Justia Civil Procedure Opinion Summaries

Iron Bar Holdings, LLC, a private landowner in Wyoming, owns a checkerboarded ranch interspersed with federal and state public lands. The only way to access these public lands, other than by aircraft, is by corner-crossing, which involves stepping from one public parcel to another at their adjoining corners without touching the private land in between. In 2020 and 2021, a group of hunters from Missouri corner-crossed to hunt elk on the public lands within Iron Bar's ranch. Iron Bar's property manager confronted the hunters, and law enforcement was contacted, but no citations were issued. In 2021, the hunters were prosecuted for criminal trespass but were acquitted. Iron Bar then filed a civil lawsuit for trespassing, seeking $9 million in damages.The United States District Court for the District of Wyoming granted summary judgment in favor of the hunters, holding that corner-crossing without physically contacting private land and without causing damage does not constitute unlawful trespass. Iron Bar Holdings appealed the decision.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that while Wyoming law recognizes a property owner's right to exclude others from their airspace, federal law, specifically the Unlawful Inclosures Act (UIA) of 1885, overrides state law in this context. The UIA prohibits any inclosure of public lands that obstructs free passage or transit over them. The court found that Iron Bar's actions effectively enclosed public lands and prevented lawful access, which is prohibited by the UIA. The court affirmed the district court's decision, allowing the hunters to corner-cross as long as they did not physically touch Iron Bar's land. View "Iron Bar Holdings v. Cape" on Justia Law

Woodsonia Hwy 281, LLC (Woodsonia) owned a retail shopping mall in Grand Island, Nebraska, and leased space to American Multi-Cinema, Inc. (AMC). Woodsonia planned to redevelop the mall and sought to terminate AMC's lease under the eminent domain provisions of the lease agreement. Woodsonia claimed that the lease was terminated after conveying AMC's leasehold interest to the Community Redevelopment Authority (CRA) under threat of condemnation. AMC disputed the termination, arguing that the conditions for termination under the lease were not met.The County Court for Hall County overruled AMC's motion to dismiss for lack of subject matter jurisdiction, finding that the lease was terminated under the eminent domain provisions and granted Woodsonia restitution of the premises. AMC appealed to the District Court for Hall County, which affirmed the County Court's decision, reasoning that the lease provisions allowed Woodsonia to transfer AMC's leasehold interest under threat of condemnation.The Nebraska Supreme Court reviewed the case and determined that the forcible entry and detainer action presented a title dispute, as the court needed to resolve whether AMC's leasehold interest was validly terminated. The court held that such a title dispute could not be determined in a forcible entry and detainer action, which is limited to determining the immediate right of possession without addressing title issues. Consequently, the County Court lacked subject matter jurisdiction and should have dismissed the action.The Nebraska Supreme Court vacated the judgment of the District Court and remanded the case with directions to vacate the County Court's judgment and dismiss the action for lack of jurisdiction. View "Woodsonia Hwy 281 v. American Multi-Cinema" on Justia Law

James and Amber May hired RES Construction to build their home in Sioux Falls. RES subcontracted First Rate Excavate, Inc. to install the septic system and construct the foundation. The Mays alleged that the foundation was installed several feet below grade level, causing significant drainage and septic issues that damaged their home, yard, and neighboring properties. They sued First Rate for negligence. The circuit court dismissed the claim based on the economic loss doctrine, and the Mays appealed.The Circuit Court of the Second Judicial Circuit in Lincoln County, South Dakota, dismissed the Mays' negligence claim, citing the economic loss doctrine, which limits remedies for purely economic losses to those specified in a contract. The court reasoned that the Mays lacked privity of contract with First Rate and that their claims were barred by the six-year statute of limitations.The Supreme Court of the State of South Dakota reviewed the case. The court held that the economic loss doctrine should not be expanded beyond claims arising from transactions involving the sale of defective goods under the Uniform Commercial Code (UCC). The court noted that the doctrine is designed to prevent parties from circumventing contract remedies by seeking tort remedies for economic losses. Since the Mays' claim was based on negligence and not on a UCC transaction, the economic loss doctrine did not apply. Additionally, the court found that the lack of privity between the Mays and First Rate further precluded the application of the economic loss doctrine. The Supreme Court reversed the circuit court's dismissal and remanded the case for further proceedings. View "May v. First Rate Excavate" on Justia Law

Plaintiffs owned property adjacent to an unpaved road where the Town of Lodi determined that low-hanging branches and dead or dying trees posed a hazard. In 2010, the Town hired a tree service company to cut or remove fifty-five trees on plaintiffs' land, believing the trees were within the right of way. Plaintiffs disagreed and sought treble damages under RPAPL 861 (1). The parties agreed to binding arbitration, and the arbitrator awarded plaintiffs damages, including treble the "stumpage value" of the trees.The Supreme Court confirmed the arbitrator's award, and a divided Appellate Division affirmed. The Appellate Division majority held that treble damages under RPAPL 861 were not punitive but intended to capture elusive compensatory damages. The dissenting justices argued that the treble damages were punitive and could not be awarded against the Town. The Town appealed to the Court of Appeals.The New York Court of Appeals reviewed the case and held that treble damages under RPAPL 861 are punitive in nature. The Court reasoned that the statute's "good faith" provision, which reduces damages from treble to single if the defendant acted in good faith, indicates a punitive intent. The Court also noted that the legislative history and structure of the statute support the conclusion that treble damages are meant to punish and deter wrongful conduct. Consequently, the Court reversed the Appellate Division's order insofar as appealed from, with costs, and granted the petition to vacate the award in part. View "Matter of Rosbaugh v Town of Lodi" on Justia Law

The case involves a dispute over the lease of a commercial property that has lasted nearly eight years. The plaintiff brought claims against the defendants for breach of contract, breach of the implied covenant of good faith and fair dealing, and a violation of G. L. c. 93A. The plaintiff prevailed at trial and was awarded a monetary judgment of over $20 million. The defendants paid the full amount of the judgment but notified the plaintiff that they intended to exercise their appellate rights.The Superior Court initially handled the case, and the plaintiff prevailed. The defendants appealed, and the Appeals Court affirmed the judgment. The defendants then sought further appellate review, which the Supreme Judicial Court granted, limited to issues related to postjudgment interest.The Supreme Judicial Court of Massachusetts reviewed the case and held that the exercise of appellate rights does not constitute a condition on the payment of a judgment. Therefore, the judgment was fully satisfied when it was paid in full, and the accrual of postjudgment interest halted upon payment. The court concluded that postjudgment interest is meant to compensate the prevailing party for the loss of the use of money when damages are not paid on time, not to punish or discourage appeals. The court reversed the portion of the lower court's order that allowed for the accrual of postjudgment interest after the defendants' payment in full. View "H1 Lincoln, Inc. v. South Washington Street, LLC" on Justia Law

The plaintiffs, Michael R. and Christine O. McElroy, claimed an express or implied easement to access Seaweed Beach in Narragansett, Rhode Island, and to traverse certain private properties to reach the beach. The private properties in question are owned by Marilyn O. Stephens, Paul G. and Nancy L. Anthony, and Vivian H. Lacroix. The dispute arose when the Stephenses blocked access to their driveway, which the McElroys used to reach Seaweed Beach.In the Superior Court, the McElroys sought to quiet title to the easement, a declaration of their rights, and injunctive relief. The court initially granted summary judgment in favor of the McElroys, but the Rhode Island Supreme Court vacated this judgment, citing unresolved factual issues. Upon remand, a bench trial was conducted, and the trial justice found that the McElroys had an express easement upon Seaweed Beach and an implied easement over the Stephens property. However, the court ruled that the McElroys did not have easements over the Anthony or Lacroix properties.The Rhode Island Supreme Court reviewed the case and affirmed the trial justice's findings. The court held that the 1986 warranty deed clearly incorporated the 1929 express easement upon Seaweed Beach. The court also upheld the trial justice's determination that the McElroys had an implied easement over the Stephens property, as it was necessary for the enjoyment of their express easement on Seaweed Beach. The court found no error in the trial justice's admission of the 1986 purchase and sales agreement as extrinsic evidence to establish the implied easement. Finally, the court concluded that the trial justice did not err in denying the motion to amend the judgment, as the alleged inconsistencies did not constitute a manifest error of law. View "McElroy v. Stephens" on Justia Law

Juanita and Stephen Clark, Linda and Cliff Trebilcock, and Dan Gurney reside on Fuller Mountain Road in the Town of Phippsburg. Gurney has operated a firewood business from his property for thirty years. In September 2020, the Clarks and the Trebilcocks complained to the Town’s Code Enforcement Officer (CEO) that Gurney’s business was a nuisance under the Town’s Land Use Ordinance (LUO). The CEO found no violation, but the Clarks and the Trebilcocks appealed to the Board of Appeals (BOA), which found the business to be a nuisance. The Board of Selectmen (BOS) later found that Gurney had abated the nuisance.The Clarks and the Trebilcocks challenged the BOS’s decision in the Superior Court (Sagadahoc County), arguing that the BOS lacked authority to conduct a de novo review and that there were due process violations. The Superior Court affirmed the BOS’s decision, leading to the Clarks’ appeal to the Maine Supreme Judicial Court.The Maine Supreme Judicial Court concluded that the BOA’s findings were outside the scope of the current appeal but found that the BOS exceeded its authority and violated due process in its review. The Court held that the BOS did not have the authority to review the CEO’s decision and that the BOS’s role was limited to deciding whether a consent agreement could be achieved or if court action was necessary. The Court also found procedural due process violations due to the conduct of BOS Chair Julia House, who exhibited bias and engaged in ex parte communications.The Court vacated the judgment and remanded the case to the Superior Court with instructions to remand to the BOS for new proceedings without the participation of Chair Julia House. View "Clark v. Town of Phippsburg" on Justia Law

Kafi, Inc. ("Kafi") owns a residential property in League City, Texas, which it purchased from Joe and Kelly Richardson in September 2020. The Richardsons had financed the property with a loan from Sand Canyon Corporation in 2006, secured by an Adjustable Rate Note and a Deed of Trust. Sand Canyon transferred its interest in the loan to Wells Fargo Bank, N.A. ("Wells Fargo") in October 2006. Kafi challenged Wells Fargo's right to foreclose on the property, claiming the assignment of the Deed of Trust was forged. Kafi also sought equitable redemption, arguing it should be allowed to pay off any valid liens before foreclosure.The case was initially filed in Texas state court and then removed to the United States District Court for the Southern District of Texas. The district court dismissed Kafi's claims against Sand Canyon and Nationwide Title Clearing, Inc., and dismissed Kafi's standalone forgery claim and claim for exemplary damages. The court allowed Kafi's claims for declaratory relief, quiet title, and equitable redemption to proceed. Wells Fargo and PHH Mortgage Corporation filed a motion for summary judgment, which the district court granted, dismissing Kafi's remaining claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that Wells Fargo, as the holder of the Note, had standing to foreclose on the property under Texas law, regardless of the alleged forgery in the assignment of the Deed of Trust. The court also upheld the dismissal of Kafi's equitable redemption claim, noting that Kafi failed to provide sufficient evidence that it was ready, willing, and able to pay the redemption amount. The court emphasized that Kafi's declaration, which stated it was ready, able, or willing to redeem the property, was insufficient to meet the conjunctive requirement of being ready, willing, and able. Thus, the Fifth Circuit affirmed the district court's summary judgment in favor of Wells Fargo. View "Kafi, Inc. v. Wells Fargo Bank" on Justia Law

Plaintiffs Clifford Osborne and Deborah Olsen sued their former landlord, Kevin Belton, for disability discrimination and retaliation under the Fair Housing Act (FHA) and the Louisiana Equal Housing Opportunity Act (LEHOA). The dispute arose when Belton, who initially allowed the plaintiffs to keep a dog temporarily, later prohibited the dog and threatened eviction. Despite Osborne providing a letter from his physician stating the need for a service dog due to mental health issues, Belton refused to accept it and proceeded with eviction, which was granted by a Louisiana justice of the peace court.In early 2020, Osborne and Olsen filed a lawsuit in the United States District Court for the Western District of Louisiana. They moved for summary judgment, which Belton did not oppose, leading the district court to grant the motion in August 2022. Belton subsequently filed a Rule 60(b) motion for relief from the judgment nearly a year later, which the district court denied. He then filed a Rule 59(e) motion for reconsideration of the denial of his Rule 60(b) motion, which was also denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it had jurisdiction to review only the order denying Belton’s Rule 60(b) motion, as the notice of appeal was timely for this order but not for the underlying summary judgment. The Fifth Circuit held that the district court did not abuse its discretion in denying the Rule 60(b) motion, as Belton failed to establish grounds for relief such as excusable neglect, newly discovered evidence, fraud, or a void judgment. Consequently, the Fifth Circuit affirmed the district court’s denial of Belton’s Rule 60(b) motion. View "Osborne v. Belton" on Justia Law

Charles Bich and the Bruno Bich Trust made a series of loans to WW3 LLC, owned by Curt Waldvogel, for constructing an oil-processing facility in North Dakota. Waldvogel assured the Bichs that their investment would be secured by real and personal property. However, the project failed, and the Bichs did not recover their investment, leading them to sue for breach of contract.The Eastern District of Wisconsin court found that Waldvogel's promise to secure the loans with property was a "special promise" under Wisconsin law, requiring compliance with the statute of frauds. Since there was no written agreement meeting the statute's requirements, the court ruled the loan agreement unenforceable. The court also determined that the promise would have constituted a mortgage, which also needed to satisfy the statute of frauds. The court granted summary judgment to the defendants on the breach of contract claim but allowed the unjust enrichment claim to proceed to trial. The jury awarded the Bichs $200,000 for unjust enrichment, and the court held Waldvogel and WW3 jointly and severally liable.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, agreeing that the promise to secure the loans with property was a mortgage under Wisconsin law and required a written agreement to be enforceable. The court found that the emails exchanged between the parties did not constitute a final agreement and did not meet the statute of frauds' requirements. Consequently, the breach of contract claim failed, and the unjust enrichment award remained the only compensation for the Bichs. View "Bich v WW3 LLC" on Justia Law