Justia Civil Procedure Opinion Summaries

In September 2016, a high school student, almost 16 years old, was involved in a fistfight during an art class. The teacher, who weighed 375 pounds and had a back condition, intervened to stop the fight. While pulling one of the boys away, the teacher lost his balance and fell onto the plaintiff, breaking the plaintiff’s leg. The plaintiff sued the teacher and the school district for negligence, arguing that the teacher should not have intervened due to his physical condition and that the school district failed to train its teachers on safely handling physical altercations.The Superior Court of Los Angeles County held a 15-day trial, during which the jury viewed a video of the incident multiple times. The jury concluded that neither the teacher nor the school district was negligent and found that the plaintiff and the other boy were each 50 percent responsible for the harm. The plaintiff’s motion for judgment notwithstanding the verdict (JNOV) and a new trial was denied.The California Court of Appeal, Second Appellate District, reviewed the case. The court found substantial evidence supporting the jury’s verdict that neither the teacher nor the school district was negligent. The court also upheld the trial court’s exclusion of the plaintiff’s expert witness on the grounds that the expert was not qualified to opine on classroom management and discipline. Additionally, the court found no error in the trial court’s refusal to give the plaintiff’s requested special jury instructions, as the standard instructions on negligence were deemed sufficient. The judgment and the order denying the plaintiff’s motion for JNOV and a new trial were affirmed. View "I.C. v. Compton Unified School Dist." on Justia Law

Edward M.R., a special-education student in Washington, D.C.'s public schools, filed an administrative due process complaint on June 19, 2020, alleging that his individualized education plans (IEPs) from 2015 through 2019 were insufficient to meet his needs under the Individuals with Disabilities Education Act (IDEA). He claimed deficiencies in speech/language therapy, occupational therapy, and other areas. The hearing officer dismissed his claims, finding that challenges to his 2015, 2016, and 2017 IEPs were untimely and that his 2018 and 2019 IEPs were appropriate.Edward then sued in the United States District Court for the District of Columbia, challenging the hearing officer's determinations regarding the 2017, 2018, and 2019 IEPs. The district court affirmed the hearing officer's decisions, leading Edward to appeal.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that Edward's challenge to his 2017 IEP was untimely, as it was filed more than two years after he knew or should have known about the alleged deficiencies. Regarding the 2018 and 2019 IEPs, the court found that Edward failed to prove by a preponderance of the evidence that the hearing officer was wrong in concluding that the IEPs were appropriate. The court noted that repeating goals in the IEPs was reasonable given Edward's severe memory issues and that the IEPs included new, appropriately ambitious goals.The court also rejected Edward's claims that his IEPs lacked research-based instruction, finding that he received such instruction even if it was not explicitly stated in the IEPs. Finally, the court did not consider Edward's claim regarding the implementation of Applied Behavior Analysis, as it was not exhausted through the administrative process. The court affirmed the district court's decision. View "M.R. v. District of Columbia" on Justia Law

Three former students of East Gaston High School, who were members of the wrestling team, filed a lawsuit against their coach, Gary Scott Goins, and the Gaston County Board of Education. They alleged that Goins subjected them to sexual abuse, physical violence, and psychological harm during the mid-1990s and early 2000s. Goins was criminally convicted in 2014 and sentenced to over thirty-four years in prison. The plaintiffs sought civil damages from the Board of Education, claiming it knew or should have known about the abuse. The claims were initially time-barred under the three-year statute of limitations, which began running on the victims' eighteenth birthdays.The Superior Court of Wake County, in a divided decision, declared the revival provision of the SAFE Child Act, which allowed previously time-barred claims to be filed during a two-year window, unconstitutional. The court held that the expiration of the statute of limitations created a vested right for the defendants, which the legislature could not retroactively alter.The North Carolina Court of Appeals reversed the lower court's decision, holding that the revival of the statute of limitations did not interfere with vested rights. The court reasoned that statutes of limitations are procedural and do not create property rights. Therefore, the legislature could retroactively alter them without violating the constitution.The Supreme Court of North Carolina affirmed the Court of Appeals' decision, holding that the running of a statute of limitations in a tort claim does not create a constitutionally protected vested right. The court emphasized that statutes of limitations are procedural and affect only the remedy, not the underlying right. The court concluded that the General Assembly has the authority to retroactively alter statutes of limitations for tort claims. View "McKinney v. Goins" on Justia Law

K.S., a minor, through his guardian James Seeger, sued Richland School District Two, alleging gross negligence in supervising K.S.'s first-grade teacher and seeking liability under respondeat superior for injuries K.S. suffered due to the teacher's actions. The teacher, under personal stress, humiliated K.S. and other students, and physically grabbed K.S., causing him pain. K.S. experienced significant emotional distress and was diagnosed with persistent depressive disorder and anxiety.The trial court granted the District a directed verdict, ruling that the District could not be liable for negligence as K.S. suffered no physical injury. The court also excluded Seeger's expert testimony and ruled that the Safe School Climate Act did not repeal the South Carolina Tort Claims Act. The court of appeals affirmed the directed verdict, agreeing that no physical injury occurred and did not address the expert testimony exclusion or the Safe Schools Act ruling.The South Carolina Supreme Court reviewed the case and reversed the directed verdict, finding that the teacher's forceful grabbing of K.S. constituted sufficient physical harm to support a negligence claim. The court also reversed the exclusion of Seeger's expert, Dr. McEvoy, ruling that his testimony was not needlessly cumulative and would have provided crucial insight into the District's policies and their implementation. The court affirmed the trial court's ruling that the Safe Schools Act did not repeal the Tort Claims Act, maintaining that the Act does not create a private right of action or alter tort liability.The Supreme Court remanded the case for further proceedings consistent with its opinion, allowing Seeger's negligence claims to proceed and permitting the District to renew objections to Dr. McEvoy's testimony on remand. View "K.S. v. Richland School District Two" on Justia Law

F.B. and M.B. filed a lawsuit on behalf of themselves and their minor child, L.B., under Section 504 of the Rehabilitation Act, alleging that Our Lady of Lourdes Parish and School failed to comply with procedural standards and requirements mandated by the Act's implementing regulations. L.B. had ADHD and reduced vision, and her parents claimed that the school initially provided necessary accommodations but later failed to do so after a change in school administration. This led to L.B. receiving failing grades and eventually being expelled from the school.The United States District Court for the Eastern District of Missouri dismissed the case, holding that Section 504 does not create a private right of action for claims based solely on an alleged failure to comply with procedural standards and requirements of the implementing regulations. The plaintiffs appealed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the plaintiffs lacked Article III standing to bring their claims. The court found that the plaintiffs' alleged injury, L.B.'s expulsion, was not fairly traceable to the school's failure to comply with the procedural regulations of Section 504. Additionally, the court determined that the relief sought by the plaintiffs would not redress their alleged injury. Consequently, the Eighth Circuit vacated the district court's judgment and remanded the case with instructions to dismiss for lack of jurisdiction. View "F.B. v. Our Lady of Lourdes Parish and School" on Justia Law

John Doe 2, a student athlete at North Carolina State University, alleged that he was sexually abused by Robert Murphy, the university’s Director of Sports Medicine, under the guise of medical treatment. Doe claimed that the university was deliberately indifferent to prior complaints of Murphy’s sexual misconduct. The district court dismissed Doe’s complaint, finding that he failed to plead facts supporting an inference that the university had actual notice of Murphy’s sexual harassment.The United States District Court for the Eastern District of North Carolina dismissed the complaint under Federal Rule of Civil Procedure 12(b)(6). The court concluded that a report of “sexual grooming” could not provide actual notice to the university of sexual harassment. The district court assumed without deciding that the report was made to an official with the requisite authority for Title IX purposes but found that the report did not describe an incident of sexual harassment and thus could not support a plausible inference of actual notice.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the district court’s judgment. The Fourth Circuit held that a report of “sexual grooming” can objectively be construed as alleging sexual harassment, thus providing actual notice to the university. The court found that the district court erred in its conclusion and remanded the case for further proceedings to determine whether the report was made to an appropriate official with the authority to address complaints of sexual harassment and to institute corrective measures on behalf of the university. View "John Doe 2 v. North Carolina State University" on Justia Law

Howard University’s Board of Trustees amended the institution’s bylaws to remove trustee positions that had been filled by alumni, students, and faculty for several decades. A group of alumni sued the University and the Board in D.C. Superior Court, seeking a declaration that the Board’s amendment was ultra vires because it violated the governing bylaws. Howard removed the case to federal court, arguing that the governance dispute hinged on the University’s federal charter. The alumni moved to remand the case back to state court.The United States District Court for the District of Columbia denied the alumni’s motion to remand, holding that the suit implicated a significant federal issue under Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing. The District Court then granted Howard’s motion to dismiss the case under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that the District Court erred in exercising jurisdiction. The Court of Appeals determined that the case did not arise under federal law nor present a significant, disputed federal issue under Grable. Consequently, the Court of Appeals reversed the District Court’s decision and remanded the case with instructions to dismiss it without prejudice for lack of subject matter jurisdiction. View "Jenkins v. Howard University" on Justia Law

In 2022, the Kentucky General Assembly enacted Senate Bill 1 (S.B. 1), which restructured the relationship between the Jefferson County Board of Education and its superintendent. The bill required the Board to delegate day-to-day operations to the superintendent, limited the Board's meeting frequency, and granted the superintendent additional administrative powers. The Jefferson County Board of Education filed a declaratory judgment action, claiming S.B. 1 violated Sections 59 and 60 of the Kentucky Constitution, which prohibit local or special legislation.The Jefferson Circuit Court ruled in favor of the Board, declaring S.B. 1 unconstitutional. The court found that the bill effectively applied only to Jefferson County, thus constituting impermissible local legislation. The court also ruled, sua sponte, that S.B. 1 violated the equal protection rights of Jefferson County residents. The Kentucky Court of Appeals affirmed the trial court's decision on the grounds of Section 59 but did not address the equal protection ruling.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that S.B. 1 did not violate Sections 59 and 60 of the Kentucky Constitution. The Court reasoned that the bill's language created an open classification applicable to any county with a consolidated local government, not just Jefferson County. The Court also found that the Board had standing to challenge the bill and that the superintendent was not a necessary party to the action. The Court declined to address the equal protection issue, as it was not properly raised or developed in the lower courts. View "COLEMAN V. JEFFERSON COUNTY BOARD OF EDUCATION" on Justia Law

Plaintiffs, Junhai Bai and Xiaofei Li, filed a lawsuit against the San Francisco Unified School District and teacher Stephanie Yip, alleging that their minor daughter, L.B., was physically abused by Yip. The complaint detailed incidents of abuse, including insufficient food and water, physical assault, and resulting injuries such as a concussion and chest contusion. The plaintiffs sought monetary damages for mental harm, impairment of working ability, future illness risk compensation, and family care.The San Francisco City & County Superior Court sustained the defendants' unopposed demurrer and granted their unopposed motion to strike portions of the complaint, allowing leave to amend but without specifying a deadline. Plaintiffs filed a revised version of their complaint several weeks after the time to amend had expired. The trial court did not consider this filing as an amended complaint. Defendants then moved to dismiss the action under section 581, subdivisions (f)(2) and (f)(4) of the Code of Civil Procedure, which the court granted.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court held that under the decision in Gitmed v. General Motors Corp., the filing of an amended complaint, even if untimely, precludes dismissal under section 581, subdivision (f)(2), unless and until the amended complaint is stricken. The court found that the plaintiffs' revised pleading should have been treated as an amended complaint, which should have precluded the dismissal of the action. Consequently, the appellate court reversed the judgment and the order granting the motion to dismiss, remanding the case for further proceedings. View "Bai v. Yip" on Justia Law

R.A. filed a lawsuit against her son G.A.'s special education teacher, Robin Johnson, and several school officials, alleging that Johnson mistreated G.A. during the first and second grades. The complaint claimed that Johnson subjected G.A. to physical and emotional abuse and that the school officials negligently failed to intervene despite knowing about the abuse. The school officials moved to dismiss the negligence claims, arguing they were protected by public official immunity. The district court denied the motion, and the school officials filed an interlocutory appeal.The United States District Court for the Western District of North Carolina initially denied the school officials' motion to dismiss the state law claims, leading to an appeal. The Fourth Circuit Court of Appeals previously ruled that the school officials were entitled to public official immunity and that the state law claims against them should be dismissed. Despite this, the district court allowed R.A. to file an amended complaint with additional details from new evidence, which the school officials again moved to dismiss. The district court denied this motion, interpreting the appellate mandate as allowing dismissal without prejudice.The Fourth Circuit Court of Appeals reviewed the case again and held that the district court violated the mandate rule by not dismissing the claims with prejudice as instructed. The appellate court emphasized that its prior decision required dismissal with prejudice and that the district court's interpretation was incorrect. The court reiterated that the mandate rule requires lower courts to follow the appellate court's instructions precisely and that no exceptions to the mandate rule applied in this case. Consequently, the Fourth Circuit reversed the district court's decision, reaffirming that the state law claims against the school officials must be dismissed with prejudice. View "R.A. v. McClenahan" on Justia Law