Justia Civil Procedure Opinion Summaries

Appellants Somerset Court, LLC, and Kari Riggin appealed a district court judgment dismissing their action seeking a declaratory judgment regarding the validity of the North Dakota Governor’s executive orders. This case began as a challenge to the Governor’s statutory powers in issuing executive orders during the COVID-19 pandemic relating to the operations of certain North Dakota businesses. In April 2020, Somerset, an assisted living facility with an in-house salon, and Riggin, a licensed cosmetologist operating the salon as an independent contractor, claimed the executive orders prohibited Somerset and Riggin from engaging in their business and profession, and placed limitations as to their business and profession. Appellants argued the executive orders were beyond the Governor’s statutory powers; the executive orders involved fundamental rights requiring the application of the strict scrutiny standard of review; and that a declaratory judgment should have been issued as a matter of law and enforced by an appropriate writ. Because Appellants failed to adequately challenge the district court’s conclusion the case was moot, the North Dakota Supreme Court affirmed. View "Somerset Court, et al. v. Burgum, et al." on Justia Law

The Second Circuit vacated the district court's grant of defendants' Rule 12(b)(6) motion to dismiss plaintiff's claim as time-barred. The court held that plaintiff's disability discrimination claim arises under the Affordable Care Act for the purposes of 28 U.S.C. 1658(a), which grants a four-year catchall statute of limitations period for all Acts of Congress enacted after December 1, 1990, and thus the district court erred in applying a three-year statute of limitations period. Accordingly, the court remanded for further proceedings. View "Vega-Ruiz v. Northwell Health" on Justia Law

In this case, the Idaho Supreme Court was asked to revisit its decision in Idaho v. Clarke, 446 P.3d 451 (2019), and determine whether its holding was applicable in an administrative proceeding regarding the suspension of driving privileges based on an alleged case of driving under the influence (“DUI”). The Idaho Transportation Department (“ITD”) appealed a district court’s decision overturning its one-year suspension of Jasmine Reagan’s driving privileges. ITD based the administrative license suspension (“ALS”) on Reagan’s arrest for misdemeanor driving under the influence of alcohol and the results of subsequent testing of her blood alcohol content (“BAC”). The arresting officer, acting on a citizen’s report of a possible intoxicated driver, did not personally witness Reagan operating or in control of a vehicle. Reagan failed field sobriety tests administered at her home and, after being arrested, failed a breathalyzer test. Reagan received notice that her driver’s license was suspended for one year, which she appealed. An administrative hearing officer for ITD, relying on Idaho Code section 49-1405, upheld the license suspension. However, on appeal the district court overturned the suspension pursuant to Clarke, reasoning that because the misdemeanor DUI was completed outside the officer’s presence, the arrest required a warrant. On certiorari review, the issues presented were: (1) whether the breathalyzer test was administered pursuant to a lawful arrest; and (2) if the arrest was unlawful, whether test results obtained pursuant to an unlawful arrest are admissible in an ALS hearing before the ITD. The SupremeCourt concluded Idaho Code section 49-1405, as applied in this case, violated the Idaho Constitution. Accordingly, the Court affirmed the district court's decision to overturn ITD's suspension of Reagan's license. View "Reagan v. Idaho Transportation Department" on Justia Law

Defendants, the State of New Hampshire, the New Hampshire Department of Education (DOE), Governor Christopher Sununu, and the Commissioner of DOE, Frank Edelblut (collectively, the State), appealed a superior court decision denying, in part, the State’s motion to dismiss and denying its cross-motion for summary judgment, granting plaintiffs’ motion for summary judgment on grounds that the amount of per- pupil base adequacy aid set forth in RSA 198:40-a, II(a) (Supp. 2020) to fund an adequate education was unconstitutional as applied to the plaintiff school districts, and awarding plaintiffs attorney’s fees. Plaintiffs, Contoocook Valley School District, Myron Steere, III, Richard Cahoon, Richard Dunning, Winchester School District, Mascenic Regional School District, and Monadnock Regional School District, cross-appealed the trial court’s failure to find RSA 198:40-a, II(a) facially unconstitutional; its determinations regarding the sufficiency of the State’s funding of transportation, teacher benefits, facilities operations and maintenance, and certain services; its failure to find that the State’s system of funding education violates Part II, Article 5 of the State Constitution; and its denial of their request for injunctive relief; and its dismissal of their claims against the Governor and the Commissioner. The New Hampshire Supreme Court affirmed the trial court’s dismissal of the Governor and the Commissioner in their individual capacities, and its denials of the State’s motion to dismiss for failure to state a claim, the State’s cross-motion for summary judgment, and plaintiffs’ request for injunctive relief. However, the Court reversed that portion of the trial court’s order granting plaintiffs’ motion for summary judgment and awarding attorney’s fees, and remanded for further proceedings. View "Contoocook Valley School District v. New Hampshire" on Justia Law

Greg and Cyndi Gomersall filed suit on behalf of their minor child, W.G.G., claiming he received negligent medical treatment at St. Luke’s Regional Medical Center (SLRMC) in Boise when he was injured in December 2010. W.G.G. was 6 years old at the time of the incident. The Gomersalls filed suit against SLRMC on January 25, 2019, more than eight years after W.G.G. was alleged to have been injured. SLRMC moved for summary judgment on the basis that the Gomersalls’ medical malpractice action was time-barred under Idaho Code sections 5-219(4) and 5-230. The district court granted SLRMC’s motion and dismissed the complaint with prejudice. The Gomersalls contended on appeal to the Idaho Supreme Court that the district court erred because Idaho Code section 5-230 was unconstitutional. Specifically, they argued that section 5-230 violated W.G.G.’s due process and equal protection rights by failing to toll the statute of limitations for medical malpractice claims until the age of majority. They also contended the district court erred when it held that the doctrine of equitable estoppel did not preclude SLRMC’s statute of limitations defense. Finding no reversible error, the Supreme Court affirmed the district court’s decision granting summary judgment in favor of SLRMC. View "Gomersall v. St. Luke's Regional Medical Center" on Justia Law

The Second Circuit affirmed the district court's dismissal of plaintiff's complaint against the New York Times. Plaintiff alleged defamation based on the Times's print and online articles about gender bias, favoritism, and groping at the Justice Department. The article details a Times investigation into a series of complaints, using records derived from an EEOC complaint and a sex discrimination and retaliation suit. One of the declarations described an incident between plaintiff and an intern. Plaintiff alleged that the language from this declaration was false and defamatory per se and that the fair report privilege did not apply.The court concluded that the district court performed the proper choice-of-law analysis, applying New York law to the conflict; correctly reasoned that New York was the state with the most significant interests in the litigation and applied New York's fair report privilege; and then properly dismissed plaintiff's complaint as barred by the fair report privilege because the alleged defamatory statement was attributed to an official proceeding. View "Kinsey v. New York Times Co." on Justia Law

After debtor voluntarily filed for Chapter 11 bankruptcy, the bankruptcy court determined that he was transferring assets and defrauding creditors. The bankruptcy court removed him as the debtor-in-possession and appointed a trustee to administer the estate. Debtor appealed, arguing that the trustee's appointment violated his Thirteenth Amendment right to be free from "involuntary servitude"—because, he said, under the trustee's direction, all of his post-petition earnings would be put into the bankruptcy estate for the benefit of his creditors. The bankruptcy court dismissed debtor's Thirteenth Amendment claim as unripe, and the district court similarly held that debtor could not show an injury-in-fact sufficient to confer Article III standing.The Eleventh Circuit reversed and held that debtor's loss of authority and control over his estate, which he suffered as a result of his removal as the debtor-in-possession, constitutes an Article III-qualifying injury-in-fact that is both traceable to the bankruptcy court's appointment of the trustee and redressable by an order vacating that appointment. Therefore, debtor has standing to pursue his Thirteenth Amendment claim. The court left it to the district court on remand to consider the merits of debtor's arguments. View "Breland v. United States" on Justia Law

The Fifth Circuit joined the Fourth Circuit in holding that the Fair Labor Standards Act preempts redundant state law tort claims for unpaid minimum wages and overtime compensation when the state's law does not provide for minimum wages and overtime compensation. In this case, Mississippi does not have state labor laws governing minimum wage or overtime, so it would be impossible for Employees to state a claim for wage and hour violations under state law independent of the FLSA. Furthermore, it would be impossible for Employees to state a claim under the FLSA because sovereign immunity bars suit against the DOC. The court explained that the state law claims based on violations of the FLSA similarly fail because of preemption. Therefore, the court concluded that dismissal with prejudice was appropriate. The court affirmed all dispositions of the district court. View "Aldridge v. Mississippi Department of Corrections" on Justia Law

Uzuegbunam, a Georgia Gwinnett College student, talked with interested students and handed out religious literature on campus until a campus police officer informed him that campus policy prohibited distributing religious materials outside two areas designated for that purpose. Speaking about religion or distributing religious materials in those areas required a permit. Uzuegbunam obtained a permit and tried to speak in a free speech zone. A campus officer again asked him to stop, saying that people had complained. Campus policy prohibited using the free speech zone to say anything that “disturbs the peace and/or comfort of person(s).” Uzuegbunam complied. Another student decided not to speak about religion because of these events. The students sought injunctive relief and nominal damages. College officials discontinued the challenged policies. The Eleventh Circuit held that the students’ plea for nominal damages could not establish standing, absent a request for compensatory damages.The Supreme Court reversed. A request for nominal damages satisfies the redressability element necessary for Article III standing where a plaintiff’s claim is based on a completed violation of a legal right. To establish Article III standing, the Constitution requires a plaintiff to identify an injury in fact that is fairly traceable to the challenged conduct and to seek a remedy likely to redress that injury. Under common law, a party whose rights are invaded can recover nominal damages without furnishing evidence of actual damages, without a plea for compensatory damages. Nominal damages are not purely symbolic. One dollar may not provide full redress, but the partial remedy satisfies the redressability requirement and constitutes relief on the merits. In addition to redressability, the plaintiff must establish the other elements of standing and satisfy other relevant requirements, such as pleading a cognizable cause of action. View "Uzuegbunam v. Preczewski" on Justia Law

The church holds weekly in-person worship services attended by approximately 80 people. Its pastor suspended these services after he received a March 31, 2020 “Cease and Desist Notice” from the county health department that threatened penalties under Illinois Executive Order 2020-10, issued March 20, 2020, if the church continued to host in-person gatherings of ten or more people. The Plaintiffs sought a preliminary injunction, citing the First Amendment and the Illinois Religious Freedom Restoration Act and alleging violations of their due process rights and that the Order exceeded the governor’s powers.On May 29, months before plaintiffs filed their appellate brief, the governor issued Executive Order 2020-38, which removed the mandate. All subsequent pandemic-related executive orders have expressly exempted religious gatherings from mandatory restrictions.The Seventh Circuit affirmed the denial of a preliminary injunction. While intervening Supreme Court decisions offer a greater prospect for success on the merits of the First Amendment claim than previously expected, they have also indicated that equitable considerations weigh against granting a preliminary injunction at this time. The prospect of irreparable injury to the plaintiffs is very low; the public interest weighs substantially against injunctive relief. The federal procedural due process claim was not presented to the district court. The Eleventh Amendment bars relief against the governor; it may also bar relief against the local defendants. All of the state-law claims are poor candidates for a federal court’s exercise of supplemental jurisdiction. View "Cassell v. Snyders" on Justia Law