Justia Civil Procedure Opinion Summaries

The case revolves around a major land development project proposed for multiple parcels of real estate in North Kingstown, Rhode Island. The project was approved by the North Kingstown Planning Commission in 2012. The North Kingstown Town Council amended the zoning ordinance to create a Compact Village District (CVD) zone, which included the developers' property. In 2017, the town council again amended the zoning ordinance for the town’s CVD zone, limiting commercial building coverage and providing a ratio of buildings on the property. The developers challenged the ordinance in federal court, alleging that their project had vested prior to the 2017 ordinance’s limitations. After mediation and settlement discussions, a proposed consent judgment was prepared. The town council approved the consent judgment and the planning commission approved the developers’ preliminary plan for the project.The North Kingstown Zoning Board of Review upheld the planning commission's decision, concluding that the consent judgment recognized the developers’ vested rights and that the project was not bound by the subsequent 2017 zoning amendments. Rickey Thompson, a property owner within 200 feet of the project, filed an action in the Superior Court seeking a declaratory judgment that the town council was not authorized to enter into the consent judgment and that the planning commission should not have relied upon the terms of the consent judgment to review the developers’ application for preliminary plan approval.The Superior Court granted the defendants' motion for summary judgment, finding that Thompson had made an improper collateral attack on the consent judgment, as a nonparty, and that the town had the authority to enter into the agreement. Thompson appealed this decision.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court found that Thompson, as a nonparty to the consent judgment, lacked the requisite standing to challenge the agreement and was thus barred from making a collateral attack on what is a valid, final judgment in federal court. The court also found that the town had the authority to enter into the agreement and the consent judgment did not illegally constrain the planning commission’s authority. The court rejected Thompson’s argument that the consent judgment illegally amended the town’s zoning ordinance. The court also found that Thompson's argument that the town and the developers engaged in contract zoning was not raised in Superior Court and was thus waived. View "Thompson v. Town of North Kingstown Zoning Board of Appeals" on Justia Law

The case revolves around a dispute between Long Lake Township and Todd and Heather Maxon. The township alleged that the Maxons were storing junk cars on their property, violating a zoning ordinance, a nuisance law, and a 2008 settlement agreement. As the property was not visible from the street, the township hired a drone operator to take aerial photographs and video of the property without the Maxons' permission or a warrant. The Maxons moved to suppress the aerial photographs and all other evidence obtained by the township from the drone, asserting that the search was illegal under the Fourth Amendment.The Grand Traverse Circuit Court denied the Maxons’ motion, reasoning that the drone surveillance did not constitute a search. The Court of Appeals, in a split decision, reversed the lower court's ruling, holding that the drone surveillance violated the Fourth Amendment. The township appealed to the Supreme Court, which ordered the parties to file supplemental briefs regarding whether the exclusionary rule applied to the facts of this case. The Supreme Court then vacated its earlier order and remanded the case to the Court of Appeals for consideration of whether the exclusionary rule applied. On remand, the Court of Appeals, in a split decision, held that the exclusionary rule did not apply and that the photographs and video could not be suppressed regardless of whether the township unreasonably searched the Maxons’ property.The Michigan Supreme Court, in a unanimous opinion, held that the exclusionary rule may not be applied to civil enforcement proceedings that effectuate local zoning and nuisance ordinances and seek only prospective, injunctive relief. The court found that the costs of excluding the drone evidence outweighed the benefits of suppressing it, and the exclusionary rule therefore did not apply. The decision of the Court of Appeals was affirmed, and the case was remanded to the trial court for further proceedings. View "Long Lake Township v. Maxon" on Justia Law

The case revolves around a dispute over oil and gas interests between Spottie, Inc., a Nevada corporation, and several other Nevada corporations and a limited liability company. Spottie alleged that the defendants had wrongfully claimed title to these interests, which were once owned by Edward Davis, who had formed Spottie as a holding company. The defendants countered that they had entered into an agreement with Davis to acquire these interests, and that Davis and Spottie had transferred the disputed interests to one of the defendants via an assignment in 2016.The district court dismissed several of Spottie's claims, leaving only a quiet title claim and a claim for unjust enrichment. After a three-day bench trial, the court ruled in favor of the defendants, finding that the assignment from Davis and Spottie to one of the defendants was valid. The court also found that Spottie had erroneously received revenue from the disputed interests and awarded damages to the defendants.Spottie appealed the decision, arguing that the district court had erred in its ownership determination, its rejection of Spottie's laches defense, its binding of a non-party to the judgment, and its award of attorney fees and costs. The Supreme Court of North Dakota affirmed in part, concluding that the district court did not err in its ownership determination and its award of attorney fees. However, it reversed in part, finding that the court had erred in awarding costs for non-legal expenses. The case was remanded for the court to recalculate its cost award and to consider the defendants' request for additional attorney fees and legal costs. View "SPOTTIE v. BAIUL-FARINA" on Justia Law

The case revolves around a construction dispute where several homeowners in the San Marcial neighborhood sued Oscar Renda Contracting, Inc., for negligence and gross negligence. The homeowners alleged that the company's misuse of heavy equipment and faulty construction techniques caused damage to their homes during the construction of a drainage pipeline. They sought actual damages to restore their properties and exemplary damages based on gross negligence.The trial court found Renda Contracting negligent and grossly negligent. However, the jury was not unanimous in deciding the amount of exemplary damages, with ten out of twelve jurors agreeing. Consequently, the trial court omitted exemplary damages from the judgment. The homeowners appealed, and the court of appeals reversed the decision, arguing that unanimity as to exemplary damages could be implied despite a divided verdict.The Supreme Court of Texas reversed the court of appeals' judgment and reinstated the trial court's judgment. The court held that under Section 41.003 of the Civil Practice and Remedies Code, a court may not imply a unanimous jury finding in imposing exemplary damages. The burden to secure a unanimous verdict is on the plaintiff and "may not be shifted." The court concluded that the plaintiff bears the burden to obtain the findings necessary to impose exemplary damages, including that the jury is unanimous as to any amount of exemplary damages awarded. It is the plaintiff who must challenge a divided verdict as infirm or in need of clarification. View "OSCAR RENDA CONTRACTING, INC. v. BRUCE" on Justia Law

The case involves Juan Angel Rubalcaba, a homeowner, who filed a wrongful foreclosure lawsuit against the Association of Apartment Owners of Makakilo Cliffs. The central issue was whether the mortgage debt of the homeowner to a third-party lender, which was discharged by the third-party lender's subsequent foreclosure, should be considered in determining the plaintiff's damages.The Circuit Court of the First Circuit sought guidance on this issue and forwarded a reserved question to the Supreme Court of the State of Hawai'i. The Supreme Court accepted the question, indicating that it would provide an answer through a related case, Wong v. Ass'n of Apartment Owners of Harbor Square, which was then pending before the court.The Supreme Court of the State of Hawai'i, after deciding the Wong case, provided guidance on how a plaintiff may calculate damages in a lawsuit against a condominium association for wrongful foreclosure. The court then remanded the case back to the Circuit Court of the First Circuit for further proceedings consistent with the Wong decision. The court did not provide a specific ruling on the reserved question but indicated that the lower court should follow the precedent set in the Wong case. View "Rubalcaba v. Association of Apartment Owners of Makakilo Cliffs " on Justia Law

The case involves successors in interest of mineral-rights holders who sued in 2019 to declare a 1999 judgment foreclosing on their predecessors’ property for delinquent taxes as void. They argued that there was constitutionally inadequate notice of the foreclosure suit, rendering the foreclosure judgment and the tax sale that followed both void. The current owners sought traditional summary judgment based on the Tax Code’s command that an action relating to the title to property against the purchaser of the property at a tax sale may not be commenced later than one year after the date that the deed executed to the purchaser at the tax sale is filed of record.The trial court granted the current owners' motion for summary judgment, and the court of appeals affirmed. The majority held that the sheriff’s deed conclusively established the accrual date for limitations, so the burden shifted to the successors to adduce evidence raising a genuine issue of material fact as to whether there was a due-process violation that could render the statute of limitations inoperable. Because the successors relied only on their arguments and presented no evidence of a due-process violation, the majority concluded, the current owners were entitled to summary judgment.The Supreme Court of Texas held that under Draughon v. Johnson, the nonmovant seeking to avoid the limitations bar by raising a due-process challenge bears the burden to adduce evidence raising a genuine issue of material fact about whether the underlying judgment is actually void for lack of due process. Because the nonmovant here adduced no such evidence, the trial court correctly granted summary judgment based on Section 33.54(a)(1). However, the court also noted that the law governing this case has undergone meaningful refinement since the summary-judgment proceedings took place. Given these recent and substantial developments in the relevant law, the court remanded this case to the trial court for further proceedings in the interest of justice. View "GILL v. HILL" on Justia Law

The case involves T & C Construction Services and Theodore Miller (collectively, T & C), who operate a rental building in St. Albans, West Virginia. The City of St. Albans inspected the premises after a tenant reported a fire, revealing numerous fire hazards and building code violations. The City issued two citations for these violations, and the St. Albans Municipal Court fined T & C $81,250.00 for the fire code violations and $116,900.00 for the building code violations. After T & C failed to appeal these orders, the City sought enforcement in the Circuit Court of Kanawha County.The Circuit Court of Kanawha County issued a cease-and-desist order that enjoined T & C from operating its rental business on the premises, granted the City a money judgment for the criminal fines, and appointed a special commissioner to sell the property to satisfy the judgment. T & C appealed this enforcement order to the Supreme Court of Appeals of West Virginia.The Supreme Court of Appeals of West Virginia affirmed the lower court's decision to grant injunctive relief, rejecting T & C’s challenges to the injunctive relief. The court found that the lower court had jurisdiction to grant injunctive relief and did not abuse its discretion in doing so. However, the court reversed the lower court's appointment of a special commissioner to sell the property. The court held that the issuance and return of a writ of fieri facias showing “no property found” is a precondition to a circuit court’s jurisdiction to order the sale of a debtor’s property to satisfy a judgment for a criminal fine. The case was remanded for proceedings consistent with this opinion. View "T & C Construction Services, LLC v. City of St. Albans" on Justia Law

The case involves plaintiffs Pamela Antosh and Ned Lashley, who challenged the Village of Mount Pleasant's use of its eminent-domain power to acquire their property for road improvements associated with the private Foxconn development. In state court, the plaintiffs contested only the amount of compensation they were owed, not the propriety of the taking. However, when the state court ruled against them on an evidentiary issue two years into litigation, they decided to try their luck in federal court. In their federal complaint, they alleged for the first time that the taking was improper because it served a private purpose, not a public one.The state court proceedings were stayed pending the resolution of the federal suit. The Village filed a motion to dismiss the federal complaint, arguing that the federal court should abstain from exercising its jurisdiction over the proceeding. The district court agreed, dismissing the federal claims without prejudice, citing Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976). The plaintiffs appealed this judgment.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that the district court was correct to refrain from exercising jurisdiction over the federal claims. The court concluded that the federal and state actions were parallel and that exceptional circumstances justified the district court's decision to abstain. The court noted that the plaintiffs' litigation strategy signaled a lack of respect for the state's ability to resolve the issues properly before its courts. The court also found that the plaintiffs' federal suit was a strategic attempt to bypass an unfavorable state-court ruling two years into that litigation. View "Antosh v. Village of Mount Pleasant" on Justia Law

A group of developers, collectively referred to as "The Preserve," entered into an agreement in 2011 to purchase land in Richmond, Rhode Island, with the intention of operating an outdoor shooting range and gun club. The town council and planning board initially supported the project, but a subsequent zoning ordinance amendment prohibited such uses. The Preserve was not notified of these changes. In 2016, a new zoning district was created, once again permitting indoor and outdoor shooting ranges. The Preserve claimed that the two-year delay caused substantial revenue loss. They also alleged that the town imposed arbitrary fees, delayed the approval process, and engaged in other discriminatory practices that increased their costs and hindered their development efforts.The Superior Court dismissed The Preserve's claims for violations of substantive due process, tortious interference with contract and prospective business advantages, civil liability for crimes and offenses, and a violation of the civil Racketeer Influenced and Corrupt Organizations (RICO) statute. The court found that the claims were either barred by the statute of limitations or failed to state a claim upon which relief could be granted.The Supreme Court of Rhode Island affirmed the judgment of the Superior Court. The court held that the claims for civil liability for crimes and offenses and civil RICO were barred by a three-year statute of limitations because they were considered torts. The court also found that the statute of limitations was not tolled for the tortious interference claims, as the harm allegedly present was merely the consequence of separate and distinct acts that had occurred prior to the final approval of the land development for the resort. Therefore, all of The Preserve's claims were time-barred. View "The Preserve at Boulder Hills, LLC v. Kenyon" on Justia Law

This case involves a dispute over unpaid rent for a department store in an Illinois mall. The store was operated by CPS Partnership, which leased the retail space from WEC 98C-3 LLC. Saks Inc. guaranteed that it would pay the rent if CPS could not. However, when CPS stopped paying rent, Saks did not make any payments to WEC. This led to WEC defaulting on its mortgage, and the property was purchased by 4 Stratford Square Mall Holdings, LLC (“Stratford”) at a foreclosure auction. Initially, WEC sued Saks for damages. Later, Stratford intervened with its own claim for damages. The district court ruled only on Stratford’s claim for unpaid rent, finding that it was entitled to payment from Saks.The district court's decision was appealed to the United States Court of Appeals for the Seventh Circuit. Saks argued that Stratford lacked standing to sue, that the district court erred in certifying its judgment for immediate appeal, and that the district court erred in rejecting Saks’s affirmative defenses. The appellate court found that Stratford did have standing to sue Saks, and the district court properly certified its judgment for appeal. On the merits, the appellate court concluded that Saks could not mount any of its desired defenses as it had waived its right to present affirmative defenses to liability in the guaranty that it signed. Therefore, the appellate court affirmed the district court’s judgment. View "WEC 98C-3 LLC v. SFA Holdings Inc." on Justia Law