Justia Civil Procedure Opinion Summaries

A man was unable to purchase a firearm because a background check revealed he was subject to a long-term domestic violence protective order (DVPO). He sued the State, claiming he was no longer subject to a protective order as defined by federal statute and sought a permanent injunction and declaratory judgment to have the Department of Public Safety (DPS) notify a national database that he was no longer subject to a protective order under 18 U.S.C. § 922(g)(8). He filed a motion for summary judgment, which the State opposed, filing a cross-motion for summary judgment. The superior court granted the State’s cross-motion, and the man appealed.The superior court found that the DVPO had not expired and remained a qualifying order under Section 922(g)(8). It also concluded that the man’s constitutional claims were not ripe because he had not initiated modification or dissolution of the order. The court entered a final judgment in favor of the State.The Supreme Court of the State of Alaska reviewed the case and affirmed the superior court’s decision. The court held that the DVPO remained in effect and was a qualifying order under 18 U.S.C. § 922(g)(8). The court found that the legislative history supported the interpretation that DVPOs issued under AS 18.66.100(c)(1) are effective until further order of the court. The court also concluded that the man’s remaining claims were not ripe for adjudication because he had not attempted to dissolve or modify the DVPO. View "Eng v. State" on Justia Law

The case involves an automobile accident that occurred on June 2, 2018, where Theresa Fisher's vehicle was rear-ended by a vehicle driven by Steven Harter, Jr., causing a chain reaction. Steven Harter, Sr., was also named as a defendant because his son was a minor at the time. The plaintiff sought a declaratory judgment challenging the constitutionality of La. R.S. 13:4163, which allows legislators and legislative employees to obtain continuances or extensions of court dates.The 1st Judicial District Court upheld the constitutionality of La. R.S. 13:4163, and the appellate court declined the plaintiff’s application for supervisory review. The district court had previously granted a partial summary judgment in favor of the plaintiff, finding Steven Harter, Jr. negligent and his father vicariously liable. The court also dismissed the defendants' affirmative defenses of comparative and third-party fault. However, the district court denied the plaintiff's motion for declaratory judgment on the constitutionality of La. R.S. 13:4163, stating that the statute did not violate the separation of powers or any constitutional rights.The Supreme Court of Louisiana reviewed the case and reversed the district court's decision. The court held that La. R.S. 13:4163 is unconstitutional on its face because it usurps the judiciary's power to grant or deny continuances, violating the separation of powers doctrine. The court emphasized that the statute mandates courts to grant continuances ex parte, without a hearing, which undermines the courts' inherent authority to manage their dockets and ensure the fair administration of justice. The case was remanded to the district court with instructions to conduct a contradictory hearing for all contested motions for continuance. View "FISHER VS. HARTER" on Justia Law

A group of inmates sentenced to death filed a declaratory judgment action in the Franklin Circuit Court, challenging the validity of the Kentucky Department of Corrections' (DOC) execution regulations. In 2010, the court issued a temporary injunction preventing the execution of an inmate under the then-current lethal injection protocols. The Commonwealth's attempt to dissolve this injunction was denied, and the court's decision effectively halted all executions until a final judgment was rendered.The DOC revised its lethal injection regulations in March 2024, prompting the Commonwealth to request the lifting of the 2010 injunction. The Franklin Circuit Court reserved ruling on this motion, noting that the original protocols were no longer in effect and questioning whether the injunction still applied. The court highlighted that no current death warrants were active and declined to issue an advisory opinion on the amended regulations' constitutionality.The Commonwealth sought interlocutory relief from the Court of Appeals under RAP 20(B), arguing that the circuit court's reservation of ruling effectively modified the injunction. The Court of Appeals recommended transferring the matter to the Kentucky Supreme Court. Both parties supported this transfer, and the Supreme Court accepted the case.The Kentucky Supreme Court dismissed the action without prejudice, ruling that RAP 20(B) does not allow for interlocutory relief from an order that maintains an injunction. The court noted that the circuit court's decision to reserve ruling did not constitute a new or modified injunction and maintained the status quo. The Commonwealth had other potential remedies, such as requesting a definitive ruling or filing a petition for a writ of mandamus, but did not pursue these options. View "DEPARTMENT OF CORRECTIONS V. BAZE" on Justia Law

In November 2023, X Corp. filed a lawsuit against Media Matters, Inc., Eric Hananoki, and Angelo Carusone, alleging interference with X Corp.'s contracts, business disparagement, and interference with prospective economic advantage. X Corp. claimed that Media Matters manipulated images to portray X Corp. as a platform dominated by neo-Nazism and anti-Semitism, which alienated advertisers, publishers, and users. During discovery, X Corp. requested Media Matters to produce documents identifying its donors and communications with them. Media Matters resisted, citing First Amendment concerns.The United States District Court for the Northern District of Texas initially ordered Media Matters to log documents responsive to X Corp.'s requests as privileged. However, Media Matters did not comply, arguing that the requests overlapped with other discovery requests. The district court then granted X Corp.'s motion to compel production, ruling that Media Matters had waived any First Amendment privilege by not searching for or logging the documents. Media Matters appealed the order and sought a stay pending appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that it had jurisdiction under the collateral order doctrine, as the discovery order involved important First Amendment issues that were separate from the merits of the case and would be effectively unreviewable on appeal. The court determined that Media Matters was likely to succeed on the merits of its appeal because the discovery requests were not proportional to the needs of the case and posed a significant burden on Media Matters and its donors. Consequently, the court granted Media Matters's motion for a stay pending appeal, staying the district court's order compelling production. View "X Corp v. Media Matters" on Justia Law

In February 2020, a police officer in Wauwatosa, Wisconsin, shot and killed a Black teenager, Alvin Cole. Following the incident, community members organized protests against police violence and racism. Anticipating unrest after the district attorney decided not to charge the officer, the mayor imposed a curfew. Plaintiffs, affected by the curfew and police conduct, filed constitutional and state law claims against the City of Wauwatosa and individual defendants.The United States District Court for the Eastern District of Wisconsin dismissed most claims, allowing only First Amendment and Driver’s Privacy Protection Act (DPPA) claims to proceed. The court later granted summary judgment for the defendants on the First Amendment claims, leaving only the DPPA claims for trial. The jury ultimately ruled in favor of the defendants on the DPPA claims.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the curfew was a permissible time, place, and manner restriction under the First Amendment. The court found that the curfew was content-neutral, served a significant government interest in public safety, was narrowly tailored, and left open ample alternative channels for communication. The court also upheld the dismissal of the plaintiffs' § 1983 claims against individual defendants, agreeing that the claims were inadequately pleaded and that the district court did not abuse its discretion in denying further amendments. Lastly, the court found no abuse of discretion in the district court’s response to a jury question regarding the definition of “personal information” under the DPPA. The judgment of the district court was affirmed. View "Knowlton v. City of Wauwatosa" on Justia Law

The case involves a dispute between a taxpayers' association and a water district over the imposition of groundwater replenishment charges. The taxpayers' association alleged that the water district's charges violated constitutional provisions and unfairly benefited large agricultural businesses. The association sought a writ of mandate to stop the collection of these charges and to vacate the resolutions imposing them. They also claimed conversion, civil conspiracy, aiding and abetting, and violations of the Unfair Competition Law (UCL) against the water district's board members, general manager, and consulting firms.The Superior Court of Riverside County denied the defendants' anti-SLAPP motion, which sought to strike several causes of action on the grounds that they arose from protected activities. The court found that the public interest exemption to the anti-SLAPP statute applied. Additionally, the court sustained the defendants' demurrer to the first amended petition and complaint, finding the claims time-barred under the validation statutes. The court also awarded over $180,000 in attorney's fees to the plaintiffs, deeming the anti-SLAPP motion frivolous.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case. The court held that the public interest exemption did not apply because the relief sought could only be provided by the water district, not the individual defendants. The court found that the anti-SLAPP motion should have been granted for most causes of action, except for conversion and the writ of mandate against the general manager. Consequently, the fee award was reversed. The court also affirmed the demurrer ruling, as the claims against the individual defendants were not legally sufficient. The case was remanded for further proceedings consistent with these findings. View "Howard Jarvis Taxpayers Assn. v. Powell" on Justia Law

Joe Baltas, a Connecticut state prisoner, was transferred to the Virginia Department of Corrections (VADOC) under the Interstate Corrections Compact. While at Red Onion State Prison (ROSP) in Virginia, Baltas alleges he was threatened by VADOC officials for filing a grievance and was later attacked by inmates, resulting in his placement in restrictive housing. He also claims that Connecticut Department of Corrections (CTDOC) officials failed to review his administrative segregation (Ad Seg) status as required, violating his due process rights under the Fourteenth Amendment. Additionally, he alleges violations of his First, Sixth, and Eighth Amendment rights due to his treatment at ROSP.The United States District Court for the District of Connecticut granted summary judgment in favor of the Defendants. The court found that CTDOC had adequately reviewed Baltas’s Ad Seg classification and dismissed his due process claim. It also dismissed his First, Sixth, and Eighth Amendment claims, concluding that Baltas failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the District Court’s ruling that CTDOC’s periodic reviews of Baltas’s Ad Seg classification satisfied due process requirements. However, it found that a genuine dispute of fact existed regarding whether VADOC’s administrative remedies were available to Baltas, making summary judgment inappropriate for his First, Sixth, and Eighth Amendment claims. The court vacated the summary judgment on these claims and remanded the case for further proceedings. The court also affirmed the dismissal of Baltas’s remaining claims in a concurrently issued summary order. View "Baltas v. Maiga" on Justia Law

Adam Richardson, a citizen and taxpayer, petitioned the Supreme Court of Florida for writs of quo warranto and mandamus, alleging that the Governor, Attorney General, and Secretary of the Florida Agency for Health Care Administration (AHCA) violated section 104.31, Florida Statutes, by advocating against a proposed constitutional amendment (Amendment 4) related to abortion rights. Richardson claimed that their actions, including statements on an AHCA webpage and social media, as well as participation in a public call and opinion piece, unlawfully interfered with the vote on Amendment 4.The lower courts did not review this case as it was directly brought to the Supreme Court of Florida. Richardson argued that the respondents' actions violated a statute limiting political activities of state officers and employees, which he believed should be enforced through extraordinary writs.The Supreme Court of Florida denied the petition. The court held that the writ of quo warranto is traditionally used to test the right of a person to hold an office or exercise a state-derived power, not to compel criminal prosecution or enable private enforcement of a criminal statute. The court found that Richardson's grievances were more about the merits of the respondents' actions rather than their authority to act. Additionally, the court denied the writ of mandamus, stating that Richardson did not establish a clear legal right or an indisputable legal duty on the part of the respondents, nor did he show that there was no other adequate remedy available. The court concluded that no further relief was required to complete the exercise of its jurisdiction and denied the petition without permitting a rehearing. View "Richardson v. Secretary, Florida Agency for Health Care Administration" on Justia Law

Robert E. Lee Flade filed a lawsuit against several defendants, including Stephanie Isaacs and the Bedford County Listening Project (BCLP), over disparaging remarks made on social media. Isaacs and the BCLP filed motions to dismiss under Rule 12.02(6) of the Tennessee Rules of Civil Procedure and petitions to dismiss under the Tennessee Public Participation Act (TPPA), seeking dismissal with prejudice, attorney’s fees, and sanctions. Before the trial court could hear these motions, Flade voluntarily dismissed his complaint without prejudice. Isaacs and the BCLP requested the court to adjudicate their TPPA petitions despite the dismissal, but the trial court declined, stating the nonsuit concluded the matter.The Court of Appeals affirmed the trial court’s decision, holding that the TPPA petitions did not limit Flade’s right to a voluntary nonsuit under Rule 41.01(1). The court reasoned that the TPPA did not specifically limit the right to a nonsuit and that the mere filing of a TPPA petition did not create a vested right that would prevent a voluntary dismissal.The Supreme Court of Tennessee reviewed the case and affirmed the Court of Appeals' judgment. The court held that the right to take a voluntary nonsuit is not subject to the provisions of the TPPA under Rule 41.01(1). It also concluded that there is no vested right to adjudication of a TPPA petition pending at the time of a voluntary nonsuit and that a TPPA petition does not constitute a counterclaim for purposes of Rule 41.01(1). Therefore, the trial court correctly declined to adjudicate the TPPA petitions after Flade voluntarily dismissed his complaint. View "Flade v. City of Shelbyville, Tennessee" on Justia Law

The case involves a challenge to New York City's Guaranty Law, which was enacted in response to the COVID-19 pandemic. The law rendered personal guaranties of commercial lease obligations arising between March 7, 2020, and June 30, 2021, permanently unenforceable and identified efforts to collect on such guaranties as proscribed commercial tenant harassment. Plaintiffs, a group of New York City landlords, argued that the law violated the Contracts Clause of the U.S. Constitution.Initially, the United States District Court for the Southern District of New York dismissed the plaintiffs' constitutional challenges, but the United States Court of Appeals for the Second Circuit reversed the dismissal of the Contracts Clause challenge and remanded the case for further consideration. On remand, the district court granted summary judgment in favor of the plaintiffs, finding that the Guaranty Law was unconstitutional.The City of New York appealed, arguing that the plaintiffs lacked standing because the City did not enforce the Guaranty Law. The Second Circuit found that while the plaintiffs had standing at the pleadings stage due to the presumption of enforcement, they failed to meet the heightened burden on summary judgment to show a credible threat of imminent enforcement by the City. The City had unequivocally disavowed any intent to enforce the Guaranty Law against the plaintiffs.The United States Court of Appeals for the Second Circuit vacated the district court's award of summary judgment and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. The court denied the City's request to vacate its earlier judgment reversing the dismissal of the Contracts Clause challenge and denied the City costs on the appeal due to its negligent delay in raising the enforcement-based standing challenge. View "Bochner v. City of New York" on Justia Law