Justia Civil Procedure Opinion Summaries

Sharon Lewis, a former employee of Louisiana State University (LSU) football department, reported sexual harassment by former head football coach Les Miles and assistant coach Frank Wilson. She claimed retaliation for these reports, including exclusion from meetings, restructuring of her position, and eventual termination in 2022. Lewis filed a lawsuit under Titles IX and VII against the LSU Board of Supervisors, alleging retaliation and hostile work environment.The United States District Court for the Middle District of Louisiana held a six-day trial, after which the jury found in favor of the Board on all claims. The district court entered judgment accordingly. Lewis filed a renewed motion for judgment as a matter of law or, alternatively, for a new trial, which the district court denied. Lewis then appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s judgment and denial of Lewis’s motions. The appellate court found that the jury had a legally sufficient evidentiary basis to conclude that Lewis’s termination was part of a broader restructuring initiative by new head coach Brian Kelly, rather than retaliation for her Title IX and Title VII complaints. The court noted that Kelly and other key decision-makers were unaware of Lewis’s prior complaints at the time of her termination. The court also found no abuse of discretion in the district court’s denial of a new trial, as the jury’s verdict was supported by the evidence presented. View "Lewis v. Board of Supervisors of Louisiana State University" on Justia Law

Christopher Shelton, Vicky Costa, and Todd Costa appealed two orders from the First Judicial District Court dismissing their claims against the State of Montana, Susan Ridgeway, and Axilon Law Group. The case arose from the adoption of L.S., Shelton's biological child, by a Utah couple. Melissa Surbrugg, L.S.'s biological mother, arranged the adoption before L.S. was born. After L.S.'s birth, Surbrugg and L.S. tested positive for drugs, leading to a report to the Department of Public Health and Human Services (DPHHS). Surbrugg relinquished her parental rights, and the adoptive parents took temporary custody of L.S. The Utah court later terminated Shelton's parental rights and finalized the adoption.The District Court dismissed the claims against Ridgeway and Axilon, ruling that they owed no duty to the plaintiffs as they represented Surbrugg, not the plaintiffs. The court also granted summary judgment to the State, finding that the Utah courts had already determined that Montana complied with the Interstate Compact on the Placement of Children (ICPC), thus precluding the plaintiffs' claims.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court's dismissal of the claims against Ridgeway and Axilon, agreeing that they owed no duty to the plaintiffs. The court also upheld the summary judgment in favor of the State, applying the doctrine of collateral estoppel. It concluded that the Utah courts had already decided the issue of ICPC compliance, and the plaintiffs had a full and fair opportunity to litigate this issue in Utah. The court also affirmed the dismissal of the plaintiffs' negligent misrepresentation claim, as the alleged misrepresentation related to a future event, not a past or existing fact. View "Shelton v. State" on Justia Law

Blossom Bell, a long-term public housing tenant, was held responsible for the criminal conduct of her guest, Daniel Lambert, who assaulted another tenant, Aaron George. Following the assault, Bell forbade Lambert from returning to her unit, and he never did. Despite this, the Oahu Eviction Board terminated Bell's rental agreement and evicted her.The Circuit Court of the First Circuit initially ruled that the Board applied the wrong legal authority and remanded the case for a new hearing. On remand, the parties agreed that the curability of Bell's violation would be governed by specific notification requirements in the rental agreement. The Board again ruled that Bell's violation was incurable and evicted her. Bell appealed, and the circuit court ruled that Bell had cured the violation by barring Lambert from the property, reversing the Board's eviction order and reinstating Bell's lease.The Supreme Court of the State of Hawai'i reviewed the case. The court held that the Board erred, abused its discretion, and acted arbitrarily and capriciously in evicting Bell. The court noted that the Board did not properly consider all relevant factors, such as the degree of crime in the housing project, the seriousness of the offending action, and the extent to which Bell took reasonable steps to mitigate the offending action. The court agreed with the circuit court that Bell's violation was curable and that she had cured it by permanently barring Lambert from the property. The Supreme Court affirmed the circuit court's final judgment reinstating Bell's lease. View "Bell v. Hawai'i Public Housing Authority" on Justia Law

In September 2020, inmate Garfield Holley, proceeding pro se, sued several officers at Wallens Ridge State Prison under Section 1983. Holley alleged that the officers transported him to a dental appointment in a dog cage and subjected him to subsequent mistreatment. He claimed that this treatment was in retaliation for filing a grievance about a delayed medical procedure. Holley, who has asthma, described being chained in a padlocked dog cage in near-freezing temperatures for over six hours, leading to pneumonia and delayed medical care. He also alleged a pattern of retaliatory treatment against prisoners who complained about their conditions.The United States District Court for the Western District of Virginia dismissed Holley's complaint without prejudice for failing to pay the filing fee, citing the three-strikes rule under the Prison Litigation Reform Act. The court found that Holley had not adequately alleged imminent danger of serious physical injury, as the incidents described occurred approximately two years before the complaint was filed. Holley's motion for reconsideration was denied, and he timely appealed.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that Holley had adequately pleaded imminent danger of serious physical injury, noting the specificity of his allegations and the ongoing pattern of retaliatory treatment against prisoners at Wallens Ridge State Prison. The court found that Holley's allegations were sufficient to meet the imminent-danger exception to the three-strikes rule. Consequently, the Fourth Circuit reversed the district court's decision and remanded the case for further proceedings. View "Holley v. Combs" on Justia Law

Cynthia Maldonado and Martha Amaro, who lived on both sides of the Oklahoma-Kansas border and in Mexico, appealed a trial court's order that Oklahoma had jurisdiction over a juvenile deprived proceeding under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). The trial court found that Maldonado's child, L.A., had resided in Oklahoma for six months preceding the commencement of the proceeding, making Oklahoma the child's home state. The court also adjudicated the children deprived as to Maldonado.The Texas County District Court of Oklahoma ordered that N.A. and L.A. be taken into emergency custody by the Oklahoma Department of Human Services (OKDHS) after Maldonado and N.A. tested positive for methamphetamine at birth. Maldonado filed a motion arguing that Oklahoma did not have jurisdiction under the UCCJEA, claiming that Mexico and Kansas were the children's home states. The State argued that Oklahoma had jurisdiction under the Oklahoma Children's Code. The trial court found that L.A. had lived in Oklahoma for six months before the proceeding and adjudicated the children deprived.The Supreme Court of the State of Oklahoma reviewed the case and affirmed the trial court's findings. The court held that the Oklahoma district court had subject matter jurisdiction over the juvenile deprived proceeding and that the UCCJEA applied to such proceedings. The court found that the trial court's determination that L.A. had resided in Oklahoma for six months preceding the proceeding was not clearly erroneous. The court also affirmed the trial court's order adjudicating the children deprived as to Maldonado, finding competent evidence to support the order. The appeal was not considered moot due to ongoing collateral consequences. View "IN RE: N.A.; STATE OF OKLAHOMA vs MALDONADO" on Justia Law

The case involves the detention and removal of Venezuelan nationals believed to be members of Tren de Aragua (TdA), a group designated as a foreign terrorist organization by the State Department. The President issued a proclamation under the Alien Enemies Act (AEA) to detain and remove these individuals. Five detainees and a putative class sought injunctive and declaratory relief against their removal under the Proclamation, initially seeking relief in habeas but later dismissing those claims.The District Court for the District of Columbia issued two temporary restraining orders (TROs) preventing the removal of the named plaintiffs and a provisionally certified class of noncitizens subject to the Proclamation. The court extended the TROs for an additional 14 days. The D.C. Circuit denied the Government’s emergency motion to stay the orders, leading the Government to seek vacatur from the Supreme Court.The Supreme Court of the United States construed the TROs as appealable injunctions and granted the Government's application to vacate the orders. The Court held that challenges to removal under the AEA must be brought in habeas corpus, as the claims necessarily imply the invalidity of the detainees' confinement and removal. The Court also determined that venue for such habeas petitions lies in the district of confinement, which in this case is Texas, making the District of Columbia an improper venue. The detainees are entitled to notice and an opportunity to seek habeas relief in the proper venue before removal. The application to vacate the District Court's orders was granted, and the TROs were vacated. View "Trump v. J. G. G." on Justia Law

H.B., III, a minor, needed a guardian after his father's death. He temporarily lived with his mother, Lasandra K., on the streets of Las Vegas before moving in with his uncle, Marques B. Marques petitioned the district court to be appointed as H.B.'s guardian, disclosing his felony conviction for attempted murder. The district court ordered a criminal background check, which confirmed the conviction. During the hearing, H.B.'s paternal grandmother supported Marques's petition, and Marques claimed Lasandra also supported it via text messages.The Eighth Judicial District Court, Family Division, denied the petition, concluding that Marques's felony conviction automatically disqualified him from serving as a guardian. Additionally, the court found that Marques failed to serve the petition and citation on all required relatives and interested parties, and did not meet the notice requirements or allege facts to support a waiver of notice. The petition was denied with prejudice, and the matter was closed.The Supreme Court of Nevada reviewed the case and held that a felony conviction does not automatically disqualify a potential guardian under NRS 159A.061(3). The statute requires the district court to consider various factors, including a felony conviction, but no single factor is dispositive. The district court erred by not considering all relevant factors. However, the Supreme Court affirmed the denial of the petition based on Marques's failure to properly effectuate service. The dismissal was affirmed without prejudice, and the district court was instructed to amend its order accordingly. View "IN RE: GUARDIANSHIP OF H.B. III" on Justia Law

In this case, the plaintiff, a tenured professor at a community college, filed a complaint alleging sexual harassment, retaliation, and related claims against the Los Angeles Community College District and a vice president of student services. The alleged harassment occurred over an eight-month period in 2017, during which the vice president made inappropriate comments and advances towards the plaintiff. The plaintiff also claimed retaliation when she did not comply with his demands, including attempts to move her program and firing her staff.The Superior Court of Los Angeles County presided over the trial, where a jury awarded the plaintiff $10 million in noneconomic damages. The defendants filed motions for a new trial and partial judgment notwithstanding the verdict, citing prejudicial errors in the admission of evidence and excessive damages. These motions were denied by the trial judge, who made inappropriate and irrelevant comments during the post-trial hearing, leading to his disqualification for cause.The California Court of Appeal, Second Appellate District, reviewed the case and found significant errors in the trial court's evidentiary rulings. The appellate court determined that the admission of 20-year-old newspaper articles and evidence of the vice president's misdemeanor convictions were prejudicial and irrelevant. Additionally, the testimony of a student who had filed a separate harassment complaint against a different administrator was improperly admitted, as it was not closely related to the plaintiff's circumstances and theory of the case.The appellate court concluded that these errors, combined with the excessive damages awarded, warranted a new trial. The judgment was reversed, and the case was remanded for a new trial. The defendants were awarded costs on appeal. View "Odom v. L.A. Community College Dist." on Justia Law

The United States District Court for the District of Massachusetts issued a temporary restraining order (TRO) on March 10, 2025, preventing the Government from terminating various education-related grants. The order also required the Government to pay past-due grant obligations and continue paying future obligations. The District Court concluded that the respondents were likely to succeed on the merits of their claims under the Administrative Procedure Act (APA).The Government filed an application to vacate the District Court's order on March 26, 2025, which was extended on March 24, 2025. The application was presented to Justice Jackson and referred to the Supreme Court. The Supreme Court noted that the District Court's order had characteristics of a preliminary injunction, making it appealable. The Government argued that the District Court lacked jurisdiction to order the payment of money under the APA, as the APA's waiver of sovereign immunity does not apply to claims seeking money damages or to orders enforcing contractual obligations to pay money.The Supreme Court of the United States granted the Government's application to stay the District Court's order pending the appeal in the United States Court of Appeals for the First Circuit and any subsequent petition for a writ of certiorari. The Court found that the respondents had not refuted the Government's claim that it would be unlikely to recover the grant funds once disbursed and that respondents would not suffer irreparable harm while the TRO is stayed. The stay will terminate automatically if certiorari is denied or upon the sending down of the judgment of the Supreme Court if certiorari is granted. The Chief Justice would have denied the application. View "Department of Education v. California" on Justia Law

Darnell Hairston was seriously injured while operating machinery at Zeeland Farm Soya, Inc. He sued Zeeland Farm Services, Inc. (ZFS) and an employee, later adding Specialty Industries, Inc. as a defendant for negligence and products liability. ZFS settled, but the case against Specialty Industries proceeded to trial, resulting in a jury awarding Hairston over $13 million. Specialty Industries had insurance policies with Burlington Insurance Company and Evanston Insurance Company, which paid their policy limits, leaving a significant portion of the judgment unpaid.The Ottawa Circuit Court denied Hairston and Specialty Industries' motion for supplemental proceedings to pursue a bad-faith refusal to settle claim against the insurers, suggesting they file a separate lawsuit. Hairston then served writs of garnishment on the insurers, which the trial court quashed, stating there was no judgment of bad faith. The trial court also imposed sanctions on Hairston for filing the writs.The Michigan Court of Appeals reversed the trial court's decision to quash the writs, relying on the precedent set in Rutter v King, which allowed bad-faith refusal to settle claims to be litigated through garnishment. However, the Court of Appeals affirmed the sanctions against Hairston.The Michigan Supreme Court reviewed the case and held that unresolved claims of bad-faith refusal to settle are not subject to garnishment under MCR 3.101(G)(1) because they are not sufficiently liquidated. The Court found that the Court of Appeals erred in relying on Rutter, which was decided before the current court rules were adopted. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "Hairston v. Lku" on Justia Law