Justia Civil Procedure Opinion Summaries

Sherran Wasserman agreed to sell land in Franklin County to Anthony Pham, contingent on the approval of a conditional use permit by the Franklin County Board of Commissioners. Pham applied for the permit to build and operate chicken houses, but the Board denied the application. Wasserman then sued the Board and the County, initially bringing multiple claims under state and federal law. She dismissed some claims, conceded others, and the trial court dismissed her remaining state-law claims due to sovereign immunity. This left two federal claims: one alleging the County violated Pham’s equal protection rights based on race, and another alleging a violation of Wasserman’s equal protection rights as a “class of one.”The trial court denied the County’s motion for summary judgment, applying the federal doctrine of third-party standing, which allows a plaintiff to assert the rights of third parties. The court found genuine issues of material fact precluded summary judgment on standing and the merits of Wasserman’s equal protection claims. The Court of Appeals reversed, concluding Wasserman lacked third-party standing and that her “class of one” claim failed as a matter of law.The Supreme Court of Georgia reviewed whether a plaintiff may rely on the federal doctrine of third-party standing to establish constitutional standing in Georgia courts. The court held that Georgia’s constitutional standing requirements, rooted in the common law and consistent precedent, do not allow a plaintiff to maintain an action by asserting only the rights of a nonparty. The court overruled its previous adoption of the federal doctrine of third-party standing, concluding that a plaintiff must assert her own legal rights to invoke the judicial power of Georgia courts. The judgment was vacated and remanded for further proceedings consistent with this opinion. View "WASSERMAN v. FRANKLIN COUNTY" on Justia Law

Shawn Riley, a former prisoner at the Wisconsin Secure Program Facility (WSPF), filed a lawsuit under 42 U.S.C. § 1983 against WSPF’s Health Services Manager, Jolinda Waterman, and Nurse Practitioner Sandra McArdle. Riley alleged that they were deliberately indifferent to his serious medical needs, violating the Eighth Amendment. Riley experienced chronic pain and sought specific medical treatments, including high-top shoes recommended by specialists. Despite receiving various treatments, including medications, physical therapy, and custom orthotics, Riley claimed that his pain persisted and that the defendants ignored specialist recommendations.The United States District Court for the Eastern District of Wisconsin granted summary judgment in favor of the defendants and denied Riley’s motions to appoint counsel. The court found that the defendants were not deliberately indifferent to Riley’s medical needs, noting that they provided extensive medical care and followed many of the specialists' recommendations. The court also concluded that Riley’s requests for special shoes were reviewed and denied by the Special Needs Committee (SNC) and that the defendants' actions did not amount to deliberate indifference.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s decision, holding that the defendants did not ignore the specialists' recommendations and provided adequate medical care. The court also found that the defendants' refusal to allow Riley to purchase shoes from outside the approved catalog did not constitute deliberate indifference. Additionally, the court upheld the denial of Riley’s motion to appoint counsel, determining that Riley was competent to litigate his case and that the case did not present complexities that necessitated appointed counsel. The judgment of the district court was affirmed. View "Riley v. Waterman" on Justia Law

Three inmates in a California state prison jointly filed a lawsuit under 42 U.S.C. § 1983, alleging Eighth Amendment violations and false imprisonment due to being forced to stand in unsanitary conditions for nearly nine hours. One inmate also claimed excessive force. They applied to proceed in forma pauperis (IFP).The United States District Court for the Eastern District of California denied their request for joinder and severed their claims, requiring each inmate to file separately. The court reasoned that the Prison Litigation Reform Act (PLRA) required each prisoner to pay the full filing fee, and allowing joint actions would result in fees exceeding statutory limits. The court also cited practical issues with pro se prisoner lawsuits, such as potential transfers and communication difficulties, as reasons for denying joinder.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the PLRA does not prohibit prisoners from proceeding together in lawsuits, but it does require each prisoner to pay the full filing fee. The district court erred by interpreting the PLRA's fee provisions in isolation and failing to harmonize them. The Ninth Circuit also found that the district court abused its discretion in denying permissive joinder under Rule 20 of the Federal Rules of Civil Procedure based on hypothetical concerns not supported by the record.The Ninth Circuit reversed the district court's decision, allowing the inmates to proceed jointly under the PLRA, provided each pays the full filing fee. View "JOHNSON V. HDSP" on Justia Law

The Commonwealth sought to civilly commit a prisoner, previously convicted of a sexual offense, as a "sexually dangerous person" (SDP) under Massachusetts law. The process required expert testimony to establish probable cause and qualified examiners to determine if the case should proceed to trial. The plaintiff, George Mackie, was initially adjudicated as an SDP based on expert reports and testimony, but this decision was later vacated on appeal due to prejudicial error.Mackie then filed separate civil actions against Dr. Katrin Rouse-Weir, a probable cause expert, and Dr. Robert Joss, a qualified examiner, alleging they submitted false reports and testimony. Both defendants moved to dismiss the complaints, claiming immunity. Superior Court judges granted the motions, concluding that the defendants were entitled to absolute quasi-judicial immunity. Mackie appealed these decisions.The Appeals Court reversed the dismissals, ruling that the experts were entitled only to qualified immunity, not absolute quasi-judicial immunity. The Supreme Judicial Court of Massachusetts granted further appellate review.The Supreme Judicial Court held that qualified examiners like Joss are entitled to absolute quasi-judicial immunity due to their essential and independent role in the judicial process. The court also concluded that probable cause experts like Rouse-Weir are protected by the litigation privilege, which shields them from liability for their statements made during judicial proceedings. Consequently, the court affirmed the Superior Court judgments dismissing Mackie's complaints against both experts. View "Mackie v. Rouse-Weir" on Justia Law

Clover Boykin filed a lawsuit against Greenwood Leflore Hospital (GLH) under 42 U.S.C. § 1983, alleging that GLH intentionally withheld her medical records, preventing her from filing a medical malpractice suit. Boykin claimed that GLH's actions violated her constitutional right of access to the courts. GLH responded with a motion to dismiss, arguing that Boykin's claims failed as a matter of law, the employee was immune from suit, GLH was never served, and the suit was time-barred.The Leflore County Circuit Court denied GLH's motion to dismiss and granted Boykin additional time to serve GLH. GLH then sought an interlocutory appeal, which the Supreme Court of Mississippi granted. Boykin did not file a brief in response to the appeal.The Supreme Court of Mississippi accepted Boykin's failure to file a brief as a confession of error and found that Boykin's claims failed as a matter of law. The court held that HIPAA does not provide a private right of action and that Boykin could not use § 1983 to enforce a federal statute that does not give her an individual right. The court reversed the trial judge's denial of the motion to dismiss and rendered judgment in favor of GLH. View "Greenwood Leflore Hospital v. Boykin" on Justia Law

An inmate at Green Bay Correctional Institution, who is a practicing Muslim, filed a lawsuit under the Religious Land Use and Institutionalized Persons Act (RLUIPA) against the Wisconsin Department of Corrections (WDOC). He challenged WDOC's policy prohibiting inmates from leading religious programs when no outside religious leader or volunteer is available, claiming it resulted in unnecessary cancellations of religious programs. He also alleged that the cancellation of these programs breached a prior settlement agreement with WDOC.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of WDOC on the RLUIPA claim, finding that the policy was the least restrictive means of furthering the compelling interest of maintaining prison safety and security. The court also granted summary judgment in favor of the inmate on the state law breach-of-contract claim as to liability but relinquished supplemental jurisdiction over the request for injunctive relief.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's summary judgment in favor of WDOC on the RLUIPA claim, agreeing that the policy was the least restrictive means to ensure prison safety and security. However, the appellate court vacated the district court's partial judgment on the state law breach-of-contract claim. The court held that the district court abused its discretion by relinquishing jurisdiction over the remedy portion of the claim while retaining jurisdiction over liability. The case was remanded to the district court to determine whether to retain or relinquish jurisdiction over the entire state law claim. View "West v Hoy" on Justia Law

Kevin Johnson, an inmate in Indiana, filed a pro se lawsuit under 42 U.S.C. § 1983, alleging that he received inadequate dental and mental health care while incarcerated. The case was complicated by the COVID-19 pandemic and Johnson's frequent transfers between prisons in Indiana, Ohio, and Virginia, which disrupted his mail service. Johnson claimed he never received the defendants' summary judgment motions due to these mail issues.The United States District Court for the Southern District of Indiana initially denied the defendants' summary judgment motions without prejudice, recognizing potential mail delivery problems. The court allowed the defendants to refile their motions and instructed them to notify the court if Johnson did not receive the filings. Despite these measures, Johnson did not respond to the refiled motions within the given 28-day period. Consequently, the district court granted summary judgment in favor of the defendants and dismissed the case. Johnson later filed a motion to vacate the judgment, asserting he never received the refiled motions, but the district court denied this motion.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court acknowledged the procedural complexities but focused on whether Johnson had constructive notice of the summary judgment motions. The court concluded that Johnson had constructive notice because he received the district court's order resetting the briefing schedule and instructing him on how to proceed. The court found no substantive or procedural error in the district court's decision and affirmed the summary judgment in favor of the defendants. View "Johnson v Purdue" on Justia Law

Deari Cole was committed to a developmental center under California Welfare and Institutions Code section 6500, which allows for the commitment of individuals with developmental disabilities who are deemed a danger to themselves or others. Cole was charged with several crimes and found incompetent to stand trial. Subsequently, he was committed to the Porterville Developmental Center for one year. Just before the expiration of his commitment, the People filed a petition to extend it, and Cole was held pending trial on the recommitment petition. Cole filed a petition for writ of mandate or habeas corpus, arguing that equal protection principles required his release pending trial.The Contra Costa County Superior Court denied Cole's request for release pending trial, relying on section 6506, which allows for interim placement at a suitable facility. Cole's petition for writ of mandate or habeas corpus was summarily denied by the Court of Appeal. Cole then petitioned for review, and the California Supreme Court directed the Court of Appeal to vacate its order and issue an order to show cause.The California Court of Appeal, First Appellate District, Division Three, reviewed the case and rejected Cole's equal protection arguments. The court held that the statutory scheme under section 6500, which allows for continued confinement pending a hearing on a recommitment petition, did not violate equal protection principles. The court reasoned that the differences between individuals with developmental disabilities and those with mental health disorders or found not guilty by reason of insanity justified the different procedures. The court concluded that the legislative distinctions were reasonable and factually based. Consequently, the court dismissed Cole's petition as moot, as he had already been released from custody for unrelated reasons. View "Cole v. Superior Court" on Justia Law

In the 1950s, the Tucson Unified School District (the District) operated a dual school system for Black and non-Black students. In 1974, class action lawsuits were filed on behalf of African American and Latino students, leading to a 1978 settlement agreement and desegregation decree. Over the years, the District undertook numerous efforts to remedy past discrimination. In 2011, the Ninth Circuit reversed a district court's preliminary finding of unitary status, remanding the case for further supervision. A Unitary Status Plan (USP) was created in 2013 to guide the District towards unitary status.The District Court for the District of Arizona found partial unitary status in 2018, retaining jurisdiction over unresolved issues. By 2021, the court found the District had achieved unitary status in most areas, except for two subsections of the USP. In 2022, after further revisions and compliance, the district court declared the District had achieved full unitary status and ended federal supervision.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's judgment. The Ninth Circuit held that the District had achieved unitary status, meaning it had complied in good faith with the desegregation decree and eliminated the vestiges of past discrimination to the extent practicable. The court found no error in the district court's conclusions regarding student assignments, transportation, staff diversity, quality of education, student discipline, family and community engagement, and transparency and accountability. The Ninth Circuit emphasized that perfect implementation of the USP was not necessary for unitary status and that the District had demonstrated a lasting commitment to the USP and the Constitution. View "MENDOZA V. TUCSON UNIFIED SCHOOL DISTRICT" on Justia Law

Clarence Lewis, an inmate at Hill Correctional Center, sued various medical staff members, alleging they were deliberately indifferent to his health issues, violating the Eighth Amendment. Lewis claimed misdiagnosis and mistreatment of diabetes, COPD, irritable bowel syndrome, and Hepatitis C. He also contended that his grievance about a delay in diabetes medication was not properly addressed.The United States District Court for the Central District of Illinois denied Lewis's motions for recruited counsel, stating he could represent himself and obtain relevant documents. The court granted summary judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, concluding no reasonable juror could find deliberate indifference. The court also granted summary judgment for Dr. Paul, citing claim splitting due to a similar prior lawsuit.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the judgment in favor of Dr. Sood, Dr. Bautista, Nurse Vollmer, and Administrator Lindor, finding no reasonable likelihood that recruited counsel would have changed the outcome. The court noted that Lewis's disagreement with his diagnoses and treatments did not constitute deliberate indifference. As for Administrator Lindor, her limited role and the lack of harm from the medication delay further supported the judgment.However, the court vacated the judgment in favor of Dr. Paul, agreeing with Lewis that the district court's application of claim splitting was erroneous. Dr. Paul had raised this defense too late, effectively acquiescing to the claim. The case was remanded for further proceedings regarding Dr. Paul, with the district court advised to reconsider Lewis's request for recruited counsel if the claim proceeds to trial. View "Lewis v Sood" on Justia Law