Justia Civil Procedure Opinion Summaries

In this matter, a member of the University of Alabama’s men’s basketball team, Kai Spears, brought suit against The New York Times Company after it published articles erroneously identifying him as the unidentified passenger in a car at the scene of a high-profile shooting. The Times based its reporting on information from two confidential sources. Spears, who was not in the car, alleges that The Times failed to use reasonable care in publishing false and damaging statements about him. During litigation in the United States District Court for the Northern District of Alabama, Spears sought discovery to uncover the identities of the sources and related information. The Times resisted, invoking Alabama’s “shield statute,” which protects journalists from being compelled to reveal confidential sources.The United States District Court for the Northern District of Alabama certified two questions to the Supreme Court of Alabama concerning the scope of the state’s shield statute. The first question asked whether the statute protects the identity of a source when information is published online. However, as Spears conceded that the print publication of the article triggered the statute’s application, the Supreme Court of Alabama declined to answer this question, finding it irrelevant to the case.The Supreme Court of Alabama addressed the second certified question, which asked whether the shield statute protects any and all information that could reasonably lead to the identification of a protected source. The Court held that Alabama’s shield statute does not extend so broadly. Instead, it protects only information that would inevitably reveal the identity of a confidential source. Thus, information that could merely “reasonably lead” to the identification of a source is not covered. The Court declined to expand the statute’s protections beyond its plain language and expressly limited the privilege to “source-identifying” information whose disclosure would make identifying the source unavoidable. View "The New York Times Company v. Spears" on Justia Law

The plaintiffs, three organizations representing millions of Americans, challenged the Social Security Administration’s (SSA) decision to grant personnel from the newly created U.S. DOGE Service access to non-anonymized, highly sensitive personal information held by the SSA. This access was authorized following an executive order charging DOGE with improving government technology. Career officials at the SSA resigned in protest, and a new acting administrator approved DOGE’s access. The plaintiffs argued that merely providing this access, regardless of actual misuse or disclosure, was itself unlawful and an intrusion upon the privacy of their members.The United States District Court for the District of Maryland conducted extensive hearings and granted a preliminary injunction blocking DOGE’s access to the data. The Supreme Court subsequently stayed this injunction, pending appellate and possible further Supreme Court review. The case came before the United States Court of Appeals for the Fourth Circuit, which had jurisdiction pursuant to 28 U.S.C. § 1292(a)(1).The United States Court of Appeals for the Fourth Circuit held that the plaintiffs had Article III standing, as the unauthorized access to their sensitive information closely resembled the common law tort of intrusion upon seclusion. However, the Fourth Circuit vacated the preliminary injunction, holding that the plaintiffs had not established that they were likely to suffer irreparable harm in the absence of preliminary relief, as required by the second factor of the Winter test for preliminary injunctions. The court reasoned that monetary damages and reparative permanent injunctions were potentially available remedies, and the record did not show that new or additional irreparable harm would occur during the litigation. The case was remanded to the district court for further proceedings. The main holding is that the preliminary injunction was vacated because the plaintiffs did not show likely irreparable harm. View "American Federation of State, County and Municipal v. Social Security Administration" on Justia Law

An Irish company leased two airplanes to an Indian airline under agreements designating English courts as the forum for resolving disputes. After the airline failed to keep up with lease payments, the lessor sued in England and secured a monetary judgment. Seeking to enforce that judgment in Washington, the lessor filed a recognition action in King County Superior Court, claiming the airline had interests in personal property within the state but did not identify specific assets.The airline challenged the action in King County Superior Court, arguing that the court lacked personal jurisdiction because it had no contacts, assets, or business in Washington. The superior court denied the airline’s motion to dismiss, holding that jurisdiction was not required to recognize a foreign-country judgment under Washington’s Uniform Foreign-Country Money Judgments Recognition Act. The court ultimately entered summary judgment recognizing the English judgment and ordering payment. The Court of Appeals affirmed, concluding that neither statute nor constitutional law required the creditor to show personal jurisdiction or a property nexus for recognition of such a judgment.The Supreme Court of the State of Washington granted review and reversed the lower courts. The court held that, under chapter 6.40A RCW, a judgment creditor must establish either general or specific jurisdiction over the debtor or, in the absence of such jurisdiction, demonstrate that the debtor has property within Washington before a foreign-country money judgment may be recognized. The court found that recognition actions under the Act are not purely ministerial and require adjudicative jurisdiction. The Supreme Court remanded the case for further proceedings to determine whether the debtor has property in Washington sufficient to support jurisdiction. View "Alterna Aircraft V B Ltd. v. SpiceJet Ltd." on Justia Law

A former mortgage underwriter sued her employer under the False Claims Act, alleging that the company submitted false certifications in a federal mortgage insurance program. The government declined to intervene and unsuccessfully moved to dismiss the case. After years of litigation, the parties reached a settlement: the employer agreed to pay $38.5 million, with a portion going to the plaintiff and the remainder to the United States Treasury. The settlement specifically excluded the plaintiff’s claims for attorneys’ fees, expenses, and costs, leaving them unresolved.The United States District Court for the Northern District of California approved the settlement in January 2023, dismissing the substantive claims but expressly keeping the attorneys’ fees issue pending. Months of disputes ensued over the amount of attorneys’ fees. In May 2024, the district court awarded the plaintiff over $8.5 million in attorneys’ fees and approximately $89,000 in expenses. The plaintiff argued that postjudgment interest on these amounts should accrue from the date of the settlement approval, since her entitlement to fees was established then. The district court disagreed, holding that interest should only begin to accrue from the date the fees were actually awarded.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that postjudgment interest under 28 U.S.C. § 1961(a) accrues only from the entry of a “money judgment,” which requires both identification of the parties and a definite, ascertainable amount owed. Because the district court’s earlier order approving the settlement did not specify the amount of attorneys’ fees, it was not a “money judgment.” Therefore, interest begins accruing only from the order that set the fee amount. The Ninth Circuit affirmed the district court’s decision. View "THROWER V. ACADEMY MORTGAGE CORPORATION" on Justia Law

A private individual brought a qui tam action under the California False Claims Act (CFCA) against two construction-related entities, alleging they submitted false claims to local government agencies in connection with airport construction projects. The plaintiff followed the statutory procedure by filing the complaint under seal in the Superior Court of Los Angeles County and mailing a copy to the Attorney General, as required by the CFCA. The complaint involved local (political subdivision) funds. The Attorney General, however, did not forward the complaint to the relevant local authorities and took no steps to intervene or extend the seal. After the 60-day sealing period expired without government action, the plaintiff served the defendants.The Superior Court of Los Angeles County sustained the defendants’ demurrer without leave to amend, holding that the plaintiff failed to comply with the CFCA’s sealing and service requirements. The trial court concluded the complaint should have remained under seal until the government notified the court of its decision to intervene, and that the plaintiff’s actions in unsealing and serving the complaint were premature. The court entered judgment dismissing the action with prejudice.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. It held that a qui tam plaintiff is not required to allege compliance with the CFCA’s sealing and service requirements to state a cause of action, nor does failure to comply automatically require dismissal. The court further held that the statutory scheme creates a default 60-day seal period, which lifts automatically unless the government requests an extension. Because the plaintiff filed the complaint under seal, served the Attorney General, and waited until after the seal lifted to serve the defendants, the plaintiff complied with the statute. The judgment was reversed and the case remanded with directions to overrule the demurrer. View "Albarghouti v. LA Gateway Partners, LLC" on Justia Law

This case concerns requests made by two media organizations to the Colorado Department of Human Services (CDHS) for information about the number of child abuse or neglect reports made from three state-funded residential child care facilities (RCCFs) over a three-year period, and how many were screened for investigation. CDHS denied the requests, asserting that providing the facility-specific numbers would violate the confidentiality provisions of the Colorado Children's Code Records and Information Act, specifically section 19-1-307(1)(a), which protects the name, address, and other identifying information of any child, family, or informant in such reports. The media organizations declined CDHS's offer to provide aggregate numbers for all three facilities combined and sued for disclosure of the per-facility data under the Colorado Open Records Act (CORA).The Denver District Court agreed with CDHS, holding that subsection (1)(a) barred disclosure of the requested information, as it would necessarily identify the addresses involved in the reports. On appeal, a divided panel of the Colorado Court of Appeals found the statute ambiguous and, after considering legislative history and potential constitutional issues, determined that only information that constitutes "identifying information" is protected. The appellate court remanded the case to the district court to determine if the requested disclosures would reveal identifying information.On review, the Supreme Court of Colorado held that section 19-1-307(1)(a) is unambiguous and extends confidentiality to all names and addresses of children, families, or informants in reports of child abuse or neglect, as well as any other identifying information. However, the court found that CDHS failed to demonstrate that disclosing the requested six numbers would reveal protected information, as the RCCFs' addresses are already public. The Supreme Court reversed the judgment of the Court of Appeals and ordered disclosure of the six numbers. View "Brubaker v. Colo. Sun & Tegna" on Justia Law

Several married couples, with one spouse in each couple serving on active military duty, purchased educational materials from a business operating on military bases. The seller, George LeMay, through his company, brought lawsuits against these couples after they stopped payment, ultimately securing state-court judgments against each couple. Some judgments were later overturned, but LeMay sought to enforce the remaining judgments in Maryland using its Uniform Enforcement of Foreign Judgments Act. The judgments were domesticated by Maryland state-court clerks without the procedural protections required by the Servicemembers Civil Relief Act (SCRA), such as affidavits regarding military status or appointment of counsel. The clerks also issued writs of garnishment, leading to the plaintiffs’ bank accounts being frozen. Plaintiffs eventually succeeded in vacating the judgments, but not before suffering financial harm.The plaintiffs filed suit in the United States District Court for the District of Maryland against LeMay (later dismissed after settlement), the Governor of Maryland, and the Justices of the Supreme Court of Maryland, all in their official capacities. The district court found that the act of domesticating a judgment did not trigger the SCRA’s protections, but that issuing writs of garnishment did. It ruled that plaintiffs lacked standing to seek injunctive or declaratory relief but allowed their damages claims against the Justices to proceed, reasoning their supervisory role was sufficiently linked to the injuries. However, the district court ultimately granted summary judgment for the defendants, relying on legislative immunity.The United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment, holding that the plaintiffs lacked Article III standing because their injuries were not fairly traceable to acts or omissions by the Governor or the Justices. The court concluded the plaintiffs failed to show any defendant’s action caused the injuries, and it remanded with instructions to dismiss the case without prejudice for lack of subject matter jurisdiction. View "Rouse v. Fader" on Justia Law

A California-based company that produces lab-grown chicken sought to distribute and sell its product in Florida. After the company received federal approval from the USDA and FDA to market its lab-grown chicken, Florida enacted SB 1084, a law banning the manufacture, sale, and distribution of all lab-grown meat within the state. The company had previously held tasting events and developed business relationships in Florida but had no plans to manufacture its product there.Following the enactment of SB 1084, the company filed suit in the U.S. District Court for the Northern District of Florida against state officials, seeking declaratory and injunctive relief. The company argued that the federal Poultry Products Inspection Act (PPIA) preempted Florida’s ban, claiming the state’s law imposed “additional or different” ingredient or facilities requirements in violation of the PPIA. The district court denied the company’s motion for a preliminary injunction, finding the company unlikely to succeed on its preemption claims because SB 1084 did not regulate the company’s ingredients, premises, facilities, or operations. The court also addressed standing and procedural questions, ultimately dismissing the preemption claims after the company amended its complaint.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed whether the filing of an amended complaint or the district court’s dismissal order rendered the appeal moot and whether the company could challenge the Florida law as preempted. The Eleventh Circuit held the appeal was not moot and that the company could bring a preemption action in equity. However, the court concluded the company was unlikely to succeed on the merits. The court held that Florida’s ban did not impose ingredient or facilities requirements preempted by the PPIA, as it simply banned the product’s sale and manufacture. Therefore, the district court’s denial of a preliminary injunction was affirmed. View "Upside Foods Inc v. Commissioner, Florida Department of Agriculture" on Justia Law

Three nonprofit organizations filed a nationwide class action against the United States, alleging that the federal judiciary overcharged the public for access to court records through the PACER system. They claimed the government used PACER fees not only to fund the system itself but also for unrelated expenses, contrary to the statutory limits set by the E-Government Act. The plaintiffs sought refunds for allegedly excessive fees collected between 2010 and 2018.The United States District Court for the District of Columbia oversaw extensive litigation, including class certification and an interlocutory appeal. The United States Court of Appeals for the Federal Circuit previously affirmed that the district court had subject matter jurisdiction under the Little Tucker Act and that the government had used PACER fees for unauthorized expenses. After remand, the parties reached a settlement totaling $125 million. The district court approved the settlement, finding it fair, reasonable, and adequate under Rule 23 of the Federal Rules of Civil Procedure. The court also approved attorneys’ fees, administrative costs, and incentive awards to the class representatives. An objector, Eric Isaacson, challenged the district court’s jurisdiction, the fairness of the settlement, the attorneys’ fees, and the incentive awards.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the district court’s judgment. The court held that the district court properly exercised jurisdiction under the Little Tucker Act because each PACER transaction constituted a separate claim, none exceeding the $10,000 jurisdictional limit. The appellate court found no abuse of discretion in approving the class settlement, the attorneys’ fees, or the incentive awards. The court also held that incentive awards are not categorically prohibited and are permissible if reasonable, joining the majority of federal circuits on this issue. The district court’s judgment was affirmed. View "NVLSP v. US " on Justia Law

A group of individuals who were victims of a Ponzi scheme obtained a default judgment for fraud against two corporations involved in the scheme. Unable to collect on this judgment, they each applied to the California Secretary of State for restitution from the Victims of Corporate Fraud Compensation Fund, which compensates victims when a corporation’s fraud leads to uncollectible judgments. The Secretary denied their claims, arguing primarily that the underlying fraud lawsuit had been filed after the statute of limitations had expired, making the judgment invalid for purposes of fund payment.The victims challenged the Secretary’s denial by filing a verified petition in the Superior Court of Orange County, seeking an order compelling payment from the fund. The Secretary maintained that the statute of limitations barred the underlying fraud claim, but the trial court disagreed. The court held that because the defendant corporations had defaulted and thus waived the statute of limitations defense in the original lawsuit, the Secretary could not raise that defense in the current proceeding. The trial court ordered payment from the fund to the victims in the amounts awarded in the underlying default judgment.On appeal, the California Court of Appeal, Fourth Appellate District, Division Three, affirmed in part and reversed in part. The appellate court clarified that under the statutory scheme, neither the Secretary nor the trial court may relitigate the merits of the underlying fraud claim, including whether it was time-barred. The court held that the trial court’s inquiry is limited to whether the claimant submitted a valid payment claim under the specific statutory requirements; it cannot revisit defenses such as the statute of limitations. However, the court found error in the trial court’s failure to cap payments at $50,000 per claimant as required by statute, and remanded the case for correction of this aspect of the order. View "Dion v. Weber" on Justia Law