Justia Civil Procedure Opinion Summaries

This summary judgment matter arose from a petition for declaratory judgment seeking a declaration (amongst other things) that defendant First Guaranty Bank (the “Bank”) applied an incorrect interest rate and thus miscalculated the principal owed on a Promissory Note executed by borrower-petitioner Leisure Recreation & Entertainment, Inc. (“Leisure”) in favor of the Bank in December 1991 (the “Note”). The Louisiana Supreme Court granted Leisure’s writ application to determine whether the court of appeal erred in applying the “voluntary payment doctrine” to hold that Leisure was estopped from recovering payments voluntarily made, regardless of whether owed. In addition, the Court reviewed whether the court of appeal erred in determining the Note presented an alternative obligation as to the Prime Rate interest structure for years 11 through 30 of its repayment, whether it erred in imposing its own interest rate structure during that period, and whether the Bank’s prescription arguments preclude Leisure’s recovery of any interest paid and not due between 2001 and 2013. Finding the “voluntary payment doctrine” contravened the Louisiana Civil Code, the Supreme Court reversed the court of appeal insofar as it: (1) reversed the portion of the district court’s judgment denying the motion for summary judgment filed by the Bank as to the voluntary payment affirmative defense; (2) dismissed Leisure’s claim for declaratory relief as to the interest it voluntary paid the Bank between 2001 and 2013; and (3) rendered judgment ordering the Bank to repay Leisure “any overcharge of interest in excess of the prime rate that Leisure paid on the [Note] since the filing of its suit on October 7, 2013, together with interest thereon from the date of judicial demand until paid.” Finding that the Note set forth an “alternative obligation,” the Supreme Court reversed the court of appeal insofar as it: (1) reversed the district court decree that Leisure was entitled to select the Prime Rate structure pursuant to La. C.C. art. 1810; and (2) reversed the district court’s declaration that Leisure paid all indebtedness owed to the Bank on the Note as of June 28, 2015, and was owed return of all amounts paid thereafter. The case was remanded to the court of appeal for consideration of the Bank’s arguments on appeal that were pretermitted by the court of appeal opinion and were not in conflict with the Supreme Court's opinion. View "Leisure Recreation & Entertainment, Inc. v. First Guaranty Bank" on Justia Law

In October 2017, plaintiffs Sadie Boyd (a student at Twin Valley Middle High School in Whitingham, Vermont) Madeleine Klein (a resident and property owner in Whitingham), and the Town of Whitingham filed a complaint for declaratory and injunctive relief against defendant State of Vermont, arguing that the education funding and property taxation system set forth in 16 V.S.A. ch. 133 and 32 V.S.A. ch. 135 violated the Education Clause, the Proportional Contribution Clause, and the Common Benefits Clause of the Vermont Constitution. They claimed that the system was unconstitutional because it deprived plaintiff Boyd of an equal educational opportunity, required plaintiff Klein to contribute disproportionately to education funding, and compelled the Town to collect an unconstitutional tax. The civil division granted the State’s motion for summary judgment, concluding that plaintiffs failed to demonstrate the alleged inequities were caused by the statutes in question or that the education property taxation system lacked a rational basis. Finding no reversible error, the Vermont Supreme Court affirmed. View "Boyd, et al. v. Vermont" on Justia Law

Plaintiff filed this federal action after a Connecticut probate court issued an order recognizing the validity of a state lien against plaintiff's interest in an estate. The district court applied the doctrine established in Younger v. Harris, 401 U.S. 37 (1971), and abstained from adjudicating plaintiff's suit because of the ongoing state probate proceedings.The Second Circuit clarified that Younger abstention applies only to a narrow class of state civil proceedings. Civil probate proceedings are no more invulnerable to federal court interference than any other state civil proceedings, unless the state order at issue protects the State's administration of its judicial system or its process for compelling compliance with the judgments of its courts. The court concluded that the district court appears to have misunderstood the narrow scope of Younger abstention to extend to state probate proceedings that concern the validity of a lien. The court considered the Commissioner's remaining arguments and found them to be without merit. Therefore, the court vacated the district court's decision and remanded for further proceedings. View "Cavanaugh v. Geballe" on Justia Law

Dr. Jacob Schmitz appealed a district court judgment ordering: (1) the State Board of Chiropractic Examiners to disclose a limited portion of a recording from an April 2020 executive session of the Board; (2) denying the disclosure of any portion of a May 2020 executive session; and (3) the denial of his motion for attorney’s fees. In June 2020, Dr. Schmitz commenced this lawsuit, alleging that the Board violated the law regarding access to public records and meetings. The North Dakota Supreme Court declined to address Dr. Schmitz’s allegation that his right to due process was violated by the in-camera review because it was not properly preserved; reversed the denial of attorney’s fees; and remanded for additional portions of the executive sessions to be disclosed to Dr. Schmitz and for a determination of an appropriate award of attorney’s fees. View "Schmitz v. State Board of Chiropractic Examiners" on Justia Law

In 2017, Ronald Van Hook was declared a vexatious litigant pursuant to Idaho Court Administrative Rule 59; this declaration was upheld by he Idaho Supreme Court. In 2021, “on behalf of his minor son” G.V.H., Van Hook filed a 28-page “Request for Leave to File Habeas Corpus and Juvenile Post-Conviction Relief” (“the Filing Request”). In the Filing Request, Van Hook alleged eight sets of “complaints” and asserted that numerous fundamental rights had been violated. He further requested a hearing on the Filing Request. Without holding a hearing on the matter, the district court denied the request because: (1) Van Hook, as a non-lawyer, could not engage in the unauthorized practice of law by representing his son in a civil court proceeding; (2) the petition for writ of habeas corpus was without merit; and (3) Van Hook was attempting to re-litigate prior court decisions that had been finally decided against him. Van Hook appealed, and the Supreme Court entered an Order Conditionally Dismissing Appeal, which stayed the proceedings, but allowed Van Hook time “to make application with the presiding district court judge permitting the notice of appeal to be filed, pursuant to I.C.A.R. 59(j).” The district court granted Van Hook permission to appeal “the narrow issue of whether [the district court’s] decision to deny Mr. Van Hook’s motion for leave to file litigation was arbitrary and capricious and/or in violation of his due process rights.” The Supreme Court withdrew its conditional order, allowing appeal on the narrow issue identified by the district court. As a matter of first impression, the Supreme Court first determined the proper standard of review to apply when reviewing a presiding judge’s denial of a vexatious litigant’s request to file new litigation pursuant to Rule 59(i) was the same standard used when reviewing a district court’s granting of a motion to dismiss pursuant to Rule 12(b)(6): “The issue is not whether the plaintiff will ultimately prevail, but whether the party is entitled to offer evidence to support the claims.” The Court found the district court did not err in denying Van Hook's request for leave to file new litigation, and his due process rights were not violated. View "Van Hook v. Idaho" on Justia Law

Exxon appealed the dismissal of its complaint against the New York and Massachusetts Attorneys General, alleging that the states' investigations into Exxon's purportedly deceptive speech regarding climate change were motivated by viewpoint discrimination and violated Exxon's constitutional rights. During the pendency of this appeal, the New York Attorney General closed the New York investigation and started an enforcement action, which resolved in Exxon's favor and is not being appealed by the state.The Second Circuit concluded that these events mooted Exxon's claims against the New York Attorney General and thus the court lacked jurisdiction over those claims. In regard to claims against the Massachusetts Attorney General, the court concluded that the claims are barred under the doctrine of res judicata because Exxon could have pursued the relief it now seeks in an earlier Massachusetts state court proceeding arising from the same events that underlie the present suit. Accordingly, the court dismissed in part and affirmed in part. View "Exxon Mobil Corp. v. Healey" on Justia Law

The New Jersey Attorney General, investigating Smith & Wesson under the state's Consumer Fraud Act, issued a subpoena seeking documents related to Smith & Wesson’s advertisements. Instead of producing the documents, Smith & Wesson filed suit in federal court under 42 U.S.C. 1983, alleging the subpoena violated the First, Second, Fourth, Fifth, and Fourteenth Amendments. The state trial court subsequently ordered Smith & Wesson to show cause and threatened the company with contempt and a ban on sales in New Jersey; the court rejected the constitutional arguments presented in the federal suit. Smith & Wesson unsuccessfully sought an emergency stay of production. In federal court, Smith & Wesson added claims that the Attorney General’s suit was “retaliation" for the exercise of its First Amendment right to petition a court for redress.The Attorney General moved to dismiss the federal suit, citing “Younger” abstention. The district court dismissed the complaint, stating “the subpoena-enforcement action involves orders in the furtherance of state court judicial function.” Smith & Wesson eventually produced the subpoenaed documents under a protective order. The Third Circuit vacated the dismissal, citing the district court’s “virtually unflagging obligation . . . to exercise the jurisdiction given.” Abstention was not warranted in this case because the document production order was not “uniquely in furtherance of the state courts’ ability to perform their judicial functions.” View "Smith & Wesson Brands Inc v. Attorney General New Jersey" on Justia Law

In October 2017, an incarcerated woman filed a lawsuit against Cumberland County and several corrections officers, including Tyrone Ellis, alleging she had been forced to engage in non-consensual sex acts on a regular basis. Plaintiff Libertarians for Transparent Government (Libertarians) obtained minutes of the public meeting of the Board of the Police and Firemen’s Retirement System at which the Board considered Ellis’s application for special retirement. According to the minutes, the County originally sought to terminate Ellis, who had been charged with a disciplinary infraction. When he submitted his resignation, the County warned that it intended to continue to prosecute the disciplinary matter. Ellis, in turn, “agreed to cooperate” with the County’s investigation of four other officers suspected of similar misconduct. “As a result of his cooperation, Cumberland County agreed to dismiss the disciplinary charges and permit Mr. Ellis to retire in good standing” with a reduced pension. Libertarians sent the County an OPRA request seeking, as relevant here, the settlement agreement and Ellis’s “'name, title, position, salary, length of service, date of separation and the reason therefor’ in accordance with N.J.S.A. 47:1A-10.” The County declined to produce the settlement agreement, claiming it was a personnel record exempt from disclosure. In response to the request for information, the County stated in part that “Officer Ellis was charged with a disciplinary infraction and was terminated.” Libertarians filed a complaint in Superior Court, and the trial court ordered the County to provide a redacted version of the settlement agreement. The County appealed, and the Appellate Division reversed the trial court’s judgment. The New Jersey Supreme Court concluded the trial court properly ordered disclosure of a redacted settlement agreement, and the Appellate Division reversed. The Supreme Court reinstated the trial court’s order. View "Libertarians for Transparent Government v. Cumberland County" on Justia Law

A hung jury on one claim is a non-finding that cannot be used to conduct a consistency analysis with another finding by the jury. In this case, the jury was given a general verdict form, found defendant liable on one count and awarded plaintiff $25,000 in damages. However, the district court invalidated that verdict based on a jury deadlock for a different count, reasoning that the deadlock on excessive force was irreconcilable with a verdict on retaliation.The Fourth Circuit reversed the district court's order granting a new trial and reinstated the jury verdict finding defendant liable for $25,000 based on plaintiff's retaliation claim and vacated the district court's final judgment based on the second trial. The court also vacated the district court's order denying plaintiff's motion for attorney's fees and vacated the district court's order denying plaintiff's motion for partial voluntary dismissal because its decision on those matters was based on the district court's ruling on the motion for a new trial. The court remanded for further proceedings. View "Jordan v. Large" on Justia Law

The PBA appeals the district court's order denying its motion to intervene in the consolidated cases captioned In re New York City Policing During Summer 2020 Demonstrations, asserting interests in the litigation that it argues the parties to the actions cannot adequately represent. Therefore, the PBA claims it is entitled to intervene as of right pursuant to Federal Rule of Civil Procedure 24(a).The Second Circuit held that the district court erred in holding that the PBA did not have a cognizable interest in the personal safety of its member officers at the merits stages of the actions seeking injunctive or declaratory relief and that such interests were adequately represented. Accordingly, the court reversed the district court's denial of intervention with respect to the actions seeking declaratory injunction relief, and affirmed the district court's denial of intervention with respect to those actions seeking neither declaratory nor injunctive relief. View "Payne v. City of New York" on Justia Law