Justia Civil Procedure Opinion Summaries

Teresa Williams and Barney's Childcare and Learning Center, Inc., doing business as Pooh Bear Academy, filed a complaint against various officials and employees of the Alabama Department of Human Resources (ADHR) and the Elmore County Department of Human Resources (EDHR). The complaint included tort claims related to the suspension and revocation of the day-care provider's operating license and the denial of its license renewal application.The Montgomery Circuit Court dismissed the complaint on April 25, 2024. Williams and the day-care provider filed a postjudgment motion to alter, amend, or vacate the judgment on May 23, 2024. The court set a hearing for July 1, 2024, but it did not occur. A hearing was eventually held on September 5, 2024, where both parties' counsel stated on record that they had agreed to extend the time for the court to rule on the postjudgment motion beyond the 90-day limit. However, the court did not enter an order denying the postjudgment motion until September 12, 2024.The Supreme Court of Alabama reviewed the case and determined that the appeal was untimely. The court noted that under Rule 59.1, Ala. R. Civ. P., the trial court had 90 days to rule on the postjudgment motion, which expired on August 21, 2024. Since the parties' consent to extend the time was not placed on the record before the 90-day period expired, the postjudgment motion was denied by operation of law on August 21, 2024. Consequently, Williams and the day-care provider had until October 2, 2024, to file their notice of appeal, but they did not do so until October 17, 2024. Therefore, the Supreme Court of Alabama dismissed the appeal for lack of jurisdiction. View "Williams v. Dodd" on Justia Law

In June 2020, the North Dakota Department of Health inspected ND Indoor RV Park, LLC and found several health, safety, and fire code violations. The Park was informed that its 2020 operating license would be revoked unless the violations were corrected. The Park did not address the violations, leading to the initiation of the license revocation process. The Park also requested a renewal of its license for 2021, which was denied due to the existing violations. The Park was allowed to operate until the hearing proceedings were final. The Park later withdrew its request for a hearing, and the Department of Health dismissed the renewal application and closed the case. Subsequently, the Park sold its property.The Park filed a complaint against the State of North Dakota, alleging regulatory taking, deprivation of substantive and procedural due process, inverse condemnation, unlawful interference with business relationships, systemic violation of due process, and estoppel. The State moved for judgment on the pleadings, claiming qualified immunity for individual defendants and lack of subject matter jurisdiction on the takings claims. The district court denied the State’s motion for summary judgment on the takings and due process claims but granted summary judgment on the unlawful interference claim. The remaining claims were dismissed by stipulation.The North Dakota Supreme Court reviewed the case. The court granted a writ of supervision, directing the district court to dismiss counts II and III because the individual defendants were entitled to qualified immunity. The court also directed the dismissal of counts I and IV for lack of subject matter jurisdiction, as the Park failed to exhaust administrative remedies. The court concluded that the Park could not prevail on its substantive and procedural due process claims and that the district court lacked jurisdiction over the takings claims. View "ND Indoor RV Park v. State" on Justia Law

John T. McFarland, a Program Support Specialist with the Department of Consumer and Regulatory Affairs (DCRA), requested a reclassification of his Grade 9 position to Grade 11 in 2011. The desk audit for this request was delayed, and the initial reviewer, Peter Delate, was replaced by Lewis Norman, who completed the audit in 2013 and concluded that the Grade 9 classification was correct. McFarland appealed this decision, but the Director of the District of Columbia’s Department of Human Resources (DCHR) upheld it. McFarland then petitioned for review in Superior Court, which affirmed DCHR’s decision. McFarland appealed to the District of Columbia Court of Appeals, which also affirmed the decision.In 2017, McFarland filed another petition in Superior Court, presenting new documents obtained through a Freedom of Information Act request that suggested Delate had initially supported a Grade 11 classification. The Superior Court vacated DCHR’s decision and remanded the case for reconsideration. On remand, a new specialist reviewed the entire record and concluded that McFarland’s position was correctly classified as Grade 9. McFarland again petitioned for review in Superior Court, which denied his petition and his motion for sanctions against the District of Columbia.The District of Columbia Court of Appeals reviewed the case and concluded that the Superior Court lacked jurisdiction to entertain McFarland’s petition for review under the Comprehensive Merit Personnel Act (CMPA), as the classification decision did not involve a reduction in grade. The court also found that McFarland had not shown that the Superior Court erred in denying his motion for sanctions. The Court of Appeals affirmed the denial of sanctions and remanded the case for dismissal of the petition for review for lack of jurisdiction. View "McFarland v. District of Columbia, Department of Human Resources" on Justia Law

The Borough of Englewood Cliffs filed a complaint and an amended complaint against its former attorneys and a builder, alleging professional malpractice, breach of contract, unjust enrichment, civil conspiracy, and aiding and abetting. The Borough's actions followed a previous affordable housing litigation where the Borough did not prevail and subsequently settled with the builder. The Borough's new council, elected after a municipal election, pursued the litigation despite warnings from the defendants that the claims were frivolous.The trial court dismissed the Borough's complaints with prejudice, finding that the Borough acted in bad faith to harass, delay, and cause malicious injury. The court awarded the defendants attorney fees and costs under New Jersey’s Frivolous Litigation Statute (FLS), totaling $216,484.45. The Appellate Division affirmed the trial court's decision, concluding that a public entity is not immune from sanctions under the FLS.The Supreme Court of New Jersey reviewed the case and held that municipalities and municipal corporations that engage in frivolous litigation are subject to sanctions under the FLS. The Court found that the FLS does not provide immunity to municipalities and that the doctrine of sovereign immunity does not protect municipalities from liability under the FLS. The Court emphasized that the FLS aims to deter frivolous litigation and compensate the victims of such actions. The judgment of the Appellate Division was affirmed as modified, holding the Borough liable for the sanctions imposed. View "Borough of Englewood Cliffs v. Trautner" on Justia Law

A former president of Panama, while residing in the United States, was extradited to Panama under a bilateral treaty. Panama initially charged him with specific crimes, but after his extradition, he was prosecuted for additional money laundering crimes not included in the original extradition request. He claimed these prosecutions violated the treaty's rule of specialty, which restricts prosecution to the crimes listed in the extradition request unless the extradited individual has had the opportunity to return to the extraditing country.The United States District Court for the Southern District of Florida dismissed his lawsuit for lack of standing. The court concluded that he failed to show that his injury was traceable to the defendants' actions or that a favorable ruling would redress his injuries. The court also determined that he lacked standing under the treaty's rule of specialty provision because the United States had waived its right to object to the additional prosecutions, and his rights under the treaty were derivative of the United States' rights.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that the plaintiff failed to establish Article III standing because his injury was not fairly traceable to the defendants' actions, as the decision to prosecute him was made independently by Panamanian officials. Additionally, the court found that a favorable declaratory judgment would not redress his injury, as it would not bind the Panamanian officials to drop the prosecutions. The court also concluded that the plaintiff lacked standing under the rule of specialty because the United States had consented to the prosecutions, extinguishing his derivative rights under the treaty. View "Berrocal v. Attorney General of the United States" on Justia Law

Thomas Clark, an inmate at Lebanon Correctional Institution (LCI), sought a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction (DRC) to provide records under Ohio’s Public Records Act, R.C. 149.43. Clark also requested $6,000 in statutory damages for six public-records requests he claimed were either denied or ignored by DRC. The requests were made between October 2020 and March 2024, during his incarceration at North Central Correctional Complex (NCCC) and LCI.Clark alleged that he made multiple requests for records, including theft/loss reports and an inmate handbook from NCCC, and chow-hall menus and mail policies from LCI. He claimed that these requests were either ignored or denied. However, Clark did not provide copies of his 2020 and 2021 requests from NCCC, relying instead on a 2024 kite requesting copies of earlier kites. For the LCI requests, Clark provided evidence of his requests for chow-hall menus and mail policies.The Supreme Court of Ohio reviewed the case. The court found that Clark failed to prove he sent the 2020 and 2021 requests to NCCC. Regarding the LCI requests, the court noted that Clark did not direct his requests to the appropriate public-information officer, Ellen Myers, as required by DRC’s protocol. The court held that it is not a violation of the Public Records Act when an employee not responsible for public-records requests directs the requester to the proper office or person responsible for the records.The court denied Clark’s writ of mandamus, as well as his requests for statutory damages and court costs, concluding that Clark did not show a violation of the Public Records Act by DRC. View "State ex rel. Clark v. Ohio Dept. of Rehab. & Corr." on Justia Law

An inmate at the Lebanon Correctional Institution filed a mandamus action against the Ohio Department of Rehabilitation and Correction (DRC) to compel the production of records in response to his public-records requests. He also sought statutory damages and court costs. The inmate requested a memorandum regarding "Legal Dockets," a ViaPath memorandum, and commissary receipts and price lists.The inmate initially sent his request for the "Legal Dockets" memorandum to the warden’s assistant, who asked for a ten-cent payment. The inmate claimed to have submitted the payment, but the assistant stated she never received it. The inmate later received the requested memorandum after filing the mandamus action. For the ViaPath memorandum, the inmate sent his request to the prison’s mailroom department, which directed him to the warden’s assistant. The inmate did not follow up with the assistant. Similarly, for the commissary receipts and price lists, the inmate sent his request to a commissary supervisor, who also directed him to the warden’s assistant, but the inmate did not follow up.The Supreme Court of Ohio reviewed the case. The court denied the writ as moot regarding the "Legal Dockets" memorandum since the inmate received it after filing the action. The court denied the writ for the other requests because the inmate failed to show a violation of the Public Records Act, as he did not direct his requests to the appropriate person responsible for public records. The court also denied the inmate’s requests for statutory damages and court costs, finding that the evidence was evenly balanced on whether the assistant received the payment for the "Legal Dockets" memorandum, and the inmate had filed an affidavit of indigency, meaning there were no costs to award. View "State ex rel. Clark v. Ohio Dept. of Rehab. & Corr." on Justia Law

Anthology, Inc. entered into a 10-year contract with Tarrant County College District (TCCD) in June 2022 to provide Enterprise Resource Planning products and services for approximately $42 million, plus annual fees. In October 2023, TCCD terminated the contract without cause, as permitted by the contract, but refused to pay the early termination fee and demanded a refund of about $1.7 million already paid. Anthology sued TCCD in the United States District Court for the Northern District of Texas, seeking a declaratory judgment and damages for breach of contract.TCCD moved to dismiss the case under Federal Rules 12(b)(1) and 12(b)(6), arguing four grounds: entitlement to immunity from suit under Texas law, state sovereign immunity, lack of diversity jurisdiction, and a statutory bar on recovering damages under Texas law. The district court granted TCCD’s Rule 12(b)(1) motion, dismissing Anthology’s claims without prejudice, based on TCCD’s entitlement to immunity from suit under Texas law, without addressing the other grounds for dismissal. Anthology appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the district court erred in its decision. The appellate court held that state-law immunity cannot limit the jurisdiction of federal courts, which is defined by the Constitution and Congress. Therefore, the district court should not have dismissed the case based on state-law immunity without first addressing the jurisdictional issues of state sovereign immunity and the absence of complete diversity. The Fifth Circuit vacated the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Anthology v. Tarrant County College District" on Justia Law

A man was injured in an accident outside city limits and sued a city and an emergency-responder employee for negligently providing assistance and aggravating his injuries. The city and employee offered the man $7,500 to settle the lawsuit, which he did not accept. They also moved for summary judgment, arguing that they could not be sued because AS 09.65.070(d)(4) does not allow lawsuits based on the “gratuitous extension of municipal services” beyond city limits. The superior court granted summary judgment in their favor, ruling that their actions were gratuitous because they were under no legal obligation to take them. The court also granted attorney’s fees to the city and employee based on a court rule that requires a party to pay the other side’s legal fees if the party rejected an offer of judgment to settle the case that was more favorable than the judgment the party ultimately received.The man appealed, arguing that the city’s emergency response was not gratuitous because he was billed a mileage fee for the ambulance service. He also argued that the city and employee were not entitled to attorney’s fees because their pretrial offer of judgment was invalid.The Supreme Court of the State of Alaska reviewed the case. The court held that AS 09.65.070(d)(4) bars the lawsuit because the city and employee’s actions were gratuitous, meaning they were performed without legal obligation and without charging more than the standard fee. The court also held that the offer of judgment was valid and that the superior court did not err in awarding attorney’s fees to the city and employee. The court affirmed the superior court’s grant of summary judgment and the award of attorney’s fees. View "Rochon v. City of Nome" on Justia Law

A state agency, WorkForce West Virginia, and its Acting Commissioner, Scott A. Adkins, sought a writ of prohibition to prevent the enforcement of three orders issued by the Circuit Court of Kanawha County. These orders granted a writ of mandamus to the plaintiffs, denied WorkForce’s motion to dismiss, and allowed the plaintiffs to file a second amended complaint. The plaintiffs, who received unemployment benefits during the COVID-19 pandemic, alleged that WorkForce engaged in illegal collection activities by attempting to recover overpayments beyond the statutory time limits.The Circuit Court of Kanawha County ruled in favor of the plaintiffs, finding that WorkForce’s collection activities were time-barred by West Virginia Code § 21A-10-21, which imposes a two-year statute of limitations for recovering overpayments made due to error. The court also concluded that WorkForce could not determine overpayments due to nondisclosure or misrepresentation through its administrative process and must instead pursue such claims in circuit court. Based on this interpretation, the circuit court granted mandamus and injunctive relief, ordering WorkForce to cease its collection activities and comply with the statutory time limits.The Supreme Court of Appeals of West Virginia reviewed the case and found that the circuit court erred in its interpretation of the relevant statutes. The higher court concluded that the administrative process established by the Legislature allows WorkForce to determine whether overpayments occurred due to error, nondisclosure, or misrepresentation. The court emphasized that claimants must exhaust their administrative remedies before seeking judicial review, as mandated by West Virginia Code § 21A-7-19. Since the plaintiffs did not exhaust their administrative remedies, the circuit court lacked subject matter jurisdiction. Consequently, the Supreme Court of Appeals granted the writ of prohibition and directed the circuit court to dismiss the case. View "Adkins v. Bailey" on Justia Law