Justia Civil Procedure Opinion Summaries

Jacquelyn N’Jai filed a lawsuit against the U.S. Department of Education, New York University (NYU), Long Island University (LIU), Immediate Credit Recovery, Inc. (ICR), and FMS Investment Corporation (FMS), alleging various violations of federal law. N’Jai claimed that she had repaid her student loans but was falsely certified for additional loans by a bank analyst, with NYU and LIU allegedly signing her name on fraudulent loan applications. She contended that the Department of Education and its debt collectors used unlawful practices to collect on these loans, including garnishing her tax refund and threatening to garnish her Social Security checks.The United States District Court for the District of Columbia dismissed N’Jai’s claims against LIU, NYU, ICR, and FMS for lack of personal jurisdiction, citing the government contacts exception. This exception prevents the assertion of personal jurisdiction based solely on a defendant’s contact with federal government agencies in the District of Columbia. The court dismissed the claims against the remaining defendants for other reasons.The United States Court of Appeals for the District of Columbia Circuit reviewed the case, focusing on whether the government contacts exception under D.C. law is limited to First Amendment activities. The court noted the ongoing uncertainty about the scope of this exception, referencing previous cases where the D.C. Court of Appeals had not definitively resolved whether the exception is confined to First Amendment activity. Due to this uncertainty, the appellate court certified two questions to the D.C. Court of Appeals: whether the government contacts exception is limited to First Amendment activity and, if so, whether the contacts alleged in this case fall under that exception. The appellate court did not make a final ruling on the personal jurisdiction issue, pending the D.C. Court of Appeals' response to the certified questions. View "N'Jai v. Department of Education" on Justia Law

The case involves the Animal Legal Defense Fund (ALDF) challenging the U.S. Department of Agriculture's (USDA) approval of Perdue's "Fresh Line" chicken and turkey product labels. ALDF claimed that the labels, which depicted birds roaming outside, were misleading because the birds were raised indoors. ALDF requested the USDA to disapprove these labels, arguing that they misled consumers. The USDA declined, leading ALDF to sue, alleging violations of the Poultry Products Inspection Act (PPIA) and the Administrative Procedure Act (APA).The United States District Court for the District of Columbia dismissed ALDF's complaint, concluding that ALDF lacked standing to challenge the USDA's actions. The court found that ALDF failed to establish both organizational and associational standing. Specifically, the court determined that ALDF's member, Marie Mastracco, did not suffer a sufficiently concrete injury to confer standing.The United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The court agreed with the district court, finding that ALDF did not demonstrate that Mastracco faced an ongoing or imminent injury. The court noted that while Mastracco was misled by the labels in the past, she now knows the truth about the birds' living conditions, making any future reliance on the labels self-inflicted. Additionally, the court found that ALDF failed to show that other poultry-product labels with similar misleading graphics existed, which would be necessary to establish a substantial likelihood of future harm.The Court of Appeals affirmed the district court's dismissal of ALDF's complaint without prejudice, holding that ALDF lacked standing to pursue its claims. View "Animal Legal Defense Fund, Inc. v. Vilsack" on Justia Law

The case involves a consumer class action against Premier Nutrition Corporation, which marketed Joint Juice, a dietary supplement drink, as effective for relieving joint pain. Mary Beth Montera, representing a class of New York consumers, alleged that Premier's advertising was deceptive and violated New York General Business Law (GBL) §§ 349 and 350. These laws require proof that the defendant engaged in consumer-oriented conduct that was materially misleading and caused injury to the plaintiff.The United States District Court for the Northern District of California certified the class and the case proceeded to trial. Montera presented evidence, including studies showing that Joint Juice's key ingredients, glucosamine and chondroitin, were ineffective for joint health. Premier countered with industry-funded studies supporting the product's efficacy. The jury found Premier's statements deceptive and awarded statutory damages based on the number of units sold in New York during the class period. Premier's post-trial motions to decertify the class and for judgment as a matter of law were denied.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed the district court's rulings on class certification, liability under GBL §§ 349 and 350, and the initial calculation of statutory damages. The court rejected Premier's arguments that its statements were not materially misleading and that Montera's injury was not cognizable under New York law. The court also upheld the jury's finding that the class members' injuries were caused by Premier's misrepresentations.However, the Ninth Circuit vacated the district court's award of prejudgment interest, ruling that statutory damages under GBL §§ 349 and 350 are not compensatory and thus do not warrant prejudgment interest. The court also remanded the case for the district court to reconsider the statutory damages award in light of the factors identified in Wakefield v. ViSalus, Inc., which addresses the substantive due process limits on aggregate statutory damages. The court affirmed in part, reversed in part, and vacated and remanded in part. View "MONTERA V. PREMIER NUTRITION CORPORATION" on Justia Law

Cybercriminals hacked into T-Mobile's computer systems, stealing personal information of approximately 76.6 million customers. Several customers filed class action lawsuits against T-Mobile, which were centralized in the U.S. District Court for the Western District of Missouri. The parties reached a settlement, with T-Mobile agreeing to create a $350 million fund for affected customers and to spend an additional $150 million on data security improvements. Class counsel requested $78.75 million in attorneys' fees, which two class members, Cassie Hampe and Connie Pentz, objected to as excessive.The district court struck Hampe's and Pentz's objections and overruled them on the merits. The court found Hampe's objection to be in bad faith, influenced by her attorneys' history as serial objectors, and struck it under Federal Rule of Civil Procedure 12(f). Pentz's objection was struck as a discovery sanction after she refused to cooperate with class counsel's discovery efforts. Both objectors appealed the district court's decisions.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that the district court abused its discretion in striking Hampe's objection, as Rule 12(f) does not apply to objections and there was no evidence of bad faith in this case. The court also found that the district court erred in awarding attorneys' fees, determining that the fee award was unreasonable given the relatively short duration and limited discovery of the case. The court affirmed the decision to strike Pentz's objection but reversed the decision to strike Hampe's objection and the award of attorneys' fees, remanding for further proceedings. View "Daruwalla v. Hampe" on Justia Law

Jose Medina purchased a used car from St. George Auto Sales in December 2014, with financing from Alaska Federal Credit Union. Medina later discovered that the car had extensive engine repairs that were not disclosed to him at the time of purchase. He experienced multiple issues with the car, including the check engine light activating several times shortly after the purchase. Despite repeated repairs, the problems persisted. In December 2015, Medina learned from a different dealership that the car had significant pre-existing engine issues, which led him to believe that St. George had concealed this information.Medina filed a lawsuit in August 2018 against St. George and Alaska Federal, claiming a violation of the Consumer Legal Remedies Act (CLRA). The defendants argued that the claim was barred by the three-year statute of limitations. They contended that Medina should have been aware of the issues by March 2015 due to the repeated activation of the check engine light. The Superior Court of San Bernardino County overruled the defendants' demurrer and denied their motion for summary judgment, finding that there were factual questions about when Medina should have suspected the harm. The jury ultimately found in favor of Medina, concluding that he did not have sufficient notice of the claim until later.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court held that the discovery rule applies to the CLRA’s statute of limitations, meaning the limitations period begins when the plaintiff discovers or should have discovered the basis for the claim. The court found no error in the trial court’s rulings on the demurrer, summary judgment, or nonsuit motions, as there were factual questions about when Medina should have known about the engine issues and the defendants' potential wrongdoing. The judgment in favor of Medina was affirmed. View "Medina v. St. George Auto Sales, Inc." on Justia Law

Windward Bora LLC purchased a junior promissory note signed by Constance and Royston Browne, secured by a junior mortgage on real property. Windward's predecessor had already obtained a final judgment of foreclosure on the junior mortgage. Without seeking leave from the court that issued the foreclosure, Windward filed a diversity action to recover on the promissory note. Both parties moved for summary judgment.The United States District Court for the Southern District of New York granted the Brownes' motion for summary judgment and denied Windward's. The court found diversity jurisdiction by comparing the national citizenship of the Brownes with that of Windward’s sole member, a U.S. lawful permanent resident, and concluded that state domiciles were irrelevant. It also held that the suit was precluded by New York’s election-of-remedies statute because Windward did not seek leave before suing on the note after its predecessor had already sued on the mortgage. The court found no special circumstances to excuse Windward’s failure.The United States Court of Appeals for the Second Circuit reviewed the case. It agreed with the district court that diversity jurisdiction was present but clarified that the state domiciles of the parties were relevant. The court resolved a divide among district courts, stating that there is no diversity jurisdiction in a suit between U.S. citizens and unincorporated associations with lawful permanent resident members if such jurisdiction would not exist in a suit between the same U.S. citizens and those permanent resident members as individuals. The court also affirmed the district court’s decision to grant summary judgment for the Brownes under New York’s election-of-remedies statute, finding no special circumstances to excuse Windward’s failure to seek leave. The judgment of the district court was affirmed. View "Bora v. Browne" on Justia Law

John Craig First purchased an agricultural combine from Rolling Plains Implement Company, which was manufactured by AGCO Corporation. First was told the combine was part of AGCO’s Certified Pre-Owned Program, had roughly 400 hours of use, and had never been to the field. However, these representations were false; the combine was not certified and had over 1,200 hours of use. After experiencing numerous issues with the combine, First discovered in 2019 that it had an extensive repair history and over 900 hours of use. He then filed a lawsuit against Rolling Plains, AGCO Corporation, AGCO Service, AGCO Finance, and other related entities.Initially, First filed his lawsuit in the District Court of Oklahoma County, but it was removed to federal court in Oklahoma, which dismissed the case without prejudice and transferred it to the Northern District of Texas. First amended his complaint multiple times, asserting claims of fraud, breach of warranty, and failure of essential purpose. The district court dismissed the fraud claims against AGCO Corporation, AGCO Service, and AGCO Finance for lack of particularity and granted summary judgment in favor of AGCO Finance on the warranty claims. The case proceeded to trial on the remaining claims, where the jury found that First knew or should have known of the fraud by April 13, 2017, and awarded him $96,000 in damages. However, the district court entered judgment in favor of Rolling Plains based on the statute of limitations.The United States Court of Appeals for the Fifth Circuit reviewed the case. It vacated the district court’s judgment as a matter of law in favor of Rolling Plains, finding insufficient evidence to support the jury’s selected date for the statute of limitations. The case was remanded for retrial on when First’s cause of action accrued. The appellate court affirmed the dismissal of fraud claims against AGCO Corporation, AGCO Service, and AGCO Finance, and upheld the summary judgment in favor of AGCO Finance on the warranty claims. View "First v. Rolling Plains Implement Co." on Justia Law

The case involves Gillian and Samuel Davidson, who filed a class action lawsuit against Sprout Foods, Inc., alleging that the labels on Sprout's baby food pouches violated California's Sherman Law, which incorporates all federal food labeling standards. The Davidsons claimed that Sprout's labels, which stated the amount of nutrients the pouches contained, were misleading and harmful to consumers.The district court dismissed the Davidsons' claims. It ruled that the Sherman Law claim was preempted by federal law, which only allows the federal government to enforce food labeling standards. The court also dismissed the Davidsons' fraud-based claims, stating that they failed to specifically allege why Sprout's products were harmful.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed in part and reversed in part. The court held that federal law did not preempt private enforcement of the Sherman Law's labeling requirements. The court reasoned that the federal food labeling statute permits states to enact labeling standards identical to the federal standards, which California has done through the Sherman Law. Therefore, the district court should not have dismissed the Sherman Law claims. However, the court affirmed the dismissal of the Davidsons' fraud-based claims, agreeing with the lower court that the Davidsons failed to meet the heightened pleading requirements for fraud. The court also reversed the dismissal of an unjust enrichment claim, which survived due to the reversal on the Sherman Law claim. View "Davidson v. Sprout Foods, Inc." on Justia Law

The case involves Angela Flowers, who had a car loan with Kia Motors Finance. One morning, Flowers and her son were followed by a truck, which she suspected was an attempt by Kia to repossess her car due to late payments. Flowers sued Kia, alleging unlawful collection practices. However, she was unable to provide any evidence linking Kia to the truck that followed her and her son.Previously, the district court granted Kia summary judgment. Flowers had attempted to include an earlier repossession in her amended complaint, but the court found that she had unduly delayed this attempt. Furthermore, she could not provide any evidence that would allow a reasonable jury to conclude that Kia was involved in the incident with the truck.In the United States Court of Appeals for the Seventh Circuit, Flowers argued that she did not need the district court's approval to file an amended complaint, as Kia had consented in writing to the amendment. However, the court found that Flowers had unduly delayed her attempt to amend the complaint and had not provided a sound excuse for this delay. Therefore, the court denied her motion to amend the complaint.The court also affirmed the district court's grant of summary judgment to Kia. Flowers had failed to present any evidence linking Kia to the unidentified truck and driver. Her theory of liability was based on speculation and conjecture, which are insufficient to defeat a summary judgment motion. Therefore, the court concluded that there was no genuine dispute of material fact and that Kia was entitled to judgment as a matter of law. View "Flowers v. Kia Motors Finance" on Justia Law

The case involves a dispute over a foreclosure judgment. The plaintiff, Susanne P. Wahba, had a loan secured by a mortgage on her property. The defendant, JPMorgan Chase Bank, N.A., acquired the loan and later counterclaimed to foreclose the mortgage. The trial court rendered a judgment of strict foreclosure in favor of the defendant. The plaintiff appealed, but the Appellate Court affirmed the judgment and remanded the case for the setting of new law days. On remand, the plaintiff objected to the defendant's motion to reset the law days, arguing that the judgment of strict foreclosure did not account for the substantial increase in property values that had occurred during the appeal. The trial court concluded that it had no authority to revisit the merits of the strict foreclosure judgment, as it was bound by the Appellate Court’s rescript order requiring the setting of new law days. The plaintiff then filed a second appeal with the Appellate Court, which affirmed the trial court's decision.The Connecticut Supreme Court held that the trial court was not barred by the doctrine of res judicata from entertaining the plaintiff’s request to modify the judgment of strict foreclosure and order a foreclosure by sale. The court also held that the Appellate Court incorrectly concluded that the trial court lacked authority to entertain the plaintiff’s request. The court further held that the Appellate Court incorrectly concluded that the plaintiff was required to file a motion to open the judgment of strict foreclosure and to present evidence that the value of the subject property had substantially increased since the date of the original judgment before the trial court could exercise that authority. The judgment of the Appellate Court was reversed and the case was remanded for further proceedings. View "Wahba v. JP Morgan Chase Bank, N.A." on Justia Law