Justia Civil Procedure Opinion Summaries

The City of Meridian filed a petition for forfeiture against Maria Catalan after police found $104,690 in her truck during a traffic stop. Catalan filed a motion to dismiss for failure to state a claim under Rule 12(b)(6) of the Mississippi Rules of Civil Procedure, which the county court granted. The Circuit Court affirmed. The City appealed, and the Court of Appeals affirmed the judgment of the circuit court. Having granted certiorari, the Mississippi Supreme Court agreed with the Court of Appeals’ dissent that the City’s forfeiture petition satisfied the notice pleading requirements of Rule 8 of the Mississippi Rules of Civil Procedure. The Supreme Court also agreed with the Court of Appeals’ dissent that in deciding the Rule 12(b)(6) motion, the county court considered matters outside the City’s petition: the court also considered matters outside the pleadings for purposes of Rule 12(c), which allowed for a judgment on the pleadings. In doing so, the county court in effect converted the Rule 12(b)(6) and/or 12(c) motion into a motion for summary judgment, as provided in Rule 56 of the Mississippi Rules of Civil Procedure. Rule 56(c) of the Mississippi Rules of Civil Procedure requires at least ten days’ notice to both parties that the court is converting the motion, which did not occur in this instance. Accordingly, the Supreme Court reversed the judgment of the Court of Appeals as well as the county court’s order, and remanded the case for further proceedings. View "City of Meridian v. $104,960.00 U.S. Currency et al." on Justia Law

Despite repeatedly asserting his innocence, Satterfield was convicted of first-degree murder in 1985 and sentenced to life in prison. After years of direct and collateral litigation, the district court, acting on his habeas petition, found that his ineffective assistance of counsel claim meritorious. The Third Circuit reversed, finding his petition barred by Antiterrorism and Effective Death Penalty Act’s (AEDPA’s) one-year statute of limitations, 28 U.S.C. 2244(d)(1). Years later, the Supreme Court decided, in McQuiggin v. Perkin, that a petitioner who can make a credible showing of actual innocence can overcome that limitations period. Satterfield sought relief from the judgment denying his habeas petition, characterizing McQuiggin’s change in law as an extraordinary circumstance to justify relief under FRCP 60(b)(6). The district court denied Satterfield’s motion. The Third Circuit vacated, holding that changes in decisional law may, under certain circumstances, justify Rule 60(b)(6) relief. “A district court addressing a Rule 60(b)(6) motion premised on a change in decisional law must examine the full panoply of equitable circumstances in the particular case.” In this case, the court did not articulate the requisite equitable analysis. If Satterfield can make the required credible showing of actual innocence, an equitable analysis would weigh heavily in favor of deeming McQuiggin’s change in law, as applied to Satterfield’s case, an exceptional circumstance justifying Rule 60(b)(6) relief. View "Satterfield v. District Attorney Philadelphia" on Justia Law

Bernstein, an attorney appointed under the Criminal Justice Act, 18 U.S.C. 3006A, to represent an indigent defendant in federal district court, hired forensic expert Speckin to analyze evidence for the defense. Bernstein disregarded the Act’s rules and failed to obtain the court’s preapproval; he submitted a voucher for the expert’s services six months after his client was sentenced, requesting $15142.90, about six times the statutory cap. The judge would not approve it. Speckin sued Bernstein in a Michigan state court, which entered a default judgment against Bernstein. Bernstein then unsuccessfully asked the federal district judge to vacate the state-court judgment or enjoin its enforcement. The Seventh Circuit vacated and remanded with instructions to dismiss for lack of subject-matter jurisdiction. No statute authorized the district court to review the Michigan judgment. Bernstein hired Speckin outside the bounds of the CJA, so their dispute is one of private contract and governed by state law. The Anti-Injunction Act prohibits federal courts from granting an “injunction to stay proceedings in a State court except as expressly authorized by Act of Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments,” 28 U.S.C. 2283. Nothing in the CJA comes close to authorizing an injunction of state-court proceedings. View "United States v. Alkaramla" on Justia Law

Claimants, Wiggins and Allison, were at the Cleveland Airport for a flight to Orange County, California. The Drug Enforcement Administration (DEA), aware of their itineraries and that each had previous felony drug convictions, observed them engaging in conversation before they walked toward the security checkpoint. The government alleged, and Wiggins denied, that Wiggins consented to a search. Agents found $31,000 hidden in the lining of his suitcase. He could not answer why he was traveling with the money. He denied knowing Allison. An agent found $10,000 in Allison’s sock. Allison stated that he had won the money at a casino but could not provide details. A canine alerted to the odor of narcotics on the separate boxes containing the money. The government seized the funds and filed a civil in rem forfeiture complaint under 21 U.S.C. 881(a)(6), which allows the government to seize items it suspects were used in furtherance of criminal activity without charging the property’s owner with a crime. The district court granted the government’s motion to strike claimants’ claims to the currency. The Sixth Circuit reversed, noting that the government apparently moved to dismiss the claim before it engaged in any discovery. The government asserted that the claimant’s pleadings must do more than assert ownership and must provide sufficient detail to draft interrogatories allowing the government to test the claim of ownership. The procedural rules governing civil forfeiture actions do not demand such a heightened standard. View "United States v. $31,000.00 in U.S. Currency" on Justia Law

Al Neeley was convicted by jury of malice murder and possession of a firearm in the commission of a felony, all relating to the shooting death of Shelton Brooks. His amended motion for a new trial was denied, and he appealed, arguing the evidence presented against him at trial was insufficient to support his convictions, and that he received ineffective assistance of counsel. Finding no reversible error after a review of the trial court record, the Georgia Supreme Court affirmed. View "Neely v. Georgia" on Justia Law

Rhonda Bennett (f/k/a Donley) filed an amended motion for new trial following a habeas court order discharging the payment of restitution and any arrearage for back child support by the purported biological father of Bennett’s minor child. Concluding that she was a non-party to the underlying action and therefore lacked standing to challenge its order, the court dismissed Bennett’s motion. The Georgia Supreme Court reversed, finding the habeas court erred in concluding that Bennett lacked standing. View "Bennett v. Etheridge" on Justia Law

At issue in this case was whether the law-of-the-case doctrine requires a court to apply the findings of a superior court in a criminal case to a civil case brought by the criminal defendant against individuals and entities who were not parties to the criminal case. The court held that the law-of-the-case doctrine does not require a court to follow a superior court’s decision in a prior appeal involving one of the parties but in the context of a different case. Rather, the law-of-the-case doctrine applies only to rulings in the same case. The Supreme Court reversed the judgment of the court of appeals, which ruled that summary judgment was improper in this case because the law-of-the-case doctrine applied. The Supreme Court held that the appellate court’s holding was not a proper application of the law-of-the-case doctrine. View "Reid v. Cleveland Police Department" on Justia Law

Three of Hand’s four wives died, two as victims of violent, unsolved home invasions. The death of Hand’s fourth wife, Jill, occurred while he was at home. Hand confronted and shot the intruder, who turned out to be his friend and employee Welch. An investigation revealed a plot between the men to kill all three women in order to receive life insurance proceeds. Hand was convicted of the aggravated murders of Jill and Welch, with death-penalty specifications, conspiracy to commit the aggravated murders, and an attempt to escape police custody after he was arrested. The jury recommended and the judge imposed the death penalty. After unsuccessful state appeals and post-conviction proceedings, Hand unsuccessfully sought federal habeas relief. The Sixth Circuit rejected several claims involving the adequacy of the voir dire at his trial to screen jurors because of pretrial publicity and ineffective assistance of counsel claims related to the voir dire; ineffective assistance claims related to mitigation evidence and the reintroduction of evidence of guilt during the sentencing phase; and the adequacy of evidence supporting the death penalty specifications. View "Hand v. Houk" on Justia Law

This case involved the expulsion of then-high school student S.G. by the Henry County Board of Education (“Local Board”) as discipline for fighting on school grounds in violation of the student handbook. Specifically, she was charged with physically abusing others, and with a violation that constituted a misdemeanor under Georgia law. Following an evidentiary hearing before a disciplinary hearing officer, S.G. was expelled from Locust Grove High School, and that decision was affirmed by the Local Board. S.G. then filed an appeal to the Superior Court. After considering the evidentiary record, briefs submitted by the parties, and oral argument, the superior court reversed the State Board’s decision and ordered the Local Board to remove the disciplinary findings from the student’s record and to amend the record to reflect the student’s innocence of the disciplinary charges brought against her. That prompted the Local Board’s appeal to the Court of Appeals, which affirmed the superior court’s reversal of the Local Board’s ruling. The Georgia Supreme Court granted the Local Board’s petition for writ of certiorari to examine two issues: whether the Court of Appeals opinion imposed an improper burden of proof upon local school boards with respect to a student’s self-defense claim to disciplinary charges for engaging in a fight; and whether, regardless of its burden of proof analysis, the Court of Appeals correctly determined that the Local Board improperly rejected S.G.’s self-defense claim. After its review, the Supreme Court reversed the Court of Appeals for “veering off courts in substituting its own findings of fact instead of remanding the case to the Local Board to apply the proper law to the record evidence and reach its own findings.” View "Henry Cty. Bd. of Education v. S.G." on Justia Law

The circuit court ruled Enoch Oliver could proceed to trial with his malicious-prosecution claim against University of Mississippi Medical Center (UMMC) and two of its law-enforcement officers, Syrone McBeath and David Stewart. Oliver was charged with three misdemeanors: disorderly conduct for failure to comply with the commands of a police officer, resisting arrest, and carrying a concealed weapon. A nol-pros order was signed by the trial court and charges were ultimately dropped against Oliver. Oliver sued civilly, and UMMC, McBeath, and Stewart were served with process; several other officers were not. UMMC, McBeath, and Stewart filed a motion to dismiss, which was joined by the unserved defendants, who specially appeared. The served defendants argued Oliver’s claims were governed by the Mississippi Tort Claims Act (MTCA) and its one-year statute of limitations. The lone exception was the malicious prosecution of the felony claim, because the one-year statute of limitations did not begin to run until that charge was nol-prossed. The unserved defendants’ motion was granted, leaving the remaining claim against the served defendants as the malicious-prosecution claim based on the felony charge. Three-and-a-half years later, UMMC, McBeath, and Stewart filed a motion for summary judgment. UMMC argued, as a state agency, it had not waived sovereign immunity for a malice-based claim; McBeath and Stewart argued Oliver lacked proof they maliciously prosecuted him. Alternatively, all defendants cited the MTCA’s police-protection and discretionary-function immunity. The circuit court denied the defendants’ motion. UMMC, McBeath, and Stewart filed this interlocutory appeal, claiming they were entitled to summary judgment. The Mississippi Supreme Court determined as a matter of law, malice-based torts did not fall under the Mississippi Tort Claims Act’s sovereign-immunity waiver. So Oliver had no malicious-prosecution claim against UMMC or its employees in their official capacity. Oliver also brought malicious-prosecution claims against the UMMC officers in their individual capacity, but the record showed Oliver failed to put forth any evidence the officers acted with malice or lacked probable cause. The Court thus reversed the circuit court’s denial of summary judgment and rendered a final judgment in defendants’ favor. View "University of Mississippi Medical Center v. Oliver" on Justia Law