Justia Civil Procedure Opinion Summaries

The case involves a challenge to the provisions of the Bipartisan Safer Communities Act of 2022, which expanded background checks for firearm purchases by individuals aged 18 to 20. The plaintiffs, Ethan McRorey, Kaylee Flores, Gun Owners of America, Inc., and Gun Owners Foundation, argued that the government failed to show a historical analogue for the Act's expanded background checks for this age group. They filed a lawsuit requesting a preliminary injunction after their attempts to purchase shotguns were delayed due to the National Instant Criminal Background Check System (NICS) protocols.The United States District Court for the Northern District of Texas denied the plaintiffs' request for a preliminary injunction. The court reasoned that while adults aged 18 to 20 are protected by the Second Amendment, laws barring the mentally ill and felons from possessing firearms are constitutional, and restrictions to further those ends are presumptively lawful. Therefore, the plaintiffs lacked a substantial likelihood of success on the merits and were not entitled to preliminary relief.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the lower court's decision. The appellate court held that background checks preceding firearm sales are presumptively constitutional, and the plaintiffs failed to rebut that presumption. The court also found that the plaintiffs had not shown that the challenged regulations had been put towards abusive ends or had otherwise rebutted the presumption of lawfulness. The court concluded that a period of 10 days for background checks does not qualify as being put towards abusive ends or as a de facto prohibition on possession. View "McRorey v. Garland" on Justia Law

The case involves successors in interest of mineral-rights holders who sued in 2019 to declare a 1999 judgment foreclosing on their predecessors’ property for delinquent taxes as void. They argued that there was constitutionally inadequate notice of the foreclosure suit, rendering the foreclosure judgment and the tax sale that followed both void. The current owners sought traditional summary judgment based on the Tax Code’s command that an action relating to the title to property against the purchaser of the property at a tax sale may not be commenced later than one year after the date that the deed executed to the purchaser at the tax sale is filed of record.The trial court granted the current owners' motion for summary judgment, and the court of appeals affirmed. The majority held that the sheriff’s deed conclusively established the accrual date for limitations, so the burden shifted to the successors to adduce evidence raising a genuine issue of material fact as to whether there was a due-process violation that could render the statute of limitations inoperable. Because the successors relied only on their arguments and presented no evidence of a due-process violation, the majority concluded, the current owners were entitled to summary judgment.The Supreme Court of Texas held that under Draughon v. Johnson, the nonmovant seeking to avoid the limitations bar by raising a due-process challenge bears the burden to adduce evidence raising a genuine issue of material fact about whether the underlying judgment is actually void for lack of due process. Because the nonmovant here adduced no such evidence, the trial court correctly granted summary judgment based on Section 33.54(a)(1). However, the court also noted that the law governing this case has undergone meaningful refinement since the summary-judgment proceedings took place. Given these recent and substantial developments in the relevant law, the court remanded this case to the trial court for further proceedings in the interest of justice. View "GILL v. HILL" on Justia Law

The case involves an insurance dispute between Travelers Casualty Insurance Company of America and A-Quality Auto Sales, Inc., along with its owners, Felicia and Shawn Richesin. The Richesins purchased a Subaru for resale through their dealership, A-Quality Auto Sales. After having the car inspected and repaired by RNS Auto Services, they experienced mechanical issues while driving it. Ms. Richesin was severely injured when she exited the vehicle on the side of the highway and was struck by another car. RNS had a garage insurance policy with Travelers, which provided commercial general liability coverage with a per-occurrence limit of $500,000 and a general aggregate limit of $1,000,000. The Richesins sought additional compensation from RNS and Travelers for Ms. Richesin's injuries.In the lower courts, the Richesins filed a suit against Travelers and other parties in New Mexico state court. The state court dismissed all claims against Travelers, citing a lack of privity between the injured party and the insurer. Later, the Richesins and RNS entered into agreements that led to Travelers paying the Richesins $500,000, which Travelers believed to be the policy limit. The Richesins, however, argued that there were multiple occurrences and therefore the policy's aggregate limit of $1,000,000 was available. Travelers then filed a complaint in federal district court seeking a judicial declaration that the accident was a single occurrence and the policy coverage limit for the accident was $500,000.The United States Court of Appeals for the Tenth Circuit affirmed the district court's entry of declaratory judgment. The court held that the dispute was ripe for resolution under Article III of the Constitution. It also ruled that the district court did not err by declining to abstain under the Brillhart and Younger abstention doctrines. The court further held that the district court did not err by denying the Richesins' Rule 56(d) motion, thereby denying them discovery needed to meaningfully oppose Travelers' motion for summary judgment. The court concluded that the accident was a single occurrence and the policy coverage limit for the accident was $500,000. View "Travelers Casualty Insurance Co. of America v. A-Quality Auto Sales" on Justia Law

In Arkansas, attorney Chris Corbitt and other plaintiffs sought to challenge the prohibition of firearms in courthouses. Corbitt had previously attempted to bring a firearm into the Pulaski County District Courthouse and the Juvenile Justice Complex, but was denied. He filed a complaint, which was dismissed by the circuit court and later affirmed by the Supreme Court of Arkansas. Despite this, Corbitt and other plaintiffs filed another complaint after encountering firearm restrictions in a different courthouse. This complaint was also dismissed.The circuit court ruled that Corbitt was not entitled to injunctive relief, declaratory judgment, or a writ of mandamus. The court also found that even if issue preclusion were not applicable, it would rule similarly to Judge Wright’s decision regarding the interpretation of Arkansas Code Annotated section 5-73-122. The court rejected the plaintiff’s argument, stating that it was based on a flawed premise that misread the plain meaning of the statute and ignored the importance of Amendment 80 to the Arkansas Constitution. The circuit court emphasized that Amendment 80 gives the Arkansas Supreme Court the power to regulate court procedure, including the discretion to determine when weapons should be allowed in courtrooms.The Supreme Court of Arkansas held that Corbitt was collaterally estopped from pursuing his claims due to the previous litigation, but the remaining plaintiffs could proceed. The court further held that attorneys, as officers of the court, are authorized by statute to possess handguns in courthouses. The court reversed the circuit court’s denial of the petition for a declaratory judgment as it pertains to the remaining plaintiffs and remanded for further proceedings consistent with this opinion. View "CORBITT v. PULASKI COUNTY CIRCUIT COURT" on Justia Law

The case involves Clifford Alan Dilbert, who filed petitions for clemency and/or commutation of his prison sentence with the Governor's office in 2016, 2017, 2019, and 2021. Dilbert claimed that he had not received any communication from the Governor's office regarding the processing of his clemency petition. He sought a writ of mandate to compel Governor Gavin Newsom to process his applications and reapplications for clemency/commutation, render a decision on those applications, and notify him of the decision in a timely manner.The Superior Court of Sacramento County sustained the Governor’s demurrer to the petition without leave to amend. The court concluded that Dilbert does not have a due process right to have his applications processed within a particular time frame and the law imposes no duty to process clemency applications within a particular time frame. Dilbert appealed this decision.The Court of Appeal of the State of California Third Appellate District affirmed the trial court’s order. The appellate court found that neither the California Constitution nor any provision of Penal Code sections 4800 to 4813 contains an express requirement that the Governor process clemency applications within a specified time frame. The court also rejected Dilbert's argument that the application instructions created an obligation for the Governor to grant discretionary clemency within a certain amount of time. The court concluded that Dilbert does not have a due process right under the Fourteenth Amendment of the U.S. Constitution and article I, section 7 of the California Constitution to have his application processed within a certain time frame. View "Dilbert v. Newsom" on Justia Law

The case involves a group of plaintiffs, including Forward Montana, Leo Gallagher, Montana Association of Criminal Defense Lawyers, and Gary Zadick, who challenged the constitutionality of two amendments to Senate Bill 319 (SB 319) passed by the Montana Legislature during the 2021 legislative session. The amendments, added during a closed-door committee meeting, were unrelated to the original subject of the bill, which was campaign finance. The plaintiffs argued that the amendments violated two sections of the Montana Constitution: Article V, Section 11(1), which requires that a law not be so altered or amended on its passage through the legislature as to change its original purpose, and Article V, Section 11(3), which requires that each bill contain only one subject, clearly expressed in its title.The District Court of the First Judicial District ruled in favor of the plaintiffs, finding that the amendments violated the aforementioned sections of the Montana Constitution. The court permanently enjoined the enforcement of the contested sections of SB 319. The State of Montana, the defendant in the case, did not appeal the decision, effectively acknowledging the unconstitutionality of the bill.The plaintiffs then sought attorney fees under the private attorney general doctrine and the Uniform Declaratory Judgments Act (UDJA). The District Court denied the request, finding that the case was a "garden-variety" constitutional challenge undeserving of attorney fees under the doctrine. The court also denied fees under the UDJA, finding that the circumstances did not make fees equitable.The Supreme Court of the State of Montana reversed the District Court's decision, ruling that the plaintiffs were entitled to attorney fees under the private attorney general doctrine. The court found that the plaintiffs had vindicated important constitutional rights and that private enforcement was necessary due to the State's defense of the unconstitutional law. The court remanded the case to the District Court for calculation of attorney fees. View "Forward Montana v. State" on Justia Law

The plaintiffs, Reverend Kenneth Simon, Reverend Lewis W. Macklin, II, and Helen Youngblood, collectively known as the "Simon Parties," filed a lawsuit against the Ohio Redistricting Commission and several of its members. They alleged that Ohio's congressional districts violated section 2 of the Voting Rights Act, the First Amendment, the Fourteenth Amendment, and the Fifteenth Amendment. The Simon Parties requested a three-judge court under 28 U.S.C. § 2284, which the Ohio Redistricting Commission opposed, and moved to dismiss the complaint.The district court denied the motion to convene a three-judge court and granted the motions to dismiss. The court also denied all other pending motions. The Simon Parties appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the district court incorrectly determined that the Simon Parties' Fourteenth Amendment claim did not raise a substantial federal question for jurisdictional purposes. The court stated that the Simon Parties' allegations on this claim were sufficient to establish federal jurisdiction. The court concluded that the district court lacked jurisdiction as a single judge to adjudicate any other pending motion because it was required to convene a three-judge court under 28 U.S.C. § 2284.The court reversed the district court's order denying the motion for a three-judge court, vacated the district court's orders granting the motions to dismiss and denying the motion for temporary restraining order and motion for class certification, and remanded the case to the district court with instructions for it immediately to initiate the procedures to convene a three-judge court under 28 U.S.C. § 2284. View "Simon v. DeWine" on Justia Law

The Supreme Court of the State of Arizona considered whether the Arizona Legislature repealed or otherwise restricted A.R.S. § 13-3603 by enacting the abortion statutes in Title 36, specifically A.R.S. § 36-2322, which prohibits physicians from performing elective abortions after fifteen weeks’ gestation. The case arose from a motion for relief under Arizona Rule of Civil Procedure 60(b)(5)–(6), seeking to set aside the permanent injunction against § 13-3603 imposed in 1973 following the U.S. Supreme Court's decision in Roe v. Wade.Previously, the trial court granted the motion, vacating the judgment in its entirety to allow full enforcement of § 13-3603. The court of appeals reversed, concluding that licensed physicians who perform abortions in compliance with Title 36 are not subject to prosecution under § 13-3603.The Supreme Court of the State of Arizona held that § 36-2322 does not create a right to, or otherwise provide independent statutory authority for, an abortion that repeals or restricts § 13-3603. The court concluded that absent the federal constitutional abortion right, and because § 36-2322 does not independently authorize abortion, there is no provision in federal or state law prohibiting § 13-3603’s operation. Accordingly, § 13-3603 is now enforceable. The court affirmed the trial court’s judgment vacating the injunction of § 13-3603, vacated the court of appeals’ opinion and stay of enforcement of § 13-3603, and remanded to the trial court for potential consideration of the remaining constitutional challenges to §13-3603 alleged in Planned Parenthood’s complaint for declaratory relief. View "Planned Parenthood v. Mayes" on Justia Law

The case involves a challenge to a decision by the Environmental Protection Agency (EPA) to reinstate a waiver granted to California under the Clean Air Act. The waiver allows California to set its own standards for automobile emissions, which are stricter than federal standards. The petitioners, a group of states and fuel industry entities, argued that the EPA's decision was not authorized under the Clean Air Act and violated a constitutional requirement that the federal government treat states equally in terms of their sovereign authority.The lower courts had upheld the EPA's decision, finding that the petitioners lacked standing to challenge the decision. The petitioners appealed to the United States Court of Appeals for the District of Columbia Circuit.The Court of Appeals affirmed the lower courts' decisions. The court found that the fuel industry petitioners lacked standing to raise their statutory claim, and that the state petitioners lacked standing to raise their preemption claim, because neither group had demonstrated that their claimed injuries would be redressed by a favorable decision by the court. The court also rejected the state petitioners' constitutional claim on the merits, holding that the EPA's decision did not violate the constitutional requirement of equal sovereignty among the states. View "Ohio v. EPA" on Justia Law

The Maine Supreme Court considered a case where Virginia and Joel Parker, a couple who secure some of their food through hunting, challenged the constitutionality of Maine's longstanding ban on Sunday hunting. The Parkers argued that the ban conflicted with the recently enacted right-to-food amendment to the Maine Constitution, which they interpreted as including a right to hunt for food.The Superior Court had dismissed the Parkers' complaint on the grounds that it failed to state a claim. On appeal, the Maine Supreme Court held that the Parkers did present a justiciable claim for a declaratory judgment, and therefore the dismissal by the Superior Court was in error.However, on the question of the constitutionality of the Sunday hunting ban, the Maine Supreme Court found that the ban did not conflict with the right-to-food amendment. The court held that while the amendment does create a limited right to hunt for food, this right does not extend to situations where hunting is illegal. Given that the Sunday hunting ban makes hunting on Sundays illegal, the court concluded that the ban falls within the 'poaching' exception provided in the amendment. Therefore, the court ruled that the Sunday hunting ban is constitutional. The case was remanded to the Superior Court for entry of judgment declaring the challenged statute to be constitutional. View "Virginia Parker v. Department of Inland Fisheries and Wildlife" on Justia Law