Justia Civil Procedure Opinion Summaries

Plaintiffs, thirty survivors of childhood sexual abuse, sought damages for negligence from the Holy See under a vicarious liability theory. They alleged that the Holy See promulgated a mandatory policy of secrecy that governed how its dioceses and bishops handled reports of sexual abuse by clerics. Plaintiffs claimed that bishops in New York failed to warn children and parents of the dangers posed by the accused clerics and failed to report suspected abuse to law enforcement, thus emboldening abusers and exposing children to harm.The District Court granted the Holy See’s motion to dismiss for lack of subject matter jurisdiction under the Foreign Sovereign Immunities Act (FSIA). The court concluded that the discretionary function exclusion from the FSIA’s tortious activity exception barred Plaintiffs’ claims. The court found that the bishops’ conduct was discretionary and susceptible to policy analysis, thus falling within the discretionary function exclusion.The United States Court of Appeals for the Second Circuit reviewed the case de novo and affirmed the District Court’s judgment. The appellate court agreed that the discretionary function exclusion applied, precluding federal courts from exercising jurisdiction over the claims against the Holy See. The court held that the bishops’ challenged conduct involved discretionary acts and that Plaintiffs failed to allege that the bishops’ conduct violated a mandatory policy. Additionally, the court found that the bishops’ conduct was susceptible to policy analysis, satisfying the second prong of the Berkovitz/Gaubert test. Therefore, the discretionary function exclusion barred the exercise of jurisdiction over Plaintiffs’ claims against the Holy See. View "Blecher v. Holy See" on Justia Law

Hamdi A. Mohamud, a plaintiff, sued Heather Weyker, a St. Paul police officer, for wrongful arrest. Weyker, while working as a cross-deputized federal agent on a federal task force, allegedly lied to protect a federal witness, Muna Abdulkadir, leading to Mohamud's arrest. Weyker falsely claimed that Mohamud and others were trying to intimidate Abdulkadir, resulting in their arrest for witness tampering. Mohamud spent about 25 months in custody before the charges were dismissed.The United States District Court for the District of Minnesota previously reviewed the case. Mohamud's claims were based on Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics and 42 U.S.C. § 1983. The district court denied Mohamud's requests for limited discovery and to amend her complaint, concluding that further discovery would be futile and that the proposed amendment would not change the outcome. The court granted summary judgment in favor of Weyker, following the reasoning from a similar case, Yassin v. Weyker, which held that Weyker did not act under color of state law.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's judgment, holding that Weyker acted under federal authority, not state law, when she protected a federal witness in a federal investigation. The court found that the new facts alleged by Mohamud did not change the analysis from the Yassin case. The court also concluded that further discovery would not have made a difference and upheld the district court's denial of Mohamud's discovery request. View "Mohamud v. Weyker" on Justia Law

Jane Doe attended high school in City View Independent School District from 2016 to 2020, where she was allegedly sexually abused by her teacher, Robert Morris. The abuse reportedly began when Doe was a fifteen-year-old freshman and continued until she graduated. Doe claims that she reported the abuse to school officials in 2018, but they threatened her with retaliation and did not report the abuse to law enforcement. In 2022, after public outcry over Morris being named coach of the year, Doe publicly stated her experiences, leading to further threats from school officials.Doe filed a lawsuit against City View ISD and several school officials in the United States District Court for the Northern District of Texas on April 4, 2023. The district court dismissed her second amended complaint with prejudice, concluding that her claims were barred by the statute of limitations. Doe appealed the dismissal of her Title IX claims, arguing that her claims were timely due to the continuing violation doctrine or equitable tolling.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Doe's Title IX claims were barred by the statute of limitations, as they accrued no later than May 2020 when she graduated. The court also found that Doe's arguments for equitable tolling and the continuing violation doctrine were unavailing. Additionally, the court determined that Doe could not convert her First Amendment retaliation claim, based on a 2022 letter from a school official, into a Title IX retaliation claim. The court concluded that the district court did not abuse its discretion in denying Doe leave to amend her complaint. View "Doe v. City View Independent School District" on Justia Law

Eight citizens of Mali alleged that, as children, they were trafficked to Côte d’Ivoire and forced to work without pay on small, remote cocoa farms. After eventually returning to Mali, they brought a putative class action in the United States against seven major cocoa importers, claiming the companies violated the Trafficking Victims Protection Reauthorization Act (TVPRA) by knowingly benefiting from a supply chain that relied on forced child labor. The plaintiffs asserted that the importers orchestrated and controlled a cocoa supply chain “venture” and delayed meaningful action against child labor through their leadership of the World Cocoa Foundation.The United States District Court for the District of Columbia dismissed the complaint for lack of standing. The court found that the plaintiffs failed to connect the defendants to any specific cocoa plantations, including those where the plaintiffs had worked. The court concluded that the plaintiffs’ general, industry-wide allegations lacked the specificity required to establish causation under Article III of the Constitution. The plaintiffs appealed, and the United States Court of Appeals for the District of Columbia Circuit held the appeal in abeyance pending resolution of a similar case, Doe 1 v. Apple Inc.The United States Court of Appeals for the District of Columbia Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiffs lacked Article III standing because they did not plausibly allege facts showing a causal connection between their forced labor and the importers’ conduct. Specifically, the complaint failed to allege that the importers sourced cocoa, directly or through intermediaries, from the specific farms where the plaintiffs worked. The court distinguished this case from Doe 1 v. Apple Inc., where plaintiffs had plausibly traced their injuries to the defendants’ suppliers. The dismissal was affirmed. View "Coubaly v. Cargill Incorporated" on Justia Law

The case involves a dispute between the former owner-operator of a professional baseball franchise in Puerto Rico and the league, its president, and other franchise owners. The plaintiffs allege that the defendants conspired to force the former owner to relinquish control of the franchise, violating the Sherman Act, a federal civil rights statute, and various Puerto Rico laws. The plaintiffs claim that the defendants' actions were in retaliation for the former owner's public criticism of the conditions at the team's stadium and his proposal to move the team to another municipality.The United States District Court for the District of Puerto Rico dismissed the plaintiffs' Sherman Act claims, citing the "business of baseball" exemption. The court also ruled that the plaintiffs' claims under Puerto Rico's antitrust and fair competition laws were preempted by federal law. Additionally, the court dismissed the plaintiffs' federal civil rights claim on res judicata grounds, based on a prior judgment from the Superior Court of San Juan. The court then declined to exercise supplemental jurisdiction over the remaining Puerto Rico law claim.The United States Court of Appeals for the First Circuit affirmed the dismissal of the Sherman Act claims, agreeing that the "business of baseball" exemption applied to the Puerto Rico professional baseball league. However, the court vacated the District Court's dismissal of the Puerto Rico antitrust and fair competition claims, finding that the District Court had incorrectly applied the Supremacy Clause. The court also reversed the dismissal of the federal civil rights claim, concluding that the District Court had misapplied the doctrine of res judicata. Consequently, the court reversed the dismissal of the remaining Puerto Rico law claim, as a federal claim remained in the case. View "Cangrejeros de Santurce Baseball Club, LLC v. Liga de Beisbol Profesional de Puerto Rico, Inc." on Justia Law

A bus driver, Wendy Alberty, was involved in an incident where she locked a passenger in the luggage compartment of a bus during a layover. The passenger called the police from inside the compartment, leading to Alberty's arrest for reckless endangerment and breach of the peace, with an additional charge of unlawful restraint added later. All charges were eventually dropped, and Alberty sued three police officers for false arrest, malicious prosecution, and retaliatory prosecution, claiming lack of probable cause.The United States District Court for the District of Connecticut granted summary judgment in favor of the defendants, holding that the officers had probable cause to arrest Alberty and arguable probable cause to prosecute her. Alberty appealed the decision.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court's decision. The appellate court concluded that the officers had probable cause to arrest Alberty based on the evidence available at the time, including the passenger's 911 call, her identification of Alberty, and statements from another bus driver about company policy. The court also found that the officers had probable cause to prosecute Alberty for all charges, despite a video suggesting the incident might have been accidental. The court held that the video and the opinion of a trooper who viewed it did not dissipate probable cause. Consequently, the court affirmed the dismissal of Alberty's claims for false arrest, malicious prosecution, and retaliatory prosecution. View "Alberty v. Hunter" on Justia Law

Matthew Warman, a former graduate student at Mount St. Joseph University (MSJU), objected to taking the COVID-19 vaccine on religious grounds. When MSJU required all students and employees to be vaccinated, Warman applied for a religious exemption. He was allegedly detained by two MSJU Police Department officers who attempted to convince him to get vaccinated and disparaged his religious beliefs. Warman later sued MSJU, MSJPD, and several individual employees.The United States District Court for the Southern District of Ohio dismissed Warman’s complaint. The court dismissed his free exercise, equal protection, and disability discrimination claims with prejudice and dismissed MSJPD from all counts with prejudice. Warman appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of Warman’s free exercise, equal protection, and disability discrimination claims. However, the court found that Warman plausibly pleaded that the two officers who detained him violated his Fourth Amendment rights. Consequently, the court reversed the district court’s dismissal of Warman’s wrongful detention claim and reinstated the claim against those defendants. The court also vacated the district court’s declination of supplemental jurisdiction over Warman’s state-law claims and remanded for reconsideration.In summary, the Sixth Circuit affirmed the dismissal of most of Warman’s claims but reinstated his Fourth Amendment wrongful detention claim against the two officers and remanded the state-law claims for further consideration. View "Warman v. Mount St. Joseph University" on Justia Law

In February 2022, a Minneapolis SWAT team executed a no-knock search warrant at an apartment in search of a murder suspect. Inside, they found Amir Locke, the suspect’s cousin, asleep on a couch. Upon entry, officers kicked the couch and commanded Locke to get on the ground. Locke, wrapped in a blanket, fell to the ground and reached for a nearby handgun. Officer Hanneman ordered Locke to show his hands. Locke began to comply by lowering the gun's barrel and raising his left hand, but before he could fully comply, Hanneman shot Locke three times, resulting in Locke's death.Karen Wells and Andre Locke, co-trustees for Locke’s next of kin, filed a lawsuit against Officer Hanneman and the City of Minneapolis under 42 U.S.C. § 1983 and Minnesota’s wrongful death statute. They claimed Hanneman violated Locke’s Fourth Amendment rights and that the City failed to properly train its officers and address unconstitutional practices. Hanneman moved for judgment on the pleadings, asserting qualified immunity, arguing that body camera footage showed Locke posed a threat. The District Court for the District of Minnesota denied the motion, finding the footage did not clearly contradict the complaint’s allegations.The United States Court of Appeals for the Eighth Circuit reviewed the case and determined it lacked jurisdiction to decide the appeal. The court found that the body camera footage did not blatantly contradict the district court’s assumed facts that Locke did not raise the gun in a threatening manner. Consequently, the court dismissed the appeal, stating it could not address Hanneman’s qualified immunity claim or the City’s municipal liability and state-law claims. View "Wells v. Hanneman" on Justia Law

In May 2018, Raynaldo Sampy Jr. was arrested by seven officers from the Lafayette Police Department after driving into an ice cooler. During the arrest, Sampy was forcibly removed from his vehicle, handcuffed, and bent over a police car. He kicked Officer Rabb while being restrained, leading to his conviction for battery of a police officer in Lafayette City Court. Sampy later filed a lawsuit under 42 U.S.C. § 1983, alleging excessive force by the officers and retaliation for his speech.The United States District Court for the Western District of Louisiana dismissed Sampy’s Fourth Amendment excessive force claim, Fourth Amendment bystander liability claim, and First Amendment retaliation claim under Heck v. Humphrey, which bars claims that would imply the invalidity of a conviction. The court did not dismiss a claim regarding a third instance of alleged excessive force, which went to trial, and the jury found for the defendants. Sampy appealed the dismissal of the initial two uses of force.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissal de novo. The court held that Sampy’s excessive force claims were barred by Heck because they were not temporally and conceptually distinct from his battery conviction. The court found that the facts in Sampy’s complaint were inconsistent with those adjudicated in the criminal case. The court also held that Sampy’s bystander liability and First Amendment retaliation claims were barred by Heck. Consequently, the Fifth Circuit affirmed the district court’s judgment. View "Sampy v. Rabb" on Justia Law

Eugene Westmoreland, an Illinois inmate who uses a wheelchair, filed a class action lawsuit seeking prospective relief to make the showers at the Northern Reception and Classification Center (NRC) accessible. He claimed the showers were inaccessible to individuals using mobility aids. Westmoreland filed the suit without first using the prison's internal grievance process as required by the Prison Litigation Reform Act (PLRA). Six weeks after filing, he was transferred to a different facility with accessible showers, which led to questions about the mootness of his claim.The United States District Court for the Northern District of Illinois dismissed Westmoreland's suit for lack of subject matter jurisdiction, finding his claim moot due to his transfer. The court also determined that no exception to mootness applied, as Westmoreland had not exhausted the internal grievance process, making him an inadequate class representative.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Westmoreland's transfer rendered his claim moot and that he did not qualify for any exceptions to mootness. The court also found that Westmoreland's failure to exhaust the grievance process as required by the PLRA made him an inadequate class representative, preventing the class action from proceeding. Consequently, the court affirmed the dismissal of the suit. View "Westmoreland v. Hughes" on Justia Law