Justia Civil Procedure Opinion Summaries

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

A woman died after a rapid health decline while receiving emergency and critical care at a West Des Moines hospital. Her husband, who was appointed as the administrator of her estate, filed a wrongful-death medical malpractice lawsuit against various medical providers. He brought the suit both on behalf of the estate and in his individual capacity, alleging multiple claims including negligence and seeking damages for emotional and financial loss. The husband, a nonlawyer, filed the petition without legal counsel and argued that, as the sole beneficiary, he should be allowed to proceed pro se or, alternatively, be given time to retain an attorney if one was required.The Iowa District Court for Polk County dismissed the lawsuit, ruling that the petition was a legal nullity because a nonlawyer cannot represent an estate or other parties in court, and denied the husband’s request for more time to secure counsel. The court also denied his motion to amend the petition. On appeal, the Iowa Court of Appeals affirmed the dismissal, agreeing that the wrongful-death action could not proceed without a lawyer and finding that the request for additional time had not been properly preserved for appeal. Two appellate judges dissented, concluding the husband was entitled to a warning and additional time to obtain counsel.The Supreme Court of Iowa granted further review. The court held that a nonlawyer cannot represent an estate or other persons in a wrongful-death action in district court. However, it found that the district court abused its discretion by not granting the husband reasonable time to retain counsel before dismissing the case. The Supreme Court vacated the court of appeals’ decision, reversed the district court’s judgment, and remanded the case with instructions to allow at least thirty days for the husband to secure trial counsel. View "Estate of Tornell v. Trinity Health Corporation" on Justia Law

A Pennsylvania-based company operating an online marketplace for firearms was sued under New Hampshire law by a former Boston police officer and his wife. Their claims alleged that the company’s website facilitated the sale of a firearm in New Hampshire in 2015, which was later used to shoot the officer in Boston in 2016. The plaintiffs asserted causes of action including negligence, aiding and abetting tortious conduct, public nuisance, loss of consortium, and loss of support, based on the website’s alleged design and operation in encouraging illegal gun sales.Previously, the plaintiffs had filed a similar suit in the Massachusetts Superior Court against the company and other defendants, but that court dismissed the claims against the company based on Section 230 of the Communications Decency Act, without ruling on personal jurisdiction. After jurisdictional discovery, the Massachusetts Superior Court subsequently dismissed the claims for lack of personal jurisdiction. The plaintiffs then filed the present action in the United States District Court for the District of New Hampshire, which denied their request for jurisdictional discovery and dismissed their claims for lack of personal jurisdiction, finding the company had not purposefully availed itself of the protections of New Hampshire’s laws.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s ruling in part and vacated it in part. The First Circuit held that the plaintiffs failed to make a prima facie case of purposeful availment based on contacts up to 2016, but concluded that evidence of thousands of “New Hampshire” firearm listings on the website from 2018 onward, when considered with other evidence, sufficed for a prima facie showing of purposeful availment. The court remanded for consideration of relatedness and reasonableness and affirmed denial of jurisdictional discovery. View "Stokinger v. Armslist, LLC" on Justia Law

After her criminal charge for false reporting was dismissed, Rebeca Hinds filed a civil complaint in county court against Corrine Foreman, alleging that Foreman knowingly made false and defamatory statements to law enforcement, which led to Hinds being charged. Foreman responded by filing a special motion to dismiss under Colorado's anti-SLAPP statute, arguing that her statements to police were protected as they related to a public issue and were made in an official proceeding. The county court found that while Hinds met her burden to show the statements’ falsity, she failed to provide sufficient evidence of actual malice. The court granted Foreman's motion to dismiss, entered a final judgment dismissing the case with prejudice, and awarded Foreman fees and costs.Hinds appealed the county court’s judgment to the Colorado Court of Appeals, relying on statutory provisions that appeared to authorize appeals of anti-SLAPP dismissals directly to that court. The Court of Appeals noted a jurisdictional issue because the Colorado Constitution and relevant statutes generally require appeals from county courts’ final judgments to be made to the district court or the Colorado Supreme Court, not the Court of Appeals. The division requested a determination of jurisdiction from the Supreme Court of Colorado.The Supreme Court of Colorado held that the statutes authorizing the Court of Appeals to review final judgments from county courts in anti-SLAPP cases are unconstitutional to the extent they conflict with article VI, section 17 of the Colorado Constitution. The court ruled that appellate review of a county court’s final judgment must be by the district court or the Supreme Court, not the Court of Appeals. The Supreme Court remanded the case with instructions to dismiss the appeal for lack of jurisdiction and granted Hinds leave to refile her appeal out of time in district court. View "Hinds v. Foreman" on Justia Law

A woman who had resided at an apartment complex in 2021 was injured when a bullet, fired from outside her apartment, struck her. She filed a pro se complaint with the Montgomery Circuit Court before the expiration of the statute of limitations, seeking to hold the apartment management responsible for her injuries on the basis that tenants were supposed to have 24-hour security due to increasing crime. The complaint, in the form of a letter, did not explicitly name a defendant or assert specific legal claims, but accompanying documents identified Hubbard Properties as the defendant and provided an address for service. However, she did not include summonses or provide instructions regarding service of process.No action was taken in the case until a status conference was held nearly two years later. Several months after that, and after the limitations period had expired, the plaintiff amended her complaint with the assistance of counsel, formally naming both Stonebridge and Hubbard Properties as defendants and asserting claims of negligence, wantonness, and failure to provide safe premises. At that time, she also included summonses and requested service by certified mail, and both defendants were served after the limitations period expired. The defendants moved to dismiss the complaint, arguing that the claims were barred by the statute of limitations because the plaintiff had not made a bona fide attempt to have the original complaint immediately served. The Montgomery Circuit Court denied the motions to dismiss without explanation.The Supreme Court of Alabama granted the defendants' petition for a writ of mandamus. The court held that, although the complaint was filed before the statute of limitations expired, the plaintiff did not have the bona fide intent to have it immediately served, as objectively required for timely commencement of an action under Alabama law. Because of this, and because service occurred after the limitations period, the court directed the circuit court to dismiss the complaint with prejudice. View "Ex parte Stonebridge, LLC" on Justia Law

Two sisters, aged twelve and nine, were sexually abused by their tutor during sessions at public libraries owned by two Alabama municipalities in 2017. The abuse was witnessed by library employees who allegedly failed to intervene or report the misconduct. The sisters disclosed the abuse to their mother later that year, prompting a police report. In 2023, the tutor was convicted of sexual abuse. In 2024, the sisters and their mother sued the municipalities, asserting negligence in failing to respond to the abuse.The initial complaint named nonprofit corporations associated with the libraries as defendants but was amended to substitute the municipalities themselves. Prior to filing the amended complaint, the plaintiffs served notices of claim to each municipality, but these were submitted more than six years after the alleged tortious conduct. Both the City of Irondale and the City of Birmingham moved to dismiss, arguing noncompliance with Alabama Code § 11-47-23, which requires notice of claim against a municipality within six months of claim accrual. The Jefferson Circuit Court granted their motions, dismissing the claims.On appeal, the Supreme Court of Alabama considered whether minors are exempt from the six-month notice requirement under § 11-47-23. The plaintiffs argued that minority status should toll the notice period, referencing statutory provisions that extend the time for filing suit by minors. The Supreme Court of Alabama held that § 11-47-23 contains no exception for minors and that the statutory tolling provision applies only to statutes of limitations, not notice-of-claim statutes. The court affirmed the Jefferson Circuit Court's dismissal of the claims against both municipalities, holding that minors are subject to the same notice requirements as adults under Alabama law. View "A.G.R. v. The City of Irondale" on Justia Law

The case involves the family of a deceased inmate who alleged that certain medical professionals and a health services foundation, after performing an autopsy at the request of correctional authorities, removed and retained the decedent’s organs without family consent. The family contended they were not informed or asked for permission regarding the autopsy or retention of organs, and only learned the organs were missing when preparing the funeral. They claimed to have relied on statements from hospital staff that such practices were standard, and only discovered in December 2023, through media reports, that retention of organs without next-of-kin consent was allegedly unlawful.The Montgomery Circuit Court reviewed and denied the defendants’ consolidated motion to dismiss, finding that statutory limitations could be tolled due to alleged fraudulent concealment. The court determined that the amended complaint sufficiently alleged facts that, if proven, could justify equitable tolling under Alabama law, and that the family’s claims were not time-barred because they filed suit within two years of learning the alleged conduct was illegal.On review, the Supreme Court of Alabama considered a petition for writ of mandamus by the University of Alabama Health Services Foundation and Dr. Stephanie Reilly. The Court held that mandamus relief was appropriate because, from the face of the complaint, the claims were barred by applicable statutes of limitations. The Court reasoned the causes of action accrued by November 6, 2021, when the family learned the organs were missing, and rejected arguments for tolling or for treating the alleged conduct as a continuous tort. The Court distinguished between statutes of limitations governing different claims, and found that all claims against the petitioners except the AUAGA claim were time-barred. It therefore granted the petition and directed dismissal of all claims against the petitioners except for the AUAGA claim. View "Ex parte University of Alabama Health Services Foundation" on Justia Law

The case involves a dispute over discovery between two companies engaged in mining operations in Peru and a group of law firms representing Peruvian plaintiffs who allege injuries from toxic exposure. The companies, seeking to defend themselves against these claims and pursuing a related criminal complaint in Peru alleging document falsification and other misconduct by a former attorney, Victor Careaga, filed an ex parte application under 28 U.S.C. § 1782 in the Southern District of Florida. They sought discovery from Careaga, who had worked for the law firms and played a key role in recruiting plaintiffs. The law firms intervened, seeking protective orders to prevent disclosure of certain documents, asserting attorney-client privilege and work product protection.Previously, the United States District Court for the Eastern District of Missouri, where the underlying personal injury cases (Reid and Collins) were pending, had denied the companies' discovery requests as to the active plaintiffs. When the companies sought discovery in Florida, the Southern District of Florida granted the application, which led to the disputed subpoena. The law firms then moved for protective orders, but the magistrate judge and the district judge found that the privilege claims were insufficiently supported—citing vague, bundled privilege logs, lack of individualized document identification, and inadequate supporting affidavits. The district court denied the motions for protective orders.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed only the Halpern law firm's appeal after the other intervenors voluntarily dismissed their appeals. The Eleventh Circuit affirmed, holding that the district court did not abuse its discretion in denying the protective order because Halpern failed to substantiate its privilege and work product claims with adequate evidence and document-specific explanations. The court also found that Halpern was not entitled to further process, such as in camera review or amendment of the privilege log, given these deficiencies. View "The Renco Group Inc. v. Napoli Shkolnik PLLC" on Justia Law

Harold Berk, while traveling in Delaware, suffered a fractured ankle and sought treatment at Beebe Medical Center, where Dr. Wilson Choy recommended a protective boot. Berk alleged that hospital staff improperly fitted the boot, worsening his injury, and that Dr. Choy failed to order an immediate follow-up X-ray, resulting in delayed treatment and the need for surgery. Berk, a citizen of another state, filed a medical malpractice suit in federal court against both the hospital and Dr. Choy under Delaware law.Delaware law requires that a medical malpractice complaint be accompanied by an affidavit of merit from a medical professional. Berk requested an extension to file this affidavit, which was granted, but ultimately failed to secure the required affidavit and instead filed his medical records under seal. The United States District Court for the District of Delaware dismissed Berk’s suit for failing to comply with Delaware’s affidavit of merit statute. The United States Court of Appeals for the Third Circuit affirmed the dismissal, finding the state law substantive and applicable in federal court because, in its view, the Federal Rules of Civil Procedure do not address the affidavit requirement.The Supreme Court of the United States reviewed the case and held that Delaware’s affidavit of merit requirement does not apply in federal court. The Court reasoned that Federal Rule of Civil Procedure 8, which governs the information a plaintiff must provide at the outset of a lawsuit, sets the standard for pleadings and does not require supporting evidence such as an affidavit. Because Rule 8 is a valid procedural rule under the Rules Enabling Act and regulates the manner and means by which claims are presented, it displaces the contrary Delaware law. The Supreme Court reversed the Third Circuit’s decision and remanded the case for further proceedings. View "Berk v. Choy" on Justia Law