Justia Civil Procedure Opinion Summaries

When authorities booked Randall as a pretrial detainee, he was medicated and intoxicated and had a history of mental health treatment. Though Randall was supposed to “be followed for alcohol withdrawal syndrome and possible delirium tremens,” he was allegedly placed in a cell without an operable source of water, not monitored, nor provided any medication or liquids. The next day, officials found him hanging from his bedsheets. He eventually died there from his injuries.A complaint filed by Randall’s mother, Karen, under 42 U.S.C. 1983, alleged that Randall was survived by his wife, Kelsey and his biological parents. Karen later amended her complaint to “substitute Plaintiff with individual heirs,” adding Kelsey, and M.A., Randall’s minor child, and to allow M.A. to appear through Morrow, her mother. The district court dismissed, holding that Karen lacked standing and adding Kelsey and M.A. could not cure the initial jurisdictional defect.The Fifth Circuit reversed. The district court was “less than meticulous” in analyzing “standing.” While Karen lacked prudential standing because Louisiana law does not authorize her to bring this particular cause of action, she has Article III standing. She has a constitutionally cognizable interest in the life of her son, which does not depend on whether Louisiana law allows her to sue. View "Abraugh v. Altimus" on Justia Law

Robinson filed a 42 U.S.C. 1983 lawsuit six years and one day after police officers arrested and allegedly beat him. The day before he sued was Veterans Day, so federal courthouses were closed. The defendants argued that his claims were untimely. The district court asked whether some of the claims were really timely filed because the limitations period, which ordinarily would have ended on a “legal holiday,” actually “continue[d] to run until the end of the next day.” Fed. R. Civ. P. 6(a)(1)(C). Despite the hint, Robinson never made that argument himself, so the court dismissed the claims.The Eighth Circuit reversed in part. Robinson’s privacy, excessive force, and false-arrest claims were timely. Robinson’s failure to argue the federal-holiday rule was forfeiture, not waiver, as it involved inaction rather than acquiescence. Once the district court raised the federal-holiday rule, Robinson’s counsel thought there was little point in pressing the issue. Forfeiture is excusable in limited, well-defined circumstances, including when “the proper resolution is beyond any doubt,” for “purely legal issue[s]” that do not require “additional evidence or argument.” Here, how the federal-holiday rule works is clear, none of the relevant dates are in dispute, and everyone agrees that a six-year statute of limitations applies; this “purely legal issue” that is “beyond doubt.” Robinson’s malicious-prosecution claim, however, does not state” a constitutional claim and was properly dismissed. View "Robinson v. Norling" on Justia Law

The California Personnel Board (Board) sustained a complaint brought by Vickie Mabry-Height, M.D., against the Department of Corrections and Rehabilitation (Department) alleging discrimination based on age, race, and gender in violation of the California Fair Employment and Housing Act (FEHA). The Board concluded that Dr. Mabry-Height established a prima facie case of unlawful discrimination based on certain conduct, and the Department failed to rebut the presumption of discrimination by offering evidence that it had a legitimate, nondiscriminatory reason for this conduct. The Department petitioned the trial court for a writ of administrative mandamus seeking an order setting aside the Board’s decision. The petition was denied, and judgment was entered in favor of Dr. Mabry-Height. The Department appealed, but finding no reversible error, the Court of Appeal affirmed the trial court. View "Dept. of Corrections & Rehabilitation v. State Personnel Bd." on Justia Law

Williams and Burton each filed civil rights complaints in the Western District of Pennsylvania against employees of the Pennsylvania Department of Corrections and moved to proceed in forma pauperis (IFP). Burton alleged that the defendants retaliated against him after he filed a grievance, concerning his use of the law library. Williams alleged that prison staff refused to accommodate his special dietary needs. Both plaintiffs consented to have their cases heard by magistrate judges, who dismissed the cases before the defendants consented to magistrate judge jurisdiction.The Third Circuit vacated. A magistrate judge can acquire jurisdiction to decide a case only by the consent of the parties, 28 U.S.C. 631(c)(1); “consent of the parties” does not mean consent just of the prisoner-plaintiff. The jurisdictional requirement cannot be waived by the parties. If the requirements of Section 636(c)(1) are not satisfied, the “magistrate judge [is deprived] of jurisdiction over the case” and the appellate court is statutorily deprived of appellate jurisdiction over the magistrate judge’s orders. Consent could not be implied in this case and retroactive, post-judgment consent cannot satisfy the statutory requirement. View "Burton v. Schamp" on Justia Law

Plaintiffs Maldonado and Hill filed suit in Florida state court, asserting violations of their federal and state constitutional rights to the free exercise of their religion. After plaintiffs were granted in forma pauperis status by the state court, the case was removed to federal court where plaintiffs did not seek in forma pauperis status. The district court dismissed Maldonado's claims under 28 U.S.C. 1915(g)—the three-strikes provision of the Prison Litigation Reform Act (PLRA)—and dismissed Hill's claims for failure to exhaust administrative remedies.In regard to Maldonado, the Eleventh Circuit held that a case commenced in state court by a prisoner and removed by a defendant to federal court—with the defendant paying the filing fee after removal—is not subject to dismissal under 28 U.S.C. 1915(g). In regard to Hill, the Eleventh Circuit held that the district court erred in dismissing his claims for failure to exhaust his administrative remedies. Accordingly, the court reversed the district court's dismissal of plaintiffs' claims. View "Maldonado v. Baker County Sheriff's Office" on Justia Law

The Fifth Circuit treated the petition for rehearing en banc as a petition for panel rehearing; granted the petition for panel rehearing; and withdrew its prior opinion in this case.Plaintiffs, two Planned Parenthood entities and three Jane Does, filed suit under 42 U.S.C. 1983, alleging that the Louisiana Department of Health is unlawfully declining to act on Planned Parenthood's application for a license to provide abortion services in Louisiana. The district court denied the Department's motion to dismiss under Federal Rule of Civil Procedure 12(b)(1); the Department filed an interlocutory appeal; and plaintiffs moved to dismiss.The court denied the motion to dismiss the appeal because the Department asserted sovereign immunity in the district court. Therefore, the court has jurisdiction over this interlocutory appeal. The court further concluded that at least one of the plaintiffs' claims for injunctive relief is a valid invocation of federal jurisdiction under Ex parte Young. In this case, because plaintiffs' requested injunction to "promptly rule" on the license application satisfies the requirements of Ex parte Young, the court concluded that plaintiffs have survived the Department's Rule 12(b)(1) motion and the case may proceed. The court remanded for further proceedings. View "Planned Parenthood Gulf Coast, Inc. v. Phillips" on Justia Law

A circuit court denied Brittany Spiers leave to amend her complaint, and granted a motion to dismiss brought by Oak Grove Credit, LLC (OGC), and other companies, including, Columbia Credit, LLC, Pine Belt Credit, LLC, and “John Does Business 1-5” (collectively, “the Creditor Companies”). Spiers worked for OGC, a creditor business located just outside Hattiesburg, Mississippi, until February 2019. At that time, OGC terminated Spiers for reasons Spiers alleged were discriminatory. According to Spiers, OGC terminated her because of her gender and her pregnancy. Specifically, Spiers alleged that her supervisor raised concerns about her pregnancy in regards to work and childcare and even called her pregnancy a “disease.” Spiers also alleged that her supervisor declined to hire another person because that person was pregnant. In February 2020, Spiers filed her complaint primarily alleging pregnancy and sex discrimination under Title VII of the Civil Rights Act of 1964. Even though Spiers only worked for OGC, she brought her lawsuit collectively against OGC and the Creditor Companies because she alleged that these companies “constitute an integrated enterprise/joint employer in relation to Spiers as employees from each location are fluid and work for and between the sister companies.” Alternatively, Spiers alleged that “the Defendant’s actions constitute the torts of negligence, negligent infliction of emotional distress, intentional infliction of emotional distress, termination in violation of public policy, gross negligence, and negligent supervision.” OGC and the Creditor Companies removed the case to federal district court, which issued an order as to Spiers’s Title VII claim, finding that Spiers “did not plead sufficient facts for the Court to infer that Defendants meet Title VII’s definition of an employer.” The district court “dismiss[ed] Plaintiff’s Title VII claims without prejudice.” The district court, however, “declin[ed] to exercise pendent jurisdiction over Plaintiff’s remaining state-law claims and remand[ed] the case [back] to the Circuit Court of Lamar County, Mississippi.” Upon remand to the circuit court, Spiers filed a motion for leave to amend her complaint. The Mississippi Supreme Court affirmed the state circuit court's order dismissing the state-law claims, but reversed to the extent that the order denied Spiers leave to amend her complaint. The case was remanded for further proceedings. View "Spiers v. Oak Grove Credit, LLC, et al." on Justia Law

On remand from the Supreme Court, the Fifth Circuit concluded that unresolved questions of state law must be certified to the Texas Supreme Court. The court certified the following questions of state law to the Supreme Court of Texas: Whether Texas law authorizes the Attorney General, Texas Medical Board, the Texas Board of Nursing, the Texas Board of Pharmacy, or the Texas Health and Human Services Commission, directly or indirectly, to take disciplinary or adverse action of any sort against individuals or entities that violate the Texas Heartbeat Act, given the enforcement authority granted by various provisions of the Texas Occupations Code, the Texas Administrative Code, and the Texas Health and Safety Code and given the restrictions on public enforcement in sections 171.005, 171.207 and 171.208(a) of the Texas Health and Safety Code. View "Whole Woman's Health v. Jackson" on Justia Law

A patient sued a hospital after learning that a hospital employee intentionally disclosed the patient’s health information in violation of the Health Insurance Portability and Accountability Act (HIPAA). The patient alleged the disclosure breached the hospital’s contractual obligations to him. The superior court instructed the jury to return a verdict for the hospital if the jury found that the employee was not acting in the course and scope of employment when she disclosed the patient’s information. The jury so found, leading to judgment in the hospital’s favor. The Alaska Supreme Court found the jury instruction erroneously applied the rule of vicarious liability to excuse liability for breach of contract. "A party that breaches its contractual obligations is liable for breach regardless of whether the breach is caused by an employee acting outside the scope of employment, unless the terms of the contract excuse liability for that reason." The Court therefore reversed judgment and remanded for further proceedings, in particular to determine whether a contract existed between the patient and hospital and, if so, the contract’s terms governing patient health information. View "Guy v. Providence Health & Services Washington" on Justia Law

Plaintiff Scott Paine appealed a superior court decision granting judgment on the pleadings for his employment discrimination claim against defendant, Ride-Away, Inc. Plaintiff suffered from Post-Traumatic Stress Disorder (PTSD) for many years, which substantially limited a major life activity. He was employed by defendant at its facility in Londonderry, New Hampshire as an automotive detailer in May 2018. In July 2018, his physician prescribed cannabis to help treat his PTSD, and plaintiff enrolled in New Hampshire’s therapeutic cannabis program. Plaintiff submitted a written request to defendant for an exception from its drug testing policy as a reasonable accommodation for his disability. Plaintiff explained that he was not requesting permission to use cannabis during work hours or to possess cannabis on defendant’s premises. Plaintiff was informed that he could no longer work for the company if he used cannabis. After plaintiff notified defendant that he was going to treat his PTSD with cannabis, his employment was terminated in September 2018. Plaintiff sued for employment discrimination, based on defendant’s failure to make reasonable accommodation for his disability. Defendant moved for judgment on the pleadings, asserting that, because marijuana use was both illegal and criminalized under federal law, the requested accommodation was facially unreasonable. After a hearing, the trial court granted defendant’s motion. The sole question before the New Hampshire Supreme Court was whether the court erred in ruling that the use of therapeutic cannabis prescribed in accordance with New Hampshire law could not, as a matter of law, be a reasonable accommodation for an employee’s disability under RSA chapter 354-A. The Supreme Court held the trial court erred in determining that the use of therapeutic cannabis prescribed in accordance with RSA chapter 126-X could not, as a matter of law, be a reasonable accommodation for an employee’s disability under RSA chapter 354-A. "[P]laintiff’s disability is PTSD, not the illegal use of or addiction to a controlled substance." Judgment was reversed and the matter remanded for further proceedings. View "Paine v. Ride-Away, Inc." on Justia Law