Justia Civil Procedure Opinion Summaries

Accuracy in Media (AIM) filed a Freedom of Information Act (FOIA) request with the Central Intelligence Agency (CIA) seeking records about American service members who were prisoners of war (POWs) or missing in action (MIA) from the Vietnam War and potentially still alive in Laos or Vietnam. The CIA conducted a search using specific terms but did not find any responsive records. AIM challenged the adequacy of the CIA's search, arguing that the search terms were insufficient.The United States District Court for the District of Columbia granted summary judgment in favor of the CIA, concluding that the search terms used by the CIA were reasonably likely to yield the requested records if they existed. The court also noted that the plaintiffs' evidence did not significantly suggest that the requested files were in the CIA's current operational files.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and found that the CIA's search terms were inadequate. The court noted that the search terms omitted key terms such as "Laos," "live sighting," "imagery," "reconnaissance," and "rescue," which were relevant to the FOIA request. The court also found that the CIA did not adequately explain why certain terms were used and others were omitted. The court held that the CIA failed to show beyond material doubt that its search was reasonably calculated to uncover all relevant documents.The Court of Appeals reversed the district court's grant of summary judgment to the CIA and remanded the case for further proceedings consistent with its opinion, requiring the CIA to either conduct a new search or provide a supplemental affidavit with adequate search terms and explanations. View "Hall v. CIA" on Justia Law

In December 2021, Officer Shelton Davis of the Montgomery Police Department, while pursuing a fleeing suspect, collided with Madilyn Shuford's vehicle at an intersection in Montgomery. Officer Davis was responding to a woman's plea for help, who claimed a man was trying to kill her. The suspect, Eugene Osborne Jr., fled in a vehicle, prompting Officer Davis to pursue him with activated lights and sirens. During the pursuit, Officer Davis slowed down at a red light but collided with Shuford's vehicle when she pulled into the intersection.Shuford sued the City of Montgomery and Officer Davis, alleging negligence and wanton conduct, and claimed the City was vicariously liable. The City and Officer Davis moved for summary judgment, asserting immunity under § 6-5-338, Ala. Code 1975, and Ex parte Cranman. They provided evidence, including Officer Davis's affidavit and body camera footage, showing he was performing his duties with activated lights and sirens. Shuford opposed, arguing Officer Davis did not use proper signals and took unreasonable risks.The Montgomery Circuit Court denied the summary judgment motion without explanation. The City and Officer Davis petitioned the Supreme Court of Alabama for a writ of mandamus to vacate the denial and grant summary judgment based on immunity.The Supreme Court of Alabama granted the petition, holding that Officer Davis was entitled to immunity as he was performing his law enforcement duties and exercising judgment. The court found no substantial evidence from Shuford to refute this. Consequently, the City was also entitled to immunity. The trial court was directed to enter summary judgment in favor of the City and Officer Davis. View "Shuford v. City of Montgomery" on Justia Law

Tom and Becky Carlson filed a contested case against the Texas Comptroller under the Private Real Property Rights Preservation Act (PRPRPA), alleging that the Comptroller’s approval of a wind turbine project resulted in a taking of their property. The case was referred to the State Office of Administrative Hearings (SOAH), where the Administrative Law Judge (ALJ) dismissed it as untimely filed, stating that neither the Comptroller nor SOAH had jurisdiction. The Carlsons sought clarification from SOAH, which indicated that the case would return to the Comptroller for a final decision. However, the Comptroller later asserted that the ALJ’s order was final and appealable, leading to the Carlsons' mandamus petition.The Carlsons filed a mandamus petition directly in the Supreme Court of Texas, seeking to compel the Comptroller to issue a final order so they could appeal to district court. The State initially defended the Comptroller’s position that the ALJ’s order was final. However, after the Supreme Court requested clarification on the State’s unified position, the Comptroller issued a final decision, rendering the Carlsons' petition moot.The Supreme Court of Texas held that the Comptroller’s issuance of a final decision extinguished the dispute, making the mandamus petition moot. The Court dismissed the petition for lack of jurisdiction, as there was no longer a justiciable controversy between the parties. The Carlsons agreed with this outcome, as they would now receive the judicial review they sought. View "IN RE CARLSON" on Justia Law

In May 2023, Officers Jacob Ondich and Mathew Lougee of the Casper Police Department arrested Daniel Charles Hemmer at his home and transported him to the Natrona County Detention Center (NCDC). Hemmer was charged with felony theft and entered a no-contest plea in December 2023. Subsequently, Hemmer filed a civil suit against the officers, the Casper Police Department, and NCDC, alleging unlawful entry, arrest without probable cause or a warrant, and a strip search at NCDC. He claimed the officers' actions constituted kidnapping and sought $12 million in damages.The Natrona County District Court dismissed Hemmer's complaint. The court found that Hemmer did not allege facts showing NCDC's involvement in his arrest or provide legal authority for his claims against the detention center. The court also dismissed the claims against the Casper Police Department due to a lack of specific allegations. The kidnapping claim against the officers was dismissed because Hemmer did not support it with legal authority. Additionally, the court concluded that Hemmer failed to submit a timely notice of claim under the Wyoming Governmental Claims Act.The Wyoming Supreme Court reviewed the case and summarily affirmed the district court's dismissal. The court noted that Hemmer's pro se brief did not comply with appellate rules, lacked a statement of issues, and failed to present cogent arguments supported by legal authority. The court emphasized that while pro se litigants are given some leniency, they must still reasonably comply with procedural rules. Consequently, the Supreme Court affirmed the lower court's decision to dismiss Hemmer's complaint. View "Hemmer v. City of Casper Police Department" on Justia Law

Fahmi Ahmed Moharam, a dual United States-Yemeni citizen, frequently travels between the two countries. In 2017, he was denied boarding a flight from Saudi Arabia to the U.S. and learned through the Transportation Security Administration (TSA) redress process that he was on the No Fly List. The government provided minimal information, citing national security concerns, and stated that his designation was based on his activities in Yemen from 2011 to 2017. After petitioning for review, the government informed him that he was no longer on the No Fly List and would not be relisted based on the currently available information.The TSA is mandated by statute to identify individuals who may pose a threat to civil aviation or national security and prevent them from boarding aircraft. The TSA also manages the Department of Homeland Security (DHS) Traveler Redress Inquiry Program (TRIP), which allows individuals to appeal their inclusion on the No Fly List. Moharam appealed through TRIP and was initially informed that he was on the list due to concerns about his activities in Yemen. Despite his requests for more information and administrative review, the TSA maintained his status on the list until the government later removed him.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that Moharam's removal from the No Fly List rendered his petitions for review moot, as the court could no longer provide effective relief. The court noted that the government’s assurance that Moharam would not be relisted based on the same information addressed the issue of potential recurrence. Consequently, the court dismissed the petitions for lack of jurisdiction, as the relief sought was no longer redressable. View "Moharam v. TSA" on Justia Law

Jaime Vargas and Francis R. Alvarez, former employees of medical supplier Lincare, Inc., and its subsidiary Optigen, Inc., filed a qui tam complaint under the False Claims Act (FCA). They alleged that Optigen engaged in fraudulent practices, including systematic upcoding of durable medical equipment, improper kickback arrangements, waiver of co-pays, and shipment of unordered supplies. The relators claimed that Optigen billed CPAP batteries and accessories under codes designated for ventilator accessories, waived patient co-pays without assessing financial hardship, shipped CPAP supplies automatically without patient requests, and paid kickbacks to healthcare providers for referrals.The case was initially filed in the Eastern District of Virginia and later transferred to the Middle District of Florida. The United States declined to intervene, and the District Court unsealed the complaint. The relators filed multiple amended complaints, each of which was dismissed by the District Court for failing to meet the heightened pleading standard of Federal Rule of Civil Procedure 9(b). The District Court dismissed the fourth amended complaint, holding that it still failed to plead sufficient facts with the requisite specificity.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the District Court's dismissal of the relators' claims regarding improper kickback arrangements, waiver of co-pays, and automatic shipment of supplies, finding that these allegations lacked the necessary specificity and failed to identify any actual false claims submitted to the government. However, the court reversed the dismissal of the upcoding claim, holding that the relators had pleaded sufficient facts with particularity to withstand a motion to dismiss. The court remanded the case for further proceedings limited to the upcoding issue. View "Vargas v. Lincare, Inc." on Justia Law

An inmate at the Hancock County Jail, Monica J. Johnson, died by suicide after being incarcerated from September 21 to September 29, 2018. Her estate and surviving spouse filed a medical malpractice notice of claim against Hancock County and several county officials and employees, alleging negligence in her care. The County and its employees, along with Jail Housing Officer Kayla Dumond, appealed the Superior Court's denial of their motions for summary judgment.The Superior Court (Penobscot County) denied the motions for summary judgment, determining that it lacked jurisdiction to decide whether the Maine Health Security Act (MHSA) applied to the defendants and that the defendants had not demonstrated immunity under the Maine Tort Claims Act (MTCA). The Maine Supreme Judicial Court reviewed the interlocutory appeal.The court concluded that the issue of whether the defendants are "health care providers" under the MHSA is not immediately appealable. Additionally, the court decided to defer to the federal court on the issue of immunity under the MTCA, as the federal court is handling a related case involving the same parties and facts. Consequently, the appeal was dismissed, allowing the MHSA screening process to proceed, with the understanding that the federal court will continue with the litigation once the screening process is completed. View "Carney v. Hancock County" on Justia Law

Steven Gomes filed a lawsuit to invalidate ordinances regulating groundwater use in Mendocino, adopted by the Mendocino City Community Services District (the district). The district argued that Gomes’s claims were barred by res judicata due to a prior case, Gomes v. Mendocino City Community Services Dist. (2019) (Gomes I), which challenged the district’s groundwater management program. The trial court found the ordinances contained an invalid attorney’s fee provision but rejected Gomes’s other claims.In Gomes I, the trial court denied Gomes’s petition challenging the district’s 2007 groundwater measures, but the judgment was reversed on appeal. The appellate court found the district had authority to limit groundwater extraction and that the 2007 measures were invalid due to non-compliance with statutory procedures. The district subsequently adopted new ordinances in 2020, which Gomes challenged in the present case.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. Gomes argued the ordinances imposed fees for groundwater extraction that required voter approval, which the district did not obtain. The court concluded that the claim was not barred by Gomes I, as it involved different ordinances and provisions. The court held that the fees imposed by the district were not for the extraction of groundwater and thus did not require voter approval under section 10710. The judgment was affirmed, except for the invalid attorney’s fee provision. View "Gomes v. Mendocino City Community Services Dist." on Justia Law

Jeremy Kennedy filed a petition to proceed in forma pauperis (IFP) to seek a declaratory judgment and writ of mandamus regarding a decision by the Arkansas Post-Prison Transfer Board (Board). The Board had denied his request for transfer to the Arkansas Division of Community Correction (DCC) and his subsequent request for a six-month reconsideration hearing. Kennedy argued that he was eligible for transfer under Arkansas law and that the Board acted outside its statutory authority by denying his transfer eligibility.The Izard County Circuit Court denied Kennedy’s IFP petition, finding that his claim was a duplicate of a previous lawsuit (case number 33CV-23-123) that was on appeal and another case (33CV-23-57) that he had voluntarily dismissed. The circuit court concluded that Kennedy’s petition did not state a colorable cause of action.The Supreme Court of Arkansas reviewed the case and affirmed the circuit court’s decision. The court held that the circuit court did not abuse its discretion in denying Kennedy’s IFP petition. The Supreme Court found that Kennedy’s latest filing did not present a legitimate claim that could be reasonably asserted based on the facts and current law. Therefore, the denial of Kennedy’s IFP petition was upheld. View "Kennedy v. Felts" on Justia Law

The United States District Court for the District of Massachusetts issued a temporary restraining order (TRO) on March 10, 2025, preventing the Government from terminating various education-related grants. The order also required the Government to pay past-due grant obligations and continue paying future obligations. The District Court concluded that the respondents were likely to succeed on the merits of their claims under the Administrative Procedure Act (APA).The Government filed an application to vacate the District Court's order on March 26, 2025, which was extended on March 24, 2025. The application was presented to Justice Jackson and referred to the Supreme Court. The Supreme Court noted that the District Court's order had characteristics of a preliminary injunction, making it appealable. The Government argued that the District Court lacked jurisdiction to order the payment of money under the APA, as the APA's waiver of sovereign immunity does not apply to claims seeking money damages or to orders enforcing contractual obligations to pay money.The Supreme Court of the United States granted the Government's application to stay the District Court's order pending the appeal in the United States Court of Appeals for the First Circuit and any subsequent petition for a writ of certiorari. The Court found that the respondents had not refuted the Government's claim that it would be unlikely to recover the grant funds once disbursed and that respondents would not suffer irreparable harm while the TRO is stayed. The stay will terminate automatically if certiorari is denied or upon the sending down of the judgment of the Supreme Court if certiorari is granted. The Chief Justice would have denied the application. View "Department of Education v. California" on Justia Law