Justia Civil Procedure Opinion Summaries

Jackson Hole Hereford Ranch, LLC (JHHR) sought to partition real property it claimed to own as a tenant in common with Leeks Canyon Ranch, LLC (Leeks). Leeks counterclaimed, asserting sole ownership based on judicial estoppel, equitable estoppel, and adverse possession. The district court granted partial summary judgment to JHHR, dismissing Leeks’s judicial and equitable estoppel claims. After a bench trial, the court ruled against Leeks on the adverse possession claim. Leeks appealed both the summary judgment and the trial findings.The District Court of Teton County granted summary judgment to JHHR on Leeks’s judicial and equitable estoppel claims. The court found that Mr. Gill, representing JHHR, had forgotten about his 25% interest in the property during arbitration, negating the application of judicial estoppel. The court also found no evidence of willful misconduct or serious negligence by Mr. Gill, which is necessary for equitable estoppel. The court held that Mr. Gill’s statements during arbitration were not sufficient to establish estoppel.The Wyoming Supreme Court reviewed the case and affirmed the district court’s decisions. The Supreme Court agreed that judicial estoppel did not apply because Mr. Gill’s prior position was based on a mistake. The court also upheld the summary judgment on equitable estoppel, finding no evidence of willful misconduct or serious negligence by Mr. Gill. Regarding adverse possession, the Supreme Court found that Leeks failed to prove that its possession of the property was hostile to JHHR’s interest. The court noted that Leeks did not provide clear notice to JHHR that its ownership was in jeopardy, a requirement for adverse possession among cotenants. The Supreme Court affirmed the district court’s rulings in favor of JHHR. View "Leeks Canyon Ranch, LLC v. Jackson Hole Hereford Ranch, LLC" on Justia Law

The case involves a dispute between a railroad company and La Plata County over land use changes made by the railroad at its Rockwood Station. The railroad made several modifications to accommodate increased passenger traffic, including enlarging a parking lot and adding portable toilets and tents. The County claimed these changes violated its land use code and demanded compliance or corrective action.The railroad initially sought a declaratory judgment and an injunction in La Plata County District Court, arguing that the County lacked jurisdiction over its operations. While this case was pending, the County petitioned the Colorado Public Utilities Commission (PUC) for a declaratory ruling that the changes required compliance with the County's land use code. The PUC accepted the petition, and an administrative law judge (ALJ) concluded that the changes constituted "extensions, betterments, or additions" under the relevant statute, thus requiring compliance with the County's code. The PUC upheld the ALJ's decision, and the district court affirmed the PUC's ruling.The Colorado Supreme Court reviewed the case and addressed several issues raised by the railroad. The court concluded that the PUC had jurisdiction to interpret the relevant land use statute, the County had standing to petition the PUC, and the PUC did not violate the railroad's due process rights. The court also found that the PUC's determination that the changes constituted "extensions, betterments, or additions" was just and reasonable and supported by the evidence. Consequently, the Colorado Supreme Court affirmed the district court's judgment upholding the PUC's decision. View "Am. Heritage Ry.s v. Colo. Pub. Utils. Comm'n" on Justia Law

The Town of Firestone applied for conditional groundwater rights and an augmentation plan to support its growing water needs. The application included five well fields, but Firestone did not provide specific well locations for three of these fields, instead proposing to use the water court's retained jurisdiction to provide more specific details later. St. Vrain Sanitation District opposed the application, arguing that Firestone's lack of specific well locations made its depletion calculations unreliable and that relying on retained jurisdiction to prove non-injury later was legally impermissible.The District Court for Water Division 1 partially granted St. Vrain's motion to dismiss, finding that Firestone's evidence was insufficient to establish that the proposed well fields would not injure senior water rights holders. The court dismissed without prejudice the claims for the three well fields with unspecified locations and declined to retain jurisdiction, as it could not make a threshold finding of non-injury. The court also allowed St. Vrain to contest the non-injury issue at trial, despite a prior conditional stipulation.The Supreme Court of Colorado affirmed the water court's decision, holding that the water court correctly evaluated the application on a case-by-case basis and did not create a new bright-line rule requiring completed wells for conditional groundwater rights. The court also upheld the water court's refusal to retain jurisdiction without a non-injury finding and found no abuse of discretion in allowing St. Vrain to contest the non-injury issue. The Supreme Court concluded that the water court's factual findings were supported by the trial record and were not clearly erroneous. View "Town of Firestone v. BCL Colo., LP" on Justia Law

Rick Holloway and John Hoskin entered into a Commercial Sales Agreement to purchase the UXU Resort Ranch from Hidden Creek Outfitters, LLC. The sale included a special use permit from the U.S.D.A. Forest Service, which required a bridge inspection and load test before transfer. Due to the inspection's delay, the parties postponed closing and placed $200,000 in escrow for bridge-related expenses. After inspections, Park County Title released the escrow funds to Hidden Creek without H&H's consent, despite unresolved bridge issues.The District Court of Park County found that Hidden Creek and H&H each breached the implied covenant of good faith and fair dealing, and Park County Title breached the escrow agreement by releasing funds without H&H's approval. However, the court determined H&H failed to prove actual damages with sufficient certainty, awarding only nominal damages. The court also denied attorney’s fees to all parties.The Supreme Court of Wyoming reviewed the case and affirmed the district court's findings. The court held that H&H did not prove actual damages because the inspections did not conclusively identify necessary or required repairs. The court also upheld the denial of attorney’s fees, finding no abuse of discretion, as both parties bore some fault in the litigation. The Supreme Court denied any attorney’s fees associated with the appeal. View "Holloway v. Hidden Creek Outfitters, LLC" on Justia Law

A group of neighbors appealed the Environmental Division’s decision affirming the District 4 Environmental Commission’s granting of an Act 250 permit amendment to JAM Golf, LLC for the construction of a housing development on a lot that was formerly part of the Wheeler Nature Park in South Burlington, Vermont. The neighbors argued that the landowner was required to show changed circumstances to amend the permit and that the development did not comply with Act 250 Criteria 8 and 10.The Environmental Division held six days of trial and conducted a site visit. In August 2024, the court affirmed the Act 250 permit amendment with conditions related to noise and safety during the construction period, concluding that the project complied with all relevant Act 250 criteria. The court also determined that the application should not be denied on the grounds of inequitable conduct because the neighbors failed to support assertions that the landowner made material misrepresentations in its application and on appeal.The Vermont Supreme Court reviewed the case and concluded that the permit-amendment argument was not preserved for appeal because it was not included in the statement of questions presented to the Environmental Division. The court also found that the Environmental Division did not err in allowing the landowner to elect to be assessed against the updated 2024 City Plan rather than the 2016 City Plan. The court determined that the evidence supported the Environmental Division’s findings that the project complied with Act 250 Criteria 8 and 10, including visual aesthetics, noise, and compliance with the local or regional plan. The court affirmed the Environmental Division’s decision. View "In re Wheeler Parcel Act 250 Determination" on Justia Law

The case involves a dispute over a parcel of land situated at the border of adjoining properties in Owings Mills, Maryland. Dr. Sharon Saunders owns one property, while Steven and Ellen Gilman own the neighboring property. The Gilmans claimed ownership of the disputed land through adverse possession, having maintained and used the land for several decades. In 2018, the Gilmans constructed a fence on the disputed property, prompting Dr. Saunders to commission a property survey and subsequently file a lawsuit to establish the boundary line and seek damages for trespass and other tort claims.The Circuit Court for Baltimore County ruled in favor of the Gilmans, declaring them the absolute owners of the disputed property by adverse possession. The court ordered the Gilmans to prepare and file an amended deed and plat reflecting their ownership. Dr. Saunders appealed the decision, but the Appellate Court dismissed the appeal, stating that the order was not a final judgment and did not fall under any exceptions allowing for an interlocutory appeal.The Supreme Court of Maryland reviewed the case to determine whether the Appellate Court erred in its decision. The Supreme Court held that the Circuit Court's order declaring the Gilmans as owners by adverse possession and directing the preparation of a deed was immediately appealable under Maryland Code, Courts & Judicial Proceedings Article §§ 12-303(1) and 12-303(3)(v). The Supreme Court reversed the Appellate Court's dismissal and remanded the case for further proceedings to address the merits of Dr. Saunders's appeal. View "Saunders v. Gilman" on Justia Law

Rajiv Sangha (landlord) rented a house to Jeremy Keen and Racheal Lomas (tenant) in 2021. In November 2023, the tenant stopped paying rent. In April 2024, the landlord served a 14-day notice to pay rent or vacate, but the tenant did not respond. In May 2024, the landlord commenced an unlawful detainer action, serving the tenant with a summons and complaint. The tenant faxed a written notice of appearance to the landlord, indicating their intention to be present at any court case or appearance. Despite this, the landlord moved for a default judgment due to the tenant's failure to file an answer by the specified date. The trial court granted the default judgment and issued a writ of restitution.The tenant received the motion for default and notice of hearing but was allegedly informed by the King County Superior Court Clerk’s Office that they did not need to attend the hearing. In July 2024, the trial court found the tenant in default for lack of answer and issued the default judgment and writ of restitution. The tenant retained counsel and moved to vacate the default judgment and quash the writ, arguing that default for an appearing tenant violated their statutory right to counsel and contradicted the statutory summons language requiring a show cause hearing. The trial court denied the motion, agreeing with the landlord that the Civil Rules required an answer and that the landlord had complied with statutory notice requirements.The Supreme Court of the State of Washington reviewed the case. The court held that RCW 59.18.365(3) precludes a default judgment against a tenant who appears but does not submit a written answer in an unlawful detainer action. The tenant’s written notice of appearance constituted a response to the summons, and the trial court erred in entering a default judgment based on the tenant’s failure to answer. The Supreme Court reversed the trial court’s entry of default and remanded the case for further proceedings. The landlord's request for appellate attorney fees was denied. View "Sangha v. Keen" on Justia Law

Sokunthim Nou appeals from a divorce judgment entered by the District Court in which the court allocated property between her and Rotanak Huot and awarded shared parental rights and responsibilities and shared residency of their children. Sokunthim challenges the court’s property determinations on multiple grounds, but does not contest the custody determination. The court found that all the parties’ assets were marital because they were acquired during the marriage and through significant effort by both parties. The court allocated just over half of the net value of the parties’ properties to Sokunthim and the remainder to Rotanak. The court also found Sokunthim’s income to be $435,598, based largely on Rotanak’s testimony about Punky’s LLC’s daily sales.The District Court held a trial with both parties represented by counsel and interpreters present. The court heard testimony from the parties, a real estate broker, Sokunthim’s accountant, and her father. The court entered a comprehensive divorce judgment, determining that all the parties’ assets were marital and allocating them accordingly. The court’s judgment awarded Panyah LLC to Rotanak and implicitly awarded Punky’s LLC to Sokunthim. Sokunthim filed motions for additional findings of fact and conclusions of law and for a new trial, which the court denied.The Maine Supreme Judicial Court reviewed the case and found that the trial court’s determination of Sokunthim’s income was unsupported by the evidence. The court’s finding as to her income may have influenced other financial aspects of the judgment. Therefore, the Supreme Judicial Court vacated the division of property and child support award and remanded for further proceedings. The judgment was affirmed in all other respects. View "Nou v. Huot" on Justia Law

Peter Farina has lived at the Victor Howell House, a group home for low-income individuals, since 1989. In 2000, the Janet Keenan Housing Corporation (JKHC), a non-profit, purchased the property to maintain it as affordable housing. Recently, JKHC attempted to sell the house to a private third party, leading to two tracks of litigation. The District of Columbia sued JKHC to halt the sale, arguing it violated JKHC’s charitable purposes. As the District and JKHC neared a settlement allowing the sale, Farina sought to intervene but was denied. Farina then filed his own lawsuit, claiming his rights under the Tenant Opportunity to Purchase Act (TOPA) and the Uniform Trust Code (UTC) were being violated.The Superior Court of the District of Columbia denied Farina’s motion to intervene in the District’s case, citing untimeliness and lack of standing. The court approved the settlement between the District and JKHC, which allowed the sale to proceed. In Farina’s separate lawsuit, the court ruled against him, stating his TOPA rights were extinguished by the court-approved settlement and that he lacked standing to bring his UTC claim.The District of Columbia Court of Appeals reviewed the case. The court held that Farina’s TOPA rights were not extinguished by the settlement, as the sale was an arm’s-length transaction and not exempt under TOPA. Farina must be given the opportunity to purchase the property under TOPA. However, the court agreed with the lower court that Farina lacked standing to bring his UTC claim, as he was neither a settlor nor a special interest beneficiary of JKHC. The court affirmed the judgment in the District’s case but vacated the judgment in Farina’s case, remanding it for further proceedings to afford Farina his TOPA rights. View "Farina v. Janet Keenan Housing Corporation" on Justia Law

The plaintiffs, Boyang Song and Travis McCune, own a unit at The 903 condominium complex in Providence, Rhode Island. They filed a lawsuit against Evan Lemoine and Stephen Rodio, the president and secretary of The 903 Condominium Owner’s Association, respectively. The dispute arose when the defendants failed to include the plaintiffs' specific agenda items in a special-meeting petition regarding gas metering and billing issues at the complex. The plaintiffs sought to address the malfunctioning gas timers and the board's decision to switch to a ratio utility billing system, which they argued conflicted with the complex’s governing documents and the Rhode Island Condominium Act.The Superior Court consolidated the plaintiffs' motion for a preliminary injunction with a trial on the merits. After a three-day nonjury trial, the Superior Court found in favor of the defendants. The trial justice determined that the notice of the special meeting sent by the board was insufficient but concluded that the plaintiffs' proposed meeting notice was improper because it did not set forth valid transactable business within the association’s authority. The court found for the defendants on count I of the verified complaint and later entered judgment in favor of the defendants on all counts of the plaintiffs' complaint, while dismissing the defendants' counterclaims.The Rhode Island Supreme Court reviewed the case and vacated the part of the Superior Court's judgment finding in favor of the defendants. The Supreme Court held that the plaintiffs had satisfied their obligation to obtain the requisite number of signatures for the special meeting and that their proposed notice complied with the statutory requirements. The court found that the trial justice overstepped by evaluating the merits of the plaintiffs' motions individually and granting relief not sought by the parties. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Song v. Lemoine" on Justia Law