Justia Civil Procedure Opinion Summaries

Two business compliance companies entered into a partnership to develop a software product, with one company providing “white-label” services to the other. The partnership was formalized in a written agreement, but disputes arose over performance, payment for out-of-scope work, and the functionality of the software integration. As the relationship deteriorated, the company that had sought the services began developing its own infrastructure, ultimately terminating the partnership and launching a competing product. The service provider alleged that its trade secrets and proprietary information were misappropriated in the process.The United States District Court for the Eastern District of Pennsylvania presided over a jury trial in which the service provider brought claims for breach of contract, trade secret misappropriation under both state and federal law, and unfair competition. The jury found in favor of the service provider, awarding compensatory and punitive damages across the claims. The jury specifically found that six of eight alleged trade secrets were misappropriated. The defendant company filed post-trial motions for judgment as a matter of law, a new trial, and remittitur, arguing insufficient evidence, improper expert testimony, and duplicative damages. The District Court denied these motions.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s rulings. The Third Circuit held that the defendant had forfeited its argument regarding the protectability of the trade secrets by not raising it with sufficient specificity at trial, and thus assumed protectability for purposes of appeal. The court found sufficient evidence supported the jury’s finding of misappropriation by use, and that the verdict was not against the weight of the evidence. The court also found no reversible error in the admission of expert testimony. However, the Third Circuit determined that the damages awarded for trade secret misappropriation and unfair competition were duplicative, and conditionally remanded for remittitur of $11,068,044, allowing the plaintiff to accept the reduced award or seek a new trial on damages. View "Harbor Business Compliance Corp v. Firstbase IO Inc" on Justia Law

A general contractor was hired to oversee the construction of a hotel in Vermont and subcontracted with a firm to install metal siding panels manufactured by a third party. The subcontractor relied on installation instructions available on the manufacturer’s website, which did not specify the use of a splice plate to connect the panels. The panels were installed without splice plates, and after construction, the panels began to detach from the building, causing some to fall and damage nearby property. The contractor later discovered that the manufacturer had created an instruction sheet in 2006 recommending splice plates, but this information was not publicly available at the time of installation.The contractor initially sued the installer for breach of contract, warranty, and negligence in the Vermont Superior Court, Chittenden Unit, Civil Division. The complaint was later amended to add a product liability claim against the manufacturer. After further discovery, the contractor sought to amend the complaint a third time to add new claims against the manufacturer, arguing that new evidence justified the amendment. The trial court denied this motion, citing undue delay and prejudice to the manufacturer, and granted summary judgment to the manufacturer on the product liability claim and on a crossclaim for implied indemnity brought by the installer, finding both barred by the economic-loss rule.On appeal, the Vermont Supreme Court affirmed the trial court’s decisions. The Court held that the trial court did not abuse its discretion in denying the third motion to amend due to undue delay and prejudice. It also held that the economic-loss rule barred the contractor’s product liability claim, as neither the “other-property” nor “special-relationship” exceptions applied. Finally, the Court found the contractor lacked standing to appeal the summary judgment on the installer’s implied indemnity claim. View "PeakCM, LLC v. Mountainview Metal Systems, LLC" on Justia Law

Plaintiff and defendant were business associates who sought to purchase three restaurants known as Jib Jab. Plaintiff, with a background in investing, initiated negotiations and sought a partner with restaurant experience, leading to an oral agreement with defendant. Plaintiff was to handle acquisition terms and financing, while defendant would manage operations. No written partnership agreement was executed. Both parties made several unsuccessful attempts to secure financing, including SBA loans, but neither was willing to personally guarantee the loan, and plaintiff refused to pay off defendant’s unrelated SBA debts. Eventually, defendant proceeded alone, secured financing, and purchased Jib Jab through an entity he formed, without plaintiff’s involvement.Plaintiff filed suit in the Superior Court, Mecklenburg County, alleging the formation of a common law partnership and asserting direct and derivative claims against defendant and the purchasing entity, including breach of partnership agreement, breach of fiduciary duty, tortious interference, misappropriation of business opportunity, and requests for judicial dissolution and accounting. Defendants moved for partial judgment on the pleadings, resulting in dismissal of all derivative claims, certain direct claims, and claims for constructive trust. The remaining claims were plaintiff’s direct claims for breach of partnership agreement, breach of fiduciary duty, tortious interference, and claims for judicial dissolution and accounting.On appeal, the Supreme Court of North Carolina reviewed the Business Court’s orders. The Supreme Court affirmed the dismissal of derivative claims, holding that North Carolina law does not permit derivative actions by a general partner on behalf of a general partnership. The Court also affirmed the dismissal of conclusory tortious interference claims and upheld the Business Court’s decision to strike portions of plaintiff’s affidavit and disregard an unsworn expert report. Finally, the Supreme Court modified and affirmed summary judgment for defendants, holding that no partnership existed due to lack of agreement on material terms, and that plaintiff failed to show he could have completed the purchase but for defendant’s actions. View "Cutter v. Vojnovic" on Justia Law

William Plott suffered severe, lifelong disabilities as a result of a vaccine administered in infancy. His family sought compensation under the National Vaccine Injury Compensation Program, filing a petition in the United States Court of Federal Claims. A special master determined that Plott’s parents were entitled to monetary relief for his care and ordered the Department of Health and Human Services (HHS) to pay a lump sum and to purchase an annuity from Wilcac Life Insurance Company, with annual payments to be made to Plott’s estate. After Plott’s death, his estate sought a final annuity payment, which Wilcac refused to pay, prompting the estate to sue both HHS and Wilcac.The estate initially filed suit in the Hamilton County, Ohio, Court of Common Pleas. Wilcac removed the case to the United States District Court for the Southern District of Ohio. HHS moved to dismiss for lack of subject matter jurisdiction, and the district court granted this motion, dismissing HHS from the case. Wilcac then argued that HHS was a necessary and indispensable party under Federal Rule of Civil Procedure 19, and the district court agreed, dismissing the entire case without prejudice because HHS could not be joined without defeating subject matter jurisdiction.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s application of Rule 19. The appellate court held that the district court erred by applying a bright-line rule that all parties to a contract are necessary and indispensable under Rule 19. Instead, the court emphasized that Rule 19 requires a pragmatic, case-specific analysis. The Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings, instructing the lower court to conduct a proper Rule 19 analysis based on the specific facts of the case. View "Estate of William Plott v. Health and Human Services" on Justia Law

A waste hauling company operating in Kansas City brought suit against a mobile waste compaction business and its franchisor. The waste hauler owns containers that are leased to customers, who sometimes contract separately with the compaction company to compress waste inside those containers. The hauler alleged that the compaction company’s activities damaged its containers and interfered with its business relationships. The hauler sought various forms of relief, including damages, injunctive and declaratory relief, and nominal damages, but ultimately disavowed any claim for actual monetary damages, citing a lack of evidence to support such damages.The United States District Court for the Western District of Missouri denied the hauler’s request for a temporary restraining order, finding no irreparable harm. During discovery, the hauler admitted it could not identify or quantify any actual damages and stipulated it was not seeking damages outside Kansas City. The district court granted the compaction company’s motion to strike the hauler’s jury demand, holding that the hauler had not presented evidence of compensatory damages, that nominal damages were unavailable under Missouri law for the claims asserted, and that the remaining claims were equitable in nature. After a bench trial, the district court entered judgment for the compaction company and its franchisor, finding the hauler failed to prove essential elements of its claims, including actual damages and direct benefit conferred for unjust enrichment.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed. The court held that the hauler was not entitled to a jury trial under the Seventh Amendment because it failed to present evidence of compensatory damages and nominal damages were not available for its claims under Missouri law. The court also affirmed judgment for the compaction company on the trespass to chattels and unjust enrichment claims, finding the hauler failed to prove dispossession, damages, or a direct benefit conferred. View "Allied Services v. Smash My Trash, LLC" on Justia Law

A married couple, who wed in 2020 and share a young child, purchased an engineering business together using loans secured by the wife’s premarital home. After their separation in 2023, the wife petitioned for divorce. The parties entered into interim agreements regarding custody, child support, and business management, but the husband repeatedly violated these orders by failing to make required payments, misusing business funds, and withholding financial disclosures. The wife raised concerns about the husband’s substance abuse and erratic behavior, providing evidence of his alcohol and marijuana use, as well as incidents of intoxication during child exchanges and at work. The husband denied these allegations but admitted to some problematic behavior in written communications.The Thirteenth Judicial District Court, Yellowstone County, held multiple hearings, finding the husband in contempt several times for violating court orders. At trial, the court heard testimony and reviewed evidence regarding the husband’s parenting, financial conduct, and the parties’ competing proposals for the business. The court found the wife more credible, sanctioned the husband for discovery violations, and ultimately awarded her primary custody of the child, with the husband’s parenting time to be phased in only after he completed chemical dependency and mental health evaluations. The court also awarded the wife sole ownership of the business and her premarital home, requiring her to assume all related debts.The Supreme Court of the State of Montana affirmed the District Court’s decisions. It held that the finding regarding the husband’s failure to make full financial disclosures was supported by substantial evidence and not clearly erroneous. The Supreme Court also found no abuse of discretion in conditioning the husband’s parenting time on completion of evaluations or in awarding the business to the wife, as these decisions were equitable and consistent with Montana law. View "In re Marriage of Boeshans" on Justia Law

A resident of a memory-care facility in Massachusetts alleged that the facility’s court-appointed receiver, KCP Advisory Group, LLC, conspired with others to unlawfully evict residents, including herself, by falsely claiming that the local fire department had ordered an emergency evacuation. The resident, after being transferred to another facility, filed suit in the United States District Court for the District of Massachusetts, asserting several state-law claims against KCP and other defendants. The complaint alleged that KCP’s actions violated statutory and contractual notice requirements and were carried out in bad faith.KCP moved to dismiss the claims against it, arguing that as a court-appointed receiver, it was entitled to absolute quasi-judicial immunity. The district court granted the motion in part and denied it in part, holding that while quasi-judicial immunity barred claims based on negligent performance of receivership duties, it did not bar claims alleging that KCP acted without jurisdiction, contrary to law and contract, or in bad faith. The court thus denied KCP’s motion to dismiss several counts, including those for violation of the Massachusetts Consumer Protection Act, intentional infliction of emotional distress, civil conspiracy, fraud, and breach of fiduciary duty. KCP appealed the denial of immunity as to these counts.The United States Court of Appeals for the First Circuit reviewed the district court’s denial of absolute quasi-judicial immunity de novo. The appellate court held that KCP’s alleged acts—removing residents from the facility—were judicial in nature and within the scope of its authority as receiver. Because KCP did not act in the absence of all jurisdiction, the court concluded that quasi-judicial immunity barred all of the resident’s claims against KCP. The First Circuit therefore reversed the district court’s denial of KCP’s motion to dismiss the specified counts. View "Suny v. KCP Advisory Group, LLC" on Justia Law

The dispute centers on approximately 930 acres of agricultural land owned by two trusts near Pocatello, Idaho. The trusts entered into a purchase and sales agreement with a developer, Millennial Development Partners, to sell a strip of land for a new road, Northgate Parkway, which was to provide access to their property. The trusts allege that Millennial and its partners, along with the City of Pocatello, failed to construct promised access points and infrastructure, and that the developers and city officials conspired to devalue the trusts’ property, interfere with potential sales, and ultimately force a sale below market value. The trusts claim these actions diminished their property’s value and constituted breach of contract, fraud, interference with economic advantage, regulatory taking, and civil conspiracy.After the trusts filed suit in the District Court of the Sixth Judicial District, Bannock County, the defendants moved for summary judgment. The trusts sought to delay the proceedings to complete additional discovery, arguing that the defendants had not adequately responded to discovery requests. The district court denied both of the trusts’ motions to continue, struck their late response to the summary judgment motions as untimely, and granted summary judgment in favor of the defendants, dismissing the case with prejudice and awarding attorney fees to the defendants. The trusts appealed these decisions.The Supreme Court of the State of Idaho affirmed the district court’s denial of the trusts’ motions to continue, finding no abuse of discretion. However, it reversed the grant of summary judgment, holding that the district court erred by failing to analyze whether the defendants had met their burden under the summary judgment standard and appeared to have granted summary judgment as a sanction for the trusts’ untimely response. The Supreme Court vacated the judgment and remanded the case for further proceedings, and declined to award attorney fees on appeal. View "Rupp v. City of Pocatello" on Justia Law

A trading company and a base oil manufacturer entered into a sales agreement in 2016, under which the manufacturer would serve as the exclusive North American sales representative for a high-quality base oil product distributed by the trading company. The agreement included noncompete provisions and was set to expire at the end of 2021. In late 2020, suspicions arose between the parties regarding potential breaches of the agreement, leading to a series of letters in which the trading company accused the manufacturer of selling a competing product and threatened termination if the alleged breach was not cured. The manufacturer responded by denying any breach and, after further correspondence, declared the agreement terminated. The trading company agreed that the agreement was terminated, and both parties ceased their business relationship.The trading company then filed suit in the United States District Court for the Southern District of Texas, alleging antitrust violations, breach of contract, business disparagement, and misappropriation of trade secrets. The manufacturer counterclaimed for breach of contract and tortious interference. After a bench trial, the district court found in favor of the manufacturer on the breach of contract and trade secret claims, awarding over $1.3 million in damages. However, the court determined that the agreement was mutually terminated, not due to anticipatory repudiation by the trading company, and denied the manufacturer’s request for attorneys’ fees and prevailing party costs.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s finding that the trading company did not commit anticipatory repudiation and that the agreement was mutually terminated. The Fifth Circuit also affirmed the denial of prevailing party costs under Rule 54(d) of the Federal Rules of Civil Procedure. However, the appellate court vacated the denial of attorneys’ fees under the agreement’s fee-shifting provision and remanded for further proceedings on that issue. View "Penthol v. Vertex Energy" on Justia Law

Gary Birdsall was stopped in traffic on the Bay Bridge when his van was rear-ended by Barton Helfet, resulting in serious injuries to Gary and a loss of consortium claim by his wife, Pamela. The Birdsalls’ attorney sent Helfet’s insurer a settlement demand for the $100,000 policy limit, specifying acceptance required delivery of a standard bodily injury release to be executed by both Gary and Pamela, a settlement check, and proof of policy limits by a set deadline. The insurer responded before the deadline with a letter accepting the offer, a release (which mistakenly listed Pamela as a releasee rather than a releasor), the check, and proof of policy limits. A corrected release was sent after the deadline. The Birdsalls’ attorney rejected the settlement, citing the release’s error and the late correction, and returned the check.The Birdsalls filed suit in the San Francisco County Superior Court. Helfet’s answer included affirmative defenses of settlement and comparative fault for Gary’s failure to wear a seat belt. The Birdsalls moved for summary adjudication on the settlement defense, which the law and motion judge granted. At trial, the assigned judge excluded evidence and jury instructions regarding Gary’s seat belt use. The jury found Helfet negligent, awarded substantial damages to both plaintiffs, and judgment was entered. Helfet’s post-trial motions were denied, and he appealed.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. It held that summary adjudication of the settlement defense was improper because there was a triable issue of material fact regarding mutual consent to the settlement. The court also found error in excluding seat belt evidence and instructions, holding that such evidence is admissible and, under the circumstances, expert testimony was not required. The judgment and amended judgment were reversed, with instructions for a new trial and denial of summary adjudication. View "Birdsall v. Helfet" on Justia Law