Justia Civil Procedure Opinion Summaries

Plaintiffs J.A. Masters Investments and K.G. Investments brought state-law claims of fraud and breach of contract against the defendant. The case was fully litigated in the United States District Court for the Southern District of Texas, which accepted jurisdiction based on the premise that the parties were citizens of different states under 28 U.S.C. § 1332(a)(1). However, the record only mentioned the residence of each party, not their citizenship, which is required to establish diversity jurisdiction.The district court conducted a five-day jury trial, and the jury rendered a verdict. Following the trial, the plaintiffs appealed to the United States Court of Appeals for the Fifth Circuit. Upon review, the Fifth Circuit identified a potential jurisdictional issue: the pleadings did not definitively establish the citizenship of each party, only their residency. The court requested a joint letter from the parties to address whether diversity jurisdiction existed. The parties insisted that jurisdiction was proper and even stipulated to facts they believed would confirm complete diversity. However, they failed to provide citations to the record establishing citizenship.The United States Court of Appeals for the Fifth Circuit found that the record did not adequately establish diversity jurisdiction. The court noted that citizenship and residence are not synonymous and that the parties had conflated the two. Given the incomplete record, the court decided to remand the case to the district court to allow the parties to supplement the record with the necessary jurisdictional facts. The court emphasized that without clear evidence of jurisdiction, any resolution would be nonbinding. The case was remanded for further proceedings to establish whether the parties are indeed citizens of different states, with the appellate panel retaining jurisdiction pending any further appeal. View "J.A. Masters Investments v. Beltramini" on Justia Law

A man sued his neighbors, claiming that an access road on their property caused flooding on his property. After settling with the neighbors and dismissing his claims with prejudice, he sued them again over continued flooding, alleging nuisance, trespass, intentional infliction of emotional distress (IIED), and breach of contract.The Superior Court of Alaska, Third Judicial District, granted summary judgment for the neighbors on the tort claims, citing res judicata, but allowed the breach of contract claim to proceed. After a bench trial, the court found the neighbors had breached the settlement agreement and awarded specific performance, consequential damages, and attorney’s fees, but denied punitive damages. The neighbors appealed the breach of contract ruling, and the man cross-appealed the dismissal of his tort claims and the denial of punitive damages.The Supreme Court of Alaska reversed the Superior Court’s ruling on the breach of contract claim, finding it was filed outside the three-year statute of limitations. The court held that the man was on inquiry notice of the breach when the driveway reconstruction was completed, as he observed defects at that time. The court affirmed the Superior Court’s decision that the tort claims were barred by res judicata, as they stemmed from the same transaction as the prior lawsuit. The court also upheld the denial of punitive damages, finding no evidence of egregious conduct by the neighbors.In summary, the Supreme Court of Alaska reversed the breach of contract ruling and associated awards, affirmed the dismissal of the tort claims under res judicata, and upheld the denial of punitive damages. View "Williams v. Strong" on Justia Law

Advanced Benefit Concepts, Inc. (ABC) filed a breach of contract lawsuit against Access Health, Inc., Preferred Care Services, Inc., and Blue Cross and Blue Shield of Alabama (collectively, Access Health). ABC alleged that Access Health failed to pay fees owed under an agreement where ABC helped Access Health secure a contract with the State of Louisiana’s Office of Group Benefits (OGB). Access Health countered that the contract was null and void because ABC did not register as a lobbyist as required by the Louisiana Executive Branch Lobbying Act.The district court ruled in favor of Access Health, declaring the contract void due to ABC’s failure to register as a lobbyist. The court granted Access Health’s motion for summary judgment, dismissing ABC’s breach of contract claim. ABC’s exceptions of lack of subject matter jurisdiction and prescription were overruled. ABC appealed the decision.The Louisiana Court of Appeal, First Circuit, reversed the district court’s decision, holding that the Board of Ethics had exclusive jurisdiction to determine the validity of the contract under the Lobbying Act. The appellate court concluded that the district court lacked subject matter jurisdiction to declare the contract void and reversed the summary judgment.The Supreme Court of Louisiana reviewed the case and reversed the appellate court’s decision. The Supreme Court held that the district court has subject matter jurisdiction to hear the contractual dispute, including the affirmative defense of nullity based on the Lobbying Act. The court emphasized that the Executive Branch Lobbying Act does not deprive the district court of jurisdiction and that the district court can consider whether the contract is an absolute nullity under Louisiana Civil Code article 2030. The case was remanded to the appellate court to consider the exception of prescription and the merits of the summary judgment motion. View "ADVANCED BENEFIT CONCEPTS, INC. VS. BLUE CROSS AND BLUE SHIELD OF ALABAMA" on Justia Law

In 2014, several homeowners' associations sued Baldwin County Sewer Service, LLC (BCSS), alleging that a rate increase violated a 1991 agreement between a real-estate developer and BCSS. The plaintiffs sought a declaratory judgment and specific performance of the agreement. The case has been brought before the Supreme Court of Alabama multiple times, with BCSS repeatedly questioning whether the plaintiffs are successors in interest to the original contract party.The Baldwin Circuit Court initially granted summary judgment in favor of BCSS, stating that the plaintiffs lacked standing. However, the Supreme Court of Alabama reversed this decision in 2016, clarifying that the issue was not one of standing but whether the plaintiffs were real parties in interest. On remand, BCSS continued to challenge the plaintiffs' status, leading to multiple nonfinal rulings and additional appellate proceedings. The circuit court denied BCSS's summary judgment motions on this issue multiple times, including in August 2023.The Supreme Court of Alabama reviewed BCSS's petition for a writ of mandamus, which sought to compel the circuit court to grant summary judgment in its favor. The Court clarified that the real-party-in-interest question does not implicate the trial court's subject-matter jurisdiction and is not appropriate for mandamus review. The Court emphasized that such issues should be resolved through a final judgment by the trial court. Consequently, the Supreme Court of Alabama denied BCSS's petition for a writ of mandamus. View "Ex parte Baldwin County Sewer Service, LLC" on Justia Law

Farnsworth Coleman, the sole member of Coleman Consulting, LLC (CC), entered into a written Confidentiality Agreement with Domtar A.W. LLC (Domtar A.W.) in November 2016 to provide consulting services for a pulp mill in Ashdown, Arkansas. CC was compensated for its services and expenses at an agreed hourly rate. CC later claimed that an oral agreement was made with Domtar A.W. for additional compensation based on a percentage of increased profits from CC's recommendations, which Domtar A.W. denied. CC filed a lawsuit for breach of contract and unjust enrichment after Domtar A.W. terminated the consulting services in May 2017.The United States District Court for the Western District of Arkansas granted summary judgment in favor of Domtar A.W., concluding that the Arkansas statute of frauds barred CC's breach of contract claim because the alleged oral agreement could not be performed within one year. The court also found that CC failed to prove its unjust enrichment claim, as CC had been fully compensated for its services under the written agreement. CC's motion for reconsideration, based on newly discovered evidence, was denied.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court agreed that the oral agreement was subject to the statute of frauds and could not be performed within one year. The court also found that the part performance and detrimental reliance exceptions to the statute of frauds did not apply. Additionally, the court upheld the dismissal of the unjust enrichment claim, noting that CC had been paid for its services and could not use unjust enrichment to enforce an unenforceable oral contract. The denial of the motion for reconsideration was also affirmed, as CC failed to demonstrate due diligence in obtaining the new evidence. View "Coleman Consulting, LLC v. Domtar Corporation" on Justia Law

A fire damaged a malt beverage store owned by A Maxon Company, LLC (AMC). Acuity Insurance Company sought a declaratory judgment to determine coverage under an insurance policy listing Greg and Tammy Weatherspoon as additional loss payees. The Weatherspoons counterclaimed for breach of contract. The circuit court granted Acuity’s motion for judgment as a matter of law on the Weatherspoons’ counterclaim, determining that the insurance policy terms prevented the Weatherspoons from recovering damages unless AMC successfully asserted a claim. The jury found that AMC principal, Russel Maxon, had intentionally started the fire, excluding coverage under AMC’s policy. The Weatherspoons appealed.The Circuit Court of the Fourth Judicial Circuit, Corson County, South Dakota, initially denied the Weatherspoons’ motion for summary judgment, ruling that the insurance contract was unambiguous and that the Weatherspoons’ claim was dependent on AMC’s claim. The court also denied Acuity’s motion for summary judgment, finding that there were factual disputes suitable for a jury. At trial, the court granted Acuity’s motion for judgment as a matter of law, concluding that the Weatherspoons could not recover under the policy because AMC’s claim was excluded due to Russel’s intentional act.The Supreme Court of the State of South Dakota affirmed the circuit court’s decision. The court held that the insurance policy’s Loss Payable Clause only allowed the Weatherspoons to collect if AMC could collect, and since the jury found that Russel intentionally started the fire, AMC was precluded from recovering. The court also found no abuse of discretion in admitting expert testimony from Special Agent Derek Hill and allowing the impeachment of Tracy Maxon with prior inconsistent statements. The court concluded that the Weatherspoons’ arguments regarding ambiguity and third-party beneficiary status were unavailing. View "Acuity Insurance V. A Maxon Company" on Justia Law

American Environmental, Inc. (plaintiff) challenged the Burlington School District (defendant) over a contract awarded for the demolition and remediation of Burlington High School, which was closed due to toxic substances. The District sent a Request for Qualifications to fifteen contractors, including the plaintiff and the winning bidder, EnviroVantage. The plaintiff argued that EnviroVantage did not meet the prequalification criteria and that the contract should have been awarded to them.The Superior Court, Chittenden Unit, Civil Division, denied the plaintiff's request for a preliminary injunction, citing potential financial harm to the District and public interest. The court later granted summary judgment to the District, finding the case moot because the project was substantially complete. The court applied factors from Citineighbors Coalition of Historic Carnegie Hill ex rel. Kazickas v. New York City Landmarks Preservation Commission, determining that no effective relief could be granted due to the project's advanced stage.The Vermont Supreme Court took judicial notice of the project's completion, including demolition and soil remediation, based on public records and visual evidence. The court dismissed the appeal as moot, stating that no effective relief could be provided under Rule 75, which does not allow for damages. The court also rejected the plaintiff's argument that the case met the exception for issues capable of repetition yet evading review, noting the plaintiff's delay in seeking expedited relief and the lack of demonstrated probability of encountering the same situation again. View "American Environmental, Inc. v. Burlington School District" on Justia Law

Wanda Bowling entered into a contract with the Interstate Medical Licensure Compact Commission to manage its information technology functions. When the contract ended, Bowling allegedly withheld login information for three online accounts, leading the Commission to sue for breach of contract. Bowling counterclaimed for libel and misclassification of her employment status. The district court dismissed the misclassification counterclaim and granted summary judgment to the Commission on all other claims.The United States District Court for the District of Colorado dismissed Bowling's counterclaim for misclassification and denied her motion to amend it, citing untimeliness. The court also granted summary judgment to the Commission on its breach of contract claim, concluding that Bowling's login information constituted intellectual property and that she had breached the contract by not certifying the erasure of confidential information. The court awarded the Commission $956.67 in damages. Additionally, the court granted summary judgment on Bowling's libel counterclaim, citing a qualified privilege defense.The United States Court of Appeals for the Tenth Circuit reviewed the case. It affirmed the district court's finding of subject-matter jurisdiction, holding that the Commission had adequately alleged damages exceeding $75,000. However, the appellate court found that the contract was ambiguous regarding whether the login information constituted intellectual property or other materials covered by the contract, and that there was a genuine dispute of material fact regarding the damages. Therefore, it reversed the summary judgment on the breach of contract claim. The court also upheld the district court's denial of Bowling's motion to amend her counterclaim for misclassification, finding no abuse of discretion.On the libel counterclaim, the appellate court agreed that the district court erred in granting summary judgment based on a qualified privilege without giving Bowling notice. However, it affirmed the summary judgment on the grounds that the Commission's statements were substantially true. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "Interstate Medical Licensure Compact Commission v. Bowling" on Justia Law

A physician in Puerto Rico, Dr. Jaime Salas Rushford, had his board certification suspended by the American Board of Internal Medicine (ABIM) after ABIM concluded that he had improperly shared board exam questions with his test prep instructor. ABIM sued Salas Rushford for copyright infringement in New Jersey. Salas Rushford counterclaimed against ABIM and several ABIM-affiliated individuals, alleging that the process leading to his suspension was a "sham."The counterclaims were transferred to the District of Puerto Rico, where the district court granted ABIM's motion for judgment on the pleadings and denied Salas Rushford leave to amend his pleading. The court found that Salas Rushford failed to state a claim for breach of contract, breach of the implied covenant of good faith and fair dealing, and tort claims against the ABIM Individuals. The court also dismissed his Lanham Act claim for commercial disparagement.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's dismissal of Salas Rushford's claims. It held that ABIM had broad discretion under its policies to revoke certification if a diplomate failed to maintain satisfactory ethical and professional behavior. The court found that Salas Rushford did not plausibly allege that ABIM acted with bad motive or ill intention, which is necessary to state a claim for breach of the implied covenant of good faith and fair dealing under New Jersey law.The court also affirmed the dismissal of the Lanham Act claim, noting that Salas Rushford failed to allege actual consumer deception or intentional deception, which is required to state a claim for false advertising. Finally, the court upheld the district court's denial of leave to amend the complaint, citing undue delay and lack of a concrete argument for why justice required an amendment. View "American Board of Internal Medicine v. Salas-Rushford" on Justia Law

A hospital and a physician entered into a settlement agreement to resolve a dispute over the suspension of the physician's clinical privileges. The agreement required the hospital to submit a report to a regulatory authority using specific language agreed upon by both parties. The hospital, however, selected codes for the report that generated additional text, which the physician claimed contradicted and was inconsistent with the agreed language. The physician sued for breach of the settlement agreement.The Circuit Court for Montgomery County granted summary judgment in favor of the hospital, ruling that the settlement agreement did not restrict the hospital's selection of codes for the report. The Appellate Court of Maryland disagreed, holding that a reasonable person would understand the hospital's obligation to report using specific language to preclude it from including contradictory and materially inconsistent language. The Appellate Court vacated the summary judgment, finding that whether the hospital breached its obligation was a question for the jury.The Supreme Court of Maryland reviewed the case and affirmed the Appellate Court's decision. The court held that the hospital's obligation to report using specific, agreed-upon language precluded it from including additional language that contradicted and was materially inconsistent with the agreed language. The court also affirmed that the physician's claim regarding the hospital's failure to provide a timely hearing was released in the settlement agreement. The case was remanded for further proceedings to determine if the hospital's actions constituted a breach of the settlement agreement. View "Adventist Healthcare v. Behram" on Justia Law