Justia Civil Procedure Opinion Summaries

Jordan Watkins, while in federal custody, underwent hernia repair surgery and subsequently experienced severe pain and swelling in his groin. Medical staff at the correctional facility dismissed his symptoms as routine side effects and refused to schedule a follow-up appointment before his transfer to another facility. Watkins filed Bivens claims against the medical and correctional staff for deliberate indifference to his serious medical needs and a Federal Tort Claims Act (FTCA) claim against the United States for negligent medical treatment.The United States District Court for the Northern District of Illinois dismissed all of Watkins' claims under Rule 12(b)(6). The court held that the Supreme Court's framework for evaluating Bivens claims barred Watkins' claims and that his FTCA claim was filed too late.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Watkins' Bivens claims could proceed under the precedent set by Carlson v. Green, which allows federal prisoners to sue for damages resulting from deliberate indifference to their serious medical needs. The court found that Watkins' claims fit within the context recognized by Carlson and were not meaningfully different. The court also held that the district court's dismissal of Watkins' FTCA claim was premature. Watkins may be able to establish the requirements for equitable tolling due to extraordinary circumstances, such as disruptions caused by COVID-19, which prevented him from filing his suit on time. The Seventh Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Watkins v. Mohan" on Justia Law

In this case, the families of Michael Jackson, Carl Wiley, Jr., and Rashad Henderson, who were killed during high-speed police chases in Houston, Texas, sued the City of Houston. They alleged that the Houston Police Department (HPD) has a policy of racial profiling that leads to more high-speed chases in predominantly black neighborhoods, resulting in the deaths of their loved ones. The plaintiffs brought several federal municipal liability claims, including violations of equal protection, Title VI, 42 U.S.C. § 1982, and substantive due process, as well as state tort claims.The United States District Court for the Southern District of Texas granted in part and denied in part Houston's motions to dismiss for lack of subject matter jurisdiction and for judgment on the pleadings. The court dismissed all claims except the equal protection claims and Jackson’s state law claims. Houston then filed an interlocutory appeal, raising issues regarding standing, failure to state federal claims, capacity to sue, and governmental immunity for Jackson’s state law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it lacked jurisdiction to review non-final district court orders except under 28 U.S.C. § 1292(b). The court found that it could only review whether the plaintiffs had standing to assert their equal protection claims. The court held that the plaintiffs lacked standing because their injuries did not stem from unequal treatment based on race. Consequently, the court reversed the district court’s order regarding standing for the equal protection claims and vacated the district court’s decision on governmental immunity for Jackson’s negligence claim, remanding the case for further proceedings. View "Jackson v. City of Houston" on Justia Law

An inmate, Thomas Clark, filed a mandamus action against the Ohio Department of Rehabilitation and Correction (DRC) seeking copies of electronic kites he sent to prison staff while incarcerated at the North Central Correctional Complex (NCCC) and the Lebanon Correctional Institution (LCI). He also requested a copy of the chow-hall menu from LCI. Clark claimed that his requests were not fulfilled and sought $2,000 in statutory damages and court costs.The lower court proceedings involved Clark sending public-records requests to LCI staff. The LCI staff forwarded his request for NCCC kites to the appropriate person at NCCC, but Clark did not receive a response. For the chow-hall menu request, LCI staff directed Clark to obtain the menu from his unit manager, which Clark did not do. Clark then filed this mandamus action.The Supreme Court of Ohio reviewed the case and found that Clark was entitled to a writ of mandamus for his request for the NCCC kites because LCI staff had forwarded his request to NCCC, and NCCC did not respond. The court held that DRC must provide Clark with the requested NCCC kites. However, the court denied the writ for the chow-hall menu request, as LCI staff had properly directed Clark to the appropriate person to obtain the menu. The court awarded Clark $1,000 in statutory damages for the NCCC kites request but denied his request for court costs. The court also denied Clark's motion for leave to file rebuttal evidence. View "State ex rel. Clark v. Department of Rehabilitation and Correction" on Justia Law

The case involves a dispute between Vermont’s Auditor of Accounts and the Attorney General. The Auditor sued the Attorney General, alleging non-compliance with the statutory obligation to provide legal advice. The Auditor sought a declaratory judgment affirming his right to retain counsel to sue the Attorney General and mandamus to compel the Attorney General to answer specific legal questions. The trial court dismissed the Auditor’s claims and denied his request for attorneys’ fees.The dispute arose from the Auditor’s audit of a Burlington tax increment financing (TIF) district. The Auditor encountered a perceived gap in TIF statutes and sought advice from the Attorney General, who answered one question but directed the Auditor to other entities for the remaining questions. The Auditor claimed this was a violation of the Attorney General’s duty under 3 V.S.A. § 159 and threatened to sue. The Attorney General responded, explaining her statutory obligations and asserting that the Auditor lacked authority to sue.The Vermont Supreme Court reviewed the case. It affirmed the trial court’s dismissal of the Auditor’s claims for mandamus and declaratory judgment related to the specific TIF questions, concluding that the Attorney General had provided legal advice as required by 3 V.S.A. § 159. The court also affirmed the dismissal of the broader declaratory judgment claim, finding no live controversy as the Attorney General had provided legal advice and there was no policy of refusing to do so.However, the court reversed the trial court’s dismissal of the Auditor’s claim for declaratory judgment regarding his right to retain counsel and sue for mandamus. The court held that the Auditor has implied statutory authorization to seek mandamus to enforce the Attorney General’s duty under 3 V.S.A. § 159. The court also affirmed the denial of attorneys’ fees, finding Rule 54 inapplicable for the relief sought by the Auditor. View "Office of the Auditor of Accounts v. Office of the Attorney General" on Justia Law

James King sued the United States under the Federal Tort Claims Act (FTCA) and individual government employees under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, alleging physical abuse by U.S. officials. The district court granted summary judgment to the defendants on both claims. King appealed only the Bivens claim, making the FTCA judgment final. The individual defendants argued that the FTCA's "judgment bar" precluded the Bivens claim. The Supreme Court ultimately ruled in favor of the defendants, stating that the FTCA judgment barred the Bivens claim.King then filed a Rule 60(b) motion in the district court to reopen the FTCA judgment to withdraw his FTCA claim and avoid the judgment bar. The district court denied the motion, reasoning that attorney error or strategic miscalculation is not a valid basis for reopening under Rule 60. King appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's denial of the Rule 60(b) motion. The court held that the district court did not abuse its discretion, as attorney error or strategic miscalculation does not justify reopening a final judgment under Rule 60. The court emphasized the public policy favoring the finality of judgments and noted that Rule 60(b)(6) relief is only available in exceptional or extraordinary circumstances, which were not present in this case. View "King v. United States" on Justia Law

The Idaho Legislature established the Community Partner Grant Program in 2021, using funds from the American Rescue Plan Act (ARPA) to address the impact of the COVID-19 pandemic on school-aged children. The funds were to be used exclusively for in-person educational and enrichment activities for children aged 5 to 13. In 2023, the Idaho Attorney General received information suggesting that some grant recipients had misused the funds to serve children under the age of five. Consequently, the Attorney General issued civil investigative demands (CIDs) to 34 grant recipients, requesting documentation related to the grant program. The recipients did not comply and instead sought a preliminary injunction in district court to set aside the CIDs.The District Court of the Fourth Judicial District of Idaho denied the preliminary injunction for 15 grant recipients, requiring them to respond to the CIDs, but granted it for 19 others, concluding that the Attorney General had not shown sufficient reason to believe these recipients had misused the funds. The court also reviewed two declarations in camera and provided redacted versions to the recipients' counsel.The Supreme Court of Idaho reviewed the case and held that both the Idaho Charitable Assets Protection Act (ICAPA) and the Idaho Charitable Solicitation Act (ICSA) applied to the grant funds, giving the Attorney General authority to issue CIDs. The court determined that the "reason to believe" standard, not probable cause, was sufficient for issuing CIDs. The court found that the district court erred in granting the preliminary injunction to the 19 recipients and remanded the case for further proceedings. Additionally, the court held that the CID issued to Elizabeth Oppenheimer was overly broad and violated her First Amendment right to freedom of association, requiring the district court to reconsider this CID. The court declined to award attorney fees to either party. View "Children's Home Society v. Labrador" on Justia Law

Monika McCallion, Brandan McCallion, and Old Bears, LLC (collectively, the McCallions) appealed a judgment affirming the Bar Harbor Board of Appeals' decision to uphold the issuance of a 2023 short-term rental registration to W.A.R.M. Management, LLC. The Town of Bar Harbor requires annual registration of short-term rental properties, classifying them as either VR-1 or VR-2. W.A.R.M. Management, LLC owns two VR-2 properties, one of which is central to this dispute. The property in question is in a district where VR-2s are generally prohibited unless they were registered before December 2, 2021. W.A.R.M. submitted renewal applications and fees for both properties in January 2023, but due to a malfunction in the Town's online portal, one application was lost, and the registration was not renewed by the May 31 deadline. The Town's code enforcement officer (CEO) later issued a registration for the property in October 2023 after determining that W.A.R.M. had timely submitted its renewal application.The McCallions filed an administrative appeal with the Bar Harbor Board of Appeals, arguing that the CEO could not renew the registration after the deadline. The Board upheld the CEO's actions after a de novo hearing. The McCallions then filed a Rule 80B complaint in the Superior Court, which affirmed the Board's decision without addressing the Town's mootness argument. While the case was pending, W.A.R.M. received a 2024 registration for the property, which the McCallions did not contest.The Maine Supreme Judicial Court reviewed the case and determined that the appeal was moot because the 2023 registration had been superseded by the 2024 registration, which was not appealed. The court concluded that even if it ruled in favor of the McCallions regarding the 2023 registration, it would have no practical effect since the 2024 registration was final and not subject to review. The court dismissed the appeal as moot, noting that no exceptions to the mootness doctrine applied in this case. View "McCallion v. Town of Bar Harbor" on Justia Law

Dr. John Doe, a federal public servant with a security clearance, was convicted of two felonies in Ohio in the early 1990s. He received a pardon from the Ohio governor in 2009, and his felony convictions were sealed by an Ohio court. In 2022, Dr. Doe applied for a position at the Federal Deposit Insurance Corporation (FDIC), but his application was denied due to a statutory bar against hiring individuals with felony convictions. Dr. Doe then filed a lawsuit challenging the constitutionality of this hiring prohibition and sought to proceed under a pseudonym to avoid public association with his sealed convictions.The United States District Court for the District of Columbia denied Dr. Doe's motion to proceed under a pseudonym. The court acknowledged Dr. Doe's privacy concerns and the lack of unfairness to the government but concluded that the privacy interest in felony convictions does not warrant pseudonymity. The court emphasized the importance of transparency in judicial proceedings, especially in cases involving constitutional challenges against the government.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court's decision. The appellate court affirmed the lower court's ruling, agreeing that Dr. Doe's privacy interest in his sealed felony convictions was insufficient to overcome the presumption against pseudonymous litigation. The court highlighted the public's significant interest in open judicial proceedings, particularly when the case involves a constitutional challenge to a federal statute. The court found that the district court did not abuse its discretion in applying the relevant factors and denying Dr. Doe's motion to proceed under a pseudonym. View "Doe v. McKernan" on Justia Law

Power Rental Op Co, LLC ("Power Rental") is a Florida-based company providing water and energy services. The Virgin Islands Water and Power Authority ("WAPA") is a municipal corporation in the U.S. Virgin Islands. In 2012, WAPA entered into a rental agreement with General Electric International, which Power Rental later acquired. By 2019, WAPA owed Power Rental over $14 million, which was reduced to approximately $9.3 million through a promissory note governed by New York law. WAPA defaulted on the note in 2020, leading Power Rental to sue in Florida state court for breach of the note and other claims.The case was removed to the Middle District of Florida, which dissolved pre-judgment writs of garnishment issued by the state court, granted partial summary judgment in favor of Power Rental, and ordered WAPA to complete a fact information sheet. The court found that WAPA waived its sovereign immunity defenses under the terms of the note. WAPA's appeal to the Eleventh Circuit was voluntarily dismissed.Power Rental registered the judgment in the U.S. District Court for the District of Puerto Rico, which issued a writ of execution served on WAPA's account at FirstBank in Puerto Rico. WAPA filed an emergency motion to quash the writ, arguing that the funds were exempt under Virgin Islands law and that the Puerto Rico court lacked jurisdiction. The District of Puerto Rico denied the motion, finding that the separate entity rule did not apply and that it had jurisdiction to issue the writ.The United States Court of Appeals for the First Circuit affirmed the District of Puerto Rico's order. The court held that the separate entity rule was outdated and did not apply, allowing the Puerto Rico court to have jurisdiction over the writ. The court also upheld the lower court's finding that WAPA had waived its statutory immunity defenses. View "Power Rental OP CO, LLC v. Virgin Islands Water and Power Authority" on Justia Law

Zayn Al-Abidin Muhammad Husayn, also known as Abu Zubaydah, was captured in Pakistan in March 2002, suspected of being an Al Qaeda leader. He was transferred to a CIA-operated secret prison where he was subjected to "enhanced interrogation techniques" by James Mitchell and John Jessen, psychologists contracted by the CIA. These techniques included waterboarding, sleep deprivation, and confinement in small boxes, which Zubaydah alleges amounted to torture. He was later transferred to Guantanamo Bay, where he remains detained as an enemy combatant.Zubaydah filed a lawsuit under the Alien Tort Statute seeking damages for the injuries he suffered during his detention and interrogations. The United States District Court for the Eastern District of Washington dismissed the case, citing lack of jurisdiction under the Military Commissions Act (MCA) of 2006, which denies federal courts jurisdiction over certain actions relating to the detention and treatment of enemy combatants by the United States and its agents.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's dismissal. The Ninth Circuit held that the MCA deprived the district court of jurisdiction because Zubaydah's claims related to his detention and treatment by the defendants, who were considered agents of the United States. The court found that the CIA had authorized, controlled, and ratified the defendants' actions, thereby establishing an agency relationship. Consequently, the MCA barred the court from hearing Zubaydah's claims. The decision was affirmed. View "HUSAYN V. MITCHELL" on Justia Law