Justia Civil Procedure Opinion Summaries

Plaintiff, a civilly confined person under Article 10 of the New York Mental Hygiene Law, filed claims under 42 U.S.C. 1983, challenging the constitutionality of aspects of his Article 10 proceedings. The district court dismissed the complaint because he filed his claims after the expiration of the applicable three-year statute of limitations. During the pendency of his appeal, the Second Circuit has deducted court fees from plaintiff's institutional account at the Central New York Psychiatric Center pursuant to the filing fee requirement of the Prison Litigation Reform Act (PLRA) that applies to a "prisoner" proceeding in forma pauperis. Plaintiff now moves for restoration of those fees.The Second Circuit granted plaintiff's motion for restoration of fees deducted from his patient account and directed the Clerk of Court to refund those fees and to cease further collections. The court concluded that plaintiff, as a civil detainee who completed his criminal sentence, was no longer a "prisoner" under the PLRA when he filed his lawsuit. Therefore, he is not subject to the fee provisions under the PLRA. View "Jones v. Cuomo" on Justia Law

The Supreme Court affirmed Defendant's convictions for rape, criminal threat, sexual battery, and battery, holding that, even if Defendant was correct that rape is essentially a strict liability crime, he failed to establish that this would violate his due process rights.Before the Supreme Court, Defendant argued that the Kansas rape statute - and by extension the jury instruction mirroring the statute - effectively rendered rape a strict liability crime. The Supreme Court affirmed, holding that, even assuming Defendant was correct that Kan. Stat. Ann. 21-5503(e) effectively rendered rape a strict liability crime in Kansas, he failed to show that this was a violation of his right to due process or outside the legislature's authority to draft criminal laws. View "State v. Thomas" on Justia Law

Appellants Lee, Bennett, and the law firm challenge the district court's orders requiring the firm to pay $15,000 into the court's registry and directing that $7,000 of those funds be paid to the Criminal Justice Act (CJA) fund to cover the fees and expenses of defendants' court-appointed counsel. In this case, shortly after defendants were arraigned, the district court disqualified the attorneys and the law firm from representing any of the defendants based upon an actual or potential conflict of interest. The law firm had already collected a total of $21,000 from defendants.The Eleventh Circuit dismissed for lack of jurisdiction appellants' challenge to the district court's determination that funds were available to defendants. The court explained that this argument does not fit within the narrow exception that permits the court to review a district court's compliance with 18 U.S.C. 3006A's procedures. The court affirmed in all other respects. The court concluded that there was no error in the district court sua sponte raising the question of whether a portion of the fees paid to appellants were available for payment from or on behalf of defendants; the district court performed a thoroughly appropriate inquiry before entering its order directing the payment of $15,000 into the court's registry; and appellants were able to seek further review in the district court when they filed objections to the magistrate judge's order. Even if the court assumed that the district court failed to afford appellants adequate notice and opportunity to be heard before directing them to pay money into the court's registry, the error was harmless. Finally, the district court committed no procedural error based on the timing of its order directing appellants to pay funds into the court's registry. View "United States v. Pacheo-Romero" on Justia Law

A majority of the active judges of the Eleventh Circuit voted to rehear this case en banc.This petition for writ of mandamus arises under the Crime Victims' Rights Act (CVRA), 18 U.S.C. 3771. Petitioner, one of more than 30 woman who were victimized by notorious sex trafficker and child abuser Jeffrey Epstein, sought mandamus relief, alleging that when federal prosecutors secretly negotiated and entered into a non-prosecution agreement with Epstein in 2007, they violated her rights under the CVRA. Specifically, petitioner alleged that federal prosecutors violated her rights to confer with the government's lawyers and to be treated fairly by them.The en banc court held that the CVRA does not provide a private right of action authorizing crime victims to seek judicial enforcement of CVRA rights outside the confines of a preexisting proceeding. The court explained that, while the CVRA permits a crime victim like Ms. Wild to move for relief within the context of a preexisting proceeding—and, more generally, to pursue administrative remedies—it does not authorize a victim to seek judicial enforcement of her CVRA rights in a freestanding civil action. In this case, because the government never filed charges against Epstein, there was no preexisting proceeding in which Ms. Wild could have moved for relief under the CVRA, and the Act does not sanction her stand-alone suit. View "In re: Courtney Wild" on Justia Law

The Supreme Court granted Petitioner's petition for writ of habeas corpus and ordered that Petitioner is and shall remain discharged from custody, holding that the subject temporary restraining order's lack of specificity regarding the conduct to be restrained rendered it and the judgment of contempt and order of confinement void.Petitioner was jailed and her solely-owned business, a cosmetology salon, was fined for violating a temporary restraining order requiring them to cease and desist for operating the salon for in-person services in violation of regulations related to the COVID-19 pandemic. The trial court issued a judgment holding Petitioner and her business in contempt. Petitioner filed this habeas corpus petition arguing that she was illegally restrained because the temporary restraining order was unconstitutional and void. The Supreme Court agreed, holding (1) the temporary order was void; and (2) therefore, the contempt judgment based on that order was void as well. View "In re Luther" on Justia Law

At issue in this appeal is whether the district court abused its discretion when it applied the fugitive disentitlement doctrine to dismiss plaintiff's action against defendant, the father of her two daughters. In this case, plaintiff left the United States against the orders of a Florida family court and could be arrested by Florida officials if she were to return to Florida. Plaintiff filed suit attacking the proceedings of the family court while remaining outside its jurisdiction.The Eleventh Circuit affirmed the district court's judgment, concluding that the district court did not abuse its discretion by applying the fugitive disentitlement doctrine to dismiss plaintiff's lawsuit. The court explained that because plaintiff remains a fugitive, her lawsuit collaterally attacks the very proceedings from which she absconded, and dismissal prevents her from using the judicial process only when it benefits her. The court denied as moot the motion to dismiss the appeal, the motion to strike part of the reply brief, and the motion to strike the appendix to the reply brief. View "Vibe Ener v. Martin" on Justia Law

Dustin Lance was denied medical treatment for priapsm at a detention center in McAlester, Oklahoma. He ultimately sued the sheriff and four jail guards; summary judgment was entered in favor of all defendants. After review of his appeal, the Tenth Circuit affirmed in part, and reversed in part. Like the district court, the Court concluded that one of the jail guards, Edward Morgan, had qualified immunity because he didn’t violate Lance’s constitutional right to medical care. But the Court concluded that qualified immunity was unavailable to the three other jail guards: Mike Smead, Dakota Morgan, and Daniel Harper. And the sheriff, Chris Morris, was not entitled to summary judgment in his official capacity because the factfinder could reasonably determine that the county’s policies had violated Lance’s constitutional right to medical care. View "Lance v. Board of County Commissioners" on Justia Law

The Supreme Court affirmed the order of the district court vacating its prior order to expunge Justin Dickey's misdemeanor records, holding that the Montana Rules of Civil Procedure apply to proceedings brought under the Misdemeanor Expungement Clarification Act and that the district court properly determined that venue was not proper under Mont. Code Ann. 46-18-1105.Dickey filed a petition for expungement of his misdemeanor criminal records, referred only to "misdemeanor criminal record(s)" generally. The district court granted the petition. On reconsideration, the district court vacated its prior expungement order and dismissed the matter, determining that venue was improper. The Supreme Court affirmed, holding (1) the Rules of Civil Procedure apply to a proceeding brought under the Expungement Act; and (2) the district court did not err in determining that Dickey's prior speeding violation in Kalispell was insufficient to establish proper venue in the Eleventh Judicial District for expungement of misdemeanors under section 46-18-1105. View "In re Dickey" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing a jury's finding that Jeffery Lee Stoddard was a sexually violent predator (SVP) and civilly committing him under Tex. Health & Safety Code chapter 841, holding that the court of appeals applied an improper standard.The court of appeals described the standard governing the factual sufficiency review in which the burden of proof was beyond a reasonable doubt the court of appeals described the standard as requiring the court to weigh the evidence in a neutral light to determined whether the jury's finding was factually insufficient or so against the great weight and preponderance as to be manifestly unjust, shock the conscience, or clearly demonstrate bias. The Supreme Court reversed, holding (1) the court of appeals applied an improper standard that allowed the court to substitute its own judgment for that of a reasonable fact-finder and incorporated a statutory element that chapter 841's text did not support; and (2) a properly conducted factual-sufficiency review in an SVP case requires the appellate court to determine whether, on the entire record, a reasonable factfinder could find beyond a reasonable doubt that the defendant is an SVP. View "In re Commitment of Jeffery Lee Stoddard" on Justia Law

Spencer Curtiss appealed the dismissal of his declaratory judgment action seeking relief from a criminal judgment and the district court’s subsequent order denying his motion for reconsideration. In 2011, Curtiss was convicted and sentenced to 25 years of imprisonment with all but 15 years suspended for Gross Sexual Imposition (GSI) with a minor. Curtiss has previously initiated a direct appeal of his conviction in the criminal case, filed two petitions for post-conviction relief under the Uniform Postconviction Procedure Act, moved for relief under N.D.R.Civ.P. 60, and moved to amend his probation. In February 2020, Curtiss filed a complaint in district court seeking a declaratory judgment, a vacation of the sex offender registration requirements of his sentence, and a removal of his probation period. Curtiss asserted a variety of claims challenging the underlying GSI conviction. The court dismissed the action under N.D.R.Civ.P. 12(b)(6) after finding the current action to be an impermissible collateral attack on the criminal judgment. Curtiss subsequently filed a motion for reconsideration of the dismissal of his action. The court denied the motion. On appeal, Curtiss argued the district court erred in dismissing his action and denying his motion to reconsider. Finding no reversible error, the North Dakota Supreme Court affirmed dismissal. View "Curtiss v. North Dakota" on Justia Law