case was remitted for further proceedings. View "Katleski v Cazenovia Golf Club, Inc." on Justia Law

Entergy companies petitioned for review of three orders by the Federal Energy Regulatory Commission (FERC). FERC had rejected tariff changes proposed by Midcontinent Independent System Operator (MISO), arguing that the new tariff would grant Entergy excessive market power. Entergy contended that FERC’s decisions were arbitrary and capricious.The case was reviewed by the United States Court of Appeals for the District of Columbia Circuit. Entergy’s opening brief did not address the issue of standing, which is a jurisdictional prerequisite. This omission violated Circuit Rule 28(a)(7), which requires petitioners to set forth the basis for their claim of standing in their opening brief. As a result, Entergy forfeited any arguments in support of standing.The D.C. Circuit Court dismissed the petitions for review, stating that Entergy lacked standing. The court emphasized that Entergy’s failure to discuss standing in its opening brief constituted a forfeiture of the argument. Even if the court were to consider the standing arguments Entergy later advanced, the company did not demonstrate the necessary concrete, imminent, and redressable injury. The court concluded that dismissal was the appropriate consequence for Entergy’s failure to establish standing. View "Entergy Arkansas, LLC v. FERC" on Justia Law

Fell Holdings LLC and Stanyan Holdings LLC, misdescribed as California limited liability companies instead of Delaware limited liability companies, filed unlawful detainer proceedings against Fell Street Automotive Clinic, Stanyan Street Automotive Clinic, and Laurence Nasey. Nasey had lost ownership of two properties in San Francisco during a nonjudicial foreclosure but continued operating his businesses through a leaseback arrangement with the new owners, memorialized in a settlement agreement. The agreement allowed Nasey to repurchase the properties, with stipulated judgments against him if he failed to do so.The trial court entered judgments in favor of Fell Holdings and Stanyan Holdings, which were later enforced. Appellants moved to vacate these judgments, arguing that the misdescription of the plaintiffs' corporate status deprived the court of jurisdiction, rendering all judicial actions void. The trial court denied the vacatur motions.The California Court of Appeal, First Appellate District, reviewed the case. The court held that the misdescription of the plaintiffs' corporate status did not automatically void the judgments. Instead, the issue was whether the discrepancy could be cured by amendment under Code of Civil Procedure section 473, subdivision (a)(1). The court reversed the trial court's orders denying the vacatur motions and remanded the case, directing the trial court to vacate the judgments and enforcement orders without prejudice. The trial court was instructed to consider any motions by the plaintiffs to amend their complaints to correct the misdescription and to address appellants' arguments regarding the release of Nasey's $202,500 earnest money deposit. The parties were to bear their own costs on appeal. View "1215 Fell SF Owner LLC v. Fell Street Automotive Clinic" on Justia Law

Steven Gomes filed a lawsuit to invalidate ordinances regulating groundwater use in Mendocino, adopted by the Mendocino City Community Services District (the district). The district argued that Gomes’s claims were barred by res judicata due to a prior case, Gomes v. Mendocino City Community Services Dist. (2019) (Gomes I), which challenged the district’s groundwater management program. The trial court found the ordinances contained an invalid attorney’s fee provision but rejected Gomes’s other claims.In Gomes I, the trial court denied Gomes’s petition challenging the district’s 2007 groundwater measures, but the judgment was reversed on appeal. The appellate court found the district had authority to limit groundwater extraction and that the 2007 measures were invalid due to non-compliance with statutory procedures. The district subsequently adopted new ordinances in 2020, which Gomes challenged in the present case.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. Gomes argued the ordinances imposed fees for groundwater extraction that required voter approval, which the district did not obtain. The court concluded that the claim was not barred by Gomes I, as it involved different ordinances and provisions. The court held that the fees imposed by the district were not for the extraction of groundwater and thus did not require voter approval under section 10710. The judgment was affirmed, except for the invalid attorney’s fee provision. View "Gomes v. Mendocino City Community Services Dist." on Justia Law