Justia Civil Procedure Opinion Summaries

The case involves John Doe, a student who was expelled from Loyola University Chicago after the university concluded that he had engaged in non-consensual sexual activity with Jane Roe, another student. Doe sued the university under Title IX of the Education Amendments Act of 1972 and Illinois contract law, alleging that the university discriminates against men.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Loyola. Doe appealed this decision to the United States Court of Appeals for the Seventh Circuit. The appellate court, however, raised questions about the use of pseudonyms by the parties and the mootness of the case, given that Doe had already graduated from another university and the usual remedy of readmission was not applicable.The Seventh Circuit Court of Appeals remanded the case back to the district court to address these issues. The court questioned whether compensatory damages were an option for Doe, and if not, the case may not be justiciable. The court also questioned the use of pseudonyms, stating that while anonymity may be common in Title IX suits, it must be justified in each case. The court noted that the public has a right to know who is using their courts and that a desire to keep embarrassing information secret does not justify anonymity. The court also raised concerns about whether revealing Doe's identity would indirectly reveal Roe's identity. The court concluded that these issues should be addressed by the district court. View "Doe v. Loyola University Chicago" on Justia Law

The case revolves around a dispute over oil and gas interests between Spottie, Inc., a Nevada corporation, and several other Nevada corporations and a limited liability company. Spottie alleged that the defendants had wrongfully claimed title to these interests, which were once owned by Edward Davis, who had formed Spottie as a holding company. The defendants countered that they had entered into an agreement with Davis to acquire these interests, and that Davis and Spottie had transferred the disputed interests to one of the defendants via an assignment in 2016.The district court dismissed several of Spottie's claims, leaving only a quiet title claim and a claim for unjust enrichment. After a three-day bench trial, the court ruled in favor of the defendants, finding that the assignment from Davis and Spottie to one of the defendants was valid. The court also found that Spottie had erroneously received revenue from the disputed interests and awarded damages to the defendants.Spottie appealed the decision, arguing that the district court had erred in its ownership determination, its rejection of Spottie's laches defense, its binding of a non-party to the judgment, and its award of attorney fees and costs. The Supreme Court of North Dakota affirmed in part, concluding that the district court did not err in its ownership determination and its award of attorney fees. However, it reversed in part, finding that the court had erred in awarding costs for non-legal expenses. The case was remanded for the court to recalculate its cost award and to consider the defendants' request for additional attorney fees and legal costs. View "SPOTTIE v. BAIUL-FARINA" on Justia Law

The case revolves around a dispute over the ownership of a purebred show dog named Oscar. The parties involved are Oscar's breeder, Elizabeth "Betsy" Shauck, and Dave Jennings and Emily McLeod, who have raised Oscar since he was a puppy. Dave and Emily filed a petition to quiet title to Oscar against Betsy, who counterclaimed for breach of contract, replevin, conversion, for a restraining order and preliminary injunction, and to quiet title. Betsy's preliminary injunction counterclaim asked the district court to prevent Dave and Emily from harboring Oscar and to order his immediate return to her.The district court held a three-day hearing, which was supposed to be on Betsy's request for a preliminary injunction. However, the court expanded the scope of the hearing and made findings of fact and conclusions of law on the merits of all issues pending in the underlying lawsuit, including Oscar's ownership, contract disputes, and damages. Dave and Emily appealed this decision, arguing that the district court denied their due process rights by deciding the case on the merits when it had only set the hearing on Betsy's preliminary injunction.The Kansas Court of Appeals panel held that the district court violated Dave and Emily's due process rights by expanding the scope of the hearing without notice. However, instead of remanding the case, the panel analyzed the parties' ownership interests in Oscar and held that Dave and Betsy co-owned Oscar. Betsy then petitioned the Supreme Court of the State of Kansas for review.The Supreme Court of the State of Kansas affirmed in part and reversed in part the decision of the panel. The court agreed with the panel that the district court erred by expanding the scope of the hearing on Betsy's request for a preliminary injunction. The court found that the district court's decision to consolidate the hearing on Betsy's request for a preliminary injunction with a trial on the case's merits without informing the parties was a denial of due process and an error of law. The court also agreed with the panel's conclusion that the district court's failure prejudiced Dave and Emily. However, the court held that the panel erred by addressing the case's merits after correctly concluding that the district court erred. The court reversed the judgment of the district court and remanded the case for further proceedings. View "Jennings v. Shauck" on Justia Law

HotChalk, LLC filed a lawsuit against the Lutheran Church—Missouri Synod and 22 other defendants, alleging breach of contract and fraud in relation to the closure of Concordia University - Portland. HotChalk claimed that the Synod orchestrated the university’s closure to financially benefit itself and its affiliates while leaving the university’s creditors out in the cold. During discovery, the Synod sought a protective order to prevent the disclosure of certain documents related to internal religious matters. The trial court granted the protective order, effectively denying a motion to compel discovery of those documents. HotChalk then filed a petition for mandamus.The trial court's decision to grant the protective order was based on an in-camera review of the documents in question. The court equated the Synod's motion to a motion to restrict discovery to protect a party from embarrassment. After completing its final in-camera review, the trial court granted the Synod's motion for a protective order. HotChalk then filed a timely petition for mandamus in the Supreme Court of the State of Oregon.The Supreme Court of the State of Oregon issued an alternative writ of mandamus, directing the trial court to either vacate its order or show cause why it should not do so. The trial court declined to vacate its order, leading to arguments in the Supreme Court. The Synod argued that the writ should be dismissed because HotChalk has a plain, speedy, and adequate remedy in the ordinary course of the law. The Supreme Court agreed with the Synod, stating that HotChalk had not established that the normal appellate process would not constitute a plain, speedy, and adequate remedy in this case. Therefore, the Supreme Court dismissed the alternative writ as improvidently allowed. View "Hotchalk, Inc. v. Lutheran Church--Missouri Synod" on Justia Law

The case originated as a class action dispute about the underpayment of oil and gas royalties due on wells in Oklahoma. The plaintiff, Chieftain Royalty Company, sued SM Energy Company, the operator of the wells, under various tort theories, including fraud, breach of contract, and breach of fiduciary duty. In 2015, the claims were settled for approximately $52 million. Following the settlement, Chieftain's counsel moved for attorneys’ fees, and Chieftain sought an incentive award for its CEO, Robert Abernathy. Two class members objected to the awards and appealed. The court affirmed the settlement but reversed the attorneys’ fees and incentive awards, remanding to the district court for further proceedings.On remand, the district court re-awarded the fees and incentive award. The class did not receive notice of the 2018 attorneys’ fees motion as required under Federal Rule of Civil Procedure 23(h)(1), so the court vacated the district court order awarding attorneys’ fees and remanded with instructions to direct class-wide notice of the 2018 attorneys’ fees motion and to re-open the period for objections. The court did not reach the merits of the appellate challenge to the re-awarded attorneys’ fees. The court affirmed the district court’s incentive award to Mr. Abernathy. View "Chieftain Royalty Company v. SM Energy Company" on Justia Law

The case revolves around a dispute between Private Jet Services Group, LLC (PJS), a private aircraft booking agent, and Tauck, Inc., a provider of domestic and international guided tours. The parties had entered into an "Air Charter Services Blanket Purchase Agreement" (BPA) in January 2018, which established the terms under which Tauck would book and pay for air transportation for the New Zealand portion of its Australia and New Zealand tours. In May 2018, they executed a Statement of Work (SOW) that required Tauck to guarantee a minimum of fifty tours per year and to pay PJS an agreed-upon sum for each "missed" tour. The SOW also included a force majeure clause that protected PJS from delays, losses, or damages caused in whole or in part by force majeure events, including epidemics and acts of civil or military authority.The dispute arose when the COVID-19 pandemic prevented Tauck from conducting tours in New Zealand. After Tauck cancelled its remaining 2020 tours, PJS sued Tauck in the New Hampshire federal court alleging a breach of contract. Tauck responded by invoking the doctrines of impossibility and frustration of purpose to excuse performance of its obligations under the contracts. Both parties moved for summary judgment on the count relating to the 2020 tour season, which the district court denied without prejudice. The district court then certified a question to the Supreme Court of New Hampshire regarding the interpretation of the force majeure clause and its impact on the common law defenses of impossibility, impracticability, and frustration of commercial purpose.The Supreme Court of New Hampshire held that the common law contract defenses of impossibility, impracticability, and frustration of commercial purpose are so fundamentally related to contract formation and purpose that they remain viable unless expressly waived. Therefore, a force majeure clause that protects only one party to a contract should not be deemed, in and of itself, a relinquishment of the other party’s right to interpose those common law defenses. The case was remanded back to the lower court for further proceedings. View "Private Jet Services Group, LLC v. Tauck, Inc." on Justia Law

The case involves a dispute between Mercedes-Benz Financial and 1188 Stratford Avenue, LLC, and its principal, Aniello Dizenzo. The plaintiff, Mercedes-Benz Financial, alleged that the defendants breached a motor vehicle lease agreement by failing to make payments. After the defendants failed to appear, the trial court granted the plaintiff's motion for judgment and rendered a default judgment in favor of the plaintiff. The defendants later moved to open and set aside the default judgment, arguing that the vehicle had serious defects, making it dangerous to operate, and that they had returned the vehicle to the dealership. They also claimed that they mistakenly thought the case had been resolved.The trial court denied the defendants' motion to open the judgment, concluding that the motion was untimely and had no basis. The defendants appealed to the Appellate Court, which acknowledged that the trial court incorrectly determined that the motion was untimely but upheld the trial court's decision, concluding that it had not abused its discretion in denying the motion on the ground that it had no basis.The defendants then appealed to the Connecticut Supreme Court. The Supreme Court held that the Appellate Court incorrectly concluded that the trial court had not abused its discretion in denying the defendants’ motion to open. The Supreme Court found that the trial court's determination that the motion was untimely was incorrect, and this error likely affected the trial court's decision on the merits of the motion. The Supreme Court reversed the Appellate Court’s judgment and remanded the case for further proceedings, directing the lower court to reverse its judgment and conduct an evidentiary hearing on the defendants' motion to open the judgment. View "Mercedes-Benz Financial v. 1188 Stratford Avenue, LLC" on Justia Law

The case revolves around a dispute between Sharon Ann Koch, a member of the Buffalo Trail Ranch subdivision, and Melissa R. Gray, who was purchasing a tract in the subdivision. Koch, along with other members and the developer of the subdivision, Rocky Mountain Timberlands, Inc. (RMT), sued Gray for allegedly violating the subdivision's restrictive covenants by placing garbage, junk, and other prohibited items on her property. The covenants, filed by RMT in 2008, also required the formation of a road maintenance association, which was never established.The District Court of Albany County dismissed all claims against Gray, applying the contractual "first to breach" doctrine. The court reasoned that RMT, by failing to form the road maintenance association, was the first to breach the covenants. Therefore, it was impossible to hold Gray to the covenants. Koch appealed this decision, arguing that she had no contractual relationship with Gray, and thus the "first to breach" doctrine should not apply to her claim.The Supreme Court of Wyoming agreed with Koch. It found that the "first to breach" doctrine, which is based on a contractual relationship, could not be applied as there was no contract between Koch and Gray. The court also rejected the lower court's conclusion that RMT's breach of the covenants rendered them inapplicable to Gray. The court found no legal basis for applying the "first to breach" doctrine to a third party's enforcement of covenants. Consequently, the Supreme Court reversed the lower court's decision and remanded the case for further proceedings. View "Koch v. Gray" on Justia Law

The case involves a dispute between Firexo Group Limited (FGL), a British company that manufactures fire extinguishers, and Firexo, Inc., a Florida-based company that was created to sell FGL's products in the United States. Scot Smith, a resident of Ohio, purchased 70% of Firexo, Inc. from FGL under a Joint Venture Agreement (JVA). The JVA included a forum-selection clause designating England or Wales as the exclusive jurisdiction for any disputes arising from the agreement. Firexo, Inc., which was not a signatory to the JVA, later sued FGL in an Ohio court over issues with the fire extinguishers. FGL sought to dismiss the case based on the forum-selection clause in the JVA.The district court granted FGL's motion to dismiss, applying the "closely related" doctrine. This doctrine allows a non-signatory to a contract to be bound by a forum-selection clause if the non-signatory is sufficiently closely related to the contract. The district court found that Firexo, Inc. was closely related to the JVA and therefore subject to the forum-selection clause. Firexo, Inc. appealed this decision, arguing that the district court applied the wrong law and analytical approach in determining the applicability of the contract.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The appellate court agreed with Firexo, Inc. that the district court had applied the wrong law. The court held that the "closely related" doctrine, a federal common law rule, should not have been used to interpret the JVA's forum-selection clause. Instead, the court should have applied the law specified in the JVA, which was English law. Under English law, contracts do not apply to non-signatories unless certain exceptions apply, none of which were present in this case. Therefore, the forum-selection clause in the JVA did not apply to Firexo, Inc., and the case was remanded for further proceedings. View "Firexo, Inc. v. Firexo Group Limited" on Justia Law

The case involves Dennis Neate, a former employee of the James B. Oswald Company (Oswald), an insurance firm. Neate left Oswald to work for Hylant Group, Inc., another insurance firm, and some of his clients followed him. Oswald accused Neate of violating his non-solicitation agreement and sued in federal district court. The court issued a preliminary injunction ordering Neate and others to comply with Oswald’s non-solicitation agreement. Neate appealed.Previously, the district court granted a preliminary injunction after an evidentiary hearing. The injunction prohibited Neate and others from violating their agreements with Oswald, retaining or using Oswald's confidential information, and soliciting or accepting business from Oswald's clients. The injunction also required all defendants to return all of Oswald's property.The United States Court of Appeals for the Sixth Circuit vacated and remanded the case. The court found that the district court failed to properly apply Ohio law in determining the reasonableness of the non-solicitation agreement. The court also found that the injunction did not meet the specificity requirements of Federal Rule of Civil Procedure 65(d)(1), as it incorporated the non-solicitation agreement by reference. However, the court agreed with the district court that Oswald had shown a likelihood of success on its trade-secrets claims. View "James B. Oswald Co. v. Neate" on Justia Law