Justia Civil Procedure Opinion Summaries

In this case, a private citizen, Robert Teig, appealed a summary judgment granted to city officials in his lawsuit alleging violations of the Iowa Open Records Act. Teig had requested job applications and other documents related to the City of Cedar Rapids' hiring processes for a new city clerk and city attorney. The City refused many of Teig's requests, citing attorney-client privilege and the Act's confidentiality provisions as reasons for withholding several documents.The district court granted the City's motion for summary judgment, leading to Teig's appeal. He argued that job applications submitted to governmental bodies are not confidential under chapter 22, municipalities cannot claim attorney-client privilege in the context of an open records request, search and retrieval fees are not authorized by chapter 22, the defendants unreasonably delayed fulfilling certain requests, and the district court should have granted him leave to submit additional interrogatories in the ensuing litigation.The Supreme Court of Iowa affirmed in part and reversed in part the district court's decision. The court held that documents subject to attorney-client privilege are protected from disclosure under chapter 22 and that chapter 22 authorizes municipalities or governmental bodies to charge search and retrieval fees. However, the court found that while job applications are generally protected from disclosure, that protection extends only to persons "outside of government." Therefore, the City was obligated to disclose those applications submitted by current employees of the City, although it properly withheld external applications. The court also found that the district court failed to address Teig’s claims of undue delay related to billing records. The case was remanded for further proceedings. View "Teig v. Chavez" on Justia Law

The case involves two petitioners, Daniel Dilly, Superintendent of the Rubenstein Juvenile Center (RJC), and Nancy Oldaker, Health Services Administrator at RJC, who were held in contempt of court by Judge Kurt Hall of the Circuit Court of Lewis County, West Virginia. The contempt charges arose from an incident involving a resident of RJC, identified as D.P., who suffered a broken jaw during a fight with other residents. The court had ordered that D.P. be taken off RJC grounds for an X-ray and that his mother be notified of his medical appointments. The court found that these orders were not adequately followed by the petitioners.The Circuit Court of Lewis County held a hearing to review D.P.'s placement and medical care, resulting in a "Medical Care Order" that directed RJC to schedule an appointment for D.P. with his oral surgeon and to allow D.P.'s mother to attend the appointment. The court also ordered RJC to provide a report concerning the incident that led to D.P.'s injury. When these orders were not fully complied with, the court held a "show cause" hearing and found both Superintendent Dilly and Ms. Oldaker in contempt of court, fining each of them $250.The Supreme Court of Appeals of West Virginia found that procedural errors in the lower court's contempt proceedings deprived the court of jurisdiction to impose such sanctions. The court noted that the lower court failed to provide the petitioners with adequate notice that they were facing indirect criminal contempt proceedings and did not afford them jury trials before imposing the fines. The court concluded that the contempt orders were void and granted the petitioners' requested writs of prohibition, thereby preventing the lower court from enforcing the contempt orders. View "State ex rel. Dilly v. Hall" on Justia Law

The case revolves around a dispute between the City of Helena-West Helena and its Mayor, Christopher Franklin, and a resident, Greg Williams. The dispute arose when the Helena-West Helena City Council passed two ordinances, one increasing the conflict-of-interest limit for contracts signed with the City and the other raising the mayor's base pay. The then-mayor, Kevin Smith, vetoed both ordinances, citing the timing of the meeting as an attempt to circumvent the new city council. When Mayor Franklin took office, he attempted to rescind Smith's veto, stating that the ordinances should become law.The Phillips County Circuit Court had previously granted Williams's request for declaratory relief, ruling that the previous mayor's veto of the two city ordinances was proper. The court found that Smith had timely and properly executed a veto regarding the ordinances and that his veto was not overridden by a two-thirds vote of the City Council. As a result, the court declared all actions taken by the Council on December 30, including the passage of the two ordinances, null and void.The Supreme Court of Arkansas affirmed the lower court's decision. The court disagreed with the appellants' argument that Smith's veto was ineffective due to his failure to comply with the statutory requirements. The court found that Smith had complied with the statute by timely vetoing the Council's actions and filing a written statement of his reasons for the veto prior to the next regular Council meeting. The court also disagreed with the appellants' interpretation of the statute, stating that the statute does not affirmatively require that the mayor's reasons for the veto be presented to the Council in order to effectuate the veto. View "CITY OF HELENA-WEST HELENA v. WILLIAMS" on Justia Law

The case involves the South Carolina Department of Parks, Recreation and Tourism (SCPRT) and Google LLC. The State of South Carolina, along with several other states, sued Google for violations of federal and state antitrust laws. Google subpoenaed SCPRT for discovery pertinent to its defense. SCPRT refused to comply, asserting Eleventh Amendment immunity and moved to quash the subpoena.The district court denied SCPRT's motion, holding that any Eleventh Amendment immunity that SCPRT may have otherwise been entitled to assert was waived when the State, through its attorney general, voluntarily joined the federal lawsuit against Google. SCPRT appealed this decision.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court found that by joining the lawsuit against Google, the State voluntarily invoked the jurisdiction of a federal court, thereby effecting a waiver of its Eleventh Amendment immunity as to all matters arising in that suit. And because SCPRT’s immunity derives solely from that of the State, South Carolina’s waiver of Eleventh Amendment immunity equally effected a waiver of SCPRT’s immunity. The district court, therefore, properly denied SCPRT’s motion to quash. View "SC Dept of Parks, Recreation and Tourism v. Google LLC" on Justia Law

Michelle Oksman sued the City of Idaho Falls after slipping and falling on a wet surface in the lobby of the West Deist Aquatic Center, a facility owned and operated by the City. Oksman alleged negligence on the part of the City. The district court initially granted the City's motion for summary judgment, concluding that the City had no actual notice of a dangerous condition and did not fail to take reasonable action to remedy potential hazards. However, the court later withdrew its grant of summary judgment after Oksman identified the person who had allegedly stated that people frequently fell in the area where she had fallen. The case proceeded to a jury trial, during which the district court limited Oksman's testimony and declined to give a jury instruction Oksman requested regarding the reasonable value of necessary services. The jury returned a verdict in favor of the City, and the district court dismissed Oksman's complaint with prejudice. Oksman appealed.The Supreme Court of the State of Idaho vacated the district court's judgment and remanded the case for a new trial. The Supreme Court found that the district court had erred in limiting Oksman's testimony about a statement made by the manager of the aquatic center, which was crucial to Oksman's case. The Supreme Court also provided guidance on issues likely to arise again on remand, including the use of depositions for impeachment and the use of leading questions. The Supreme Court further vacated the district court's award of costs to the City as the prevailing party. Neither party was awarded attorney fees on appeal. View "Oksman v. City of Idaho Falls" on Justia Law

The case revolves around a public-records request dispute between Kimani Ware and Glenn Booth, the public-information officer at the Trumbull Correctional Institution. Ware alleges that he personally handed over a request for public records to Booth, who signed for it and promised to process it the following week. However, Ware claims he never received the records and, after sending three follow-up letters to Booth, decided to sue him for a writ of mandamus and statutory damages. Booth, on the other hand, denies receiving any follow-up letters from Ware and asserts that Ware has submitted fabricated evidence to the court.Previously, Booth filed a motion for judgment on the pleadings, arguing that Ware failed to verify his mandamus complaint with a proper affidavit and that the evidence of delivery of Ware's public-records request is at best "evenly balanced". However, the Supreme Court of Ohio denied the motion, stating that a motion for judgment on the pleadings does not allow a court to weigh the evidence; instead, it simply tests the sufficiency of the complaint.The Supreme Court of Ohio decided to grant an alternative writ and refer the case to a master commissioner for a full evidentiary hearing. This decision was made due to Booth's allegations that Ware has committed fraud and submitted a fraudulent document. The court noted that either Booth or Ware is lying, and the best way to determine the truth is to conduct an evidentiary hearing where witnesses can be called to testify and be subject to cross-examination. The hearing will also allow the court to decide whether a writ of mandamus is appropriate and if Ware should be sanctioned for presenting fabricated evidence. View "State ex rel. Ware v. Booth" on Justia Law

The case involves a dispute between investigative journalist Amy Silverman and the Arizona Department of Economic Security (ADES). Silverman requested access to records maintained by the Adult Protective Services (APS), a program within ADES, for her research on issues affecting individuals with intellectual and developmental disabilities. ADES denied her request, citing a state law that generally shields APS records from public inspection, except for certain exceptions, including one for "bona fide research." Silverman sued ADES, arguing that her journalistic activities qualified as "bona fide research."The Superior Court in Maricopa County ruled in favor of Silverman, finding that her journalistic activities qualified as "bona fide research" and ordered ADES to produce the requested documents after redacting personally identifying information. ADES appealed this decision, and the Court of Appeals affirmed in part, reversed in part, and remanded the case back to the Superior Court. The Court of Appeals concluded that "research" under the exception must be conducted for "educational, administrative, or scientific purposes" and that ADES still has discretion whether to disclose APS records.Both parties were dissatisfied with the Court of Appeals' decision and filed petitions for review with the Supreme Court of the State of Arizona. The Supreme Court concluded that "bona fide research" under the relevant statute occurs when the researcher engages in a good faith and genuine study to acquire more knowledge, discover new facts, or test new ideas concerning reporting or stopping the abuse, exploitation, or neglect of vulnerable adults. The court also held that anyone, including journalists, can qualify under the bona fide research exception. However, the court found that ADES has discretion whether, and on what conditions, to release APS records for bona fide research. The court vacated the Court of Appeals' opinion, affirmed the Superior Court's judgment insofar as it denied ADES's motion to dismiss, but reversed the judgment for Silverman and remanded the case for further proceedings. View "SILVERMAN v ADES" on Justia Law

The case revolves around Morgan Morales, who appealed against an administrative law judge's (ALJ) decision that she was not disabled and hence, not entitled to Social Security disability benefits. Morales claimed to suffer from several conditions, including bipolar disorder, depression, anxiety, ADHD, and narcolepsy. After being treated at a mental health center and starting on prescription medications, Morales reported that her conditions were in remission. The ALJ, however, denied her application for benefits, finding that her mental impairments were mild and did not limit her ability to perform basic work activities, including her past job as a material handler.Morales challenged the ALJ's decision in the United States District Court for the Southern District of Indiana, Indianapolis Division. She criticized the ALJ's decision about her functional capacity to work but failed to provide evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The District Court upheld the ALJ's decision, stating that Morales had not carried her burden of proof and that the ALJ's decision was supported by substantial evidence.The case was then brought to the United States Court of Appeals for the Seventh Circuit. The court affirmed the lower court's decision, stating that Morales had misunderstood the burden she bore on appeal. The court noted that it was not enough to criticize the ALJ's decision; Morales needed to point to evidence compelling the conclusion that the adverse disability decision lacked substantial support in the record. The court also dismissed Morales's criticism of the District Court's decision, stating that the District Court had conducted an adequate review of the ALJ's determination and correctly applied the law. The court concluded that the ALJ's determination was reasonable and supported by substantial evidence, and therefore, affirmed the decision. View "Morales v. O'Malley" on Justia Law

The case revolves around a child, R.N., who was removed from his mother's care and placed in foster care with Ben and Charissa Wagner. The Wagners had previously adopted two of the mother's other children. The Department of Public Health and Human Services was granted temporary legal custody of R.N. and ordered the mother to complete a treatment plan. The Department later filed a petition to terminate the mother's parental rights due to her failure to complete the treatment plan and alleged abandonment of R.N. However, the mother began to engage with the Department and made positive changes, leading to the Department's shift from termination to reunification.The Wagners, unhappy with the Department's change of stance, filed a motion to intervene, asserting that it was appropriate under M. R. Civ. P. 24 and § 41-3-422(9)(b), MCA. The District Court granted the Wagners' intervention motion, despite objections from the mother, the Department, and the guardian ad litem. The Wagners then filed a motion seeking an order for R.N. to be immediately placed in their care and for the Department to pursue termination of the mother's parental rights. The District Court did not set a hearing or issue a determination on the Wagners' motion. The Department filed a motion to dismiss the case, which the District Court granted.The Supreme Court of the State of Montana affirmed the District Court's decision to dismiss the case. The Supreme Court found that the District Court had misinterpreted the law when it allowed the Wagners to intervene. The court also ruled that the Wagners did not have a fundamental liberty interest in the care and custody of R.N. because the mother's rights had not been terminated. Furthermore, the court held that neither the District Court nor the Supreme Court had the authority to order or compel the Department to refile and prosecute its petition for termination. View "In re R.N." on Justia Law

An investigative reporter, Jason Leopold, sought access to the written directives of the United States Capitol Police and audits and reports prepared by the Inspector General of the Capitol Police. He invoked the District Court’s mandamus jurisdiction under 28 U.S.C. § 1361, claiming a common law right to access public documents and a statutory right under 2 U.S.C. § 1909(c)(1). The District Court dismissed these claims, holding that sovereign immunity barred the suit.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the District Court’s dismissals for lack of jurisdiction, but for different reasons. The court found that Leopold failed to establish that the Capitol Police had a clear, indisputable, and ministerial duty to provide access to the records. The court also rejected Leopold's argument that the Inspector General of the Capitol Police breached his duty to publish all audits and reports that recommend corrective action under 5 U.S.C. § 404(e)(1)(C), as applied to the Inspector General of the Capitol Police under 2 U.S.C. § 1909(c)(1). The court concluded that even if this duty existed, the Inspector General was forbidden from publishing the audits and reports due to their designation as "security information" under 2 U.S.C. § 1979. The dismissal was affirmed without prejudice, allowing Leopold to refile his complaint with the requisite allegations to satisfy the mandamus standard if he so desires and if he plausibly believes that he can prove those allegations. View "Leopold v. Manger" on Justia Law