Justia Civil Procedure Opinion Summaries

Lonas Goins was injured when a train locomotive that he was operating collided with a garbage truck at a railroad intersection. Goins sued the owner and the driver of the truck. After a five-day trial, a jury found in favor of Goins and awarded him damages. Dissatisfied with the jury's damages award, Goins appealed the judgment, arguing that the trial court committed multiple errors that warranted a new trial. Finding no reversible error, the Alabama Supreme Court rejected Goins's arguments and affirmed the judgment. View "Goins v. Advanced Disposal Services Gulf Coast, LLC" on Justia Law

Shirley English sued Murphy Oil USA, Inc., after she slipped and fell in the restroom of a Murphy Oil gas station. Murphy Oil moved for summary judgment, but the trial court denied the motion. After a bench trial, the court entered a judgment in favor of English. The trial court made no findings of fact during the trial and instead took the matter under consideration after inviting the parties to submit briefs. One day after the briefing deadline had passed, the trial court entered a judgment in favor of English and awarded her compensatory damages in the amount of $125,000. The trial court did not make any written factual findings as a part of its judgment. It appeared from the record that Murphy Oil did not move for a new trial or for judgment as a matter of law, and it did not otherwise challenge the sufficiency of the evidence before it appealed to the Alabama Supreme Court. Murphy Oil argued on appeal that: (1) the trial court erred by denying its summary-judgment motion; (2) English offered no evidence at trial to sustain a judgment holding it liable for negligence; and (3) the trial court erred by admitting evidence of medical expenses that was unsupported by expert testimony. The Supreme Court determined none of Murphy Oil's arguments provided a ground for reversing the trial court judgment: Murphy Oil did not establish the Supreme Court should disregard the general rule against reviewing a trial court's denial of a summary- judgment motion after a trial on the merits. And its argument about the sufficiency of the evidence at trial was not properly before the Supreme Court. Finally, based on the record before it, the Supreme Court could not say that the trial court erred by admitting evidence of English's medical expenses. View "Murphy Oil, USA, Inc. v. English" on Justia Law

Chris and Suzanne Moore, as parents and next friends of Sydney Moore, a minor, appealed the grant of summary judgment entered in favor of Pamela Tyson and Jennifer Douthit, two employees of the Huntsville City Board of Education ("the Board"), with regard to negligence and wantonness claims asserted against Tyson and Douthit by the Moores arising from injuries suffered by Sydney at her elementary school. Tyson was employed by the Board as a teacher at Goldsmith-Schiffman Elementary School. Douthit was employed as the principal of the school. Sydney was enrolled at the school as a third-grade student in Tyson's class. Tyson left the students unsupervised in the classroom while she went to the restroom. During that time, Sydney and another student in the class left their seats, and, according to Sydney, the other student caused her to fall and hit her head and face on a counter in the classroom. Sydney suffered injuries from her fall, including fractures of her left orbital bone, her eye socket, and her nose and entrapment of her eye. Sydney was admitted for treatment at a hospital and underwent surgery as a result of the injuries. THe Alabama Supreme Court determined the Moores did not demonstrate the trial court erred in entering summary judgment in favor of Tyson and Douthit based on immunity. Accordingly, the Court affirmed the trial court's judgment. View "Moore v. Tyson" on Justia Law

Defendant Allstate Property and Casualty Insurance Company ("Allstate"), appealed a circuit court's order granting the posttrial motion of the plaintiff, Doyle Harbin, which sought the imposition of sanctions based on Allstate's purported violation of a pretrial mediation order. In 2015, Harbin was injured as the result of a motor-vehicle accident that he alleged was caused by Irvin Stewart. Harbin subsequently filed a complaint in the trial court asserting a negligence claim against Stewart. In the same complaint, Harbin also named Allstate, Harbin's automobile insurance carrier, as a defendant and sought to recover uninsured/underinsured-motorist ("UIM") benefits under his Allstate policy. Following Stewart's dismissal, Harbin, without opposition from Allstate, requested that the scheduled trial date be continued and the matter referred to mediation. Unable to reach a settlement, the matter proceeded to trial. A jury returned a $690,000 verdict in Harbin's favor. Approximately two weeks later, Harbin filed a "Motion for Entry of Judgment and Motion for Sanctions," essentially contending Allstate in bad faith failed to abide by the Order which set the Court-ordered mediation in which Allstate had agreed to participate. The motion requested Allstate pay Harbin's trial-related attorneys' fees. The Alabama Supreme Court found the evidence failed to show Allstate violated the trial court's mediation order, thus it exceeded its discretion by issuing Harbin's requested sanctions. The Court therefore reversed the portion of the trial court's order imposing sanctions exceeding Harbin's request for costs and fees totaling $57,516.36, and remanded this matter for further proceedings. View "Allstate Property & Casualty Ins. Co. v. Harbin" on Justia Law

The issue this case presented for the Colorado Supreme Court's review centered on whether an injured passenger riding in a vehicle negligently driven by one co-worker and owned by another co-worker, when all three were acting within the course and scope of their employment, could recover UM/UIM benefits under the vehicle owner’s insurance policy. Although the parties disputed the meaning of the phrases “legally entitled to recover” and “legally entitled to collect” under section 10-4-609, C.R.S. (2020) the Court did not resolve that dispute here because, assuming without deciding that plaintiff Kent Ryser’s interpretation was correct, the Court concluded that he still could not prevail. Specifically, the Court found an injured co-worker was barred by operation of the Workers’ Compensation Act's (“WCA”) exclusivity and co-employee immunity principles from recovering UM/UIM benefits from a co-employee vehicle owner’s insurer for damages stemming from a work-related accident in which another co-employee negligently drove the owner’s vehicle and the injured party was an authorized passenger. Though the Court's reasoning differed from the appellate court's judgment, it affirmed the outcome: summary judgment was properly entered in favor of the insurance company. View "Ryser v. Shelter Mutual Insurance" on Justia Law

Chris Oden appealed a district court order vacating a transcribed Missouri foreign judgment. Oden argued: (1) vacating the transcribed Missouri judgment violated the Full Faith and Credit Clause of the United States Constitution; (2) the court erred in relying on a decision issued between the parties in prior litigation because that decision was barred by administrative res judicata as the result of Oden’s Missouri workers compensation claim; and (3) the court erred by affording a prior judgment res judicata effect while that case was pending on appeal. In May 2010, Oden was injured in Missouri while employed by Minot Builders Supply. North Dakota Workforce Safety and Insurance (“WSI”) accepted the claim and awarded benefits for Oden’s injuries. In May 2013, Oden filed a claim for compensation in Missouri for the same work-related injury. In October 2013, WSI suspended payment of further benefits on Oden’s claim after Oden claimed benefits Missouri. Subsequent to Oden settling his Missouri workers compensation claim, WSI sent Oden notice that the prior North Dakota workers compensation award was being reversed because Oden’s receipt of benefits in Missouri. WSI provided notice to Oden his workers compensation benefits were being denied, informed Oden he would need to reimburse WSI, and informed Oden he had thirty days to request reconsideration. Oden did not request reconsideration of WSI’s decision. In July 2018, WSI commenced an action in North Dakota against Oden seeking reimbursement for previous payments made to Oden. The district court in the Burleigh County case granted summary judgment in favor of WSI and awarded WSI the full amount paid to Oden, plus accruing interest, costs, and disbursements. Oden argued in the North Dakota case that WSI was bound by the Missouri workers compensation settlement because the settlement agreement included a signature of an attorney purportedly acting on behalf of WSI. The court determined WSI could not be bound by the Missouri agreement because WSI was not a party to the settlement, and there was no evidence to support a finding that the attorney who purportedly signed on behalf of WSI had any authority to represent WSI or act as WSI’s agent. Finding no reversible error, the North Dakota Supreme Court affirmed the district court. View "Oden v. Minot Builders Supply, et al." on Justia Law

Menard, Inc. (“Menards”) appealed an order denying a motion for summary judgment, an order denying a motion for judgment as a matter of law, an order granting attorney’s fees, an order as to the amount of attorney’s fees recoverable and entry of judgment, and a judgment. In 2013, Darlene Johnson visited a Menards store in Minot to exchange an item. A Menards employee directed Johnson to find the exchange in the store and return to the service counter. Johnson turned toward her right and started walking away. Almost immediately, Johnson tripped over a flatbed cart. The cart was one Menards offers its customers to use while in the store. As a result of the trip and fall, Johnson cracked seven teeth. 2017, Johnson filed a negligence action against Menards in small claims court seeking damages in the amount of $14,818.00. Menards removed the case to district court. Johnson then amended her claim with the consent of Menards. In the amended complaint, Johnson sought a jury trial and “a reasonable amount but not less than $50,000” in damages. Before trial, Menards moved for summary judgment contesting whether sufficient facts created a duty of care it owed to Johnson. The court denied the motion. At trial, Menards moved for judgment as a matter of law at the close of Johnson’s case. Menards again claimed insufficient evidence existed to require a duty of care Menards owed Johnson. Alternatively, Menards argued it had met any duty it owed Johnson. The court denied the motion. Menards did not renew its motion for judgment as a matter of law at the close of its case or after the jury returned the verdict. After review, the North Dakota Supreme Court affirmed the trial court, but remanded for consideration of Johnson's attorney's fees for this appeal. View "Johnson v. Menard, Inc." on Justia Law

Plaintiff-Respondent David Collins suffered serious injuries following his arrest by San Diego County Sheriff's Deputies for public intoxication. After a three-week trial, a jury found in favor of Collins on his negligence claims against the two deputies involved in the arrest and two nurses employed by the County of San Diego (County) who attended to Collins while in jail. On appeal from the subsequent judgment and the denial of its motion for judgment notwithstanding the verdict (JNOV), the County raised five claims of error: (1) the jury’s finding that the deputies had a reasonable basis to arrest Collins foreclosed his claim of negligence against the deputies; (2) the court erred by instructing the jury it could find the deputies liable for injuries caused by private physicians who treated Collins after he was released from custody; (3) the court erred by failing to instruct the jury it could not hold defendants liable for an injury Collins sustained while in jail; (4) governmental immunity requires reversal of the judgment against one of the nurse defendants; and (5) the court erred in its calculation of the amount of setoff the defendants were entitled to based on Collins’s prior settlement with the private physicians and their employer. The Court of Appeal rejected these arguments and affirmed the judgment. View "Collins v. County of San Diego" on Justia Law

At issue in this appeal was whether claimant Curtis Stanley filed a timely complaint against the Industrial Special Indemnity Fund ("ISIF") when Stanley filed his complaint more than five years after his industrial accident and more than one year after receiving his last payment of income benefits. The Idaho Industrial Commission (“Commission”) held it did not have continuing jurisdiction to entertain Stanley’s complaint against ISIF for non-medical benefits. The Commission found Idaho Code section 72-706 barred Stanley’s complaint and dismissed it. Stanley appealed, arguing continuing jurisdiction over medical benefits alone was sufficient to confer jurisdiction over complaints against ISIF and that the Commission erred in determining section 72-706 barred his complaint. Finding the Commission erred in determining section 72-706 barred Stanley's complaint, the Idaho Supreme Court reversed the Commission’s decision. View "Stanley v. Idaho Industrial Special Indemnity Fund" on Justia Law

In March 2014, Evvie Punches rented a one-bedroom apartment in the Conifer Groves complex in Anchorage; she renewed the lease in April 2015. The complex was owned by McCarrey Glen Apartments, LLC and managed by Weidner Property Management, LCC. Punches complained to the property manager since moving in regarding air quality in the apartment, and mold around the toilet. These issues continued despite a number of attempts by Weidner’s maintenance staff to fix them. Punches nonetheless renewed her lease in April 2015. When the property manager tried to arrange an inspection, Punches refused to allow maintenance staff into her apartment because she would not be home. Punches moved out of her apartment on March 2016 after delivering Weidner a “Notice of Defects in Essential Services.” Her notice listed issues with the front door, mold on the ceiling, mold on the carpet, damage from a previous fire, water damage, and “insufficient windows” that permitted “free flowing air throughout” the apartment. Punches moved to Minneapolis some time after she left her Alaska apartment, and sought care in Minnesota for various skin infections and reported that she had been exposed to mold for two years. She continued to pursue a connection between mold exposure and her recurring skin infections and other ailments. In 2017, she sued her former landlord and the property management company, claiming the companies negligently failed to eradicate mold in her apartment, thereby breaching the habitability provisions of the lease and causing her to suffer personal injury and property damage. After considerable delay involving discovery disputes, the superior court granted summary judgment dismissing Punches' personal injury claim. The parties went to trial on the tenant’s property damage and contract claims after the superior court precluded the tenant from introducing evidence relating to her personal injury claim. The jury rejected Punches' claims, and judgment was entered in favor of the companies. Punches appealed, contending that the court erred by ruling against her in discovery disputes, by denying her a further extension of time to oppose summary judgment, and by limiting the evidence she could present at trial. The Alaska Supreme Court concluded the court did not abuse its discretion when making the challenged rulings, and therefore affirmed the judgment against the tenant. View "Punches v. McCarrey Glenn Apartments LLC" on Justia Law