Justia Civil Procedure Opinion Summaries

A municipal water and gas board entered into four contracts with a contractor to replace and expand gas lines in and around a city. The total project cost exceeded $4 million, and the contractor began work after being the sole bidder for each project phase. After paying the contractor over $2.8 million, the board ceased payments, leaving over $800,000 due for completed work. The board asserted it could not continue payments because the advertisement for sealed bids had not strictly complied with the version of the applicable Alabama statute in effect at the time the bids were solicited. The contractor then sued the board for breach of contract and other claims.The Franklin Circuit Court granted summary judgment for the board, finding, in effect, that strict compliance with the statutory advertising requirements was necessary and that the contracts were void due to noncompliance. The trial court denied the contractor’s postjudgment motion, and the contractor appealed.The Supreme Court of Alabama reviewed the case de novo. It held that substantial compliance, rather than strict compliance, with the advertising requirements for public works contracts under the relevant statute can satisfy the law’s objectives. The court distinguished this situation from prior precedent where there was a complete absence of competitive bidding and evidence of favoritism or corruption. Here, there was no such evidence, and the board had taken affirmative steps to advertise, including publication and online postings. The court concluded that the contractor presented substantial evidence of substantial compliance, creating a genuine issue of material fact. The Supreme Court of Alabama reversed the summary judgment and remanded the case for further proceedings. View "Pinpoint Locating, Inc. v. The Water Works and Gas Board of the City of Red Bay" on Justia Law

Four property-specific limited liability companies owned real estate in Wisconsin, which was leased to skilled nursing facilities operated by Kevin Breslin through his company, KBWB Operations, LLC. Breslin and his co-guarantors executed personal guaranties ensuring payment and performance under the leases. The nursing facility tenants defaulted on their rent obligations starting in 2018 and subsequently lost their operating licenses after a court-appointed receiver moved residents out. The tenants also failed to complete a purchase option for the properties, triggering a liquidated damages clause. Plaintiffs later sold the properties at a loss.The plaintiffs sued Breslin, his company, and co-guarantors in the United States District Court for the Northern District of Illinois to enforce the guaranties and recover damages. During the litigation, plaintiffs discovered that one co-guarantor was a California citizen, which destroyed complete diversity and thus federal jurisdiction. Plaintiffs moved to dismiss this non-diverse defendant, arguing he was not indispensable because the guaranties provided for joint and several liability. The district court agreed and dismissed him. Breslin did not oppose the dismissal. Plaintiffs then moved for summary judgment; Breslin, facing criminal charges, invoked the Fifth Amendment and presented no evidence on liability or damages. The district court granted summary judgment to plaintiffs and awarded nearly $22 million in damages across several categories.On appeal, the United States Court of Appeals for the Seventh Circuit held that jurisdiction was proper because the dismissed co-guarantor was not an indispensable party under Rule 19, given joint and several liability. The court affirmed the district court’s findings on most damages but vacated the awards for accelerated rent under one lease (pending further consideration of its enforceability as a liquidated damages clause) and for liquidated damages related to the purchase option (finding it unenforceable as a penalty). The case was remanded for recalculation of damages consistent with these holdings. In all other respects, the judgment was affirmed. View "CCP Golden/7470 LLC v. Breslin" on Justia Law

Michael Dixon and Kalie Dixon entered into a contract with Best Choice Roofing Alabama, LLC for the replacement of the roof on their home in Washington County, Alabama. After the work was completed, the Dixons noticed leaks and water damage, and despite contacting the company and providing an opportunity to fix the issues, their concerns were not resolved. They alleged that their house became nearly uninhabitable and sought damages for breach of contract and wantonness.Best Choice Roofing Alabama moved to dismiss the claims for improper venue, pointing to a forum-selection clause in the contract requiring any lawsuits to be brought in Sumner County, Tennessee, under Tennessee law. The Dixons argued that enforcing this clause would be seriously inconvenient and deprive them of their day in court, citing financial hardship, the distance to Tennessee, and the location of evidence and witnesses in Alabama. The Washington Circuit Court denied the motion to dismiss, finding the forum-selection clause clearly unreasonable and the chosen forum seriously inconvenient due to the circumstances faced by the Dixons, including their financial situation and the impact of the alleged damage.The Supreme Court of Alabama reviewed the trial court’s denial of the motion to dismiss through a petition for writ of mandamus. Applying Alabama law, the Supreme Court held that outbound forum-selection clauses are enforceable unless enforcement would be unfair or unreasonable. The Court found that the Dixons failed to meet their burden to show that enforcement would deprive them of their day in court or that extraordinary facts justified disregarding the clause. The Court concluded that the trial court exceeded its discretion and granted the petition, directing the trial court to dismiss the claims against Best Choice Roofing Alabama. View "Ex parte Best Choice Roofing Alabama, LLC" on Justia Law

A business dispute arose when an individual agreed to sell her furniture and design company to a limited liability company controlled by two individuals for $2.7 million, with payment to be made in installments. The seller also entered into a consulting agreement to assist in the transition but was terminated a few months later. The seller alleged that she did not receive compensation due under the consulting agreement and that the buyer failed to pay the final installment of the purchase price. She asserted claims for breach of contract, unjust enrichment, fraudulent inducement, and promissory fraud. The defendants counterclaimed and brought in several third parties, but most of those claims were eventually dismissed, leaving several claims—including for declaratory judgment, conversion, slander, breach of contract, and tortious interference—still pending.The Cullman Circuit Court tried only the seller’s promissory fraud and fraudulent inducement claims against the two individual defendants, entering judgment based on a jury verdict for the seller and awarding over $10 million in damages. The court stayed all claims against the corporate defendants after they filed for bankruptcy. Despite multiple claims and parties remaining, the circuit court certified its judgment against the individuals as final under Rule 54(b) of the Alabama Rules of Civil Procedure.Upon review, the Supreme Court of Alabama determined that the circuit court’s Rule 54(b) certification was improper. The Supreme Court found that closely intertwined and factually overlapping claims, counterclaims, and third-party claims remained unresolved, and that proceeding in piecemeal fashion risked inconsistent results and unnecessary duplication. The Supreme Court dismissed the appeal, holding that the circuit court’s order was not properly certified as final and thus was not appealable at this stage. View "Roberson v. Daniel" on Justia Law

The case concerns an automobile accident in Prince George’s County, Maryland, involving George Bowens and a driver named Lisa Daniels, who was at fault. Bowens sustained injuries and held a $50,000 underinsured motorist (UIM) policy with State Farm. Daniels’ insurance had a $30,000 liability limit, which was offered to Bowens as a settlement for his injuries. Following established statutory procedures, Bowens notified State Farm of this offer, State Farm consented and waived subrogation rights, and Bowens accepted the $30,000. Bowens then sought to recover the remaining $20,000 available under his UIM policy from State Farm, which denied the claim.Bowens filed a breach of contract action in the District Court for Prince George’s County, seeking $20,000. State Farm moved to dismiss, arguing that the District Court lacked subject matter jurisdiction because Bowens would have to prove total damages of $50,000—exceeding the court’s $30,000 jurisdictional cap. The District Court agreed and dismissed the case. Bowens appealed to the Circuit Court for Prince George’s County, which affirmed the dismissal, reasoning that the District Court would need to find damages over $30,000 and thus could not grant relief.The Supreme Court of Maryland reviewed the case and held that the District Court’s jurisdiction is determined by the amount the plaintiff seeks from the defendant in the pending action, not by the total underlying damages or prior settlements received from the tortfeasor’s insurer. Since Bowens’ claim against State Farm was for $20,000, the District Court had jurisdiction. The Supreme Court of Maryland reversed the judgment of the circuit court and ordered the case remanded to the District Court for further proceedings. View "Bowens v. State Farm Mut. Auto. Ins." on Justia Law

Bridgelink Engineering LLC, managed by two individuals, entered into a loan agreement with two banks in August 2021. The loans, totaling $34 million, were initially guaranteed by several LLCs also managed by the same individuals. A few months later, the individuals personally guaranteed Bridgelink’s loan obligations, with a guaranty agreement containing an early-release clause. This clause allowed the individuals to be released from liability if specific conditions were met, including the borrower’s loan being in good standing and compliance with financial covenants for two consecutive quarters. After a default in July 2022, the banks and Bridgelink amended the agreement, but Bridgelink later failed to meet the conditions for waiver of default and remained in default into 2023. Neither Bridgelink nor its guarantors made payments on the loans.The banks sued Bridgelink, the individuals, and the LLCs for breach of contract in the United States District Court for the Northern District of Texas, asserting diversity jurisdiction. The individuals argued they had satisfied the guaranty’s early release conditions, and later challenged the court’s subject-matter jurisdiction, contending that one of the banks was a Texas citizen, which would destroy diversity.The United States Court of Appeals for the Fifth Circuit reviewed both the jurisdictional challenge and the merits. The appellate court held that complete diversity existed as the banks and all defendants were citizens of different states, confirming the district court’s jurisdiction. The court further held that the individuals had not satisfied the conditions for early release from their guaranty obligations because the borrower’s loan was in default and the required confirmations of compliance were not provided for two consecutive quarters. The appellate court affirmed the district court’s summary judgment holding the individuals liable as guarantors for the loans. View "Cadence Bank v. Johnson" on Justia Law

After a car accident in Prince George’s County, Maryland, George Bowens, who was injured by the clear negligence of another driver, sought to recover compensation for his injuries. The at-fault driver had $30,000 in liability insurance, which was offered to Bowens in settlement. Bowens, however, had a $50,000 underinsured motorist (UIM) policy with his own insurer, State Farm. After accepting the $30,000 from the at-fault driver’s insurer (with State Farm’s consent and waiver of subrogation rights), Bowens sought the remaining $20,000 from State Farm under his UIM policy, claiming breach of contract when State Farm denied the claim.Bowens filed his action in the District Court of Maryland, which has jurisdiction over contract claims not exceeding $30,000. State Farm moved to dismiss, arguing that to recover the $20,000, Bowens would have to prove total damages of $50,000—an amount above the District Court’s jurisdictional cap. The District Court granted the motion to dismiss for lack of subject matter jurisdiction, and the Circuit Court for Prince George’s County affirmed, reasoning that the court would need to find Bowens’ damages exceeded $30,000, thus exceeding the District Court's authority.The Supreme Court of Maryland reviewed the case and reversed the lower courts. It held that, for purposes of determining the District Court’s jurisdiction under § 4-401(1) of the Courts and Judicial Proceedings Article, the relevant amount is the “debt or damages claimed” in the pleadings—that is, the net recovery sought from the defendant in the action—not the plaintiff’s total damages. Because Bowens sought only $20,000 from State Farm, the District Court had jurisdiction to hear the case. The Supreme Court of Maryland remanded the case for further proceedings consistent with this opinion. View "Bowens v. State Farm Mutual Automobile Insurance Co." on Justia Law

A dispute arose between a manufacturer of construction equipment and its distributor over a 2012 distribution agreement. The distributor alleged that the manufacturer breached the agreement by selling covered equipment directly to third parties, bypassing the distributor. The manufacturer, in turn, counterclaimed that the distributor failed to pay amounts due under a 2016 rental agreement and for various purchases made between 2016 and 2017. Both parties sought damages and prejudgment interest related to their respective claims and counterclaims.The United States District Court for the Southern District of New York, after the completion of discovery, granted summary judgment for the distributor on liability for its breach-of-contract claim, leaving damages to be determined by a jury. The court also granted summary judgment for the manufacturer as to both liability and damages on its breach-of-contract counterclaim. A jury awarded the distributor substantial damages for the manufacturer’s breach. The district court denied the manufacturer’s post-trial motions for judgment as a matter of law and for a new trial or remittitur, and later awarded prejudgment interest to the distributor, despite the manufacturer’s objection that the request was untimely under Federal Rule of Civil Procedure 59(e).On appeal, the United States Court of Appeals for the Second Circuit addressed whether the distributor’s motion for prejudgment interest was timely. The court held that the initial judgment entered by the district court was not sufficiently final, as it omitted reference to the manufacturer’s successful counterclaim and the award of prejudgment interest. As a result, the 28-day deadline for a Rule 59(e) motion was not triggered until a later, comprehensive, final judgment was entered. The Second Circuit affirmed the district court’s award of prejudgment interest to the distributor. View "Alessi Equip., Inc. v. Am. Piledriving Equip., Inc." on Justia Law

An incarcerated individual at Corcoran State Prison hired an attorney to file a petition for writ of habeas corpus, both in state and potentially federal court, for a total fee of $35,000. The attorney did not file the petition as agreed, leading the client to sue for breach of contract. Throughout the proceedings, the plaintiff notified the Superior Court of Orange County multiple times that he was incarcerated, requested remote appearances, and actively participated by filing necessary court documents, including a case management statement and fee waiver application. Despite these efforts, the plaintiff failed to appear for the scheduled trial, and the attorney attended and testified that the plaintiff was incarcerated.After the plaintiff's failure to appear at trial, the Superior Court of Orange County dismissed the lawsuit without prejudice, stating it was unaware of the plaintiff’s incarceration until the day of trial. The plaintiff appealed this dismissal, arguing that the court should have recognized his incarceration and taken additional steps before terminating the case.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the dismissal. The appellate court found that the trial court abused its discretion by dismissing the lawsuit without first issuing an order to show cause or ensuring that the plaintiff had meaningful access to the court. The court emphasized that incarcerated, indigent litigants must be afforded meaningful access to civil courts, and that dismissal is a drastic remedy reserved for rare circumstances. The appellate court reversed the judgment of dismissal and remanded the case, instructing the trial court to provide the plaintiff with meaningful access to the court and to communicate with prison officials as necessary. The plaintiff may recover costs on appeal, subject to further determination by the trial court. View "Park v. Guisti" on Justia Law

A resident of Madison County, Mississippi, received medical treatment at a hospital in Hinds County and later filed a claim with her health insurer, a foreign corporation doing business in the state. The insurer partially paid the claim but later, through its third-party administrator, asserted the hospital was out of network before eventually admitting it was in network. Despite repeated efforts by the insured to resolve the dispute, the insurer failed to pay the remaining balance or provide an explanation, ultimately stating the claim was untimely. The insured then sued the insurer and the administrator in Hinds County, seeking damages for breach of contract and related claims.The Circuit Court of Hinds County denied the insurer’s motion to dismiss or transfer venue to Madison County. Only the insurer sought and was granted an interlocutory appeal from this order. The administrator did not join the appeal.The Supreme Court of Mississippi reviewed the case, applying de novo review to the interpretation of the venue statute and abuse of discretion to the trial court’s venue ruling. The Court held that, under Mississippi Code Section 11-11-3(1)(a)(i), venue is proper where a substantial act or omission by the defendant caused the injury for which the plaintiff seeks redress. The Court found that the medical treatment in Hinds County was not a substantial event caused by the insurer that resulted in the alleged injury; rather, the alleged injury arose from the insurer’s acts or omissions related to the insurance contract, which were not tied to Hinds County. The Court overruled prior precedent to the extent it conflicted with this interpretation and concluded that venue was proper in Madison County. The judgment of the Hinds County Circuit Court was reversed and the case remanded for further proceedings in Madison County. View "National Health Insurance Company v. Lever" on Justia Law