Justia Civil Procedure Opinion Summaries

A Texas truck driver was injured while making roadside repairs in Iowa when his parked semi was struck by another vehicle. After the accident, the driver retained a Texas attorney to pursue his personal injury claim. That attorney negotiated with the insurer for the other driver, ultimately agreeing to a settlement of $125,000 and requesting a release. However, the client did not sign the release and later replaced his attorney, claiming he had not authorized the settlement. The client then filed a lawsuit in Iowa, seeking additional compensation and naming the driver, the driver’s employer, and others as defendants.The defendants responded by moving to enforce the settlement agreement in the Iowa District Court for Warren County. The district court, acting as factfinder with no objection from either party, held a hearing, accepted evidence, and considered the client’s affidavit. The court found that the attorney was presumed to have settlement authority and that the client had not rebutted this presumption with clear and convincing evidence. The court enforced the settlement and dismissed the case upon payment of the agreed sum. The client’s motion to reconsider was denied, and he appealed.The Iowa Court of Appeals affirmed, finding the district court’s factual findings were supported by substantial evidence. The Iowa Supreme Court granted further review. The Supreme Court held that, because the client did not object to the district court’s procedure, the court properly acted as factfinder. The Supreme Court further held that the district court’s finding—that the attorney had authority to settle—was supported by substantial evidence, and thus the settlement agreement was enforceable. The court affirmed the decisions of the lower courts. View "Recio v. Fridley" on Justia Law

A fire at a property in Washington, D.C. in 2015 resulted in the deaths of two tenants. The parents of the tenants sued both the property’s record owner, Len Salas, and his father, Max Salas, who managed the property, for wrongful death in a D.C. trial court. The jury found both defendants jointly and severally liable and awarded multimillion-dollar verdicts. After the verdict, both Len and Max filed for bankruptcy in different jurisdictions. In Max’s bankruptcy case, the court held he was entitled to an unlimited homestead exemption in the property. Subsequently, in Len’s bankruptcy case in Tennessee, the estate’s interest in certain avoidance and recovery rights under the Bankruptcy Code was sold at auction, with the plaintiffs purchasing those rights.The plaintiffs then filed an adversary proceeding in the United States Bankruptcy Court for the Middle District of Tennessee, seeking to avoid transfers and recover property. The bankruptcy court denied their motion for summary judgment and granted partial summary judgment to Max on the fraudulent conveyance claims. Plaintiffs sought and received leave from the United States District Court for the Middle District of Tennessee to pursue an interlocutory appeal. The district court affirmed the bankruptcy court’s partial grant and denial of summary judgment and remanded the case for further proceedings, but did not certify the order for appeal or designate it as a final order.On appeal, the United States Court of Appeals for the Sixth Circuit found that it lacked jurisdiction. The court determined that because the district court’s order was neither final nor properly certified for interlocutory appeal, it could not exercise appellate jurisdiction under the relevant statutes. As a result, the Sixth Circuit dismissed the appeal for lack of jurisdiction. View "Brekelmans v. Salas" on Justia Law

The case involves a woman who, as a minor, engaged in a sexual relationship with an adult more than twice her age. After the relationship ended, she experienced significant psychological distress, including anxiety and difficulty with personal relationships, and was later diagnosed with PTSD by a psychologist. Years after the relationship, she reported the events to the police, resulting in criminal charges against the adult, who was ultimately acquitted. Over a decade after the relationship ended, she brought civil claims for negligence per se, battery, and intentional infliction of emotional distress.The Circuit Court of Fairfax County sustained the defendant’s plea in bar, finding that the statute of limitations had run. The court determined that the version of the Virginia accrual statute in effect when the plaintiff reached the age of majority governed the action. The court found no legislative intent to apply later, more favorable statutes retroactively and ruled that the limitations period began when the plaintiff turned 18. The Court of Appeals of Virginia affirmed, concluding that the relevant accrual statute did not apply retroactively and that the plaintiff’s own complaint demonstrated awareness of her injuries and their connection to the relationship before reaching adulthood.On appeal, the Supreme Court of Virginia reviewed whether the lower courts erred in refusing to apply the more recent accrual statute retroactively and in finding that the plaintiff was aware of her injuries and their causal connection before the age of majority. The Supreme Court held that arguments for retroactive application of the statute were waived because they were not properly raised below, and that the record supported the finding that the plaintiff knew of her injury and its connection to the relationship as a minor. The Supreme Court of Virginia affirmed the judgment of the Court of Appeals, holding that the claims were time barred. View "Doe v. Green" on Justia Law

Mike Dennis developed mycosis fungoides, a subtype of non-Hodgkin’s lymphoma, after regularly applying Roundup, a glyphosate-based herbicide manufactured by Monsanto, for approximately 20 years. Dennis claimed his cancer resulted from exposure to Roundup, which he alleged was sold and marketed without adequate warnings about its carcinogenic risks, despite Monsanto’s knowledge of the potential danger. He brought claims for design defect, failure to warn (under both negligence and strict liability), and negligence. At trial, the jury found that Monsanto was liable for failing to warn about the cancer risk, determining Monsanto knew or should have known of the risk, failed to provide adequate warnings, and acted with malice or oppression. The jury awarded Dennis $7 million in economic damages and $325 million in punitive damages.Following the verdict, Monsanto moved for a new trial and for judgment notwithstanding the verdict (JNOV). The Superior Court of San Diego County denied Monsanto’s requests to overturn the liability findings but reduced the punitive damages award from $325 million to $21 million, finding the original award disproportionate to the compensatory damages. Monsanto timely appealed, arguing that Dennis’s failure to warn claims were preempted by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and that the punitive damages were excessive and unconstitutional.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that FIFRA does not preempt state law failure to warn claims that parallel federal misbranding requirements, in line with United States Supreme Court precedent and California decisions. The court also found that the punitive damages award, as reduced by the trial court, did not violate due process, as it was based on highly reprehensible conduct directly related to Dennis’s harm. The Court of Appeal affirmed the judgment in full. View "Dennis v. Monsanto Co." on Justia Law

OneTaste, Inc., a company founded in 2004 that promoted “orgasmic meditation,” sued Netflix for defamation in 2023. The lawsuit was based on a Netflix documentary that featured allegations from former employee Ayries Blanck, who claimed she was sexually assaulted and abused in connection with her employment and participation in OneTaste’s activities. The documentary included statements from Blanck’s sister and other former associates, as well as references to earlier media investigations and reports about alleged exploitative and abusive practices at OneTaste. OneTaste asserted that Netflix published false statements with actual malice, despite being provided with information it claimed disproved the allegations.The Superior Court of Los Angeles County reviewed Netflix’s special motion to strike under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16). Netflix argued its conduct was protected activity and that OneTaste could not demonstrate a probability of prevailing, especially on the element of actual malice. After considering the pleadings and both parties’ evidence, the trial court concluded that OneTaste failed to present sufficient evidence that Netflix published the challenged statements with actual malice. The court also found OneTaste’s additional evidence did not establish that Netflix was aware of probable falsity or recklessly disregarded the truth. As a result, the court granted Netflix’s motion to strike the complaint.On appeal, the California Court of Appeal, Second Appellate District, Division Three, affirmed the trial court’s order. The appellate court held that OneTaste did not meet its burden to show a probability of prevailing on the defamation claim because it failed to produce evidence of actual malice by Netflix. The court also rejected OneTaste’s constitutional and public policy challenges to the anti-SLAPP statute and denied its requests for judicial notice of materials not considered by the trial court. View "Onetaste Incorporated v. Netflix, Inc." on Justia Law

A patient underwent a laparoscopic bilateral tubal ligation and endometrial ablation performed by a physician at a women’s clinic. About a week after the procedure, she experienced severe abdominal pain and was hospitalized for sepsis. An exploratory surgery revealed a perforated small bowel, which was surgically repaired. The patient subsequently recovered.The patient filed a medical negligence lawsuit in the Hinds County Circuit Court against the clinic and the physician, attaching the required certificate of expert consultation to her complaint. The defendants moved for summary judgment, supporting their motion with an expert affidavit. The plaintiff did not timely file an expert affidavit or testimony in response. On the day before the scheduled summary judgment hearing, she filed a response without any expert affidavit. The circuit court denied the summary judgment motion and granted her an additional thirty days to obtain an expert affidavit. After she submitted an expert affidavit and a second hearing was held, the circuit court again denied summary judgment, finding that the competing expert affidavits created a genuine issue of material fact.On interlocutory appeal, the Supreme Court of Mississippi reviewed the circuit court’s denial of summary judgment de novo and its grant of additional time for abuse of discretion. The Supreme Court held that, in medical malpractice cases, a plaintiff must produce sworn expert testimony to survive summary judgment. The court found that the plaintiff failed to provide such testimony before the initial hearing and that the circuit court abused its discretion by granting additional time without a specific finding of diligence or good faith. The Supreme Court reversed the circuit court’s judgment and rendered summary judgment in favor of the defendants. View "Lakeland Premier Women's Clinic, PLLC v. Jackson" on Justia Law

A woman with COVID-19 and multiple underlying health conditions was admitted to a hospital and then transferred to a skilled nursing facility for ongoing treatment. During her stay at the facility, she was under the care of a physician who prescribed various treatments for her COVID-19 infection. Despite these interventions, her condition deteriorated, and she developed additional complications, including pressure wounds and dehydration. After being discharged from the facility without hospice or home health arrangements, she was readmitted to the hospital, where her condition continued to decline. She was eventually discharged home under hospice care and died shortly thereafter. Her surviving spouse filed a wrongful death lawsuit, alleging that the facility and physician were negligent in her care.The District Court of Garfield County granted summary judgment in favor of the defendants, finding that they were immune from liability under both the federal Public Readiness and Emergency Preparation (PREP) Act and Oklahoma’s COVID-19 Public Health Emergency Limited Liability Act. The district court reasoned that the acts and omissions in question were incident to the provision of care for a COVID-19 patient and thus fell within the scope of the immunity statutes. The plaintiff appealed this decision.The Supreme Court of the State of Oklahoma reviewed the case de novo. It held that the defendants were not entitled to summary judgment on the basis of immunity. The court found that the defendants failed to provide evidence establishing a causal relationship between the administration or use of covered countermeasures and the plaintiff’s injuries, as required for PREP Act immunity. Additionally, the court determined that the defendants did not meet the evidentiary burden to show the requisite impact under the state COVID-19 Act, and that a genuine issue of material fact existed regarding gross negligence. The Supreme Court reversed the district court’s judgment and remanded the case for further proceedings. View "AUSTBO v. GREENBRIAR" on Justia Law

After a fatal car accident involving a 2008 Lexus ES350, the driver, whose wife died in the crash, sued Toyota, alleging the vehicle was defective due to unintended acceleration. His case was added to a coordinated group of California state court proceedings (JCCP) involving similar claims against Toyota. The coordinated proceedings had established a Common Benefit Fund, requiring all plaintiffs whose cases resolved after a certain date to pay an 8 percent assessment from their recoveries. This fund compensated lead counsel for work that benefited all plaintiffs, such as shared discovery and expert work.The plaintiff’s case was coordinated with the JCCP in 2018. After settling with Toyota, he moved in the Superior Court of Los Angeles County to exempt his case from the 8 percent assessment, arguing he did not use or benefit from the shared work product and that his case was factually distinct. The Committee overseeing the fund opposed, submitting evidence that the plaintiff’s original attorney had relied on common benefit materials and that the issues in his case overlapped with those in the coordinated proceedings. The trial court found the plaintiff had not met his burden to show he was entitled to an exemption and denied his motion for relief from the assessment.On appeal, the California Court of Appeal, Second Appellate District, Division Seven, held that the order denying relief was appealable as a collateral order. The court affirmed the lower court’s decision, concluding that the plaintiff failed to demonstrate as a matter of law that neither he nor his counsel benefited from the common work product. The court found the assessment applied, as the plaintiff’s case fell within the scope of the coordination order and he did not prove entitlement to an exemption. The order requiring the 8 percent assessment was affirmed. View "Pruchnik v. JCCP4621 Common Benefit Committee" on Justia Law

A group of companies that are frequently sued in asbestos litigation brought an action against several settlement trusts and a claims processing facility. These trusts were established as part of bankruptcy reorganizations by former asbestos manufacturers to handle and pay out current and future asbestos-related claims. The plaintiffs rely on information held by these trusts—specifically, data about claimants’ other asbestos exposures—to defend themselves in ongoing and anticipated lawsuits. In January 2025, the trusts announced new document retention policies that would result in the destruction of most existing claims data after one year, which the plaintiffs argued would severely impair their ability to defend against asbestos claims and seek contribution or indemnification from the trusts.Previously, the trusts notified claimants of the impending data destruction, and the plaintiffs, upon learning of this, requested that the trusts not implement the new policies. When the trusts refused, the plaintiffs filed suit in the Court of Chancery of the State of Delaware, seeking a declaratory judgment that the trusts have a duty to preserve the claims data and a permanent injunction to prevent the destruction of this information. The trusts moved to dismiss, arguing that the court lacked subject matter jurisdiction, that the plaintiffs lacked standing, and that the complaint failed to state a claim.The Court of Chancery denied the motions to dismiss. It held that it had subject matter jurisdiction because the plaintiffs sought injunctive relief and because the case fit within the court’s traditional equitable powers, including the authority to grant a bill of discovery to preserve evidence for use in litigation. The court found that the plaintiffs had standing, as they faced a concrete and imminent injury from the threatened destruction of data essential to their defense and contribution claims. The court also held that the complaint stated a claim for relief, allowing the case to proceed beyond the pleading stage. View "DBMP LLC v. Delaware Claims Processing Facility, LLC" on Justia Law

David and Bonnie Faulk, residents of Alaska, purchased over one hundred windows from Spenard Builders Supply for their custom-built home and alleged that the windows, manufactured by JELD-WEN, were defective in breach of an oral warranty. They filed a class action in Alaska state court against Spenard Builders Supply, an Alaska corporation, and JELD-WEN, a Delaware corporation, asserting state-law claims. The defendants removed the case to federal court under the Class Action Fairness Act (CAFA), which allows federal jurisdiction based on minimal diversity in class actions.After removal, the Faulks amended their complaint to remove all class action allegations and sought to remand the case to state court. The United States District Court for the District of Alaska denied their motion to remand, relying on Ninth Circuit precedent that held federal jurisdiction under CAFA is determined at the time of removal and is not affected by post-removal amendments. The district court allowed the amendment to eliminate class allegations but ultimately dismissed the second amended complaint with prejudice, finding most claims time-barred and one insufficiently pled.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the impact of the Supreme Court’s decision in Royal Canin U.S.A., Inc. v. Wullschleger, which held that federal jurisdiction depends on the operative complaint, including post-removal amendments. The Ninth Circuit concluded that, after the Faulks removed their class action allegations, the sole basis for federal jurisdiction under CAFA was eliminated, and complete diversity was lacking. The court vacated the district court’s order dismissing the complaint and remanded with instructions to remand the case to state court unless another basis for federal jurisdiction is established. View "FAULK V. JELD-WEN, INC." on Justia Law