Justia Civil Procedure Opinion Summaries

Taxinet Corporation sued Santiago Leon, alleging various claims stemming from a joint effort to secure a government concession for a taxi-hailing app in Mexico City. The district court granted summary judgment for Leon on all claims except for a Florida-law unjust enrichment claim, which went to trial along with Leon’s counterclaims for fraudulent and negligent misrepresentation. The jury awarded Taxinet $300 million for unjust enrichment and Leon $15,000 for negligent misrepresentation. However, the district court granted Leon’s Rule 50(b) motion for judgment as a matter of law, ruling that the damages award was based on inadmissible hearsay and was speculative.The United States District Court for the Southern District of Florida initially allowed testimony regarding a $2.4 billion valuation by Goldman Sachs, which was later deemed inadmissible hearsay. The court concluded that without this evidence, there was insufficient support for the jury’s $300 million award. The court also noted that the valuation was speculative and not directly tied to the benefit conferred by Taxinet in 2015.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s Rule 50(b) order, agreeing that the valuation evidence was inadmissible hearsay and that the remaining evidence was insufficient to support the $300 million award. However, the appellate court exercised its discretion to remand for a new trial on the unjust enrichment claim. The court found that Taxinet had presented enough evidence to show that it conferred a benefit on Leon, which he accepted, and that it would be inequitable for him to retain the benefit without payment. The court also noted that Taxinet could potentially present other evidence of damages in a new trial.The appellate court affirmed the district court’s summary judgment on Taxinet’s other claims, ruling that the alleged joint venture agreement was subject to Florida’s statute of frauds, as it could not be completed within a year. Thus, any claims based on the existence of the joint venture agreement were barred. View "Taxinet Corp. v. Leon" on Justia Law

Jason Ziemann, the plaintiff, became involved in the operation of Grosz Wrecking, a business owned by his grandmother, Juanita Grosz, after her husband passed away. Ziemann moved into a home on the business property in 2014. In 2022, Grosz sought to evict Ziemann after he refused to purchase the home. Ziemann then sued Grosz, alleging they had an oral partnership agreement and sought a declaration of partnership, accounting, and dissolution, along with claims for breach of fiduciary duties and tortious interference with a business relationship. Grosz denied the partnership and counterclaimed for trespass.The District Court of McLean County denied Ziemann’s motion for partial summary judgment, ruling factual issues existed regarding the partnership. The court granted Grosz’s motion, dismissing Ziemann’s claims for tortious interference and breach of fiduciary duty, citing inadmissible hearsay and lack of evidence for damages. After a bench trial, the court found the parties had formed a partnership with specific profit-sharing terms and dismissed Grosz’s trespass claim, allowing Ziemann to remain on the property until the business was dissolved. The court ordered the liquidation of partnership assets and awarded Ziemann costs.The Supreme Court of North Dakota reviewed the case. It affirmed the lower court’s findings that a partnership existed and that Grosz contributed property to it. The court also upheld the dismissal of Grosz’s trespass claim and Ziemann’s claims for tortious interference and breach of fiduciary duty. However, it reversed the lower court’s decision not to apply the default partnership winding up provisions under N.D.C.C. § 45-20-07. The case was remanded for the district court to enter judgment consistent with this decision. The Supreme Court affirmed the award of costs and disbursements to Ziemann as the prevailing party. View "Ziemann v. Grosz" on Justia Law

Perdue Farms operates a poultry-processing plant in Indiana. In August 2018, an L&B Transport driver mistakenly delivered aluminum chloride instead of bleach, causing a chemical reaction that damaged the plant. Perdue sued L&B Transport, its driver, U.S. Security Associates, and three security guards employed by U.S. Security, seeking over $1.2 million in damages. The security-service contract between Perdue and U.S. Security included a forum-selection clause designating Maryland federal court as the venue for disputes.The Daviess Circuit Court dismissed Perdue’s claims against U.S. Security and its employees, citing the forum-selection clause. Perdue appealed, arguing the clause was unenforceable and did not apply to the employees. The Indiana Court of Appeals reversed, holding the clause unenforceable due to the potential for multiple lawsuits in different jurisdictions. A dissenting judge argued that Perdue, as a sophisticated entity, should adhere to its contractual agreement.The Indiana Supreme Court reviewed the case and held that the forum-selection clause is enforceable against U.S. Security, requiring Perdue to litigate those claims in Maryland federal court. However, the court found that the clause does not apply to the individual employees, as they were not parties to the contract and not in privity with U.S. Security. The court rejected the argument that the employees' duties under the contract made them subject to the forum-selection clause.The Indiana Supreme Court affirmed the trial court’s dismissal of claims against U.S. Security for improper venue but reversed the dismissal of claims against the individual employees. The case was remanded for further proceedings consistent with this opinion. View "Perdue Farms Inc. v. L & B Transport, LLC" on Justia Law

Bruce Molzan, a well-known chef, filed a lawsuit against Bellagreen Holdings, LLC, and other associated entities and individuals, alleging trademark infringement and other claims under the Lanham Act and Texas law. Molzan claimed that he had been using the "RUGGLES" trademarks for over forty years and that the defendants misused these trademarks after a forced sale of his restaurants. He alleged that the defendants continued to use the "RUGGLES GREEN" trademark and domain name without authorization, causing consumer confusion.The United States District Court for the Southern District of Texas dismissed all of Molzan's claims under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The court found that Molzan's allegations were conclusory and did not establish a connection between the defendants and the third-party websites causing the confusion. The court also determined that the Settlement Agreement between the parties addressed the alleged infringements and provided a remedy for such transgressions.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that Molzan's complaint contained well-pleaded factual allegations that made his claims facially plausible. The court noted that the allegations established a likelihood of confusion due to the defendants' continued use of the "RUGGLES" trademarks. The court also found that the district court erred in assuming the veracity of the defendants' assertions over Molzan's well-pleaded allegations. The Fifth Circuit reversed the district court's dismissal of Molzan's federal and state trademark infringement, false advertising, unfair competition, and state trademark dilution claims. The court also reversed the dismissal of Molzan's breach of contract and unjust enrichment claims and remanded the case for further proceedings. Additionally, the court vacated the district court's dismissal of the Web Defendants and the denial of Molzan's motion for leave to amend his complaint. View "Molzan v. Bellagreen Holdings" on Justia Law

Cynthia Roberge, a State of Rhode Island employee, was involved in a car accident with an underinsured motorist while driving her personal vehicle during the course of her employment. She sought uninsured/underinsured motorist (UM/UIM) coverage under the State's insurance policy issued by Travelers Property Casualty Company of America. Travelers denied her claim, stating that she was not entitled to UM/UIM coverage because she was not driving a "covered auto" as defined by the policy.Roberge filed a lawsuit in Providence County Superior Court, asserting claims for breach of contract, declaratory judgment, and bad faith. Travelers removed the case to the United States District Court for the District of Rhode Island. The district court granted summary judgment in favor of Travelers, concluding that Roberge was not entitled to UM/UIM coverage under the policy's terms and that neither the Rhode Island Supreme Court's decision in Martinelli v. Travelers Insurance Companies nor the Rhode Island Uninsured Motorist Statute required such coverage.On appeal, the United States Court of Appeals for the First Circuit reviewed the case. The court noted that the policy's language clearly excluded Roberge from UM/UIM coverage because she was not driving a "covered auto." However, the court found that the case raised unresolved questions of Rhode Island insurance law, particularly regarding the applicability of the Martinelli exception and the requirements of the Rhode Island Uninsured Motorist Statute. The First Circuit decided to certify two questions to the Rhode Island Supreme Court: whether an employee must be considered a named insured under an employer's auto insurance policy when operating a personal vehicle in the scope of employment, and whether it violates Rhode Island law and public policy for an employer's policy to provide liability but not UM/UIM coverage to employees in such circumstances. The case was stayed pending the Rhode Island Supreme Court's response. View "Roberge v. Travelers Property Casualty Co. of America" on Justia Law

Next Millennium Telecom Co. (Nextel), a Saudi Arabian corporation, was contracted by the Saudi Arabian government to install an emergency siren system. Nextel paid American Signal Corporation, a Wisconsin corporation, approximately $11 million for the sirens and related components. After installation, the sirens failed to operate correctly, and American Signal refused to repair or replace the defective parts or refund the payment. Consequently, Nextel sued American Signal in federal court for breach of contract, among other claims.The case was heard in the United States District Court for the Eastern District of Wisconsin. The litigation was marked by Nextel's uncooperative behavior, which hindered the discovery process. At the final pretrial conference, the district court noted the lack of progress on key factual issues and ordered Nextel to take specific steps, including obtaining local counsel, conferring with American Signal, and filing a plan for testing the sirens and securing visas for witnesses. Nextel's failure to comply with these orders led the district court to dismiss the case for failure to prosecute.The United States Court of Appeals for the Seventh Circuit reviewed the dismissal. The court held that the district court did not abuse its discretion in dismissing the case. The appellate court found that Nextel's conduct, including its failure to facilitate inspections, schedule depositions, adhere to local rules, and comply with the court's pretrial order, justified the dismissal. The court emphasized that the responsibility to move the case forward rested with Nextel, and its pattern of delay and non-compliance supported the district court's decision. The Seventh Circuit affirmed the dismissal and did not address Nextel's argument regarding remote testimony for its witnesses. View "Next Millennium Telecom Co. v. American Signal Corporation" on Justia Law

Benchmark Property Remodeling, LLC, a construction company, performed remodeling work on a building owned by Grandmothers, Inc., which was leased to the Kansas Department of Revenue (KDOR). The work was based on quotes finalized between KDOR and Benchmark, and a "Third Amendment to Lease" between KDOR and Grandmothers. Benchmark completed the work and invoiced Grandmothers and KDOR. KDOR paid Grandmothers, but Grandmothers only partially paid Benchmark, withholding some amounts for various reasons. Benchmark sued Grandmothers, KDOR, and others for breach of contract, unjust enrichment, and other claims.The Shawnee District Court granted partial summary judgment in favor of Grandmothers on several claims, concluding there was insufficient evidence of a contract between Benchmark and Grandmothers. The court also granted KDOR's motion for judgment on the pleadings. Benchmark then dismissed its remaining claims without prejudice and appealed the partial summary judgment and judgment on the pleadings.The Kansas Court of Appeals reviewed the case and concluded that appellate jurisdiction was proper because Benchmark did not refile its dismissed claims, making the district court's judgment final. The panel reversed the district court's entry of judgment on the pleadings for KDOR, noting significant factual issues regarding the parties' intent. The panel also reversed the district court's summary judgment for Grandmothers, finding that the evidence could support a finding of a contract between Benchmark and Grandmothers.The Kansas Supreme Court affirmed the Court of Appeals' decision, holding that the district court's partial summary judgment became final with the dismissal of the remaining claims, thus granting appellate jurisdiction. The Supreme Court agreed that there were genuine disputes of material fact regarding the existence of a contract, making summary judgment inappropriate. The case was remanded to the district court for further proceedings. View "Benchmark Property Remodeling v. Grandmothers, Inc." on Justia Law

The case involves a contract dispute between Kenneth E. Salamone and RUFSTR Racing, LLC (Plaintiffs) and Douglas Marine Corporation (Defendant). Plaintiffs contracted with Douglas Marine to purchase a custom-made race boat and trailer for $542,117, making payments totaling $501,500. Douglas Marine failed to deliver the boat on time, leading Plaintiffs to cancel the contract. Douglas Marine sold the boat and engines for $375,000 but only remitted $50,000 to Plaintiffs. Plaintiffs sued for breach of contract, seeking damages.The United States District Court for the Northern District of New York held a jury trial, which found in favor of Plaintiffs, awarding them $131,171 in damages. Plaintiffs moved to alter the judgment under Fed. R. Civ. P. 59(e), arguing the jury's calculation was fundamentally erroneous and should be increased to $451,500. The district court agreed, ruling that the jury's verdict constituted a fundamental error and increased the damages to $451,500. Douglas Marine appealed, arguing the district court erred in increasing the damages and in not instructing the jury on a mitigation-of-damages defense. They also challenged the court's personal jurisdiction.The United States Court of Appeals for the Second Circuit reviewed the case. It found merit in Douglas Marine's argument that the district court improperly increased the damages award, ruling that the jury's verdict did not constitute fundamental error. The appellate court reversed the amended judgment to the extent it increased the damages and remanded the case for entry of a second amended judgment consistent with the jury's original award of $131,171. The court affirmed the district court's denial of Douglas Marine's post-judgment motion to dismiss for lack of personal jurisdiction. View "Salamone v. Douglas Marine Corp." on Justia Law

The case involves a dispute over the allocation of attorneys' fees from a $1.51 billion settlement between Syngenta AG and numerous plaintiffs. The settlement arose after Syngenta failed to obtain regulatory approval for its genetically modified corn seeds to be imported into China, leading to significant financial losses for American corn farmers and producers. As part of the settlement, $503 million was allocated for attorneys' fees, which was divided into four pools: three common benefit pools and one for individually retained private attorneys (IRPAs). The IRPA pool was allocated $60 million.The United States District Court for the District of Kansas initially approved the allocation scheme and the modification of contingent-fee contracts, capping IRPA fees at approximately 10% of their clients' recovery. The Objecting Firms, including Hossley-Embry and Byrd/Shields, challenged this allocation and the modification of their fee contracts. They filed motions for reconsideration, arguing that the settlement claims process was more complex than anticipated, requiring additional work. The district court denied these motions, and the Objecting Firms appealed.The United States Court of Appeals for the Tenth Circuit previously affirmed the district court's allocation scheme and the modification of the contingent-fee contracts in In re Syngenta I. The current appeal focuses on the district court's June 2021 IRPA Pool Allocation Order, which adopted the special master's recommendations on the allocation of the $60 million within the IRPA pool. The Objecting Firms argued that the district court's allocation was insufficient and that their due process rights were violated.The Tenth Circuit affirmed the district court's June 2021 IRPA Pool Allocation Order, concluding that the Objecting Firms failed to raise any arguments within the scope of the appeal, which was limited to the allocation of the IRPA pool itself. The court also dismissed the contingent cross-appeal by MDL Co-Lead Counsel as moot, given the affirmation of the district court's order. View "In re: SYNGENTA AG MIR162 CORN LITIGATION" on Justia Law

Anthony Cordero, a student at Montana State University (MSU) during the Spring 2020 semester, sued MSU for prorated reimbursement of his tuition and fees after the university transitioned to online learning due to the COVID-19 pandemic. Cordero claimed that MSU breached an express contract to provide in-person education and services. He also asserted claims for breach of implied contract, unjust enrichment, due process violation, violation of the takings clause, and inverse condemnation.The First Judicial District Court of Lewis and Clark County dismissed four of Cordero’s six claims, including the implied contract and unjust enrichment claims, under M. R. Civ. P. 12(b)(6). The court granted summary judgment in favor of MSU on the remaining claims, including the express contract claim, and denied Cordero’s motion to certify the case as a class action. The court found that Cordero did not identify a specific, bargained-for promise by MSU to provide in-person education and that he had no compensable property interest in the tuition and fees paid.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decisions. The court held that there was an express contract between Cordero and MSU, but it did not include a specific promise to provide in-person education. The court found that MSU had the right to change its regulations and policies, including transitioning to online learning during emergencies. The court also affirmed the dismissal of the implied contract and unjust enrichment claims, noting that an implied contract cannot exist when an express contract is present. The court concluded that MSU did not breach its contractual duties regarding tuition and fees, as it maintained campus facilities and services to the extent possible during the pandemic. View "Cordero v. Montana State University" on Justia Law