Justia Civil Procedure Opinion Summaries

In 2020, Georgia ratified an amendment to its Constitution waiving sovereign immunity for actions seeking declaratory relief from unlawful acts by the State or local governments. This amendment included a procedural requirement that such actions must be brought against and in the name of only the State or the relevant local government, or they would be dismissed. The case at hand questions whether a complaint that does not comply with this naming requirement can be cured by dropping or adding parties to avoid dismissal.Warbler Investments, LLC sued the City of Social Circle, its mayor, and three City Council members in their individual capacities, alleging unlawful rezoning of Warbler's property and violations of the Open Records Act. The defendants moved to dismiss the claims, arguing that the complaint violated the naming requirement of the Georgia Constitution. Warbler then moved to amend the complaint to drop the individual defendants, which the trial court allowed. However, after the Georgia Supreme Court's decision in State v. SASS Group, LLC, which mandated dismissal of cases not complying with the naming requirement, the City renewed its motion to dismiss. The trial court granted the motion, dismissing the case despite the amendment.The Supreme Court of Georgia reviewed the case and concluded that the procedural defect of not complying with the naming requirement could be cured by amending the complaint to drop or add parties. The court held that the waiver of sovereign immunity was not affected by the initial failure to comply with the naming requirement, and the amended complaint, which complied with the requirement, should not be dismissed. The judgment was reversed, and the case was remanded. View "WARBLER INVESTMENTS, LLC v. CITY OF SOCIAL CIRCLE" on Justia Law

The Santa Ana Police Officers Association (SAPOA) and certain anonymous City of Santa Ana police officers (Doe Officers) sued the City of Santa Ana, alleging wrongful disclosure of confidential personnel records, failure to investigate a complaint about the disclosure, and denial of a request for related communications. The first amended complaint included four causes of action: violation of Penal Code section 832.7 and Evidence Code sections 1043 and 1045, negligence, failure to investigate under Penal Code sections 832.5 and 832.7, and violation of the Meyers-Milias Brown Act (MMBA).The Superior Court of Orange County sustained the City’s demurrer to the first amended complaint without leave to amend, leading to the dismissal of the case. The court found that the Doe Officers could not proceed anonymously without statutory authority or court authorization. It also concluded that the SAPOA lacked standing and that there was no private right of action for the alleged violations of the Penal Code and Evidence Code sections cited.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court affirmed the judgment as to the Doe Officers, agreeing they lacked authorization to proceed anonymously. It also affirmed the trial court’s decision regarding the first, second, and fourth causes of action, finding no private right of action for damages under the cited statutes and that the SAPOA failed to exhaust administrative remedies for the MMBA claim. However, the appellate court reversed the judgment concerning the third cause of action, holding that the SAPOA had standing to seek mandamus relief to compel the City to investigate the complaint and notify the SAPOA of the disposition, as required by Penal Code sections 832.5 and 832.7. The case was remanded for further proceedings on this cause of action. View "Santa Ana Police Officers Assn. v. City of Santa Ana" on Justia Law

Shanta Webster filed a complaint in the Grenada County Circuit Court against the University of Mississippi Medical Center-Grenada (UMMC-Grenada) and Drs. Aimee Watts and Kimberly Farmer, alleging medical negligence in the performance of a hysterectomy and post-operative care. Webster served the complaint to Dr. Watts, Dr. Farmer, and Dodie McElmurry, the CEO of UMMC-Grenada. The defendants requested an extension to answer the complaint and later claimed immunity under the Mississippi Tort Claims Act (MTCA). Webster argued that service of process was proper under Rule 4(d)(8) of the Mississippi Rules of Civil Procedure.The Grenada County Circuit Court dismissed the complaint, ruling that service of process was improper because it was not made to the Attorney General as required by Rule 4(d)(5) for state institutions. Webster appealed the dismissal, maintaining that UMMC-Grenada is a community hospital and that service on the CEO was sufficient.The Supreme Court of Mississippi reviewed the case de novo and upheld the trial court's decision. The court found that UMMC-Grenada is not a separate entity but a part of UMMC, a state institution. Therefore, service of process should have been made to the Attorney General under Rule 4(d)(5). Webster failed to serve the Attorney General within the 120-day period required by Rule 4(h), rendering the service invalid. Additionally, the court noted that Drs. Watts and Farmer, acting within the scope of their employment, were immune from personal liability under the MTCA.The Supreme Court of Mississippi affirmed the trial court's order of dismissal, concluding that proper service of process was not effected, and the individual defendants were immune from liability. View "Webster v. University of Mississippi Medical Center Grenada" on Justia Law

A hospital in Siskiyou County, California, filed a lawsuit against the County of Siskiyou and other defendants, challenging the practice of bringing individuals with psychiatric emergencies to its emergency department under the Lanterman-Petris-Short (LPS) Act. The hospital argued that it was not equipped or licensed to provide the necessary psychiatric care and sought to prevent the county from bringing such patients to its facility unless they had a physical emergency condition. The hospital also sought reimbursement for the costs associated with holding these patients.The Siskiyou County Superior Court denied the hospital's motion for a preliminary injunction, which sought to stop the county from bringing psychiatric patients to its emergency department. The court found that the hospital had not demonstrated a likelihood of success on the merits and that the burden on the county and the potential harm to the patients outweighed the hospital's concerns.The hospital's complaint included several causes of action, including violations of Medicaid laws, disability discrimination laws, mental health parity laws, and section 17000 of the Welfare and Institutions Code. The hospital also alleged breach of an implied-in-fact contract for the costs incurred in providing post-stabilization services to psychiatric patients. The trial court sustained demurrers to the complaint without leave to amend, finding that the hospital failed to identify any clear legal mandate that the county or the Department of Health Care Services had violated.The California Court of Appeal, Third Appellate District, affirmed the trial court's judgment of dismissal. The appellate court concluded that the hospital had not identified any mandatory and ministerial duty that the county or the department had violated, which is necessary to obtain a writ of mandate. The court also found that the hospital's breach of contract claim failed because there were no allegations of mutual consent to an implied contract. Consequently, the hospital's appeal from the denial of its motion for a preliminary injunction was dismissed as moot. View "Siskiyou Hospital v. County of Siskiyou" on Justia Law

Michael Chapman, an Alabama inmate, sued prison officials and staff for deliberate indifference to his medical needs, violating the Eighth Amendment. Chapman alleged that an untreated ear infection led to severe injuries, including mastoiditis, a ruptured eardrum, and a brain abscess. He also claimed that the prison's refusal to perform cataract surgery on his right eye constituted deliberate indifference. The district court granted summary judgment for all defendants except the prison’s medical contractor, which had filed for bankruptcy.The United States District Court for the Middle District of Alabama found Chapman’s claim against nurse Charlie Waugh time-barred and ruled against Chapman on other claims, including his request for injunctive relief against Commissioner John Hamm, citing sovereign immunity. The court also concluded that Chapman’s claims against other defendants failed on the merits and dismissed his state-law claims without prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court reversed the district court’s determination that Chapman’s claim against Waugh was time-barred, finding that Chapman’s cause of action accrued within the limitations period. The court vacated the district court’s judgment for Waugh and remanded for reconsideration in light of the recent en banc decision in Wade, which clarified the standard for deliberate indifference claims. The court also vacated the judgment for Hamm on Chapman’s cataract-related claim for injunctive relief, as sovereign immunity does not bar such claims. Additionally, the court vacated the summary judgment for all other defendants due to procedural errors, including inadequate notice and time for Chapman to respond, and remanded for further consideration. View "Chapman v. Dunn" on Justia Law

The plaintiff, Richard Paiva, an inmate at the Adult Correctional Institutions (ACI), filed a suit against Lynne Corry, the warden of the maximum-security facility, in Providence County Superior Court. Paiva sought a declaratory judgment and either a writ of mandamus or an injunction based on a Department of Corrections (DOC) policy that mandates a daily minimum out-of-cell time of 8.5 hours for general population inmates, barring exigent circumstances. Paiva argued that this policy was a legislative rule with the force of law and sought declarations to that effect, along with enforcement of the policy.The defendant filed a motion to dismiss under Rule 12(b)(6) of the Superior Court Rules of Civil Procedure, arguing that DOC policies do not create a private cause of action and that prison officials have discretion in matters affecting facility security. The defendant also contended that the DOC director, an indispensable party, was not named in the complaint. The Superior Court granted the motion to dismiss, leading to Paiva's appeal.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court noted procedural issues, including the absence of transcripts from the lower court proceedings, which hindered appellate review. More critically, the Court found that Paiva's failure to join the DOC director as a defendant was fatal to his request for declaratory relief, as the director's interests would be affected by such a declaration. Additionally, the Court held that a writ of mandamus was inappropriate because the DOC policies involved discretionary functions, not ministerial duties. Thus, the judgment in favor of the defendant was affirmed. View "Paiva v. Corry" on Justia Law

Mark L. Sadler, a former employee of the United States Army, was suspended and then removed from his position for insubordination. Sadler claimed that these actions were retaliatory under the Whistleblower Protection Act and sought corrective action from the Merit Systems Protection Board (Board). He also requested sanctions against the government for the destruction of evidence. The Board denied both his motion for sanctions and his request for corrective action.The Merit Systems Protection Board initially dismissed Sadler’s first complaint, finding it did not sufficiently allege protected activity. For his second complaint, the Board acknowledged that Sadler engaged in protected whistleblower activity but concluded that the Army had shown by clear and convincing evidence that it would have taken the same actions regardless of the protected activity. The Board also denied Sadler’s motion for sanctions, finding that the destruction of evidence was part of the Army’s ordinary procedures and did not warrant sanctions.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the Board’s decision. The court agreed that Sadler’s first complaint did not allege protected activity and that the Army had provided clear and convincing evidence that it would have taken the same actions absent the whistleblowing. The court also upheld the Board’s decision on the sanctions issue, agreeing that the destruction of evidence was part of routine procedures and did not meet the intent standard required for sanctions under Rule 37(e) of the Federal Rules of Civil Procedure. View "SADLER v. ARMY " on Justia Law

Louisville/Jefferson County Metro Government (LJCMG) entered into a contract with Omni Louisville, LLC (Omni) in 2014, which included the demolition of Liberty Hall. In 2019, the Metro Council directed the Historic Landmarks and Preservation Districts Commission to review Liberty Hall for landmark status. Despite the Commission's vote to designate Liberty Hall as a landmark, the Metro Council overturned this decision in 2021, citing various reasons including the building's association with racism and lack of architectural significance.The Louisville Historical League, Inc. (LHL) sought review in the Jefferson Circuit Court, which found that the Metro Council had violated procedural due process, concluding that the decision was predetermined due to the 2014 contract with Omni. The court held that the hearing was a pretext and that the decision was tainted by blatant favoritism and conflict of interest.The Kentucky Court of Appeals addressed the issue of jurisdiction, concluding that LHL failed to allege particularized injury or aggrievement, thus depriving the circuit court of subject matter jurisdiction. The Court of Appeals held that strict compliance with statutory requirements was necessary for jurisdiction.The Supreme Court of Kentucky reversed the Court of Appeals, clarifying that the requirement to plead particularized injury or aggrievement pertains to particular-case jurisdiction, not subject matter jurisdiction. The Court held that the judiciary has inherent constitutional authority to review administrative decisions for arbitrariness, and compliance with statutory requirements affects particular-case jurisdiction. The Court also reversed the Jefferson Circuit Court's conclusion of procedural due process violations, affirming the Metro Council's decision to overturn the landmark designation of Liberty Hall. View "Louisville Historical League, Inc. v. Louisville/Jefferson County Metro Government" on Justia Law

A man on probation was subject to a domestic violence protective order (DVPO) requiring him to give a day's notice to security personnel before visiting the medical center where his former girlfriend worked. The woman alleged that the man violated this notice provision multiple times over three years, causing her severe emotional distress and job loss. The probation officer investigated the alleged violations but decided not to revoke the man's probation or penalize him.The Superior Court of Alaska, Third Judicial District, Anchorage, granted summary judgment for the State, finding no genuine issues of material fact, that the probation officer fulfilled her duty of reasonable care, and that her actions were shielded by discretionary function immunity. The woman appealed the decision.The Supreme Court of the State of Alaska reviewed the case and concluded that there was no genuine issue of material fact to preclude summary judgment for the State regarding whether the probation officer fulfilled her operational duty to investigate the alleged violations. The court further concluded that the probation officer's subsequent decisions were shielded from suit by discretionary function immunity. The Supreme Court affirmed the superior court's grant of summary judgment. View "Smith v. Department of Corrections" on Justia Law

Linda Lee owned a motel in Pascagoula, Mississippi, which had deteriorated significantly and was being used improperly, attracting vagrants and drug users. The city council ordered the demolition of the motel after a hearing, citing it as a menace to public health and safety. Lee did not attend the hearing, but her son did. The city council decided the motel was beyond repair and ordered its demolition.Lee appealed the city council's decision to the Jackson County Circuit Court, arguing that the city failed to provide substantial evidence and did not comply with statutory notice provisions. The Circuit Court affirmed the city's decision. Lee then appealed to the Court of Appeals, which found that the city’s notice was insufficient and reversed and remanded the case for further determination.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the appeal was moot because the motel had already been demolished by a new owner, as admitted by Lee in her appellate filings. Additionally, Lee lacked standing to pursue the appeal because she had transferred the property to her son on the day of the city council meeting and no longer had any interest in it. Consequently, the Supreme Court of Mississippi vacated the Court of Appeals' decision and dismissed Lee's appeal. View "Lee v. The City of Pascagoula, Mississippi" on Justia Law