Justia Civil Procedure Opinion Summaries

A Kentucky citizen who is subject to lifetime sex offender registration due to prior convictions challenged a new state law requiring certain sex offenders to display their full legal names on social media accounts they create or control. The law defines covered offenses as those committed against minors and applies to a wide range of social media platforms, with exceptions for services such as email and search engines. The plaintiff, who uses social media anonymously for personal and political expression, alleged that the law’s disclosure requirement would subject him and his family to harassment and would force him to stop using social media.The United States District Court for the Western District of Kentucky reviewed the case. Initially, it found the plaintiff was likely to succeed on his claim that the law infringed his First Amendment right to post anonymously and was overbroad, granting a preliminary injunction that barred all Kentucky County Attorneys from enforcing the law. The court later denied class certification, concluding the plaintiff lacked standing to represent absent class members against other County Attorneys and failed to meet requirements for class actions. Consequently, the injunction was narrowed to apply only to the named defendant and protect only the plaintiff.On appeal, the United States Court of Appeals for the Sixth Circuit found the district court erred in its facial overbreadth analysis. The Sixth Circuit held that a proper facial challenge under the First Amendment requires a comprehensive review of the law’s scope and its constitutional and unconstitutional applications, as described in Moody v. NetChoice, LLC. The district court had failed to conduct this thorough analysis and focused too narrowly on the plaintiff’s own circumstances. The Sixth Circuit vacated the preliminary injunction and remanded the case for further proceedings consistent with the proper two-step facial overbreadth approach. View "Doe v. Burlew" on Justia Law

Mahmoud Khalil, an Algerian citizen and lawful permanent resident, was arrested in March 2025 by Homeland Security agents at his New York City apartment and charged as removable under the Immigration and Nationality Act’s foreign-policy provision. Khalil, a Columbia University student and vocal advocate for Palestinian rights, was accused of having activities with potentially adverse foreign policy consequences for the United States. After his arrest, he was quickly transferred from New York to New Jersey, and then to Louisiana. His attorney initially filed a habeas petition in the Southern District of New York, seeking to enjoin his detention and removal, arguing retaliation against protected speech, and due process violations.The Southern District of New York, finding Khalil was already detained in New Jersey when the petition was filed, transferred the case to the U.S. District Court for the District of New Jersey. The New Jersey District Court asserted jurisdiction, denied the government’s motion to dismiss, and determined that the INA did not strip it of subject-matter jurisdiction. The court granted Khalil’s motion for a preliminary injunction on the foreign-policy removal charge, ordered that he not be removed, and later ordered his release from custody. Meanwhile, an immigration judge in Louisiana found Khalil removable on both foreign-policy and fraud charges and ordered his removal, resulting in conflicting mandates.Reviewing the case, the U.S. Court of Appeals for the Third Circuit held that the District Court had habeas jurisdiction, as the petition was properly transferred and related back to Khalil’s district of confinement. However, the Third Circuit found that 8 U.S.C. § 1252(b)(9) of the INA strips the District Court of subject-matter jurisdiction over claims arising from removal actions, channeling such claims into a petition for review of a final order of removal in the court of appeals. As a result, the Third Circuit vacated and remanded with instructions to dismiss Khalil’s habeas petition. View "Khalil v. President United States of America" on Justia Law

Several individuals who reside in DeKalb County, Georgia, outside the city limits of Atlanta, opposed the construction of a new public safety training facility on city-owned land and wished to collect signatures for a referendum petition to repeal the city ordinance authorizing the lease for the facility. Atlanta’s municipal code required that signature gatherers for such petitions be residents of the City of Atlanta. Because they did not meet this residency requirement, the plaintiffs filed suit against the City, arguing that the restriction violated their First Amendment rights. They sought a preliminary injunction to prevent enforcement of the residency requirement, as well as other relief connected to the signature collection process.The United States District Court for the Northern District of Georgia granted the preliminary injunction, enjoining Atlanta from enforcing the residency requirement for signature gatherers. The court also ordered the City to issue new petitions without the residency restriction and restarted the 60-day signature collection period, while counting previously collected signatures. The City appealed the injunction and obtained a stay from the United States Court of Appeals for the Eleventh Circuit.On appeal, the United States Court of Appeals for the Eleventh Circuit held that the plaintiffs failed to demonstrate irreparable harm sufficient for injunctive relief. The court specified that, under Kemp v. City of Claxton, 496 S.E.2d 712 (Ga. 1998), Georgia law does not allow the use of a referendum petition to challenge or repeal a city ordinance unless it amends the city charter. Because the plaintiffs could not lawfully utilize the referendum process for their intended purpose, they lacked a right to the process and consequently could not show irreparable injury. The Eleventh Circuit vacated the preliminary injunction and remanded the case to the district court for further proceedings. View "Baker v. City of Atlanta" on Justia Law

Indiana amended its laws in 2022 to prohibit and criminalize the use of telehealth and telemedicine for abortions, requiring that abortion-inducing drugs be dispensed and consumed in person by a physician in a hospital or qualified surgical center. The Satanic Temple, a Massachusetts-based religious nonprofit, operates a telehealth abortion clinic serving only patients in New Mexico but seeks to extend these services to its Indiana members. It does not run, nor intends to operate, an in-person abortion clinic in Indiana or maintain ties to Indiana hospitals or surgical centers. The Temple filed suit against the Indiana Attorney General and Marion County Prosecutor, seeking to enjoin enforcement of the criminal statute (§ 16-34-2-7(a)) and to obtain declaratory relief under Indiana’s Religious Freedom Restoration Act.The United States District Court for the Southern District of Indiana reviewed the case and granted the defendants’ motion to dismiss for lack of standing. The court found that the Satanic Temple failed to identify any specific member who suffered an injury from the challenged law, thus lacking associational standing. It also held that the Temple itself lacked standing, as it could not show an injury in fact and could not demonstrate that favorable relief would redress its alleged harms due to other Indiana laws independently barring its intended conduct.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the Satanic Temple lacked both associational and individual standing. The Temple failed to identify a specific injured member and relied only on statistical probabilities and generalized claims of stigmatic injury, which were insufficient. Additionally, the Temple did not present concrete plans to violate the law, and even if § 16-34-2-7(a) were enjoined, other statutes would independently prevent its telehealth abortion services in Indiana. Thus, the Seventh Circuit affirmed the dismissal for lack of subject matter jurisdiction. View "Satanic Temple, Inc. v Rokita" on Justia Law

Several individuals and organizations sought to circulate a petition to place a campaign finance ordinance on Houston’s ballot, but the city’s charter at that time required petition circulators to be both residents and registered voters of Houston. The plaintiffs did not meet these requirements. They notified the city of their intent to circulate petitions and challenge the constitutionality of the residency and voter registration requirements. The city initially did not clarify its position but later stated it would not enforce the challenged provisions. Despite this, the plaintiffs filed suit in federal court, seeking injunctive and declaratory relief, arguing that the requirements were unconstitutional under Supreme Court precedent.The United States District Court for the Southern District of Texas first granted the plaintiffs a temporary restraining order barring enforcement of the requirements. After the petition circulation period ended, the court dismissed the claims as moot following a stipulation by the parties. The plaintiffs moved to alter or amend the judgment, which was denied. On appeal, the Fifth Circuit reversed, holding that the plaintiffs had standing and that the case was not moot, and remanded for further proceedings. On remand, the district court granted the plaintiffs declaratory relief and, after the city repealed the challenged provisions, awarded the plaintiffs attorneys’ fees as prevailing parties. However, in a subsequent appeal, a different Fifth Circuit panel concluded there was no case or controversy because all parties agreed the provisions were unconstitutional, vacated the judgment, and remanded for dismissal.On remand, the district court vacated the attorneys’ fees award and ordered reimbursement to the city. The United States Court of Appeals for the Fifth Circuit affirmed this ruling, holding that after the prior appellate decision vacated the underlying merits judgment for lack of a case or controversy, there was no basis for a fee award under Rule 60(b)(5). The court also clarified that the city was not required to appeal the fee award directly, and the plaintiffs’ claims of prejudice were unavailing. View "Pool v. City of Houston" on Justia Law

The plaintiffs in this case are trustees who own a property in Kīhei, Maui, which they use as a vacation home for personal use. In 2021, Maui County reclassified their property as a “short-term rental” based solely on zoning, not actual use, resulting in a higher property tax rate. The plaintiffs paid the assessed taxes but did not utilize the administrative appeals process available through the Maui County Board of Review. Instead, they filed a class action in the Circuit Court of the Second Circuit, seeking a refund and alleging that the County’s collection of the higher taxes was unconstitutional, violated due process, and resulted in unjust enrichment.The Circuit Court of the Second Circuit granted the County’s motion to dismiss, finding it lacked subject matter jurisdiction. The court determined that under Hawai‘i Revised Statutes chapter 232 and Maui County Code chapter 3.48, the proper procedure for contesting real property tax assessments—including constitutional challenges—requires first appealing to the County Board of Review and, if necessary, then to the Tax Appeal Court. Because the plaintiffs bypassed these required steps and missed the statutory deadline to appeal, the court dismissed the case with prejudice.On appeal, the Supreme Court of the State of Hawai‘i affirmed the circuit court’s dismissal. The Supreme Court held that the Tax Appeal Court has exclusive jurisdiction over appeals regarding real property tax assessments, including those raising constitutional issues, and found that the plaintiffs’ claims were time-barred due to their failure to timely pursue the established administrative remedies. As a result, the Supreme Court affirmed the circuit court’s judgment dismissing the plaintiffs’ claims for lack of subject matter jurisdiction. View "Piezko v. County of Maui" on Justia Law

The case involves a Nevada-domiciled trust, managed by a Nevada family trust company, whose trustee petitioned the Second Judicial District Court of Nevada to seal confidential information and close all court proceedings under NRS 164.041 and NRS 669A.256. The district court sealed nearly all documents and concealed the existence of the case, citing concerns over revealing personal, financial, and business information, and later provided limited case information after media inquiries. Several media organizations, having reported on the matter—especially due to its connection to Rupert Murdoch and control over major media holdings—sought intervention to access court records and proceedings, arguing that the First Amendment presumption of public access applied.The probate commissioner recommended allowing media intervention but denying access, and the district court entered an order adopting this recommendation. The court interpreted the statutes as granting automatic and comprehensive confidentiality, finding that privacy and security concerns—heightened by the parties’ public profiles—constituted a compelling interest for sealing and closure. The district court also concluded it lacked discretion to consider redaction as an alternative and held that the statutes’ confidentiality provisions justified the broad closure, even after the Nevada Supreme Court’s decision in Falconi v. Eighth Judicial District Court recognized a First Amendment presumption of access in civil and family court proceedings.The Supreme Court of Nevada reviewed the district court’s decision, holding that NRS 164.041 and NRS 669A.256 permit only provisional sealing and require judicial discretion. The statutes do not automatically justify blanket sealing or closure, nor do they displace the common law or constitutional presumption of openness. The court found that the district court failed to make specific, non-speculative factual findings to justify the sealing and closure and did not adequately consider less restrictive alternatives. The Supreme Court granted the petition for a writ of mandamus, directing the district court to vacate its sealing order and conduct the required analysis for each document and hearing transcript. View "New York Times Co. v. District Court" on Justia Law

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

After Mikel Neil fled from a traffic stop initiated by two St. Louis County police officers, a high-speed chase ensued, reaching speeds over ninety miles per hour through a residential area. During the pursuit, one of the officers used a PIT maneuver, causing Neil’s vehicle to crash into a tree, resulting in his death. The officers left the scene without administering aid or calling for assistance and later falsely reported the crash as a single-car incident. Neil’s mother, Clara Cheeks, brought a federal civil rights action under 42 U.S.C. § 1983, alleging that the officers had used excessive force.The United States District Court for the Eastern District of Missouri dismissed Cheeks’s excessive force claim, finding that the officers were entitled to qualified immunity because the complaint did not sufficiently allege a constitutional violation. Over a year after the dismissal, and after the deadline for amending pleadings had passed, Cheeks sought leave to amend her complaint to revive the excessive force claim. The district court denied the motion, concluding that the proposed amendments would be futile. Cheeks then appealed the dismissal and the denial of leave to amend, after voluntarily dismissing her remaining claim for failure to provide medical aid.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decisions. The Eighth Circuit held that, under the circumstances described in the complaint, the use of a PIT maneuver during a dangerous high-speed chase did not constitute excessive force in violation of the Fourth Amendment, following precedents such as Scott v. Harris. The court also concluded that the district court did not abuse its discretion in denying leave to amend, because the proposed amendments would not cure the deficiencies in the excessive force claim. The court’s disposition was to affirm the dismissal and denial of leave to amend. View "Cheeks v. Belmar" on Justia Law

Michelle Evans attended a debate at the Texas Capitol in May 2023 regarding gender reassignment treatments for children. While at the Capitol, Evans encountered a transgender politician in the women’s restroom. A photo of this individual washing their hands was posted to Facebook by someone in Evans’s group, and Evans subsequently tweeted the same photo with a caption expressing her belief that the politician should not have used the women’s restroom. The tweet led to controversy and an investigation by the Department of Public Safety, prompted by Travis County District Attorney José Garza, to determine if Evans’s actions violated Texas Penal Code § 21.15(b), which prohibits transmitting images of individuals in bathrooms or changing rooms without consent and with intent to invade privacy.Evans sought a temporary restraining order and preliminary injunction in the United States District Court for the Western District of Texas, aiming to prevent Garza from investigating or prosecuting her for disseminating the photograph. She argued that the statute was unconstitutional both facially and as applied to her conduct, citing First and Fourteenth Amendment grounds. The district court denied her requests for injunctive relief, reasoning that the equities weighed against granting the injunction, and that the values underlying abstention doctrines informed its decision. The court found no ongoing state judicial proceeding that would trigger abstention and did not make explicit findings on the likelihood of success on the merits.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s denial of a preliminary injunction. The appellate court held that Evans had standing but agreed that she failed to meet her burden to demonstrate a substantial likelihood of success on the merits or that the balance of harms justified injunctive relief. The Fifth Circuit concluded that the statute was not facially unconstitutional and that Evans had not shown it was unconstitutional as applied to her situation. The district court’s judgment was affirmed. View "Evans v. Garza" on Justia Law