Justia Civil Procedure Opinion Summaries

Marek Matthews, a seaman and captain, filed a lawsuit against Tidewater, Inc. and Tidewater Crewing, Ltd., alleging that he was exposed to toxic chemicals during his employment, resulting in severe health issues including end-stage renal failure and stage IV cancer. Matthews, a Florida resident, claimed that the exposure occurred while working on offshore supply vessels in the Red Sea. His employment contract included a forum-selection clause mandating that any disputes be litigated in the High Court of Justice in London, England.Initially, Matthews and other plaintiffs filed the suit in Louisiana state court, asserting claims under the Jones Act and general maritime law. Tidewater removed the case to the United States District Court for the Eastern District of Louisiana and moved to dismiss it based on the forum-selection clause and, alternatively, for failure to state a claim. The district court granted the motion to dismiss on forum non conveniens grounds, finding the forum-selection clause valid and enforceable. Matthews's subsequent motion to reconsider the dismissal was denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision, holding that the forum-selection clause was enforceable. The court applied a de novo review to the enforceability of the clause and an abuse of discretion standard to the forum non conveniens analysis. It concluded that Matthews did not meet the heavy burden of proving the clause was unreasonable under the circumstances, despite his health conditions and Louisiana's public policy against such clauses. The court emphasized the federal policy favoring the enforcement of forum-selection clauses in maritime contracts, which outweighed the conflicting state policy. View "Matthews v. Tidewater" on Justia Law

Jill and Grant Wiese were married for nearly 30 years before their marriage was dissolved in 2016. They had a premarital agreement (PMA) that kept their assets and earnings separate, with Grant responsible for reasonable support. Jill worked as an independent agent for Grant’s real estate brokerage, receiving 100% of her commissions after deductions for business expenses and estimated taxes. Grant deducted amounts for taxes and personal expenses he believed exceeded his support obligations, but the tax deductions did not match the actual taxes paid, and he did not refund the excess to Jill.The Superior Court of Orange County found the PMA valid and enforceable. Jill then brought claims against Grant for breach of fiduciary duty, arguing that his deductions from her commissions were excessive and impaired her separate property. Grant countered that Jill’s claims were time-barred and meritless. The trial court ruled in Jill’s favor on the tax-withholding claims, awarding her over $1.3 million, but rejected her other claims. Both parties appealed.The California Court of Appeal, Fourth Appellate District, reviewed the case. It held that Jill’s fiduciary duty claims were subject to a four-year statute of limitations and that most were time-barred. For the surviving claims, the court found Grant breached his fiduciary duty by withholding excessive amounts for taxes but erred in awarding Jill the entire amount withheld rather than the excess. The court also found that Grant’s deductions for personal expenses required reconsideration. It affirmed that Grant was solely liable for the mortgage debt on their jointly owned property but reversed the order requiring Jill to reimburse Grant for housing during their separation. The court remanded for further proceedings, including recalculating damages and reconsidering attorney fees. View "Marriage of Wiese" 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

Donald and Mary Fuger own forty acres of land in Wyoming. Larry Wagoner began using a five-acre section of this land for his oilfield business around 2008. The Fugers and Wagoner agreed to construct two buildings on the site, with Wagoner handling construction and the Fugers securing financing. They did not formalize this agreement in writing. A lease agreement was signed, giving Wagoner exclusive use of the buildings for five years. Wagoner claimed there was an oral agreement to transfer ownership of one building and the land to him in exchange for his construction work and loan payments, which the Fugers denied.The District Court of Sweetwater County initially found in favor of Wagoner, awarding him damages for breach of the oral contract. However, the Wyoming Supreme Court reversed this decision in Fuger v. Wagoner, 2020 WY 154, ruling the oral contract void because Mrs. Fuger did not join the agreement. The case was remanded to consider Wagoner’s equitable claims. On remand, the district court found the Fugers were unjustly enriched by Wagoner’s construction work and awarded him damages, offsetting some of these due to his use of the buildings. The court also awarded prejudgment interest on a portion of the damages.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The court held that the district court did not err in offsetting Wagoner’s damages by the actual rent he received rather than the fair rental value of the second building. The court also upheld the award of prejudgment interest, finding that a portion of Wagoner’s damages were liquidated and thus subject to such interest. The court concluded that the district court acted within its discretion in its equitable determinations regarding offset and prejudgment interest. View "Fuger v. Wagoner" on Justia Law

Lippa and Manmohan Grewal sold a gas station to Theodore Hansen, who later sold it to Junction Market Fairview, L.C. (JMF). The sale contract required Hansen to make regular installment payments, with the final balance due after three years. Hansen missed many payments and failed to pay the full balance when due. The Grewals initiated foreclosure proceedings over six years after Hansen's first missed payment. The applicable statute of limitations for a breach of contract action is six years, raising the question of when the statute begins to run for installment contracts.The Sixth District Court in Sanpete County granted partial summary judgment in favor of JMF, concluding that the statute of limitations began when Hansen missed the first payment, making the Grewals' foreclosure action too late. The court awarded sole control of the gas station to JMF and ordered the Grewals to release the title. When the Grewals failed to comply, JMF seized the station and sold it to a third party. The district court also awarded JMF attorney fees under the Public Waters Access Act and the reciprocal attorney fees statute.The Utah Supreme Court reviewed the case and found that the sale of the gas station to a third-party bona fide purchaser rendered the Grewals' appeal on the title issue moot, as no court action could affect the litigants' rights to the property. However, the issue of attorney fees was not moot. The court held that the district court did not abuse its discretion in awarding attorney fees to JMF under the reciprocal attorney fees statute. The court affirmed the award of attorney fees and remanded to the district court to determine the amount of reasonable attorney fees JMF incurred in defending against the appeal. View "Grewal v. Junction Market Fairview" on Justia Law

The case involves a dispute between Mary Roth and Gary Meyer, who were in a relationship and cohabitated from 2002 to 2022. They shared a bank account and ran an intermingled cattle herd. The dispute arose over the ownership of a property and cattle, and the enforcement of oral loan agreements. The property in question was initially owned by Anthony and Jean Ehrmantrout, who transferred it to each other in 1994. After their deaths in 2001, the property was distributed to their grandchildren, Chet, Carlos, and Marty Meyer, as co-trustees of the Jean Ehrmantrout Residuary Trust. In 2004, Marty Meyer transferred his interest in the property to Gary Meyer. In 2010, Gary Meyer transferred his interest in the property to Mary Roth.The District Court found that Gary Meyer had gained ownership of the property through adverse possession and had valid title when he transferred it to Mary Roth in 2010. The court also found that Gary Meyer had converted 13 of Mary Roth's cattle and breached oral loan agreements with her, awarding her damages. Both parties appealed the decision.The North Dakota Supreme Court reversed the District Court's decision. The Supreme Court found that the District Court had erred in finding that Gary Meyer had gained ownership of the property through adverse possession. The Supreme Court also found that the District Court had erred in admitting certain evidence, in failing to determine when the alleged conversion of cattle began, in valuing the converted cattle, and in finding that Gary Meyer owed on loan contracts that were unenforceable under the statute of frauds. The case was remanded to the District Court for further proceedings. View "Roth v. Meyer" on Justia Law

This case involves a dispute over the will of the late Donelson C. Glassie. The plaintiff, Marcia Sallum Glassie, is the testator’s former wife. She appealed from a Superior Court judgment in favor of the defendant, Paul Doucette, in his capacity as Executor of the Estate of Donelson C. Glassie. The Superior Court affirmed an order of the Newport Probate Court denying the plaintiff’s petition for leave to file a claim out of time against the estate. The denied claim would have alleged a breach of contract, based on the plaintiff’s contention that a key provision of the testator’s will violated the terms of the couple’s property-settlement agreement.The plaintiff and the testator were married in 1986, had three children, and were divorced in 1993. According to their property-settlement agreement (PSA), the testator was to execute a will that would not only treat his obligations under the PSA as “a claim against any assets in [his] [e]state” but also “specifically bequest to [plaintiff] an amount equal to said obligations.” A dispute soon unfolded over what the PSA required of the testator’s will.In 2017, the Supreme Court of Rhode Island vacated the Superior Court judgment on multiple grounds. Relevant to the present appeal, the court determined “that the disputed provision in the will is ambiguous” because it “does not clearly specify under what circumstances plaintiff is to receive the sum of $2,000,000 or the circumstances under which she is to receive such other amount necessary to satisfy all of [the testator’s] remaining obligations.” Because “a proper resolution of this matter require[d] factfinding and conclusions of law with respect to [the] testator’s intent,” the court remanded the case to the Superior Court.Back in Superior Court, the plaintiff sought to amend her complaint with a claim for breach of contract. The Superior Court denied plaintiff’s motion to amend her complaint, in part because she did not first submit the claim to the probate court, and also because the applicable statute of limitations had expired. The plaintiff thereafter filed a petition in the Newport Probate Court for leave to file a claim out of time and, after the court denied her petition, she appealed that denial to the Superior Court.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court, concluding that the plaintiff’s failure to timely present her claim for breach of contract was not due to excusable neglect and, therefore, her claim must be denied. View "Glassie v. Doucette" on Justia Law

The case revolves around a dispute over attorney's fees in a Social Security disability benefits case. The plaintiff, Christian Arnold, was represented by the law firm Binder & Binder. After Arnold was determined to be disabled and entitled to past-due benefits, the law firm requested attorney's fees under 42 U.S.C. § 406(b), based on a contingency fee agreement Arnold had signed. However, the district court reduced the requested fees by nearly sixty percent, arguing that the full request would result in a "windfall" for the law firm, which was prohibited by statute. Binder & Binder appealed this decision.The case was initially heard by an administrative law judge (ALJ) who concluded that Arnold was not disabled. Arnold appealed this decision to the district court, which remanded the case back to the ALJ. On remand, the ALJ ruled in Arnold's favor, and the Social Security Administration issued a Notice of Award to Arnold for past-due benefits. Binder & Binder then moved for attorney's fees in the district court under 42 U.S.C. § 406(b), based on their contingency fee agreement with Arnold. The district court, however, reduced the requested fees.The United States Court of Appeals for the Seventh Circuit reviewed the case and concluded that the district court had abused its discretion by not basing its analysis primarily on the contingency agreement before considering the reasonableness of the request. The Court of Appeals vacated the district court's decision and remanded the case for further proceedings consistent with its opinion. The court emphasized that the contingency fee agreement should be the starting point for determining reasonableness under § 406(b), and any reduction should be justified based on relevant factors such as the claimant's satisfaction with their attorney's representation, the attorney's expertise and efforts expended, and the uncertainty of recovery and risks of an adverse outcome. View "Arnold v. O'Malley" on Justia Law

A group of medical providers sued a former employee for breach of an employment agreement. The employee counterclaimed, alleging he was owed unpaid wages and bonuses. The providers initially raised "failure to state a claim" as their sole affirmative defense. However, after nearly four years of litigation, they attempted to argue for the first time that the contract was illegal and therefore void. The lower court found that the providers had waived this affirmative defense and issued a judgment in favor of the employee. The providers appealed, and the Court of Civil Appeals reversed, concluding that the lower court had abused its discretion by refusing to consider the providers' claim of illegality.The Supreme Court of the State of Oklahoma disagreed with the Court of Civil Appeals. It held that the trial judge did not abuse her discretion in striking the providers' last-minute effort to raise a new affirmative defense. The court noted that the providers had failed to raise the illegality defense in their initial responsive pleading and did not seek to amend their answer in a timely manner. Furthermore, the providers did not raise the illegality defense until after the trial court had already awarded summary judgment to the employee on the issue of breach of contract, more than ten months after the close of discovery, more than nine months after the lower court's deadline for filing dispositive motions, and almost four years after the original lawsuit was filed. The court concluded that the record was sufficient to support a finding that the providers' delay was unjustified and prejudicial. The court vacated the opinion of the Court of Civil Appeals, affirmed the trial court's order striking the illegality affirmative defense, and remanded the case to the Court of Civil Appeals to resolve any remaining undecided issues raised in the appeal. View "Tulsa Ambulatory Procedure Center v. Olmstead" on Justia Law

The case involves a putative class action of approximately 2,000 payees who received structured settlement annuities to resolve personal injury claims. The plaintiffs, Renaldo White and Randolph Nadeau, alleged that defendants Symetra Life Insurance Company and Symetra Assigned Benefits Service Company wrongfully induced them to cash out their annuities in individualized “factoring” arrangements, whereby they gave up their rights to periodic payments in return for discounted lump sums.The district court certified two nationwide classes under Federal Rule of Civil Procedure 23. The first class consisted of all persons who were annuitants of a structured settlement annuity (SSA) issued by Symetra and who subsequently sold to a Symetra affiliate the right to receive payments from that SSA in a factoring transaction. The second class was a subclass of the first, consisting of all members of the class whose contract defining the annuity at issue included language explicitly stating that the annuitants lack the power to transfer their future SSA payments.The United States Court of Appeals for the Ninth Circuit reversed the district court’s certification of the two nationwide classes. The court held that individual issues of causation will predominate over common ones when evaluating whether defendants’ acts and omissions caused the plaintiffs to enter factoring transactions and incur their alleged injuries. The court also held that the district court erred in certifying the nationwide subclass of plaintiffs whose original settlement agreements with their personal injury tortfeasors contained structured settlement annuity (SSA) anti-assignment provisions. The record indicates that the annuitants hail from a wide array of different states, and some of the settlement agreements have choice of law provisions denoting the law of a state other than the location where the contract was executed. The apparent variations in state law on the enforceability of anti-assignment provisions in SSAs and the need to apply multiple state laws to the subclass raised a substantial question of whether individual issues predominate and how the matter can be fairly managed as a class action. View "WHITE V. SYMETRA ASSIGNED BENEFITS SERVICE COMPANY" on Justia Law