Justia Civil Procedure Opinion Summaries

Mark Hamilton, the former Chief of the Fire Department of Wilmer, Texas, was terminated after testifying at a probation revocation hearing for a former employee, Craig Lawrence, who had hidden recording devices in fire station bathrooms. Hamilton testified in uniform, drove a city car to the hearing, and did not take leave from work. He claimed his termination was in retaliation for his protected First Amendment activity.The United States District Court for the Northern District of Texas dismissed Hamilton's complaint under Federal Rule of Civil Procedure 12(b)(6). The court found that Hamilton did not state a claim for First Amendment retaliation, as his speech was not protected under the First Amendment. Hamilton appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that Hamilton did not speak as a citizen on a matter of public concern, as his testimony was given pursuant to his official duties as Fire Chief. The court also found that even if Hamilton's speech were protected, the City of Wilmer had adequate justification for treating him differently from any other member of the public due to his use of city resources and uniform during his testimony. The court affirmed the district court's dismissal of Hamilton's claims and denied his request for leave to amend his complaint, finding that any amendment would be futile. View "Hamilton v. City of Wilmer, Texas" on Justia Law

After a welfare check was requested by his fiancée, Joseph Maser was involved in a standoff with police at his suburban Iowa home. Maser had threatened suicide, fired a gun inside his house, and was reportedly intoxicated with access to firearms. Officers attempted to negotiate with Maser for nearly an hour, during which Maser became increasingly agitated and made threats. Maser exited his garage holding a rifle, ignored commands to drop the weapon, and raised the rifle outward from his body. Officer Joshua Van Brocklin, perceiving a threat, shot Maser twice in the chest. Maser survived and subsequently brought a claim under 42 U.S.C. § 1983, alleging that Officer Van Brocklin used excessive force in violation of the Fourth Amendment.Initially, Maser filed suit in state court against Officer Van Brocklin, the City of Coralville, and other officers, asserting both state and federal claims. The case was removed to the United States District Court for the Southern District of Iowa. Following a decision by the Iowa Supreme Court in Burnett v. Smith, which foreclosed excessive force claims under the Iowa Constitution, the district court granted summary judgment on those claims. The district court also granted summary judgment for Officer Van Brocklin on the federal excessive force claim, finding no constitutional violation and awarding qualified immunity.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that, under the totality of the circumstances, Officer Van Brocklin’s use of deadly force was objectively reasonable because Maser’s actions—raising a rifle outward after repeated noncompliance and threats—created an imminent threat of serious harm. The court found no genuine dispute of material fact and affirmed the district court’s grant of summary judgment, holding that Maser’s Fourth Amendment rights were not violated. View "Maser v. City of Coralville, IA" on Justia Law

The Association for Accessible Medicines (AAM), representing generic drug manufacturers, challenged a Minnesota law regulating drug prices, Minn. Stat. § 62J.842, arguing it violated the dormant Commerce Clause. The law prohibits manufacturers from imposing excessive price increases on generic or off-patent drugs sold in Minnesota. The district court granted AAM's motion for a preliminary injunction, finding the law likely violated the dormant Commerce Clause.The United States District Court for the District of Minnesota concluded that AAM was likely to succeed on the merits of its claim, faced a threat of irreparable harm, and that the balance of harms and public interest factors were neutral. Minnesota appealed, contesting the likelihood of success on the merits and the balance of harms/public interest.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s ruling for abuse of discretion and its legal conclusions de novo. The court found that the Minnesota law had the impermissible extraterritorial effect of controlling prices outside the state, similar to laws previously struck down by the Supreme Court. The court rejected Minnesota's argument that the law did not control out-of-state prices, noting that it effectively regulated out-of-state transactions if the drugs ended up in Minnesota.The Eighth Circuit affirmed the district court’s decision, agreeing that AAM was likely to succeed on the merits of its dormant Commerce Clause claim. The court also found no abuse of discretion in the district court’s assessment of the balance of harms and public interest, noting that protecting constitutional rights is always in the public interest. The preliminary injunction against the Minnesota law was upheld. View "Ass'n for Accessible Medicines v. Ellison" on Justia Law

The case involves a post-dismissal challenge to a trial court’s order that permanently sealed the petitioners’ actual names and allowed them to be identified by pseudonyms in court records. The petitioners, identified as John Does P, Q, R, and S, sought to prevent Thurston County from releasing unredacted sex offender records in response to a Public Records Act (PRA) request by Donna Zink. The trial court granted the Does’ motion for voluntary dismissal and entered a permanent order to maintain the use of pseudonyms and seal a court record listing their actual names.The trial court initially allowed the Does to proceed in pseudonym to preserve their ability to seek relief in their PRA injunction action. However, over the course of the litigation, nearly all of the Does’ PRA exemption claims were rejected, and Zink received most of the records she requested. The trial court’s preliminary orders allowing pseudonyms were based on the potential harm of being identified as sex offenders. On remand, the trial court granted the Does’ motion for voluntary dismissal and permanently sealed their names, citing compelling privacy and safety concerns.The Washington Supreme Court reviewed the case and held that the trial court abused its discretion in permanently sealing the Disclosure Document and allowing the Does to remain in pseudonym. The court found that the trial court’s findings were insufficient to satisfy GR 15 or the Ishikawa factors, which require specific and compelling reasons to restrict public access to court records. The court noted that the Does’ identities as sex offenders were already publicly available, and the trial court’s order did not articulate new compelling privacy or safety concerns. The Supreme Court remanded the case with instructions to unseal the Disclosure Document, use the Does’ actual names in future proceedings, and replace the pseudonyms in court records with their actual names. View "Doe P v. Thurston County" on Justia Law

The Arkansas Board of Corrections filed a complaint against the Governor of Arkansas, the Secretary of the Arkansas Department of Corrections, and the Arkansas Department of Corrections, challenging the constitutionality of Acts 185 and 659 of 2023. The Board argued that these acts unlawfully transferred its power to manage the Department of Corrections to the Governor and the Secretary, in violation of amendment 33 of the Arkansas Constitution. The Board sought a declaratory judgment and a permanent injunction to prevent the enforcement of the challenged legislation.The Pulaski County Circuit Court granted a temporary restraining order (TRO) and later a preliminary injunction, finding that the Board demonstrated irreparable harm and a likelihood of success on the merits. The court also denied motions to dismiss the Board’s complaint and to disqualify the Board’s special counsel. The appellants, including the Governor and the Secretary, appealed the preliminary injunction, arguing that the Board failed to demonstrate irreparable harm.The Supreme Court of Arkansas reviewed the case and denied the appellants' motion to remand with instructions to vacate the preliminary injunction and dismiss as moot. The court found that the dispute was not moot despite the firing of Secretary Profiri, as the Board's complaint concerned the constitutionality of the legislation, not the individual holding the Secretary position. The court also dismissed the appellants' motion to disqualify the Board’s counsel, as it was outside the scope of interlocutory review.The Supreme Court of Arkansas affirmed the circuit court’s decision, holding that the circuit court did not abuse its discretion in determining that the Board demonstrated irreparable harm in the absence of the preliminary injunction. The court emphasized that the dispute over the Board’s authority would continue until the constitutionality of the challenged legislation was resolved. View "Sanders v. Arkansas Board of Corrections" on Justia Law

T.M. has a medical condition that causes psychosis when she ingests gluten. After an episode in 2023, she was involuntarily committed to Baltimore Washington Medical Center. Despite her and her father's request for voluntary admission, an administrative hearing led to her involuntary commitment. A clinical review panel approved forcibly injecting T.M. with antipsychotic medication, a decision affirmed by a Maryland administrative law judge. T.M. and the medical center later reached an oral agreement for her release, which was formalized in a consent order by a state court. The consent order required T.M. to follow certain conditions, including taking prescribed medications and dismissing other lawsuits.The United States District Court for the District of Maryland dismissed T.M.'s claims, citing the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court found it lacked subject matter jurisdiction over T.M.'s claims and dismissed the parents' claims for failure to state a claim. T.M.'s claims were dismissed with prejudice, while the parents' claims were dismissed without prejudice.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal of T.M.'s claims for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. The court held that T.M. was a state court loser seeking to overturn a state court judgment, which is barred by the doctrine. The court vacated the dismissal with prejudice and remanded with instructions to modify the judgment to dismiss T.M.'s claims without prejudice. The court also affirmed the dismissal of the parents' claims for failure to state a claim, noting that the complaint did not allege a violation of their First Amendment rights. View "T.M. v. University of Maryland Medical System Corporation" on Justia Law

The defendant was previously convicted of murder and criminal possession of a firearm. This court reversed the murder conviction due to the prosecutor's improper comments on the defendant's post-Miranda silence, violating Doyle v. Ohio. The defendant then moved to dismiss the murder charge, arguing that double jeopardy protections barred a retrial because the prosecutor intended to prevent an acquittal that was imminent without the impropriety.The trial court denied the motion to dismiss, finding that the defendant did not establish that the prosecutor intended to prevent an acquittal. The court based its decision on the trial transcripts and this court's previous decision, which concluded that the evidence was sufficient to support the conviction. The defendant appealed, renewing his argument that the double jeopardy clause barred a retrial and asserting that the Connecticut constitution provided broader protections.The Supreme Court of Connecticut affirmed the trial court's decision. The court held that the defendant failed to demonstrate that the prosecutor engaged in impropriety with the intent to prevent an acquittal that the prosecutor believed was imminent. The court noted that the evidence at trial, although not overwhelming, was sufficient to support a conviction, and the prosecutor's actions did not indicate an intent to provoke a mistrial or prevent an acquittal. The court also declined to overrule its previous decisions in State v. Colton and State v. Michael J., maintaining that the Connecticut constitution does not provide broader double jeopardy protections than the federal constitution. View "State v. Patrick M." on Justia Law

Leslie Torgerson filed a lawsuit in federal district court against Roberts County, South Dakota, and several individuals, including County Sheriff Tyler Appel, County Deputies Zachary Angerhofer and Wesley Bowsher, his adopted son Ross Torgerson, and his ex-wife Terri Torgerson. Torgerson alleged violations of his substantive and procedural due process rights under the Fourteenth Amendment and civil conspiracy. He also asserted a Monell claim against the County, a state-law claim for common law battery against Ross, and a state-law intentional-infliction-of-emotional distress claim against Deputy Angerhofer, Deputy Bowsher, Ross, and Terri. These claims stemmed from a domestic dispute involving Torgerson, Ross, and Terri.The defendants moved for summary judgment on Torgerson’s claims. The United States District Court for the District of South Dakota granted the defendants' motions for summary judgment and declined to exercise jurisdiction over the remaining state-law claims. The court concluded that Torgerson failed to state a claim for a Fourteenth Amendment violation, as he did not plead that he possessed a constitutional interest that had been violated. The court also determined that Torgerson’s civil conspiracy claim failed due to the lack of a stated constitutional interest and insufficient facts showing a conspiracy. Consequently, Torgerson’s Monell claim against the County also failed. The court declined to exercise supplemental jurisdiction over the state-law claims, considering them to be purely state-related issues.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Torgerson did not suffer a deprivation of liberty as he was not charged or prosecuted for any crime, thus failing to establish a Fourteenth Amendment violation. The court also upheld the summary judgment on the civil conspiracy and Monell claims, as there was no underlying constitutional violation. Finally, the court found no abuse of discretion in the district court’s decision to decline supplemental jurisdiction over the state-law claims. View "Torgerson v. Roberts County of South Dakota" on Justia Law

Mary Doe, a social worker proceeding under a pseudonym, challenged New York’s Reproductive Health Act (RHA), arguing it violated constitutional rights. Doe sought to represent a class of viable fetuses, claiming the RHA’s decriminalization of abortion and elimination of fetal homicide laws harmed them. She also sought to amend her complaint post-judgment to include a specific fetus, "Baby Nicholas," alleging he faced harm due to the RHA.The United States District Court for the Northern District of New York dismissed Doe’s claims for lack of standing, denying her motion to be appointed as "next friend" to the fetuses, citing her lack of a significant relationship with them. The court also denied her post-judgment motion to amend the complaint, finding it futile as Baby Nicholas lacked standing.The United States Court of Appeals for the Second Circuit reviewed the case. The court agreed that the district court erred in requiring a significant relationship for next friend appointments under Federal Rule of Civil Procedure 17(c). However, it affirmed the dismissal of Doe’s claims on the grounds that she failed to identify or describe any specific member of the viable fetus class, thus failing to establish a live case or controversy under Article III.Regarding the post-judgment motion, the Second Circuit affirmed the district court’s denial, concluding that Baby Nicholas lacked standing. The court found that the alleged risks to Baby Nicholas were not imminent and traceable to the RHA, as required for standing. The potential harm from a third party was not sufficiently connected to the RHA’s provisions.The Second Circuit affirmed the district court’s judgment, maintaining the dismissal of Doe’s claims and denying the motion to amend the complaint. View "Doe v. Hochul" on Justia Law

A group of appellants, including Firearms Owners Against Crime and two firearms dealers, filed a case against the Pennsylvania State Police (PSP) Commissioner, alleging that PSP was not complying with the Pennsylvania Uniform Firearms Act. The appellants claimed that PSP was intentionally understaffing its Pennsylvania Instant Check System (PICS) Operations Section, leading to significant delays in background checks for firearm purchases, sometimes exceeding seven hours. They argued that these delays violated the statutory requirement for "instantaneous" or "immediate" background checks and caused financial harm to firearms dealers due to canceled transactions.The Commonwealth Court initially issued a preliminary injunction, finding that PSP had a statutory duty to employ sufficient personnel to ensure compliance with the Act and that the delays were causing financial harm to the dealers. However, the court later sustained PSP's preliminary objections, ruling that the statute did not specify a mandatory timeframe for background checks and that the operational decisions regarding staffing were discretionary. The court also dismissed the appellants' request for a refund of the $2.00 background check fee, as the statute did not provide for such refunds.The Supreme Court of Pennsylvania reviewed the case and held that while the statute did not require "instantaneous" responses, it did mandate that PSP provide results as quickly as possible with available resources. The court affirmed the Commonwealth Court's denial of injunctive and mandamus relief, as these would compel affirmative action barred by sovereign immunity. However, the court reversed the denial of declaratory relief, allowing the appellants to seek a judicial declaration of PSP's duties under the Act. The court also vacated the order denying leave to amend the petition, allowing the appellants to include new allegations regarding PSP's response to the preliminary injunction. The case was remanded for further proceedings consistent with these findings. View "Firearms Owners v. Comm'r of PSP" on Justia Law