Justia Civil Procedure Opinion Summaries

Julian Rodriguez, an hourly machine operator for Lawrence Equipment, Inc., filed a class action lawsuit in December 2015 alleging various wage-and-hour violations under the California Labor Code. Rodriguez claimed that Lawrence failed to pay for all hours worked, provide adequate meal and rest breaks, issue accurate wage statements, and pay final wages timely. In July 2014, Rodriguez had signed an arbitration agreement with Lawrence, which led to the arbitration of his non-PAGA claims. The arbitrator ruled in favor of Lawrence, finding that Rodriguez failed to prove any of the alleged Labor Code violations.The Superior Court of Los Angeles County confirmed the arbitration award and entered judgment in favor of Lawrence. Rodriguez appealed the judgment, but it was affirmed by the Court of Appeal. Subsequently, Lawrence moved for judgment on the pleadings, arguing that Rodriguez's remaining PAGA claim was barred by issue preclusion because the arbitrator had already determined that no Labor Code violations occurred. The trial court initially denied the motion but later granted it after the U.S. Supreme Court's decision in Viking River Cruises, Inc. v. Moriana, which influenced the court's interpretation of PAGA standing.The Court of Appeal of the State of California, Second Appellate District, Division Three, reviewed the case and affirmed the trial court's judgment. The appellate court held that the arbitrator's findings precluded Rodriguez from establishing standing as an aggrieved employee under PAGA. The court concluded that issue preclusion applied because the arbitrator's decision was final, the issues were identical, actually litigated, and necessarily decided, and the parties were the same. Consequently, Rodriguez lacked standing to pursue the PAGA claim, and the judgment of dismissal was affirmed. View "Rodriguez v. Lawrence Equipment, Inc." on Justia Law

Marlon Quesada, a deputy sheriff with the Los Angeles County Sheriff's Department, was not promoted to sergeant despite taking the sergeant's examination in 2017 and 2019, scoring in band two and band one respectively. Quesada had a mixed employment record, including two suspensions for misconduct and a 2015 investigation that was terminated due to the statute of limitations. Quesada claimed the Department improperly considered this time-barred investigation during the promotion process.The Los Angeles County Superior Court denied Quesada's petition for a writ of mandate, which sought to compel the Department to promote him and provide back pay and other damages. The trial court rejected Quesada's argument for a burden-shifting approach and found that Quesada did not establish that the Department's decision was illegal.The California Court of Appeal, Second Appellate District, reviewed the case. Quesada argued that the trial court should have applied a burden-shifting approach similar to that used in discrimination cases under McDonnell Douglas Corp. v. Green. The appellate court declined to adopt this approach, noting that Quesada's case did not involve discrimination based on race or membership in a historically oppressed group. The court emphasized that the standard approach to civil litigation, where the plaintiff bears the burden of proof, was appropriate.The appellate court also found substantial evidence supporting the Department's decision not to promote Quesada, citing his mediocre performance evaluations and past misconduct. The court affirmed the trial court's judgment, concluding that Quesada's policy arguments did not justify a departure from the standard legal approach. View "Quesada v. County of L.A." on Justia Law

Joe David Hudson was injured while working for Joplin Regional Stockyards, Inc. (JRS) in 2002. In 2005, Hudson, JRS, and JRS' insurer, Star Insurance Company, entered into a settlement agreement where Hudson received an $80,000 lump sum. The settlement left future medical expenses for Hudson's left ankle open. In 2011, Hudson had a below-the-knee amputation, which Star refused to cover. Hudson filed the settlement in circuit court in 2013, and the court rendered judgment in accordance with the settlement. Hudson later filed an equitable garnishment action, leading Star to pay $92,000 for his medical bills. In 2015, Star agreed to reimburse Hudson up to $610,311.75 for future medical expenses. In 2016, Hudson and JRS entered into a subordination agreement, acknowledging all payments due under the judgment had been received.In 2022, Hudson filed a motion to revive the judgment, which JRS opposed, arguing the judgment had been satisfied and the Division of Workers' Compensation had not determined the future medical care provision. JRS also filed a motion for relief from the judgment, claiming it was void due to lack of due process. The Circuit Court of Jasper County sustained Hudson's motion to revive the judgment and overruled JRS' motion for relief.The Supreme Court of Missouri reviewed the case and determined that JRS had standing to appeal. The court found that the circuit court erred in reviving the judgment because JRS had satisfied the judgment by paying the $80,000 lump sum. The court reversed the circuit court's order sustaining Hudson's motion to revive the judgment and overruled Hudson's motion to revive the judgment. Hudson's motion for damages for a frivolous appeal was also overruled. View "Hudson v. Joplin Regional Stockyards, Inc." on Justia Law

A dental hygienist brought claims for sex discrimination, retaliation, and negligence against her former employer and supervisors. She alleged that her supervisor made repeated sexual advances and harassed her throughout her employment. The United States District Court for the Southern District of New York granted summary judgment in favor of the defendants on the retaliation claims and allowed the other claims to proceed to trial. A jury awarded the plaintiff $575,000 in emotional distress damages and $2 million in punitive damages. However, the district court granted a motion for a new trial, finding the damages excessive and indicative of unfair prejudice. In the second trial, the court precluded certain evidence, and the jury awarded the plaintiff only $1 in nominal damages.The plaintiff appealed the district court’s summary judgment ruling, the order granting a new trial, and the evidentiary rulings. The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court’s summary judgment on the retaliation claims, agreeing that the plaintiff did not engage in protected activity as required for such claims. The court also upheld the district court’s decision to grant a new trial, finding no abuse of discretion in the determination that the jury’s damages award was excessive and indicative of prejudice. Additionally, the court affirmed the district court’s evidentiary rulings, including the exclusion of the plaintiff’s psychiatric records, portions of a coworker’s deposition testimony, and an anonymous fax.The Second Circuit concluded that the district court did not err in any of its challenged rulings and affirmed the judgment of the district court. View "Qorrolli v. Metropolitan Dental Associates" on Justia Law

Krista Dittus sued her former employer, Black Hills Care and Rehabilitation Center, LLC, and the company that took over its operations, RC North SD Skilled Nursing Facility, LLC d/b/a Avantara North, alleging wrongful termination in retaliation for filing a workers' compensation claim. Avantara denied the allegations, asserting it had no employment relationship with Dittus at the time of her termination. Black Hills Care did not respond or appear in the case.The Circuit Court of the Seventh Judicial Circuit, Pennington County, South Dakota, granted summary judgment in favor of Avantara after striking Dittus's untimely response to the motion for summary judgment. The court found no genuine issues of material fact and ruled that Avantara was entitled to judgment as a matter of law. Written orders were entered, and Avantara's counsel served notice of entry of the orders on Dittus's counsel via the court's electronic filing system on September 15, 2023. Dittus's counsel filed a notice of appeal and a civil case docketing statement through the same system on October 13, 2023, but only the docketing statement was served on Avantara's counsel.The Supreme Court of the State of South Dakota reviewed the case and determined that it lacked appellate jurisdiction due to Dittus's failure to serve the notice of appeal on Avantara's counsel as required by SDCL 15-26A-4. The court emphasized that both timely filing and service of the notice of appeal are mandatory jurisdictional requirements. Consequently, the appeal was dismissed. View "Dittus v. Black Hills Care & Rehab and Avantara" on Justia Law

Terry Hall worked for BPM Lumber, LLC, and was terminated in 2015 after failing a drug test. In 2018, Hall filed a claim for permanent occupational disability benefits, alleging various health issues due to exposure to a mixture of hydraulic fluid and diesel fuel at work. The Administrative Law Judge (ALJ) dismissed Hall's claim, finding that the medical evidence did not support the work-relatedness of his conditions.Hall appealed to the Workers’ Compensation Board, which affirmed the ALJ's decision in part, vacated in part, and remanded for further explanation regarding the rejection of the University Evaluator’s report on Hall’s respiratory impairment. The ALJ provided additional findings on remand, again dismissing Hall's claims. Hall appealed to the Board, which affirmed the ALJ's decision. Hall then sought review from the Court of Appeals.The Court of Appeals held that the Board’s initial July 22, 2022, Order was final and appealable, precluding Hall from raising certain issues again. The court affirmed the Board’s decision on the merits of the remaining issues.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals' decision. The court held that the Board’s July 22, 2022, Order was final and appealable, and Hall’s failure to appeal that order immediately precluded him from raising those issues in a subsequent appeal. The court also noted that the workers’ compensation process does not require exhaustion of all administrative remedies before seeking judicial review. View "HALL V. BPM LUMBER, LLC" on Justia Law

Sarah Lindsley filed a discrimination lawsuit against her employer, Omni Hotels Management Corporation, alleging sex-based pay discrimination under the Equal Pay Act (EPA) and Title VII of the Civil Rights Act of 1964. Lindsley claimed that her initial salary was set too low due to her sex, causing her to earn less than her male colleagues despite subsequent raises. She also alleged that she faced harassment and that her complaints about pay discrepancies were ignored.The United States District Court for the Northern District of Texas initially granted summary judgment in favor of Omni on all claims. However, the United States Court of Appeals for the Fifth Circuit reversed and remanded the case for trial on the pay-discrimination claims under Title VII and the EPA. At trial, the jury found Omni not liable under the EPA but awarded Lindsley over $25 million in Title VII damages despite finding no liability under Title VII. The district court deemed the jury's answers inconsistent, amended the verdict form, and ordered further deliberation. The jury then found for Lindsley on her Title VII claim, again awarding over $25 million in damages, which the district court reduced under the statutory cap.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the district court did not err in handling the first verdict form but did err in handling the second verdict form. The appellate court found that the jury's answers in the second verdict form were inconsistent, as they found that any pay disparity resulted from a factor other than sex (an affirmative defense to both the EPA and Title VII claims) but still awarded Title VII damages. The court vacated the district court's judgment and remanded the case for a new trial. View "Lindsley v. Omni Hotels" on Justia Law

Harold Winston, an African-American male with over 30 years of service, sued his employer, the County of Los Angeles, alleging race-based discrimination, retaliation, and failure to maintain a discrimination-free environment under the California Fair Employment and Housing Act (FEHA) and whistleblower retaliation in violation of Labor Code section 1102.5. While the case was pending, section 1102.5 was amended to allow courts to award reasonable attorney fees to prevailing whistleblower plaintiffs. After the jury found in Winston’s favor on his retaliation claim under section 1102.5, he filed a motion for attorney fees based on the new provision.The Superior Court of Los Angeles County denied Winston’s motion for attorney fees, ruling that the fee provision did not apply retroactively to his case, which was filed in 2019 before the amendment took effect. The court found no legislative intent supporting retroactive application and noted that Winston did not prevail on his FEHA claims, which could have provided a basis for attorney fees.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that a new statute authorizing an award of attorney fees applies to actions pending on the statute’s effective date. The court cited case precedent establishing that newly enacted attorney fee provisions are procedural and apply to pending litigation. The court reversed the trial court’s decision and remanded the case with directions for the trial court to determine the appropriateness and reasonableness of Winston’s fee request. The judgment was reversed, and the case was remanded for further proceedings. View "Winston v. County of Los Angeles" on Justia Law

Regena Strable, a marketing director at Altoona Nursing and Rehabilitation Center, injured her left ankle at work, leading to permanent partial disability. This injury caused further physical injuries to her hip and lower back, as well as mental injuries such as post-traumatic stress disorder and anxiety. Strable had previously suffered carpal tunnel injuries to both wrists a decade earlier. After settling with her employer for the ankle injury and the sequela injuries, Strable sought benefits from the Second Injury Fund of Iowa based on her prior carpal tunnel injuries.The deputy commissioner denied Strable’s request for benefits from the Fund, concluding that Iowa Code section 85.64 imposes liability on the Fund only when the second injury is limited to a scheduled injury. The Iowa Workers’ Compensation Commissioner disagreed and granted benefits. On judicial review, the Iowa District Court for Polk County reversed the Commissioner’s decision, agreeing with the deputy commissioner that awarding benefits from the Fund would result in double recovery for Strable.The Iowa Supreme Court reviewed the case and reversed the district court’s order. The court held that the Fund is liable under Iowa Code section 85.64 if the first and second qualifying injuries caused a compensable injury to an enumerated member, regardless of whether the injuries caused other non-enumerated or unscheduled injuries. The court found that the Commissioner erred in calculating the Fund’s liability by not including the employer’s liability for the sequela injuries. The case was remanded to the Commissioner for a determination of the amount and timing of the Fund’s liability, consistent with the court’s opinion. View "Second Injury Fund of Iowa v. Strable" on Justia Law

An employee, Ashley Koester, worked as a mobile crisis counselor for Eyerly-Ball Community Health Services. She believed she was entitled to overtime compensation for her on-call hours and filled out timesheets accordingly, which were approved by her supervisor. Later, her employer objected to the overtime payments and terminated her employment. Koester sued her employer under Iowa Code chapter 91A and for wrongful discharge in violation of public policy, claiming she was terminated for asserting her right to overtime pay.The Iowa District Court for Polk County dismissed Koester's claims, ruling that she did not have a claim under chapter 91A because she had been paid in full, including for the overtime hours she claimed. The court also found her statutory claim time-barred. Koester appealed, and the Iowa Court of Appeals reversed the dismissal of her public policy claim but affirmed the dismissal of her statutory claim.The Iowa Supreme Court reviewed the case and concluded that Koester did not state a claim for relief under chapter 91A or the common law tort of wrongful discharge in violation of public policy. The court held that chapter 91A is a wage collection law, not a generalized fair practices law, and since Koester did not have a claim for unpaid wages, she was not entitled to relief. The court also determined that Koester's public policy claim failed because she was not engaged in protected activity under the statute, as she did not file a complaint or claim unpaid wages before her termination. The Iowa Supreme Court vacated the decision of the Court of Appeals and affirmed the District Court's judgment dismissing Koester's claims. View "Koester v. Eyerly-Ball Community Mental Health Services" on Justia Law