Justia Civil Procedure Opinion Summaries

Mark L. Sadler, a former employee of the United States Army, was suspended and then removed from his position for insubordination. Sadler claimed that these actions were retaliatory under the Whistleblower Protection Act and sought corrective action from the Merit Systems Protection Board (Board). He also requested sanctions against the government for the destruction of evidence. The Board denied both his motion for sanctions and his request for corrective action.The Merit Systems Protection Board initially dismissed Sadler’s first complaint, finding it did not sufficiently allege protected activity. For his second complaint, the Board acknowledged that Sadler engaged in protected whistleblower activity but concluded that the Army had shown by clear and convincing evidence that it would have taken the same actions regardless of the protected activity. The Board also denied Sadler’s motion for sanctions, finding that the destruction of evidence was part of the Army’s ordinary procedures and did not warrant sanctions.The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the Board’s decision. The court agreed that Sadler’s first complaint did not allege protected activity and that the Army had provided clear and convincing evidence that it would have taken the same actions absent the whistleblowing. The court also upheld the Board’s decision on the sanctions issue, agreeing that the destruction of evidence was part of routine procedures and did not meet the intent standard required for sanctions under Rule 37(e) of the Federal Rules of Civil Procedure. View "SADLER v. ARMY " on Justia Law

Louisville/Jefferson County Metro Government (LJCMG) entered into a contract with Omni Louisville, LLC (Omni) in 2014, which included the demolition of Liberty Hall. In 2019, the Metro Council directed the Historic Landmarks and Preservation Districts Commission to review Liberty Hall for landmark status. Despite the Commission's vote to designate Liberty Hall as a landmark, the Metro Council overturned this decision in 2021, citing various reasons including the building's association with racism and lack of architectural significance.The Louisville Historical League, Inc. (LHL) sought review in the Jefferson Circuit Court, which found that the Metro Council had violated procedural due process, concluding that the decision was predetermined due to the 2014 contract with Omni. The court held that the hearing was a pretext and that the decision was tainted by blatant favoritism and conflict of interest.The Kentucky Court of Appeals addressed the issue of jurisdiction, concluding that LHL failed to allege particularized injury or aggrievement, thus depriving the circuit court of subject matter jurisdiction. The Court of Appeals held that strict compliance with statutory requirements was necessary for jurisdiction.The Supreme Court of Kentucky reversed the Court of Appeals, clarifying that the requirement to plead particularized injury or aggrievement pertains to particular-case jurisdiction, not subject matter jurisdiction. The Court held that the judiciary has inherent constitutional authority to review administrative decisions for arbitrariness, and compliance with statutory requirements affects particular-case jurisdiction. The Court also reversed the Jefferson Circuit Court's conclusion of procedural due process violations, affirming the Metro Council's decision to overturn the landmark designation of Liberty Hall. View "Louisville Historical League, Inc. v. Louisville/Jefferson County Metro Government" on Justia Law

A man on probation was subject to a domestic violence protective order (DVPO) requiring him to give a day's notice to security personnel before visiting the medical center where his former girlfriend worked. The woman alleged that the man violated this notice provision multiple times over three years, causing her severe emotional distress and job loss. The probation officer investigated the alleged violations but decided not to revoke the man's probation or penalize him.The Superior Court of Alaska, Third Judicial District, Anchorage, granted summary judgment for the State, finding no genuine issues of material fact, that the probation officer fulfilled her duty of reasonable care, and that her actions were shielded by discretionary function immunity. The woman appealed the decision.The Supreme Court of the State of Alaska reviewed the case and concluded that there was no genuine issue of material fact to preclude summary judgment for the State regarding whether the probation officer fulfilled her operational duty to investigate the alleged violations. The court further concluded that the probation officer's subsequent decisions were shielded from suit by discretionary function immunity. The Supreme Court affirmed the superior court's grant of summary judgment. View "Smith v. Department of Corrections" on Justia Law

Linda Lee owned a motel in Pascagoula, Mississippi, which had deteriorated significantly and was being used improperly, attracting vagrants and drug users. The city council ordered the demolition of the motel after a hearing, citing it as a menace to public health and safety. Lee did not attend the hearing, but her son did. The city council decided the motel was beyond repair and ordered its demolition.Lee appealed the city council's decision to the Jackson County Circuit Court, arguing that the city failed to provide substantial evidence and did not comply with statutory notice provisions. The Circuit Court affirmed the city's decision. Lee then appealed to the Court of Appeals, which found that the city’s notice was insufficient and reversed and remanded the case for further determination.The Supreme Court of Mississippi reviewed the case on certiorari. The court found that the appeal was moot because the motel had already been demolished by a new owner, as admitted by Lee in her appellate filings. Additionally, Lee lacked standing to pursue the appeal because she had transferred the property to her son on the day of the city council meeting and no longer had any interest in it. Consequently, the Supreme Court of Mississippi vacated the Court of Appeals' decision and dismissed Lee's appeal. View "Lee v. The City of Pascagoula, Mississippi" on Justia Law

Tennessee and sixteen other states challenged a regulation by the Equal Employment Opportunity Commission (EEOC) under the Pregnant Workers Fairness Act, which mandates reasonable accommodations for pregnancy-related conditions, including abortion. The states argued that the regulation unlawfully required them to accommodate employees seeking abortions, conflicting with their policies. They sought an injunction and a declaratory judgment against the rule, claiming it was arbitrary, exceeded EEOC's authority, violated the First Amendment and federalism principles, and was unconstitutional under Article II.The United States District Court for the Eastern District of Arkansas dismissed the case, ruling that the states lacked standing as they did not demonstrate an imminent injury or that the alleged injuries were redressable. The court found the risk of enforcement speculative and compliance costs not directly traceable to the rule. The court also dismissed the states' motion for a preliminary injunction as moot and for failing to show irreparable harm.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and reversed the district court's decision. The appellate court held that the states had standing as they were the direct objects of the EEOC's regulation, which imposed new obligations on them. The court found that the states were injured by the regulatory burden itself and that setting aside the rule would remedy this injury. The court concluded that the states' need to comply with the rule constituted an injury in fact, caused by the EEOC's action, and redressable by a favorable judicial decision. The case was remanded for further proceedings without addressing the merits of the claims. View "State of Tennessee v. EEOC" on Justia Law

Puffy’s, LLC was first on a waiting list to receive a state registration certificate from the South Dakota Department of Health (Department) to operate a medical cannabis dispensary in Rapid City. After the Department failed to issue the certificate, Puffy’s filed a mandamus action in circuit court to compel the Department to issue the certificate. The circuit court granted the writ of mandamus, and the Department appealed, arguing the court lacked jurisdiction and abused its discretion in granting the writ.The circuit court found that it had jurisdiction because Puffy’s had no administrative remedy to exhaust, as the Department had not taken final action that could be appealed. The court also ruled that the matter was not moot because the Department had not issued the certificate. On the merits, the court concluded that the Department had a clear duty to issue the certificate to Puffy’s under ARSD 44:90:03:16, which mandates that a voided certificate must be awarded to the next applicant on the waiting list. The court found that Puffy’s had no other remedy and was entitled to the writ.The South Dakota Supreme Court affirmed the circuit court’s decision. It held that the circuit court had jurisdiction because there was no administrative remedy available for Puffy’s to exhaust. The court also agreed that the matter was not moot. On the merits, the Supreme Court found that the Department had a clear duty to issue the certificate to Puffy’s under the plain language of ARSD 44:90:03:16, which does not require additional application or fees from waitlisted applicants. The court concluded that the circuit court did not abuse its discretion in granting the writ of mandamus without an evidentiary hearing, as the case turned on legal interpretation rather than factual disputes. View "Puffy’s LLC v. State of South Dakota" on Justia Law

Dr. Ahmed Diaa Eldin Ali Hussein, a dual citizen of Egypt and the United States, sought to enforce an Egyptian administrative court ruling and a related ministerial decree in the United States. These rulings purportedly entitled him to compensation for the expropriation of his shares in the SIMO Middle East Paper Company by the Egyptian government in the 1990s. Hussein filed an enforcement action in New York State court against Dr. Mohamed Ahmed Maait, the Egyptian Minister of Finance, in his official capacity.The case was removed to the United States District Court for the Southern District of New York by Maait, albeit after the 30-day deadline for removal. The District Court found that Egypt was the real party in interest and allowed the late removal under Section 1441(d) of the U.S. Code, which permits enlargement of the removal period for cause. The court then dismissed the suit under Rule 12(b)(1) for lack of subject matter jurisdiction, concluding that Egypt was immune under the Foreign Sovereign Immunities Act (FSIA) and that no exceptions to this immunity applied.On appeal, the United States Court of Appeals for the Second Circuit affirmed the District Court's decision. The appellate court agreed that Egypt was the real party in interest, as Hussein's claims were fundamentally against the Egyptian government and sought compensation from the public treasury. The court also upheld the District Court's finding of cause to extend the removal period, noting the lack of prejudice to Hussein and the procedural challenges faced by Maait in securing U.S. counsel. Finally, the appellate court determined that Hussein had waived any argument regarding exceptions to FSIA immunity by not raising them on appeal. Thus, the dismissal for lack of jurisdiction was affirmed. View "Hussein v. Maait" on Justia Law

Dale Staten, a coal miner for nearly thirty years, retired in 2000 and passed away in January 2017 from respiratory failure after a two-week hospitalization. His widow, Bernadette Staten, filed for survivor benefits under the Black Lung Benefits Act. A Department of Labor administrative law judge (ALJ) awarded benefits, concluding that Bernadette qualified for a statutory presumption that Dale died from black lung disease due to his extensive underground mining work and total disability at the time of his death. The Benefits Review Board affirmed the ALJ's decision in a divided ruling.Consolidation Coal Company (CONSOL), Dale's former employer, challenged the ALJ's award, arguing that the 15-year presumption should only apply to chronic pulmonary conditions, not acute illnesses like Dale's respiratory failure. CONSOL contended that Dale's total disability was due to an acute condition rather than a chronic one. The ALJ had credited Dr. Sanjay Chavda's opinion that Dale was totally disabled at the time of his death, while discounting the opinions of CONSOL's experts, Dr. James Castle and Dr. Robert Farney, who argued that Dale was not disabled based on his medical history before his hospitalization.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the ALJ's award of benefits. The court held that the Black Lung Benefits Act does not require a claimant to prove that a miner's total disability arose from a chronic pulmonary condition to invoke the 15-year presumption. The court found that the ALJ acted within its authority in crediting Dr. Chavda's opinion and concluding that CONSOL failed to rebut the presumption that Dale's death was due to pneumoconiosis. The court denied CONSOL's petition for review and affirmed the judgment of the Benefits Review Board. View "Consolidation Coal Company v OWCP" on Justia Law

Seven states challenged a rule by the Department of Education that modified an existing income contingent repayment (ICR) plan for federal student loans, known as the Saving on a Valuable Education (SAVE) plan. This plan altered payment thresholds, stopped interest accrual, and forgave loan balances after as little as ten years of repayment. The states argued that the Secretary of Education exceeded statutory authority by forgiving loans through an ICR plan.The United States District Court for the Eastern District of Missouri found that the states were likely to succeed on their claim and issued a preliminary injunction against the rule’s early loan forgiveness provisions. Both parties appealed: the federal officials sought to vacate the preliminary injunction, while the states requested a broader injunction.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the states were likely to succeed in their claim that the Secretary’s authority to promulgate ICR plans does not include loan forgiveness at the end of the payment period. The court held that the statute requires ICR plans to be designed for borrowers to repay their loan balances in full through payments that can fluctuate based on income during the payment term. The court determined that the Secretary had exceeded this authority by designing a plan where loans are largely forgiven rather than repaid.The Eighth Circuit affirmed the entry of the preliminary injunction but concluded that the district court erred by not enjoining the entire rule. The court remanded the case with instructions to modify the injunction to cover the entire SAVE Rule and the revived forgiveness provisions under the previous REPAYE plan. View "State of Missouri v. Trump" on Justia Law

The plaintiff, the register of deeds for Norfolk County, filed a lawsuit against the county commissioners for Norfolk County, seeking declaratory, mandamus, and injunctive relief regarding funding and personnel matters within the registry of deeds. The dispute centered on hiring a new chief information officer and the funding for that position. While this litigation was ongoing, the plaintiff requested the county director to transfer funds within the registry's budget to cover legal fees for the personnel litigation. The county director denied these requests, prompting the plaintiff to file a second lawsuit for declaratory, mandamus, and injunctive relief.In the Superior Court, the plaintiff moved for summary judgment regarding the budget transfers, and the defendants cross-moved for summary judgment. The judge granted summary judgment in favor of the plaintiff, ruling that under G. L. c. 35, § 32, the plaintiff had the authority to transfer funds within a main group of the budget based on his opinion of public necessity and convenience. The defendants appealed this decision.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the Superior Court's decision. The court held that the statutory language of G. L. c. 35, § 32, clearly grants the authorized official the discretion to transfer funds within a main group based on their opinion of public necessity and convenience. The court found that the plaintiff's opinion was sufficient justification for the transfers and that the defendants' interference was unlawful. The court ordered that any outstanding amounts that should have been transferred be specifically authorized by the defendants and that the defendants refrain from hindering lawful transfers within the Contractual Services main group in the future. View "Register of Deeds for Norfolk County v. County Director for Norfolk County" on Justia Law