Justia Civil Procedure Opinion Summaries

Springboards for Education (“Springboards”) brought trademark infringement claims against McAllen Independent School District (“MISD”), a public school district in Texas, and IDEA Public Schools (“IDEA”), a nonprofit organization operating charter schools in Texas. The district court dismissed the suit against IDEA, concluding it was an arm of the state and therefore shared Texas’s sovereign immunity. As for MISD, the court found that it did not have sovereign immunity but ultimately granted summary judgment in MISD’s favor.   The Fifth Circuit affirmed the district court’s judgment for MISD. The court explained that while it disagrees with the district court’s conclusion that IDEA has sovereign immunity, the court affirmed the judgment for IDEA on alternate grounds. The court reasoned that in determining whether an entity is an arm of the state, the court balances the so-called “Clark factors,” which our court first articulated decades ago in Clark v. Tarrant County. Those factors are: (1) whether state statutes and case law view the entity as an arm of the state; (2) the source of the entity’s funding; (3) the entity’s degree of local autonomy; (4) whether the entity is concerned primarily with local, as opposed to statewide, problems; (5) whether the entity has the authority to sue and be sued in its own name; and (6) whether it has the right to hold and use property. The court held that factors one and three favor sovereign immunity while factors two, four, five, and six do not. The court concluded that IDEA is not an arm of the state and does not share in Texas’s sovereign immunity. View "Springboards v. IDEA Public Schools" on Justia Law

Under California law, certain political advertisements run by a committee must name the committee’s top contributors. The City and County of San Francisco adds a secondary-contributor disclaimer requirement that compels certain committees, in their political advertisements, also to list the major donors to those top contributors. Plaintiffs—a political committee that runs ads, the committee’s treasurer, and a contributor to the committee— seek to enjoin enforcement of San Francisco’s ordinance.   The Ninth Circuit affirmed the district court’s denial of Plaintiffs’ motion for a preliminary injunction. The panel first determined that even though the June 2022 election had occurred, this appeal was not moot because the controversy was capable of repetition yet evading review. The panel held that Plaintiffs had not shown a likelihood of success on the merits. Applying exacting scrutiny, the panel held that San Francisco’s requirement was substantially related to the governmental interest in informing voters of the source of funding for election-related communications. The panel next held that the ordinance did not create an excessive burden on Plaintiffs’ First Amendment rights relative to the government interest and was sufficiently tailored. Thus, the panel was not persuaded that the secondary-contributor requirement was an impermissible burden on speech because the size of the disclaimer was excessive with respect to larger ads. The district court was within its discretion to conclude that the secondary-contributor requirement had a scope in proportion to the City’s objective. View "NO ON E, SAN FRANCISCANS OPPOSING THE AFFORDABLE, ET AL V. DAVID CHIU, ET AL" on Justia Law

On March 20, Plaintiff, an inmate, experienced abdominal pain, nausea, and vomiting. He was transported to an outside hospital for evaluation and testing. The results were deemed “unremarkable,” and Plaintiff was returned to his home institution. Ultimately, Plaintiff was diagnosed with an abdominal infection due to a small bowel obstruction and alleged permanent injury.Plaintiff brought a claim of deliberate indifference against various prison officials ("Defendants"). The district court dismisses Plaintiff's claim under 12(b)(6). Defendants argued that Plaintiff's “generalized, conclusory, and collective allegations” fail to plausibly allege deliberate indifference on the part of each Defendant.The Fourth Circuit affirmed. Plaintiff's complaint made collective allegations against all “Defendants,” without identifying how each individual Defendant personally interacted with Langford or was responsible for the denial of his Eighth Amendment rights. View "Chad Langford v. Hector Joyner" on Justia Law

The States of Illinois and Nevada (collectively referred to as “the States” or “Plaintiffs”) filed a mandamus action in the district court, seeking to compel the Archivist of the United States to certify and publish the Equal Rights Amendment (“ERA”) as part of the Constitution of the United States. The States argued that the Archivist had a duty to certify and publish the ERA because it was ratified by the requisite three-fourths of the States of the Union as required by Article V of the Constitution. The district court agreed, dismissing the case for lack of jurisdiction.   The DC Circuit affirmed. The court explained that the States have not clearly and indisputably shown that the Archivist had a duty to certify and publish the ERA or that Congress lacked the authority to place a time limit in the proposing clause of the ERA. Under the rigid standard required for mandamus actions, the court wrote it must affirm the district court’s dismissal of the States’ complaint on the ground that the lower court lacked subject matter jurisdiction. View "State of Illinois v. David Ferriero" on Justia Law

Plaintiff brought a qui tam case on behalf of the State of California alleging Defendants and Respondents engaged in medical insurance fraud. Plaintiff asserted the alleged fraud victimized the state workers’ compensation system, including the State Compensation Insurance Fund, as well as Medi-Cal, and brought her action under the California False Claims Act (CFCA) and the California Insurance Frauds Prevention Act (IFPA). Plaintiff filed her qui tam complaint under seal and in camera as statutorily required. Before the matter reached trial, however, the trial court dismissed the action pursuant to the “five-year rule” set out in Code of Civil Procedure section 583.310.   The Second Appellate District reversed the judgment of dismissal, reinstated the action, and remanded it. The court held that the 962 days the action was kept under seal should have been excluded from the five-year period pursuant to Section 583.340(b). Further, the five-year period had not expired at the time the court dismissed the action. A five-year period totals 1,825 days. Adding to that period, the 962 days during which the action was under seal, the 712 days of the first stay and the 236 days of the second stay total 3,735 days. The date 3,735 days from the date Plaintiff filed her complaint (July 13, 2012) is October 3, 2022. Adding six months due to the COVID-19 emergency rule extends the period to April 3, 2023. Therefore, the trial court erred in prematurely dismissing Plaintiff’s action on February 24, 2021. View "State of Cal. ex. rel. Sills v. Gharib-Danesh" on Justia Law

The Securities and Exchange Commission sued Defendant for trading Corporate Executive Board, Inc. (“CEB”) stock using inside information. The Commission alleged that Defendant aggressively traded CEB stock after he received inside information about a potential merger from co-Defendant, Defendant’s brother-in-law and CEB’s Corporate Controller. At trial, Defendant moved for judgment as a matter of law under Rule 50(a)1 at the conclusion of the Commission’s case. He argued the Commission failed to present evidence that co-Defendant possessed inside information about the merger at the time Defendant began the relevant trading. And if co-Defendant had no such information at that time, Defendant contended, co-Defendant could not have passed it on to Defendant The district court agreed and granted judgment for Defendant.   The Fourth Circuit reversed and remanded. The court explained the right to a trial by jury is enshrined by the Seventh Amendment. And the Federal Rules of Civil Procedure require that juries, not judges, decide cases so long as there is evidence from which a reasonable decision can be made. Here, evidence existed from which a reasonable jury could infer that Defendant engaged in prohibited insider trading beginning on December 9, 2016. View "SEC v. Christopher Clark" on Justia Law

South Carolina law makes it a crime for elementary and secondary school students to act “disorderly” or in a “boisterous manner,”; use “obscene or profane language”; or “interfere with,” “loiter about,” or “act in an obnoxious manner” in (or sometimes near) a school. Four students who had been referred or charged under the disorderly conduct or disturbing schools laws, and a nonprofit organization that advocates for at-risk youth filed a putative class action challenging both laws as unconstitutionally vague. After denying a motion to dismiss, the district court certified one main class and two subclasses under the Federal Rule of Civil Procedure 23(b)(2). The court held that both laws were unconstitutionally vague as applied to elementary and secondary school students, and it permanently enjoined future enforcement of the disorderly conduct law against those students. South Carolina’s Attorney General—appealed, lodging multiple challenges to the district court’s rulings.   The Fourth Circuit affirmed. The court reasoned that the district court committed no abuse of discretion here—not just because the challenged laws are facially invalid as applied to elementary and secondary school students but also because the subclasses demonstrated ongoing injury by the retention of existing records. A delinquency adjudication under South Carolina law may impair a minor’s future practice of law, application for military service, use of a driver’s license, and educational opportunities. Having concluded the laws may not be constitutionally enforced against South Carolina’s elementary and secondary students, the court saw no reason for allowing such continuing injuries to stand. View "Carolina Youth Action Project v. Alan Wilson" on Justia Law

After prevailing in state court on claims that he was fired in retaliation for exercising his state constitutional right to freedom of expression, Plaintiff filed a federal suit alleging the same set of facts but asserting for the first time a First Amendment claim. The district court dismissed Plaintiff’s suit, finding that Defendants’ factual attack showed that the only remedy not barred by sovereign immunity was impossible to grant and that Kling’s claim was prescribed. On appeal, Plaintiff contends that a factual attack on a district court’s subject matter jurisdiction is improper at the pleadings stage and that his state lawsuit interrupted prescription on his newly asserted federal claim because both rely on the same set of operative facts.   The Fifth Circuit concluded that the district court did not err in dismissing Plaintiff’s official capacity claims as barred by sovereign immunity and accordingly affirmed that ruling in the district court’s decision. However, because there are no clear controlling precedents from the Louisiana Supreme Court as to whether prescription on Plaintiff’s federal claim was interrupted by his state action, the court certified to that court to answer the following:In Louisiana, under what circumstances, if any, does the commencement of a suit in a court of competent jurisdiction and venue interrupt prescription as to causes of action, understood as legal claims rather than the facts giving rise to them, not asserted in that suit? View "Kling v. Hebert" on Justia Law

The United States Department of Agriculture (“USDA”) permanently disqualified Euclid Market Inc. (“Euclid Market”) from the Supplemental Nutrition Assistance Program (“SNAP”) after it determined Euclid Market had unlawfully trafficked SNAP benefits. After the USDA issued its final decision, Euclid Market filed an action in federal court under 7 U.S.C. Section 2023, requesting the district court set aside the USDA’s final decision. The district court found Euclid Market did not meet its burden to show the USDA’s action was invalid and entered judgment in favor of the government. Euclid Market appealed. Euclid Market argued that the district court erred by requiring it to produce transaction-specific evidence for every transaction raised by the USDA to meet its burden of proof.   The Eighth Circuit vacated the judgment and remanded. The court agreed with Euclid Market that the transaction-specific standard is erroneous and that the district court applied such a standard in this case. A store’s failure to provide transaction-specific evidence for every transaction does not inherently doom its case. Concluding otherwise would create unnecessary tension with the fundamental principles of evidence. Further, a hardline rule that a store cannot prevail without transaction-specific evidence for each transaction raised by the USDA is inconsistent with the district court’s rightful discretion in weighing all of the relevant, admissible evidence to determine the validity of the disqualification by a preponderance of the evidence. View "Euclid Market Inc. v. United States" on Justia Law

A man was shot and killed in his jewelry shop in 1983, and Decedent was sentenced to death for the crime. Thirty years later, Louisiana vacated Decedent’s conviction because new evidence identified the real murderer. After his release from prison, Decedent filed a Section 1983 suit seeking damages from police officers, prosecutors, and the local government for suppressing, fabricating, and destroying evidence. Decedent died shortly thereafter, leaving Plaintiff as the executrix of his estate. In 2021, the district court dismissed Plaintiff’s amended complaint in its entirety based on Fed. R. Civ. P. 12(b)(6) as to some defendants and 12(c) as to others.   The Fifth Circuit affirmed. The court explained that Plaintiff brought a traditional negligence claim. Louisiana uses the typical reasonable-person standard to assess an individual’s liability for negligence. For the same reasons that Plaintiff did not adequately plead constitutional violations due to the defendants’ suppression, fabrication, and destruction of evidence, she also fails to plead sufficient factual matter to show that they violated the standard of care of a reasonable officer. Accordingly, the court found that the district court thus properly dismissed this claim. View "Armstrong v. Ashley" on Justia Law