Justia Civil Procedure Opinion Summaries

Plaintiffs, representing their minor son, sued a hospital and a doctor for medical malpractice after their baby suffered birth injuries during delivery. They sought $6,000,000 in damages. Under Puerto Rico law, damages would be capped at $150,000 if the doctor was a faculty member at the hospital at the time of the birth. The defendants claimed the doctor was a faculty member, but could not produce a contract to prove it. The district court held a pretrial evidentiary hearing and concluded that the doctor was a faculty member, thus applying the statutory cap on damages.The U.S. District Court for the District of Puerto Rico adopted a magistrate judge's Report & Recommendation, which stated that the applicability of the statutory cap was a matter of law. The district court found that the doctor was a faculty member based on testimony and letters from the medical school, despite the absence of a contract. Plaintiffs appealed, arguing that the applicability of the statutory cap was a factual question that should have been decided by a jury.The United States Court of Appeals for the First Circuit reviewed the case. The court held that whether the doctor was a faculty member at the time of the birth was a factual question requiring a jury's determination. The court found that the evidence was not one-sided enough to compel the district court's conclusion and that the district court improperly took the question from the jury. The First Circuit vacated the district court's order and remanded the case for further proceedings consistent with its opinion. View "Perez-Perez v. Hospital Episcopal San Lucas Inc." on Justia Law

David Burke died after falling down retractable steps attached to his motorhome. His estate, wife, and children filed product liability claims against Lippert Components, Inc., and LCI Industries, who had purchased the product brand after the Burkes bought the vehicle. The plaintiffs alleged negligence, design defects, manufacturing defects, and inadequate instructions and warnings. They later sought to add the previous owners of the product brand as defendants and amend the scheduling order, but the district court denied these motions and granted summary judgment in favor of Lippert and LCI.The United States District Court for the Northern District of Iowa denied the plaintiffs' motions to amend the complaint and the scheduling order, citing unreasonable delay. The court then granted summary judgment for Lippert and LCI, finding that they did not manufacture, distribute, or sell the steps in question, and thus were not liable under Iowa law. The plaintiffs appealed these decisions.The United States Court of Appeals for the Eighth Circuit affirmed the district court's rulings. The appellate court held that Lippert and LCI were not required to plead an affirmative defense regarding successor liability, as their defense negated an essential element of the plaintiffs' claims. The court also found that Lippert and LCI did not assume liability through the purchase agreement and that expert testimony was necessary to support the claim of inadequate post-sale warnings. Finally, the court agreed that the plaintiffs failed to show good cause for their delayed motions to amend the complaint and scheduling order. The judgment of the district court was affirmed. View "Burke v. Lippert Components, Inc." on Justia Law

Jose Vasquez was detained twice by the Metropolitan Police Department (MPD) because he shares the same name and birthdate as a wanted criminal. He sued the District of Columbia and an officer for constitutional violations under Section 1983, and the District alone for negligence, malicious prosecution, and false imprisonment. The District Court granted summary judgment on the Section 1983 and negligence claims. The jury found the District liable for false imprisonment but not for malicious prosecution, awarding Vasquez $100,000. However, the District Court later granted the District's motion for judgment as a matter of law, nullifying the jury's award, and alternatively granted a motion for remittitur.The United States District Court for the District of Columbia initially reviewed the case. It granted summary judgment in favor of the District and Officer Agosto on the Section 1983 claims, finding no constitutional violations. The court also dismissed the negligence claim. The jury trial on the common law claims resulted in a mixed verdict, with the jury awarding damages for false imprisonment but not for malicious prosecution. The District Court subsequently overturned the jury's verdict on false imprisonment and reduced the damages awarded.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. It affirmed the District Court's summary judgment on the Section 1983 claims, agreeing that there was no clearly established constitutional violation and that qualified immunity applied to Officer Agosto. However, the appellate court vacated the District Court's judgment as a matter of law and the alternative remittitur on the false imprisonment claim. The appellate court reinstated the jury's verdict and remanded for further proceedings, emphasizing that the jury could reasonably find that the differing social security numbers indicated Vasquez was not the wanted criminal, and that the jury's damages award was justified based on the emotional harm suffered. View "Vasquez v. District of Columbia" on Justia Law

Justin Nelson filed a lawsuit against his former mother-in-law, Traci Phillips, former sister-in-law, Ashley Phillips, and other friends and family of his deceased wife, Tiffani Nelson. Justin alleged that Traci, Ashley, and the other defendants conspired to defame him by suggesting he was responsible for Tiffani’s death. None of the defendants reside in Utah, and each moved to dismiss the complaint for lack of personal jurisdiction. They provided sworn statements denying the allegations, while Justin relied solely on his complaint’s allegations without submitting counter-evidence.The Fifth District Court in Washington County, Utah, denied the motions to dismiss. The court concluded that Justin had sufficiently alleged facts that, if proven, would demonstrate a conspiracy to defame him, thus establishing personal jurisdiction over the defendants. For Traci and Ashley, the court found that their personal contacts with Utah were sufficient to assert specific personal jurisdiction.The Utah Supreme Court reviewed the case. The court dismissed the petitions for interlocutory review filed by Traci and Ashley as improvidently granted, as the lower court had not ruled on the conspiracy theory of jurisdiction for them. The court reversed the lower court’s denial of the motions to dismiss for the other defendants, finding that Justin failed to meet his burden of providing evidence to support his allegations once the defendants had submitted sworn statements contradicting his claims. The court emphasized that without evidence to support the allegations, the district court could not assert jurisdiction based on a conspiracy theory. The case was remanded for further proceedings consistent with this opinion. View "Nelson v. Phillips" on Justia Law

Three customers, D.W., L.T., and J.G., filed a lawsuit against FPA Sandy Mall Associates (SMA) and Hong Guang Lin, an unlicensed massage therapist, after Lin allegedly sexually assaulted them during their massage appointments at a shopping center owned by SMA. The plaintiffs claimed premises liability and negligence, arguing that SMA, as the landlord, had a duty to ensure the safety of its invitees and to verify Lin's licensure status.The Third District Court in Salt Lake County denied SMA's motion to dismiss the claims, concluding that SMA owed a duty to the plaintiffs as invitees to keep the premises safe and to exercise reasonable care. The court also applied the five-factor analytical framework from B.R. ex rel. Jeffs v. West, 2012 UT 11, 275 P.3d 228 (Jeffs factors), to assess whether SMA had a duty to verify Lin's licensure status and found that the factors favored recognizing such a duty.The Utah Supreme Court reviewed the case on interlocutory appeal. The court clarified that the Jeffs framework is only applicable when a party seeks to establish a previously unrecognized duty. Since the plaintiffs invoked established duties under Utah law, the district court's application of the Jeffs factors was unnecessary. The Supreme Court struck the district court's analysis based on the Jeffs factors, including its observations on foreseeability, and remanded the case for further proceedings consistent with its instructions. The court did not address whether SMA owed a duty to verify Lin's licensure status, as this was not the duty recognized by the district court. View "D.W. v. FPA Sandy Mall Associates" on Justia Law

Anne G. McNair experienced a perforated esophagus and infection following cervical fusion surgery performed by Dr. Joshua D. Beck at North Lincoln County Hospital District, d/b/a Star Valley Health. Dr. Beck, employed by Orthopaedics of Jackson Hole, P.C., d/b/a Teton Orthopaedics, continued to treat her post-surgery. McNair filed a complaint against Dr. Beck, Teton, and Star Valley, alleging medical malpractice, negligence, and vicarious liability. The district court dismissed her complaint, citing the statute of limitations, and denied her motion to amend the complaint, deeming it futile.The District Court of Lincoln County granted the defendants' motions to dismiss, concluding that McNair's claims were filed beyond the two-year statute of limitations for medical malpractice actions. The court determined that the continuous treatment rule did not apply, as McNair's injury stemmed from a single act of negligence during the surgery on December 30, 2020. Consequently, the court found that the statute of limitations began on December 31, 2020, the date McNair was discharged from the hospital, making her April 2023 filings untimely. The court also denied McNair's motion to amend her complaint, asserting that any amendment would be futile.The Supreme Court of Wyoming reviewed the case and found that the district court erred in its application of the continuous treatment rule. The Supreme Court held that the continuous treatment rule applies when a medical provider has provided ongoing care for the same or related complaints. The court noted that McNair's complaint alleged continuous treatment by Dr. Beck and Teton into early 2021, which could extend the statute of limitations. The court also found that the district court abused its discretion in denying McNair's motion to amend her complaint, as the proposed amendments did not show on their face that the claims were untimely. The Supreme Court reversed the district court's decision and remanded the case for further proceedings. View "McNair v. Beck" on Justia Law

Christopher Hildebrant, a real-estate developer, facilitated a property sale in 2011 and expected consulting fees from both the seller and the buyer. During the transaction, Hildebrant alleged that Thomas Weidman, a trustee on the Sycamore Township Board, demanded a kickback. To avoid paying, Hildebrant created a fictitious email account and sent himself an email portraying Weidman as demanding payments. This email was forwarded to another party but remained private until 2020, when Hildebrant showed it to other township officials during a separate transaction. Weidman learned of the email in November 2020 during an investigation and received a copy in January 2021.The Warren County Court of Common Pleas granted Hildebrant’s motion for summary judgment, ruling that Weidman’s defamation claim was time-barred by the statute of limitations, which began when the email was first sent in 2011. The court also ruled that Weidman’s claims for intentional infliction of emotional distress (IIED) and false-light invasion of privacy were similarly time-barred as they were derivative of the defamation claim.The Twelfth District Court of Appeals reversed, holding that the discovery rule applied to defamation claims when the publication was secretive or inherently unknowable. The court ruled that Weidman’s claims were not time-barred because he could not have known about the defamatory email until it was disclosed to him in 2020.The Supreme Court of Ohio affirmed the appellate court’s decision, holding that the discovery rule applies to libel claims when the publication is secretive or inherently unknowable. The court also held that the discovery rule applies to derivative claims like IIED and false-light invasion of privacy when they are based on the same allegations as the libel claim. The case was remanded to the Warren County Court of Common Pleas for further proceedings. View "Weidman v. Hildebrandt" on Justia Law

Jessica Wiseman and her children sued Dr. Nathan Rencher and others for the wrongful death of Eric Wiseman, alleging medical malpractice and gross negligence. Rencher, the only defendant subject to Idaho's prelitigation screening panel requirement, moved for summary judgment, arguing that the Wisemans failed to comply with this requirement. He supported his motion with the panel’s advisory decision, filed under seal. The district court granted Rencher’s motion, concluding that the Wisemans did not meet the prelitigation requirement based on the advisory decision. The Wisemans also sought to disqualify the district judge, which was denied.The district court, part of the Seventh Judicial District of Idaho, ruled that the advisory decision could be considered to determine compliance with the prelitigation requirement. The court found the statutes ambiguous and concluded that they allowed limited review of the advisory decision. The court also ruled that the statutes controlled over conflicting Idaho Rules of Evidence. Consequently, the district court granted summary judgment in favor of Rencher, finding no genuine issue of material fact regarding the Wisemans' compliance with the prelitigation requirement.The Supreme Court of Idaho reversed the district court’s decision, holding that the prelitigation screening statutes unequivocally precluded judicial review of the advisory decision for any purpose. The court emphasized that the statutes clearly stated there should be no judicial review and that parties should not be affected by the panel’s conclusions. The Supreme Court remanded the case for further proceedings. Additionally, the court declined to disqualify the district judge on remand, distinguishing this case from precedent and finding no appearance of bias. Neither party was awarded attorney fees on appeal, as both prevailed in part. View "Wiseman v. Rencher" on Justia Law

Pearl Ray and Andrew Ray, Sr. sued medical providers in Illinois state court for medical malpractice, which allegedly injured Pearl and caused Andrew to suffer a loss of consortium. They settled with all but one defendant. Pearl was enrolled in a federal health benefits plan, and Blue Cross and Blue Shield Association (BCBSA) was the plan’s carrier. Under the plan, BCBSA sought reimbursement from the settlement for benefits paid to Pearl. The plaintiffs filed a motion to reduce BCBSA’s reimbursement by their attorney’s fees and costs under Illinois’s common fund doctrine.The case was removed to federal court by BCBSA, arguing federal question jurisdiction and federal officer removal. The United States District Court for the Northern District of Illinois initially denied the remand motion but later reconsidered and remanded the entire case, concluding it lacked federal question jurisdiction. BCBSA appealed, asserting federal question jurisdiction and federal officer removal.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The court held that federal question jurisdiction was not present, as federal common law did not govern the reimbursement dispute, following the precedent set by Empire Healthchoice Assurance, Inc. v. McVeigh and Blue Cross Blue Shield of Illinois v. Cruz. However, the court found that BCBSA met the requirements for federal officer removal under 28 U.S.C. § 1442, as it was acting under a federal agency (OPM) and had a colorable federal defense.The Seventh Circuit affirmed the district court’s decision in part, reversed in part, and remanded, instructing the district court to exercise jurisdiction over the motion for adjudication while remanding the rest of the case to state court. View "Ray v. Tabriz" on Justia Law

In 2019, the California Legislature enacted Assembly Bill No. 218 (AB 218), which allowed plaintiffs to bring childhood sexual assault claims against public entities within a three-year window, even if those claims were previously barred by statutes of limitations or claim presentation requirements. A.M.M. filed a complaint against the West Contra Costa Unified School District, alleging sexual assaults by a District employee from 1979 to 1983. The District argued that reviving such claims constituted an unconstitutional gift of public funds under the California Constitution. The trial court overruled the District’s demurrer, leading the District to seek writ review.The trial court sustained the demurrer for the first three causes of action but overruled it regarding the gift clause argument. The District then petitioned the California Court of Appeal, First Appellate District, for a writ of mandate to sustain the demurrer in its entirety. The appellate court issued an order to show cause, and both parties filed responses, including amicus curiae briefs from various entities.The California Court of Appeal, First Appellate District, held that AB 218’s retroactive waiver of the claim presentation requirement did not constitute an unconstitutional gift of public funds. The court reasoned that the waiver did not create new substantive liability but merely removed a procedural barrier to existing claims. The court also found that AB 218 served a valid public purpose by providing relief to victims of childhood sexual assault, aligning with the state’s interest in public welfare. Additionally, the court ruled that the District lacked standing to assert due process claims under both the federal and California Constitutions. The petition for writ of mandate was denied. View "West Contra Costa Unified School District v. Superior Court" on Justia Law