Justia Civil Procedure Opinion Summaries

A group of former student-athletes filed suit against a university, alleging that between 2012 and 2015, they sustained serious hip injuries while participating on the university's women's rowing team. They claimed that the injuries were caused by deficient coaching, athletic training, and medical care, which they argued were influenced by systemic gender-based disparities. The athletes pursued claims under Title IX for gender discrimination and under Texas law for negligence. The university moved for summary judgment, arguing that the claims were barred by the applicable two-year statute of limitations.The United States District Court for the Northern District of Texas agreed with the university as to eight plaintiffs, granting summary judgment and finding their claims time-barred. For a ninth plaintiff, the district court partially granted and partially denied summary judgment, allowing some claims for compensatory damages to proceed. The plaintiffs appealed the ruling for the eight time-barred claims, and the United States Court of Appeals for the Fifth Circuit affirmed, holding that the claims were indeed barred by the statute of limitations.Following summary judgment, the university sought to recover litigation costs as the prevailing party under Rule 54(d) of the Federal Rules of Civil Procedure and 28 U.S.C. § 1920. The district court found the university to be a prevailing party and awarded the majority of the costs requested, after reducing the amount. The plaintiffs appealed the cost award. The United States Court of Appeals for the Fifth Circuit held that the university was properly designated the prevailing party, that none of the factors in Pacheco v. Mineta weighed against awarding costs, and that the university had met its burden to show the necessity and amount of costs sought. The Fifth Circuit affirmed the district court’s award of costs. View "Clouse v. Southern Methodist University" on Justia Law

Susan Cox, a resident of Albion, Washington, died from an alleged overdose of medications prescribed by her primary care physician, Dr. Patricia Marciano. Susan’s husband, Mark Cox, and her estate initiated a wrongful-death and survivor action against Dr. Marciano and Gritman Medical Center after Susan’s death. The Coxes had lived in Washington, while Dr. Marciano and Gritman are based in Idaho, with all medical treatment having taken place in Idaho. However, at Susan’s request, her prescriptions were regularly transmitted by Dr. Marciano and Gritman to pharmacies in Washington, and Gritman engaged in marketing and accepted patients from the Washington area.The United States District Court for the Eastern District of Washington dismissed the action for lack of personal jurisdiction over the Idaho-based defendants, holding that Washington’s long-arm statute did not reach them and the exercise of jurisdiction would violate due process. The district court also denied the plaintiffs’ request for jurisdictional discovery relating to general personal jurisdiction over Gritman, and did not address the issue of venue.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The Ninth Circuit held that the district court’s exercise of personal jurisdiction over Dr. Marciano and Gritman Medical Center was proper under both Washington’s long-arm statute and the Due Process Clause. The court found that the defendants had sufficient minimum contacts with Washington, as they cultivated relationships with Washington residents and regularly transmitted prescriptions to Washington pharmacies in compliance with Washington law. The court also held that venue was proper in the Eastern District of Washington because a substantial part of the events underlying the claims occurred there. The Ninth Circuit remanded the case for further proceedings and affirmed the dismissal only as to one defendant who was conceded to be properly dismissed. View "COX V. GRITMAN MEDICAL CENTER" on Justia Law

A two-year-old child was struck and killed by a vehicle in the drive-through lane of a Chick-fil-A in Yukon, Oklahoma. The child’s parents sued Chick-fil-A, alleging that its design for pedestrian access, which required crossing the drive-through lane, created a dangerous condition. They claimed Chick-fil-A breached its duty to provide reasonably safe premises. The parents served discovery requests seeking documents and communications about adverse pedestrian incidents at all Chick-fil-A restaurants nationwide over a ten-year period, later offering to limit the scope to five years and incidents involving pedestrians in parking lots.Chick-fil-A objected, arguing the requests were overbroad, unduly burdensome, and not limited to substantially similar incidents. Chick-fil-A said it would provide information only for substantially similar incidents within Oklahoma in the preceding five years. The District Court of Oklahoma County, presided over by Judge Richard Ogden, granted the parents’ motion to compel but limited the requests to pedestrian incidents in parking lots of any Chick-fil-A with a drive-through in the United States within five years prior to the incident. Chick-fil-A sought extraordinary relief from this order.The Supreme Court of the State of Oklahoma assumed original jurisdiction and found the district court abused its discretion by not requiring the parents to show how their overly broad discovery requests were relevant to any claim or defense, as now required by 12 O.S. 2021 § 3226. The Supreme Court emphasized that discovery must be proportional and relevant to a party’s claim or defense, not just to the subject matter. The Supreme Court issued a writ of prohibition, barring enforcement of the lower court’s order and authorizing reconsideration of the motion to compel in line with its opinion. View "CHICK-FIL-A v. OGDEN" on Justia Law

An individual died from a heroin overdose while incarcerated in a county jail, after another inmate smuggled the drug into the facility and provided it to him. The jail had a known, ongoing issue with inmates smuggling drugs and evading searches, and the person who brought in the drugs had a history of such behavior but was not thoroughly searched. The decedent’s estate sued the county, alleging negligence for failing to prevent the smuggling and resultant death.The Superior Court denied the county’s motion for summary judgment, in which the county sought to invoke two statutory defenses: the felony bar defense (RCW 4.24.420) and the intoxication defense (RCW 5.40.060). The court certified the case for interlocutory review. The Washington Court of Appeals accepted review, focusing on whether the jailer’s special common law duty to protect inmates precluded the county from asserting these statutory defenses. The Court of Appeals concluded that the county could not invoke the statutory defenses, based on prior Washington Supreme Court decisions interpreting the jail’s special duty.The Supreme Court of the State of Washington reviewed the case. It held that the existence of the jailer’s special common law duty to protect incarcerated individuals does not preclude the county from raising the statutory felony and intoxication defenses enacted by the legislature. The court concluded that these statutes do not abrogate the jailer’s duty but create separate affirmative defenses that, if proven, bar liability. The court therefore reversed the Court of Appeals and remanded for further proceedings, holding that the county may assert both statutory defenses. View "Anderson v. Grant County" on Justia Law

A patient was hospitalized after contracting COVID-19 and, as his condition worsened, was transferred between several hospitals in Kentucky and Indiana. During his treatment, he was intubated, placed on a ventilator, and medically immobilized. While under this care, he developed a severe bed sore that progressed to necrotizing fasciitis. Despite ongoing treatment, he ultimately died, with his death certificate listing multiple causes including cardiopulmonary arrest and sepsis. His estate claimed that negligence in the treatment of the bed sore caused his death and filed a proposed medical malpractice complaint against more than eighty healthcare providers.The case began when the estate filed its complaint with the Indiana Department of Insurance, while a medical-review panel was being requested. Before the panel was constituted, the providers moved for summary judgment in Vanderburgh Superior Court, arguing they were immune from liability under Indiana’s Healthcare Immunity Act, Premises Immunity Act, and the federal PREP Act. The trial court granted summary judgment for the providers, finding that statutory immunity applied and that the court, not the medical-review panel, could decide the immunity issue. The estate appealed, and the Indiana Court of Appeals reversed, holding that the question of immunity required expert input from the medical-review panel, especially regarding causation.The Indiana Supreme Court granted transfer, vacating the Court of Appeals’ decision. It held that the trial court could make a preliminary determination on statutory immunity without waiting for a medical-review panel’s opinion, since the facts relating to the connection between the patient’s COVID-19 treatment and his injury were undisputed for summary judgment purposes. The court further held that the providers were immune from civil liability under both state and federal law, as the patient’s injuries arose from treatment provided in response to the COVID-19 emergency. The court affirmed summary judgment for the providers. View "Estate of Waggoner v. Anonymous Health System, Inc." on Justia Law

A homeowner alleged that he hired a roofing company in 2011 to install a specific type of roof on his residence. After installation, problems with roof materials became apparent, including issues with a protective layer that remained unresolved despite multiple repair attempts by both the roofing company and the manufacturer over more than a decade. The homeowner asserted that these defects persisted, and that communication from the roofing company ceased in early 2024. As a result, he filed a lawsuit in Etowah County, Alabama, alleging breach of express and implied warranties, as well as negligent or wanton installation and repair, and sought damages.The roofing company moved to dismiss the lawsuit for improper venue, arguing that a forum-selection clause in a “Service Agreement” required all disputes to be heard in Madison County, Alabama. The company attached an unsigned and undated sample agreement to its motion, but did not produce a copy signed by the homeowner or any evidence that the homeowner had agreed to such a clause. The homeowner responded that he had never signed, nor was he aware of, the agreement submitted by the company and also challenged the clause’s reasonableness. The Etowah Circuit Court denied the company’s motion to dismiss for improper venue.The Supreme Court of Alabama reviewed the company’s petition for a writ of mandamus, which sought to compel the lower court to dismiss the case or transfer it to Madison County. The Supreme Court held that the company failed to meet its burden of proving that the forum-selection clause applied, as it did not present evidence linking the blank agreement to the parties’ actual contract. Therefore, the Supreme Court of Alabama denied the petition, concluding that the circuit court did not clearly err in refusing to dismiss or transfer the case. View "Ex parte Continental Roofing Company, LLC" on Justia Law

The parents of a young child in Texas purchased and fed him baby food manufactured by one company and sold by another. After the child began exhibiting serious developmental and physical disorders, doctors attributed his condition to heavy-metal poisoning. Years later, a congressional subcommittee released a report identifying elevated levels of toxic heavy metals in certain baby foods, including that manufactured by the company in question. The parents then sued both the manufacturer and the retailer in Texas state court, alleging various state-law product liability, negligence, and breach-of-warranty claims.The manufacturer, a Delaware corporation with its principal place of business in New York, removed the case to federal court, arguing that the retailer—a Texas citizen like the plaintiffs—had been improperly joined and should be dismissed, thereby creating complete diversity. The United States District Court agreed, dismissed the retailer, denied the plaintiffs’ motion to remand, and proceeded to trial against the manufacturer alone. After trial, the District Court granted judgment as a matter of law to the manufacturer. On appeal, the United States Court of Appeals for the Fifth Circuit disagreed with the District Court’s finding of improper joinder, reversed the dismissal of the retailer, and concluded that because the retailer was a proper party, complete diversity was lacking. The Fifth Circuit vacated the judgment and remanded the case to state court.The Supreme Court of the United States held that the District Court’s erroneous dismissal of the nondiverse defendant did not cure the jurisdictional defect present at the time of removal. Because the jurisdictional defect was not cured and persisted through final judgment, the federal court’s judgment had to be vacated. The Supreme Court affirmed the Fifth Circuit’s decision and remanded the case for further proceedings. View "Hain Celestial Group, Inc. v. Palmquist" on Justia Law

The plaintiff purchased a vehicle in 2017 and later alleged it was defective, suing the manufacturer in 2021. The parties eventually settled, with the plaintiff surrendering the vehicle and dismissing the suit, and the manufacturer agreeing to pay $100,000. The settlement specified the plaintiff would be deemed the prevailing party for purposes of attorney fees, and the manufacturer would pay the amount determined by the trial court upon noticed motion. After the settlement was reported to the Superior Court of San Diego County, the court ordered dismissal within 45 days. When no dismissal was filed, the clerk issued notice that the case would be deemed dismissed without prejudice on August 15, 2023, unless a party showed good cause otherwise. No such cause was shown, and the plaintiff subsequently filed a motion for attorney fees.The motion for attorney fees was opposed by the manufacturer, arguing it was untimely under California Rules of Court, as it was not served within 180 days of the dismissal date. The plaintiff countered that the 180-day deadline did not apply, claiming the case had not been formally dismissed and no judgment had been entered. The Superior Court of San Diego County disagreed, finding the case had been dismissed on August 15, 2023, per the clerk’s notice and court rules, and denied the motion as untimely. The plaintiff appealed the denial, and a signed minute order dismissing the complaint was later entered, but the court maintained that the earlier date controlled.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the matter de novo. It held that a voluntary dismissal, even if not appealable, starts the clock for filing a motion for attorney fees when it concludes the litigation. The court found the case was dismissed on August 15, 2023, and the plaintiff failed to timely serve the fee motion. The order denying attorney fees was affirmed. View "Hatlevig v. General Motors LLC" on Justia Law

Susan Cox, a resident of Albion, Washington, died from an overdose of medications prescribed by her primary care physician, Dr. Patricia Marciano. Dr. Marciano, along with Gritman Medical Center, both based in Idaho near the Washington border, had treated Susan for several years. Although Susan lived in Washington, her medical treatment occurred in Idaho. At Susan’s request, her prescriptions were regularly transmitted to pharmacies in Washington. Susan’s husband, Mark Cox, and her estate brought a wrongful death and survivor action in the Eastern District of Washington, alleging that Susan’s death resulted from negligent over-prescription of pharmaceuticals.The United States District Court for the Eastern District of Washington denied the plaintiffs’ request for jurisdictional discovery regarding general personal jurisdiction over Gritman and dismissed the case for lack of personal jurisdiction. The district court found that Washington’s long-arm statute did not confer jurisdiction and that exercising specific jurisdiction would violate due process, as the defendants had not purposefully availed themselves of the Washington forum. The district court did not reach the question of venue.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The court of appeals held that the district court’s exercise of personal jurisdiction over the Idaho defendants was proper under Washington’s long-arm statute and consistent with the Due Process Clause because the defendants maintained ongoing, deliberate relationships with Washington residents and regularly sent prescriptions to Washington pharmacies in compliance with state law. The court also held that venue was proper in the Eastern District of Washington since a substantial part of the events underlying the claims occurred there. The case was remanded for further proceedings, with dismissal affirmed only for one defendant whom the plaintiffs conceded was properly dismissed. View "COX V. GRITMAN MEDICAL CENTER" on Justia Law

A healthcare provider and several of its employees became involved in a dispute after the Idaho Department of Health and Welfare took protective custody of a child suffering from severe malnutrition. Following the hospital’s treatment of the child, a relative of the child, using media platforms and political organizations, publicly accused the hospital and its staff of participating in a conspiracy to kidnap, traffic, and harm children. These accusations led to public protests, threats, and disruptions at the hospital. The healthcare provider and its employees then sued the relative, his associates, and affiliated entities, alleging defamation, invasion of privacy, intentional infliction of emotional distress, trespass, and civil conspiracy, among other claims. They sought compensatory and punitive damages, injunctive relief, and removal of false statements.During proceedings in the District Court of the Fourth Judicial District, the defendant repeatedly failed to comply with discovery orders, missed depositions, and did not attend court hearings, despite multiple warnings and opportunities to comply. The court imposed escalating sanctions, culminating in striking the defendant’s pleadings and entering default as to liability. The court held a jury trial solely on damages, at which the defendant did not appear in person despite being given the opportunity. The jury awarded $52.5 million in compensatory and punitive damages, and the court issued a permanent injunction preventing further defamatory statements or harassment.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in imposing sanctions, entering default, and excluding evidence not properly disclosed. The court found that the defendant’s due process rights were not violated given repeated, willful noncompliance with court orders. The Supreme Court affirmed the district court’s judgment, including the damages award and the injunction, and awarded attorney fees and costs on appeal to the respondents. View "St. Luke's Health System, LTD v. Rodriguez" on Justia Law