Justia Civil Procedure Opinion Summaries

Ammar al-Baluchi, a Pakistani national, has been detained at the U.S. naval base in Guantánamo Bay since 2006. He is accused of supporting the September 11, 2001, attacks as a senior member of al-Qaeda. In 2008, al-Baluchi filed a habeas corpus petition in federal district court. In 2022, he moved to compel the government to convene a Mixed Medical Commission to assess his eligibility for repatriation due to alleged torture and resulting serious health issues. The district court denied his request, ruling that detainees captured during non-international armed conflicts are not entitled to such examinations under the Third Geneva Convention or Army Regulation 190-8.The United States District Court for the District of Columbia initially stayed al-Baluchi’s habeas case pending the outcome of his military commission trial. After temporarily lifting the stay to consider his motion for a Mixed Medical Commission, the court denied the motion, leading al-Baluchi to appeal the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court determined that it lacked jurisdiction to review the district court’s nonfinal order. The court found that al-Baluchi did not demonstrate that the denial of his motion had the practical effect of denying injunctive relief or that it caused serious or irreparable harm requiring immediate review. The court noted that even if a Mixed Medical Commission found al-Baluchi eligible for repatriation, the government retained discretion to delay repatriation until the completion of his military commission proceedings. Consequently, the appeal was dismissed for lack of jurisdiction. View "Al-Baluchi v. Hegseth" on Justia Law

David J. Rudometkin was found guilty of several offenses by a military judge in 2018 and sentenced to seventeen years of confinement. His post-trial motion for a mistrial was denied by another military judge after the original judge was suspended for inappropriate conduct. Rudometkin then submitted FOIA requests to the Army and the Department of Defense for records related to the judges involved. The government either did not respond meaningfully or rejected the requests under FOIA exemptions.Rudometkin filed a pro se complaint in the District Court in 2020, challenging the government's withholding of records. He later amended his complaint to focus solely on records related to the appointment of the Chief Trial Judge. The District Court granted the government's motion for summary judgment, concluding that the government had adequately searched for records and appropriately withheld information under Exemption 5’s deliberative-process privilege. The court also denied Rudometkin’s motions to amend his complaint to include his original FOIA claim regarding the Army’s investigatory records of the first judge.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the government did not establish that it properly withheld records under Exemption 5’s deliberative-process privilege and had not shown that it released all reasonably segregable information. The court reversed and remanded on the segregability issue. However, the court affirmed the District Court’s denial of Rudometkin’s motion to amend his complaint, as his FOIA claim regarding the Army’s investigatory records of the first judge was now live in a separate action. View "Rudometkin v. USA" on Justia Law

The plaintiff, Jose Antonio Cossio, Jr., sought reconsideration of his bad-conduct discharge from the Air Force, which stemmed from court-martial convictions in 2004. Cossio had used his access to an Air Force computer system to reroute another airman’s paycheck to an orphanage in Siberia, leading to his conviction for larceny and violating the Computer Fraud and Abuse Act, among other charges. He was sentenced to ten months of confinement, demotion, a fine, and a bad-conduct discharge. His convictions and sentence were affirmed on direct appeal in the military courts.Cossio has repeatedly challenged his convictions and sentence over the years. In this case, he petitioned for writs of habeas corpus and mandamus in the United States District Court for the Northern District of Illinois, arguing that his conduct did not meet the elements of larceny and that a Supreme Court decision invalidated his computer fraud conviction. The district court dismissed his petitions, finding that Cossio did not meet the requirements for habeas corpus jurisdiction as he was not “in custody” under 28 U.S.C. § 2241(c) and that he did not meet the essential elements for a writ of mandamus.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that Cossio was not “in custody” as required for habeas corpus jurisdiction because the consequences of his convictions were collateral and did not restrain his physical liberty. Additionally, the court found that Cossio’s petition for a writ of mandamus failed because he did not demonstrate that the Secretary of the Air Force had a clear, nondiscretionary duty to grant the requested relief, nor did he show a clear right to the issuance of the writ. View "Cossio v Air Force Court of Criminal Appeals" on Justia Law

Andrew J. Winterbottom, a veteran, was awarded a 30% disability rating for his service-connected post-traumatic stress disorder (PTSD), which was later increased to 50%. He appealed to the Board of Veterans’ Appeals seeking a higher rating. During a Board hearing in June 2021, the judge questioned Winterbottom about specific violent episodes, which he later claimed demonstrated judicial bias. In May 2022, the Board denied a higher rating, concluding that his violent behavior was not unprovoked.Winterbottom appealed to the Court of Appeals for Veterans Claims, arguing that the Board failed to provide adequate reasons for its decision and exhibited bias. The Veterans Court partially agreed, remanding the case because the Board did not adequately explain why it gave less weight to a private counselor's opinion. However, the court found no bias warranting reassignment, stating the judge's questions aimed to determine if the violent conduct was provoked.Winterbottom then appealed to the United States Court of Appeals for the Federal Circuit. The Federal Circuit dismissed the appeal, stating it lacked jurisdiction to review non-final orders from the Veterans Court. The court noted that exceptions to the finality requirement, as outlined in Williams v. Principi, did not apply to Winterbottom's case. The court also declined to create a new exception for judicial bias claims, suggesting that such claims should be raised through a mandamus petition or after a final judgment. Thus, the appeal was dismissed. View "WINTERBOTTOM v. MCDONOUGH " on Justia Law

Angela Reading, a mother and former school board member, alleged that federal and local government officials violated her First Amendment rights by censoring and retaliating against her after she posted comments on Facebook. The controversy began when Reading criticized a poster at her child's elementary school that featured various sexual identities. Her post drew significant attention and backlash from military personnel at a nearby base, leading to a series of communications and actions by local and federal officials, including heightened security at a school board meeting and referrals to counter-terrorism authorities.Reading sought a preliminary injunction to prevent further interference with her free speech rights. The United States District Court for the District of New Jersey denied her motion, concluding that she failed to demonstrate irreparable harm.The United States Court of Appeals for the Third Circuit reviewed the case and focused on whether Reading had standing to seek a preliminary injunction. The court found that the bulk of the alleged unlawful conduct occurred during a brief period and had significantly subsided by the time Reading filed her lawsuit. The court determined that Reading did not show a substantial risk of future harm or a likelihood of future injury traceable to the defendants. Consequently, the court held that Reading lacked standing to seek a preliminary injunction and affirmed the District Court's order denying her motion. The case was remanded for further proceedings consistent with this opinion. View "Reading v. North Hanover Township" on Justia Law

Carl Grant, a Vietnam War veteran suffering from dementia and PTSD, left his home in Conyers, Georgia, on February 2, 2020, and ended up in Birmingham, Alabama. Officer Vincent Larry of the Birmingham Police Department found Grant disoriented and detained him for a misdemeanor. Grant was taken to a hospital, where he was treated for minor injuries. While being escorted to the restroom, Larry allegedly assaulted Grant, causing severe spinal injuries that led to Grant's death on July 24, 2020. William Jenkins, representing Grant's estate, filed a lawsuit against Larry, the City of Birmingham, and various city officials.The Jefferson Circuit Court granted a summary judgment in favor of the City defendants, dismissing Jenkins's claims with prejudice on February 22, 2023. Jenkins filed a postjudgment motion on March 21, 2023, which was denied by operation of law on June 20, 2023. Jenkins also filed a "motion for clarification" on April 28, 2023, which the court purported to grant on June 21, 2023, reinstating claims against Larry and Scott Thurmond. However, this order was a nullity as the court had lost jurisdiction after the postjudgment motion was denied by operation of law.Jenkins filed a notice of appeal on November 3, 2023, which was dismissed as arising from a non-final order. He then filed another appeal on January 24, 2024, which was transferred to the Supreme Court of Alabama. The Supreme Court of Alabama dismissed the appeal, instructing the circuit court to vacate its June 21, 2023, order and all subsequent orders, as they were nullities. The February 22, 2023, judgment was deemed final, and Jenkins's failure to appeal it timely resulted in the dismissal of his current appeal. View "Jenkins v. City of Birmingham" on Justia Law

Seven plaintiffs, all members of the Air Force, challenged the Air Force’s COVID-19 vaccine mandate, arguing it violated their religious beliefs. They sought religious exemptions, which were denied, leading to administrative discharge proceedings. One plaintiff, Byron O. Starks, Jr., was separated from service, allegedly for a preexisting medical condition, though he claimed it was due to his refusal to get vaccinated.The United States District Court for the Western District of Louisiana dismissed the case as moot after the Air Force rescinded the vaccine mandate. The court also dismissed Starks’s claims for lack of standing, citing his separation from service and failure to exhaust administrative remedies.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the rescission of the mandate did not address all alleged harms, particularly the claim that the Air Force’s religious exemption process was a sham. The court held that Starks had standing because his separation caused ongoing harm, such as ineligibility for certain veteran benefits. The court also clarified that RFRA claims are not subject to the Mindes exhaustion requirement, allowing Starks to proceed without exhausting intraservice remedies.The Fifth Circuit determined that the claims of the six still-serving plaintiffs were not moot, as they alleged ongoing harm from the Air Force’s religious exemption process. The court reversed the district court’s dismissal and remanded the case for further proceedings, allowing the plaintiffs to continue their challenge against the Air Force’s broader vaccination policies and religious accommodations process. View "Crocker v. Austin" on Justia Law

The case revolves around the murder of Sallie Copeland Evans by her grandson, Isaiah Evans Ceasar, a lance corporal in the United States Marine Corps. Sallie's son, Mitchell Garnet Evans, acting as the executor of her estate, filed a wrongful death claim against the United States under the Federal Tort Claims Act, alleging that the Marine Corps was negligent in its handling of Ceasar, who had previously expressed suicidal intentions and violent tendencies. The district court dismissed the claim for lack of subject-matter jurisdiction.The United States Court of Appeals for the Fourth Circuit found that the district court had erred in dismissing the claim under Federal Rule of Civil Procedure 12(b)(1) because the jurisdictional question and the merits of the case were inextricably intertwined. However, the court also found that Evans failed to state a wrongful death claim under North Carolina law. The court concluded that even if the Marine Corps had a duty to Sallie, her murder was not foreseeable under the circumstances. Therefore, while the district court's decision was procedurally incorrect, it was substantively proper. The court affirmed the district court's decision on alternative grounds and dismissed the case under Rule 12(b)(6). View "Evans v. US" on Justia Law

The case involves four veterans who appealed from judgments of the United States Court of Appeals for Veterans Claims, which dismissed their petitions for writs of mandamus due to lack of jurisdiction. The veterans' disability ratings were reduced, and they sought to have their original ratings continue pending the final resolution of the validity of the reduction. The veterans argued that the Department of Veterans Affairs (VA) could not lawfully decrease or discontinue their payments until their appeals challenging the reduction were exhausted.The Veterans Court found that there was no basis on which it could issue a writ under the All Writs Act in aid of its jurisdiction. The Veterans Court dismissed the veterans' petitions for lack of jurisdiction. The veterans then appealed to the United States Court of Appeals for the Federal Circuit.The Federal Circuit Court affirmed the Veterans Court's decision. The court held that mandamus relief was not available for the veterans under the All Writs Act because there was an adequate remedy by appeal that the veterans had chosen not to invoke. The court concluded that when there is a remedy by appeal, mandamus is unavailable. The court found that the veterans could have requested relief from the VA, and if a decision had been obtained from the Board denying the requested relief, a remedy by appeal would have been available to the veterans. The court also noted that an appeal is available if three conditions are satisfied: a clear and final decision of a legal issue, the resolution of the legal issues adversely affects the party seeking review, and there is a substantial risk that the decision would not survive a remand. The court found that these conditions would have been satisfied if the veterans had appealed the question of their entitlement to interim payments while the merits of their reductions were still pending. View "LOVE v. MCDONOUGH " on Justia Law

The case involves Benito R. Chavez, a Vietnam War veteran who sought service connection for posttraumatic stress disorder (PTSD). After being diagnosed with chronic, moderately severe PTSD, he was granted a 100 percent disability evaluation by the Department of Veterans Affairs (DVA). However, after a subsequent medical examination, his disability rating was reduced to 50 percent, and later increased to 70 percent, as it was determined that his condition did not result in total occupational impairment. Chavez disagreed with this decision and appealed to the Board of Veterans’ Appeals, which upheld the reduction.Chavez then appealed to the Court of Appeals for Veterans Claims, arguing that the Board's decision should be reversed and his 100 percent rating reinstated. The Veterans Court agreed that the Board may have improperly relied on evidence developed after the rating reduction, but instead of reversing the Board’s decision, it remanded the case back to the Board for further examination.Chavez appealed this decision to the United States Court of Appeals for the Federal Circuit, arguing that the Veterans Court should have reversed the Board’s decision rather than remanding the case. The government contended that the Federal Circuit lacked jurisdiction over Chavez's appeal. The Federal Circuit rejected the government's jurisdictional argument but affirmed the decision of the Veterans Court on the merits. The Federal Circuit held that the Veterans Court was fully entitled to remand the case to the Board for clarification, and therefore, the decision of the Veterans Court was affirmed. View "Chavez v. McDonough" on Justia Law