Justia Civil Procedure Opinion Summaries

The United States Court of Appeals for the Ninth Circuit reversed a judgment from the United States District Court for the Central District of California regarding the FBI's "inventory" of 700 safe deposit boxes at US Private Vaults (USPV). The USPV was under investigation for various criminal activities. The FBI seized the boxes and their contents under a warrant that expressly did not authorize a criminal search or seizure of the box contents. After a trial based on written submissions, the district court ruled in favor of the government, holding that the government's "inventory" of the safe deposit boxes was a constitutionally valid inventory search. The Ninth Circuit disagreed, stating that the inventory search doctrine did not apply because one of the key features of the doctrine is the existence of standardized instructions which limit the discretion of officers and apply consistently across cases. The court found that the FBI had supplemented its standardized instructions with additional instructions specifically designed for the USPV raid, which took the case out of the realm of a standardized "inventory" procedure. The Ninth Circuit also held that the government exceeded the scope of the warrant, which did not authorize a criminal search or seizure of the contents of the safe deposit boxes. The case was remanded for the FBI to sequester or destroy the records of its inventory search pertaining to the class members. View "Snitko v. United States" on Justia Law

The United States Court of Appeals for the Eleventh Circuit vacated and remanded a decision by the United States District Court for the Northern District of Florida, which had ruled against Andrew Warren, a Florida State Attorney for the Thirteenth Judicial Circuit. Warren had filed a lawsuit against Governor Ron DeSantis, claiming that DeSantis had suspended him in retaliation for his First Amendment activity. The circuit court agreed with the district court that Warren had satisfied his initial burden of showing that he had engaged in protected activity, suffered an adverse action, and that DeSantis's actions were motivated by Warren's protected activity. However, the circuit court disagreed with the district court's conclusion that the First Amendment did not protect certain activities that motivated DeSantis's decision, and found that the district court erred in concluding that DeSantis would have suspended Warren based solely on unprotected activities. The case was remanded for the district court to reconsider whether DeSantis would have made the same decision based solely on the unprotected activities. View "Warren v. DeSantis" on Justia Law

The United States Court of Appeals for the Eighth Circuit ruled in a case concerning a law in Iowa that penalized anyone who, while trespassing, knowingly placed or used a camera or surveillance device on the trespassed property. The law was challenged by five animal-welfare groups who argued that it unconstitutionally punished activity protected by the First Amendment. The lower court agreed with the plaintiffs, ruling that the law was unconstitutional on its face because it was not narrowly tailored to achieve the state's substantial interests. On appeal, the Eighth Circuit affirmed in part and reversed in part the lower court's decision. The appellate court found that the plaintiffs had standing to challenge the part of the law that penalized the use of cameras while trespassing (the "Use Provision"), but not the part penalizing the placement of cameras on trespassed property (the "Place Provision"). The court also disagreed with the lower court's conclusion that the law was unconstitutional, holding that it survived intermediate scrutiny against a facial challenge and was not unconstitutionally overbroad, as it did not prohibit a substantial amount of protected speech relative to its plainly legitimate sweep. The court remanded the case for further proceedings consistent with its opinion. View "Animal Legal Defense Fund v. Reynolds" on Justia Law

In the case before the Supreme Court of the State of Idaho, the plaintiffs, Dallen and Rachel Worthington, filed an expedited unlawful detainer action against the defendant, Carlene Crazy Thunder, for failure to pay rent. Crazy Thunder requested a jury trial, which was denied by the magistrate court. Following a bench trial, the magistrate court ruled that Crazy Thunder had unlawfully detained the Worthingtons’ property and ordered her to vacate the residence. Crazy Thunder appealed to the district court, arguing she had a right to a jury trial under Idaho’s constitution and Idaho Code section 6313. The district court agreed, concluding that section 6-311A conflicted with section 6-313, and that section 6-311A violated Article I, section 7 of the Idaho Constitution. The Worthingtons then appealed to the Supreme Court of Idaho.The Supreme Court of Idaho held that Idaho Code section 6-311A does not violate the Idaho Constitution. The court reasoned that an action for unlawful detainer is an equitable claim, and under Article I, section 7 of the Idaho Constitution, the right to trial by jury only exists for legal claims, not equitable ones. However, the court also ruled that Crazy Thunder was entitled to a jury trial on her legal claims. The court held that in wrongful detainer cases like this one, when issues of fact are presented by the pleadings, those issues must be tried by a jury, unless such a jury is waived. As such, the Supreme Court of Idaho affirmed the district court’s decision, though on different grounds. The court further ruled that Crazy Thunder, as the prevailing party on appeal, was entitled to costs, but neither party was entitled to attorney fees. View "Worthington v. Crazy Thunder" on Justia Law

In 2011, Veronica-May Clark, an incarcerated transgender woman, was repeatedly sexually assaulted by corrections officer Thomas Hanley. More than seven years after the abuse, Clark filed a lawsuit against Hanley and other officers, alleging violations of her Eighth Amendment rights and seeking equitable tolling of the statute of limitations due to the traumatic effects of the abuse. After holding an evidentiary hearing on the issue of equitable tolling, the United States District Court for the District of Connecticut (Meyer, J.) denied Clark's claim for equitable tolling and dismissed her case as untimely. Clark appealed, claiming that the court improperly conducted factfinding at the pleading stage and violated her Seventh Amendment rights. The United States Court of Appeals for the Second Circuit affirmed the district court's ruling, finding that the court properly resolved Clark's equitable tolling claim and did not infringe her Seventh Amendment rights. View "Clark v. Hanley" on Justia Law

In this case, the United States Court of Appeals for the Seventh Circuit examined the constitutionality of Cook County, Illinois's use of cameras to record holding cell toilets in courthouses throughout the county. The plaintiffs, pretrial detainees, claimed that the cameras infringed upon their Fourth Amendment privacy interests and also constituted an intrusion upon seclusion under Illinois law. The district court granted summary judgment in favor of the defendants, Cook County and Sheriff Thomas J. Dart, and the plaintiffs appealed.The Court of Appeals held that the plaintiffs did not have a reasonable expectation of privacy when using the toilets in courthouse holding cells. While it acknowledged that there are questions around the extent to which detainees have a reasonable expectation of privacy in their bodies while in a holding cell, it found that any privacy rights are substantially diminished. The court further held that Cook County's use of cameras in courthouse holding cells was reasonable due to the security risks inherent in the setting. The court also determined that one of the plaintiffs, Alicea, had standing to sue, but the other plaintiffs did not.Furthermore, the court affirmed the district court's decision to grant summary judgment on the plaintiffs' claim for intrusion upon seclusion. It held that the plaintiff had not met his burden on the fourth element of the claim, anguish and suffering.Lastly, the court affirmed the district court's decisions related to discovery and attorneys' fees. The court held that the district court did not abuse its discretion in these decisions. Thus, the judgment of the district court was affirmed. View "Alicea v. County of Cook" on Justia Law

The New York Court of Appeals held that the New York State Independent Redistricting Commission (IRC) failed to fulfill its constitutional duties for redistricting maps after the 2020 census. The court affirmed a lower court decision ordering the IRC to reconvene and deliver a second set of lawful redistricting maps.In 2014, New York voters amended the state constitution to mandate that the IRC, not the courts or the legislature, draw legislative districts. However, the IRC failed to deliver the required maps, resulting in a court-ordered redistricting plan for the 2022 elections.The court clarified that such court-directed plans are limited to the "extent" that the court is "required" to do so, and are not meant to last longer than necessary to remedy a violation of law. Therefore, the existing court-drawn districts are limited to the 2022 election.The court dismissed arguments that it was too late to compel the IRC to act, explaining that the court-ordered maps were not required to last a decade and that the IRC's constitutional obligation could be enforced at any time, unless barred by laches. The court also rejected arguments that the lawsuit was a collateral attack on an earlier decision, which dealt with a different issue.The ruling orders the IRC to submit a second set of redistricting maps and implementing legislation to the legislature as soon as possible, but no later than February 28, 2024. View "Matter of Hoffmann v New York State Ind. Redistricting Commn." on Justia Law

In this case, a group of New Hampshire voters challenged the constitutionality of the state's new boundaries for state senate and executive council districts. The plaintiffs claimed that the legislature violated the New Hampshire Constitution by drawing districts that unfairly benefitted one political party at the expense of another. They sought a declaration that the districts violated various parts of the state constitution and an injunction preventing the implementation of the new boundaries.The Supreme Court of New Hampshire held that the issue of partisan gerrymandering raised a non-justiciable political question because the New Hampshire Constitution committed the task of redistricting to the legislature and did not provide any legal standard for the courts to review such decisions. The court noted that the plaintiffs did not claim that the redistricting plans violated any mandatory requirements of the state constitution.The court also rejected the argument that the constitution's guarantees of free speech, equal protection, and association were violated by the alleged gerrymandering. The court found that these constitutional provisions did not provide clear and manageable standards for adjudicating claims of extreme partisan gerrymandering.The court affirmed the lower court's decision to dismiss the plaintiffs' complaint, concluding that the challenge to the constitutionality of the districts based on claims of excessive political gerrymandering presented non-justiciable political questions. View "Brown v. Secretary of State" on Justia Law

In a consolidated case before the United States Court of Appeals for the Second Circuit, plaintiffs Ivan Antonyuk, Corey Johnson, Alfred Terrille, Joseph Mann, Leslie Leman, Lawrence Sloane, Jimmie Hardaway Jr., Larry A. Boyd, Firearms Policy Coalition Inc., Second Amendment Foundation Inc., Brett Christian, Micheal Spencer, and His Tabernacle Family Church Inc., sought to challenge certain provisions of New York's Concealed Carry Improvement Act ("CCIA"). The CCIA regulates the public carriage of firearms and includes licensing requirements and prohibitions on carrying firearms in "sensitive" and "restricted" locations. The plaintiffs argued that the provisions violated their First and Second Amendment rights.The court affirmed the preliminary injunction against the enforcement of certain provisions of the CCIA, but vacated the injunction in other respects. Specifically, the court upheld district court's injunctions with respect to the social media disclosure requirement, the application of restricted locations provision to private property open to the general public, and the application of the same provision to Pastor Spencer, the Tabernacle Family Church, its members, or their agents and licensees.However, the court vacated the injunctions in all other respects, concluding that either the district court lacked jurisdiction or that the challenged laws do not violate the Constitution on their face. The court rejected the plaintiffs' challenges to the CCIA's licensing requirements and sensitive locations provisions, holding that the laws did not infringe on the plaintiffs' Second Amendment rights.The court also held that the CCIA's restricted locations provision, which makes it a crime to possess firearms in a "restricted location", did not violate the plaintiffs' First and Second Amendment rights. Instead, the court found the provision to be a reasonable regulation consistent with the Second Amendment's protection of the right to keep and bear arms.The court's decision affirms in part, vacates in part, and remands the case for further proceedings. View "Antonyuk v. Chiumento" on Justia Law

In the case before the Supreme Court of the State of Alaska, a group of trade associations (Resource Development Council for Alaska, Inc., Alaska Trucking Association, Inc., Alaska Miners Association, Inc., Associated General Contractors of Alaska, Alaska Chamber, and Alaska Support Industry Alliance) sued the State and a ballot initiative group "Vote Yes for Alaska’s Fair Share" (Fair Share), seeking to invalidate the State’s approval of a ballot initiative petition. The litigation primarily revolved around the constitutionality of a statute limiting the compensation that could be paid for obtaining signatures on ballot initiative petitions. The superior court ruled that the statute was unconstitutional and dismissed the trade associations’ claims that a large number of petition signatures should be invalidated because the statutory compensation limits had been exceeded.Following this ruling, Fair Share moved for an attorney’s fees award against the trade associations, contending that it was a qualified prevailing constitutional claimant entitled to full reasonable attorney’s fees under AS 09.60.010, or at least an award of partial attorney’s fees under Alaska Civil Rule 82. The trade associations responded that Fair Share could not be a constitutional claimant because it was not a “plaintiff, counterclaimant, cross claimant, or third-party plaintiff.”The superior court concluded that Fair Share was a constitutional claimant because its claim was effectively a counterclaim. However, it also concluded that the Trade Associations did not have sufficient economic incentive to bring their claim, and thus were constitutional claimants protected from an award of full attorney’s fees under AS 09.60.010. The court nonetheless awarded Fair Share partial attorney’s fees under Rule 82.On appeal, the Supreme Court of the State of Alaska affirmed the superior court’s determination that the trade associations did not have a sufficient economic incentive to bring their claims. Thus, the trade associations are qualified, non-prevailing constitutional claimants and the Rule 82 attorney’s fees award must be vacated. View "Vote Yes for Alaska's Fair Share v. Resource Development Council for Alaska, Inc." on Justia Law