Justia Civil Procedure Opinion Summaries

A developer purchased a historical property in Newton, Massachusetts, and began restoration work. The Newton Historical Commission issued a stop-work order, claiming the developer violated the permit by demolishing large portions of the building. The developer, 29 Greenwood, LLC, disagreed but complied with the order and submitted revised proposals, all of which were denied. The developer then filed a lawsuit, alleging a violation of the Takings Clause of the U.S. Constitution and state law.The case was initially filed in state court but was removed to the U.S. District Court for the District of Massachusetts. The district court dismissed the complaint, ruling that the dispute was a typical zoning issue not rising to the level of a constitutional taking. The developer appealed the dismissal, arguing that the Commission acted in bad faith and would never permit the reconstruction.The United States Court of Appeals for the First Circuit reviewed the case. The court noted that two related actions were pending in state court, which could potentially resolve or narrow the federal constitutional issues. The court decided to abstain from ruling on the federal issues until the state court proceedings concluded, invoking the Pullman abstention doctrine. The court vacated the district court's dismissal and remanded the case with instructions to stay the federal proceedings pending the outcome of the state court cases. Each party was ordered to bear its own costs. View "29 Greenwood, LLC v. City of Newton" on Justia Law

The case involves three consolidated appeals concerning the constitutionality of the Child Victims Act of 2023, which retroactively eliminated the statute of limitations for child sexual abuse claims. The plaintiffs, who are alleged survivors of childhood sexual abuse, filed lawsuits against various institutions, including the Roman Catholic Archbishop of Washington, the Board of Education of Harford County, and The Key School, Inc. The defendants argued that the 2023 Act unconstitutionally abrogated their vested rights by reviving claims that were previously time-barred.In the Circuit Court for Prince George’s County, the court denied the Archbishop’s motion to dismiss, determining that the relevant statute was a statute of limitations, not a statute of repose, and thus did not create vested rights. The Circuit Court for Harford County reached a similar conclusion regarding the Board of Education of Harford County. In the United States District Court for the District of Maryland, the court certified the question of the 2023 Act’s constitutionality to the Supreme Court of Maryland without ruling on The Key School’s motion to dismiss.The Supreme Court of Maryland held that the 2017 statute, which the 2023 Act amended, was a statute of limitations rather than a statute of repose. The court reasoned that the statute of limitations is a procedural device that does not create vested rights, whereas a statute of repose creates substantive rights that cannot be retroactively abrogated. The court concluded that the 2023 Act did not retroactively abrogate vested rights and was constitutional as applied to the defendants. The court applied heightened rational basis review and found that the 2023 Act bore a real and substantial relation to addressing the problem of delayed reporting of child sexual abuse and the need for justice for survivors. The judgments of the lower courts were affirmed, and the certified question was answered in the negative. View "Archbishop of Washington v. Doe" on Justia Law

In 2011, plaintiffs sued the Roman Catholic Diocese of Charlotte, alleging sexual abuse by priests in the 1970s and 1980s. The trial court granted summary judgment for the Diocese, finding the claims time-barred by the statute of limitations. One plaintiff appealed and lost, while the other did not appeal. Both judgments became final a decade ago.In 2019, the General Assembly passed the SAFE Child Act, which revived previously time-barred claims for child sexual abuse. In 2020, plaintiffs filed new lawsuits asserting the same claims dismissed in the earlier judgments, arguing that the SAFE Child Act allowed them to do so. The trial court dismissed these new lawsuits with prejudice, citing the res judicata effect of the earlier judgments. The Court of Appeals affirmed, holding that the new lawsuits were barred by res judicata because final judgments had already been entered on the same claims.The Supreme Court of North Carolina reviewed the case and affirmed the Court of Appeals' decisions. The court held that the General Assembly does not have the power to set aside a final judgment of the judicial branch. The court emphasized that under the North Carolina Constitution, the judicial power belongs exclusively to the judicial branch, and the legislature cannot annul a judgment or decree of a court. The court concluded that the SAFE Child Act, like any other legislative act, cannot overturn a final judgment entered by the judicial branch. View "Doe v. Roman Cath. Diocese" on Justia Law

Fourteen civilly committed clients of the Minnesota Sex Offender Program (MSOP) filed a lawsuit challenging MSOP policies that affected their spiritual group activities, particularly those impacted by the COVID-19 pandemic. Before the pandemic, MSOP allowed clients to participate in spiritual groups under certain conditions. However, during the pandemic, MSOP implemented new regulations that restricted these activities. Plaintiffs argued that these restrictions violated the U.S. Constitution and the Religious Land Use and Institutionalized Persons Act (RLUIPA).The United States District Court for the District of Minnesota granted summary judgment in favor of the defendants, finding that the plaintiffs' claims were moot because the COVID-19 restrictions had been lifted, and pre-pandemic policies were reinstated. The court also declined to address new concerns raised by the plaintiffs regarding MSOP's current policies, as these issues were not included in the second amended complaint.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims about the pandemic-era policies were moot since those policies were no longer in effect. The court also found that the plaintiffs' new concerns about MSOP's current policies were not properly pled in the second amended complaint and thus were not before the court. Additionally, the appellate court denied the plaintiffs' motion to supplement the record with discovery documents, as the plaintiffs failed to provide a valid reason for not including these documents earlier, and their inclusion would not change the case's resolution. View "Allan v. Minnesota DHS" on Justia Law

Robert E. Dupuis and twelve other plaintiffs filed lawsuits against the Roman Catholic Bishop of Portland, seeking damages for sexual abuse allegedly perpetrated by the Bishop’s clergy when the plaintiffs were minor children. Their claims were previously barred by the statute of limitations. The Bishop moved for judgment on the pleadings, arguing that 14 M.R.S. § 752-C(3) (2022), which purports to revive the plaintiffs’ claims, deprives the Bishop of a constitutionally protected vested right.The Business and Consumer Docket (McKeon, J.) denied the Bishop’s motions but reported its orders to the Maine Supreme Judicial Court under Maine Rule of Appellate Procedure 24(c). The court accepted the report to determine whether the retroactive application of section 752-C(3) is constitutional.The Maine Supreme Judicial Court held that the retroactive application of section 752-C(3) contravenes centuries of precedent and multiple provisions of the Maine Declaration of Rights, as well as the Constitution’s provisions regarding separation of powers. The court concluded that once a statute of limitations has expired for a claim, a right to be free of that claim has vested, and the claim cannot be revived. Therefore, section 752-C(3) is unconstitutional as applied to expired claims. The court remanded the case for further proceedings consistent with this opinion. View "Dupuis v. Roman Catholic Bishop of Portland" on Justia Law

Sherran Wasserman agreed to sell land in Franklin County to Anthony Pham, contingent on the approval of a conditional use permit by the Franklin County Board of Commissioners. Pham applied for the permit to build and operate chicken houses, but the Board denied the application. Wasserman then sued the Board and the County, initially bringing multiple claims under state and federal law. She dismissed some claims, conceded others, and the trial court dismissed her remaining state-law claims due to sovereign immunity. This left two federal claims: one alleging the County violated Pham’s equal protection rights based on race, and another alleging a violation of Wasserman’s equal protection rights as a “class of one.”The trial court denied the County’s motion for summary judgment, applying the federal doctrine of third-party standing, which allows a plaintiff to assert the rights of third parties. The court found genuine issues of material fact precluded summary judgment on standing and the merits of Wasserman’s equal protection claims. The Court of Appeals reversed, concluding Wasserman lacked third-party standing and that her “class of one” claim failed as a matter of law.The Supreme Court of Georgia reviewed whether a plaintiff may rely on the federal doctrine of third-party standing to establish constitutional standing in Georgia courts. The court held that Georgia’s constitutional standing requirements, rooted in the common law and consistent precedent, do not allow a plaintiff to maintain an action by asserting only the rights of a nonparty. The court overruled its previous adoption of the federal doctrine of third-party standing, concluding that a plaintiff must assert her own legal rights to invoke the judicial power of Georgia courts. The judgment was vacated and remanded for further proceedings consistent with this opinion. View "WASSERMAN v. FRANKLIN COUNTY" on Justia Law

Iowa enacted Senate File 2340, which criminalizes the presence of aliens who have illegally reentered the United States within its boundaries. The Act mandates that aliens violating it must return to the country they reentered from and prohibits judges from abating state prosecutions due to pending or possible federal determinations of the alien’s immigration status. The United States sought a preliminary injunction against the enforcement of the Act, which the district court granted. Iowa appealed the decision.The United States District Court for the Southern District of Iowa ruled that the United States had standing to sue and could state a cause of action to enjoin the Act. The court found that the United States established a likelihood of success on the merits, showing that federal immigration law preempts the Act under both conflict and field preemption. The court also found that irreparable harm would occur if the Act went into effect and that the balance of equities and public interest favored granting the injunction.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion, examining factual findings for clear error and legal conclusions de novo. The appellate court affirmed the district court’s decision, holding that the United States had standing and an equitable cause of action to enjoin the Act. The court found that the Act likely conflicts with federal immigration law, as it obstructs the discretion of federal officials and creates a parallel enforcement scheme. The court also agreed that the United States demonstrated irreparable harm and that the balance of equities and public interest favored the injunction. The preliminary injunction against the enforcement of the Act was affirmed. View "United States v. State of Iowa" on Justia Law

The case involves Maine healthcare workers who were terminated from their employment for refusing to comply with a COVID-19 vaccine mandate based on their religious beliefs. The mandate, initially promulgated by emergency rule on August 12, 2021, was no longer enforced as of July 12, 2023, and was repealed effective September 5, 2023. The plaintiffs filed suit in the United States District Court for the District of Maine, asserting that the mandate's lack of religious exemptions violated the First and Fourteenth Amendments. Their motion for a temporary restraining order and preliminary injunction was denied, and the denial was affirmed by the First Circuit. The Supreme Court also denied their application for emergency injunctive relief.The defendants moved to dismiss the complaint for failure to state a claim, which was granted. The First Circuit affirmed in part and reversed in part, reinstating the First Amendment Free Exercise and Fourteenth Amendment Equal Protection Clause claims for declaratory and injunctive relief against state health officials. Following the repeal of the mandate, the defendants moved to dismiss the remaining claims as moot, and the district court granted the motion, also denying the plaintiffs leave to amend the complaint.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's determinations. The court held that the challenge was moot because the COVID-19 vaccine mandate had been repealed and was no longer in effect. The court also found that no exceptions to mootness, such as voluntary cessation or capable of repetition yet evading review, applied. The court further affirmed the denial of the plaintiffs' request to amend their complaint, concluding that justice did not require permitting further amendments to broaden the scope of their claims. View "Lowe v. Gagne-Holmes" on Justia Law

Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law

Deborah Jane Clapp, a Minneapolis homeowner and taxpayer, filed a declaratory judgment action against the Minneapolis Public Schools and its officials. Clapp challenged the constitutionality of racial and ethnic preference provisions in a collective bargaining agreement between the school district and its teachers' union. She sought to stop the school district from implementing and spending public money on these provisions, alleging they violated the Minnesota Constitution's Equal Protection Guarantee.The district court dismissed Clapp's complaint, ruling that she lacked standing and that her claims were not ripe. Clapp appealed, and the Minnesota Court of Appeals reversed the district court's decision, concluding that Clapp had taxpayer standing and that her claims were ripe for judicial review. The school district then petitioned for review by the Minnesota Supreme Court.The Minnesota Supreme Court reviewed the case and focused on the issue of taxpayer standing. The court held that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. In this case, the court found that the alleged unlawful disbursements were merely incidental to the central dispute, which was the constitutionality of the racial and ethnic preference provisions in the collective bargaining agreement. Therefore, Clapp lacked taxpayer standing to bring her claims. The court reversed the decision of the court of appeals, upholding the district court's dismissal of Clapp's complaint. View "Clapp vs. Sayles-Adams" on Justia Law