Justia Civil Procedure Opinion Summaries

Mary Bennett owns a farm on the U.S.–Mexico border. In 2008, the United States built a segment of the border wall on a portion of her property where it had an easement. In 2020, the government initiated a condemnation action to take that portion of the land and surrounding areas to further build the wall and make related improvements. Bennett argued that the government exceeded the scope of its easement when it built the wall, claiming ownership of the wall and seeking just compensation for its value. She attempted to present expert testimony on the wall's value, which the district court excluded.The United States District Court for the Southern District of Texas excluded Bennett's expert testimony, concluding that she was not entitled to just compensation for the wall's value. The court interpreted the common-law rule from Searl v. School-Dist. No. 2, which states that fixtures built by a trespasser become part of the estate, to include an exception for trespassers with an objective, good-faith belief in their right to build. The court found that the government had such a belief and thus precluded Bennett from recovering the wall's value. Bennett appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the government acted under its power of eminent domain, which cannot be limited by state trespass laws. The court affirmed that Bennett is entitled to compensation for the land taken but not for the value of the wall, as the government built it at its own expense for a public purpose. The court affirmed the district court's exclusion of the expert testimony and remanded the case for further proceedings consistent with this opinion. View "United States v. Bennett" on Justia Law

The Vinales family leased a home at Randolph Air Force Base, managed by AETC II Privatized Housing, LLC, and other associated entities. They experienced issues with the home's condition, including mold and asbestos, which they claimed led to health problems and property damage. They sued the housing providers for breach of contract, fraud, and other claims, seeking damages and attorneys' fees.The United States District Court for the Western District of Texas granted summary judgment for the defendants on most claims, citing the federal enclave doctrine, which limits applicable law to federal law and pre-cession state law. The court dismissed the fraud claim for lack of evidence and denied the plaintiffs' motion for attorneys' fees. The breach of contract claim proceeded to trial, where the jury awarded the plaintiffs over $90,000 in damages. The magistrate judge denied the plaintiffs' motion for attorneys' fees and the defendants' motion for judgment as a matter of law.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the application of the federal enclave doctrine, which barred most of the plaintiffs' claims. It upheld the dismissal of the fraud claim, agreeing that the plaintiffs failed to identify actionable fraudulent statements. The court also affirmed the denial of attorneys' fees, finding no legal basis for the award. The exclusion of certain evidence at trial was deemed not to be an abuse of discretion. The court found sufficient evidence to support the jury's damages awards for personal property and diminution in rental value. Finally, the court held that the jury instructions were proper and did not create substantial doubt about the jury's guidance. The judgment of the magistrate judge was affirmed. View "Vinales v. AETC II Privatized Housing, LLC" on Justia Law

Capital Video Corporation (CVC) obtained a judgment against Joseph A. Bevilacqua in 2002 for $178,000 plus interest. CVC requested and received an original execution in December 2002, which lapsed. In 2004, CVC obtained an alias execution, recorded it against property jointly owned by Bevilacqua and his wife, Donna Bevilacqua. In 2005, CVC obtained another alias execution, recorded it against another jointly owned property, and later partially discharged it. In 2020, CVC requested a replacement execution, which was issued and recorded against a property in North Providence. This property was later transferred to Donna Bevilacqua and then to her trust. In 2022, CVC obtained another pluries execution and scheduled a constable’s sale of the property. Donna Bevilacqua intervened, seeking to prevent the sale.The Superior Court invalidated the 2020 and 2022 pluries executions, finding that they were not issued within the six-year limitation period set by § 9-25-3. The court determined that the 2020 execution was not issued within six years of the 2005 alias execution and that the 2022 execution was invalid because it assumed the validity of the 2020 execution.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's decision. The Court held that the 2020 and 2022 pluries executions were invalid because they were not issued within the six-year period required by § 9-25-3. Additionally, CVC failed to properly apply for a replacement execution and did not provide proof that the 2005 alias execution was lost or destroyed. The Court concluded that the trial justice did not err in ordering the release and discharge of the 2020 and 2022 pluries executions. View "Capital Video Corp. v. Bevilacqua" on Justia Law

In April 2011, JJJTB, Inc. initiated a foreclosure action against Stephen Schmidt and Schmidt Farms, Inc. in Hillsborough County. In 2015, the Thirteenth Judicial Circuit denied the foreclosure judgment, and the Second District Court of Appeal affirmed this decision. Over two years later, JJJTB amended its complaint to include new defaults. Schmidt moved to dismiss the amended complaint but did not argue lack of case jurisdiction. The trial court denied the motion, and Schmidt filed an answer with affirmative defenses and a counterclaim but again did not raise the issue of case jurisdiction. In 2021, the court entered a foreclosure judgment against Schmidt, who then unsuccessfully moved for rehearing, asserting lack of subject matter jurisdiction.Schmidt appealed to the Second District Court of Appeal, arguing the trial court lacked jurisdiction. The Second District reversed the foreclosure judgment, holding that the trial court lacked case jurisdiction and that such objections cannot be waived. The court certified conflict with the Fourth District Court of Appeal's decision in MCR Funding v. CMG Funding Corp., which held that case jurisdiction is waivable.The Supreme Court of Florida reviewed the case to resolve the conflict. The court held that case jurisdiction is waivable and that objections must be timely raised, or they are waived. The court quashed the Second District's decision and approved the Fourth District's decision in MCR Funding. The Supreme Court concluded that Schmidt waived the objection to the trial court's lack of case jurisdiction by not raising it timely and by seeking affirmative relief. The Second District erred in reversing the foreclosure judgment based on untimely objections to case jurisdiction. View "JJJTB, Inc. v. Schmidt" on Justia Law

John and Stacy Bang own several parcels of real property in Dunn County, including the subject property in this dispute. They own both the surface and mineral estates. In May 2004, John Bang executed an oil and gas lease agreement with Diamond Resources, Inc., whose successor, Continental Resources, Inc., is the operator and holds the mineral lease. Continental notified the Bangs of its intent to install oil and gas facilities on the property, which the Bangs objected to. Continental subsequently constructed various facilities on the property.The Bangs filed a lawsuit against Continental in 2022, alleging trespass, seeking an injunction, and claiming damages under North Dakota law. The district court denied the Bangs' motions for a temporary restraining order and preliminary injunction. Continental filed a separate action seeking a declaratory judgment and an injunction against John Bang, which was consolidated with the Bangs' case. In January 2024, the district court granted Continental partial summary judgment, declaring Continental had the right to install a pipeline corridor and denied the Bangs' claims for trespass and permanent injunction. The court also denied Continental summary judgment on damages. A jury trial in February 2024 awarded the Bangs $97,621.90 for their compensation claims. The Bangs' motions for a new trial and other relief were denied.The North Dakota Supreme Court reviewed the case and affirmed the district court's amended judgment and order denying a new trial. The court held that the lease was unambiguous and provided Continental the authority to install pipeline facilities on the subject property. The court also upheld the district court's evidentiary rulings, including the exclusion of certain expert testimony and evidence of settlement agreements, and the exclusion of speculative evidence of future agricultural damages. The court found no error in the jury instructions and concluded that the district court did not abuse its discretion in denying the Bangs' motions under N.D.R.Civ.P. 59 and 60. View "Bang v. Continental Resources" on Justia Law

Thomas Hamann brought a lawsuit against Heart Mountain Irrigation District (HMID) and its manager, Randy Watts, alleging that HMID, through Watts' actions, damaged his property and caused him bodily injury. Hamann sought damages based on claims of inverse condemnation and violation of his constitutional rights under 42 U.S.C. § 1983. The district court granted summary judgment in favor of HMID and Watts, dismissing Hamann’s lawsuit entirely. Hamann appealed only the dismissal of his inverse condemnation claim against HMID.The district court found that HMID had not taken any official action to authorize Watts to enter Hamann’s property beyond the limited scope of work on the Riolo bowl, which Hamann had consented to. The court held that without such authorization, Hamann’s inverse condemnation claim could not survive summary judgment. Hamann argued that there was a material issue of fact regarding whether Watts was acting under the scope, authority, and direction of HMID’s board.The Wyoming Supreme Court reviewed the case and found that there were genuine issues of material fact regarding the extent of Watts’ authority and whether his actions were authorized by HMID. The court noted that HMID’s bylaws allowed for delegation of responsibilities to its manager and other agents, and there was evidence suggesting that Watts had general discretion as HMID’s manager. Additionally, there was conflicting testimony about whether Watts had specific authorization to access Hamann’s property beyond the Riolo bowl.The court concluded that the district court erred in granting summary judgment to HMID, as there were unresolved factual issues regarding the authorization of Watts’ actions and the extent of damage to Hamann’s property due to activities on adjoining land. The Wyoming Supreme Court reversed the district court’s order and remanded the case for further proceedings. View "Hamann v. Heart Mountain Irrigation District" on Justia Law

Valderra Land Holdings, LLC owns real property encumbered by a performance trust deed held for the benefit of Jenco, LC and others. After Valderra defaulted on its obligations, Jenco sought judicial foreclosure. Valderra counterclaimed, asserting a right to cure its default and requested the court to determine the amount owed. The district court set the payoff amount and directed Jenco to instruct the trustee to reconvey the property upon Valderra’s tender of funds.Valderra tendered the payoff amount, but Jenco did not instruct the trustee to release the trust deed. Instead, Jenco appealed the judgment and moved for a stay of the obligation to reconvey the property under rule 62(b) of the Utah Rules of Civil Procedure. The district court granted the stay over Valderra’s objection, which argued that the order was injunctive and should be governed by rule 62(c), not 62(b).The Supreme Court of Utah reviewed the case and agreed with Valderra that the district court erred in granting the stay under rule 62(b). The court held that rule 62(b) applies only to stays of orders or judgments to pay money, not injunctive orders, which are governed by rule 62(c). The court found that the order requiring Jenco to instruct the trustee to reconvey the property was injunctive in nature. Consequently, the district court should have considered the motion under rule 62(c), which requires the court to determine whether the conditions for the security of the rights of the adverse party are just.The Supreme Court of Utah reversed the district court’s decision to grant the stay under rule 62(b) and vacated the order rejecting Valderra’s rule 62(i) objection. The court also denied Valderra’s request for appellate attorney fees, as Valderra was not awarded fees in the lower court. View "Jenco v. Valderra Land Holdings" on Justia Law

In 1999, Rosemary Colver executed the Colver Land Trust agreement, naming her five children as beneficiaries and appointing Bruce and Karin as co-trustees. Rosemary and her husband, Richard, retained life estates in any real property held by the Land Trust. The Land Trust sold and purchased properties over the years, with the final property being the Sanders County Property, purchased by Rosemary and Richard in 2010. Richard quitclaimed his interest to Rosemary in 2012, and Rosemary's will devised the Sanders County Property in trust for Richard and their daughter, Gretchen, allowing them to reside there until their deaths.After Rosemary's death in 2017, Bruce and Gretchen were appointed co-personal representatives of her estate. The final accounting identified the Sanders County Property as an estate asset. In 2023, Gretchen filed a petition to correct the distribution of the Sanders County Property, claiming a life estate per the will. Bruce and the Land Trust filed a cross-motion, asserting the property belonged to the Land Trust, alleging it was purchased with Land Trust funds.The Twentieth Judicial District Court, sitting in probate, denied Bruce and the Land Trust's motion for summary judgment and granted Gretchen's motion, ruling that the Land Trust did not equitably own the Sanders County Property and that Gretchen had a valid life estate per the will.The Supreme Court of the State of Montana reviewed the case. It held that the probate court lacked subject matter jurisdiction to adjudicate the Land Trust's claim of equitable ownership, as such claims are equitable in nature and fall outside the probate court's limited jurisdiction. The Supreme Court reversed the probate court's decision regarding the Land Trust's claim and remanded with instructions to dismiss it. However, it affirmed the probate court's ruling that Gretchen had a valid life estate in the Sanders County Property as per the will. View "In re R.E. Colver" on Justia Law

In this case, the plaintiffs, Kristina Urbonas and Arunas Aniukstis, purchased property at 5 Bowser Court in Newport, Rhode Island. The defendant, NRI 51 Kingston Partnership (NRI), acquired adjacent property at 51 Kingston Avenue. A dispute arose when NRI's representative, John Gullison, conducted renovations and removed part of the plaintiffs' cobblestone landing, claiming it encroached on NRI's property. Plaintiffs filed a lawsuit seeking a declaration of ownership over the disputed land based on the doctrine of acquiescence, adverse possession, and an easement by prescription.The Superior Court awarded title to the plaintiffs for the disputed land, finding that the plaintiffs had acquired the land through the doctrine of acquiescence. The court also granted title to other abutters of Bowser Court, even though they had not requested such relief. NRI appealed, arguing that the trial justice misapplied the doctrine of acquiescence and erred in awarding title to other abutters.The Rhode Island Supreme Court reviewed the case and found that the trial justice erred in granting relief to the other abutters who had not requested it. The court also determined that the doctrine of acquiescence was not applicable because the disputed boundary was not solely on the parties' adjoining lots but also bordered Bowser Court. However, the court found that the plaintiffs had established an easement by prescription over the five-foot strip of land, as they had used the walkway openly, continuously, and hostilely for the statutory period.The Rhode Island Supreme Court affirmed the Superior Court's judgment in part, recognizing the plaintiffs' easement by prescription, and vacated the part of the judgment granting relief to the other abutters. View "Urbonas v. Gullison" on Justia Law

In 2008, Andy Luu Tran granted Citizens Bank a mortgage on his Massachusetts home. In 2022, the Bank foreclosed on the property, and Herbert Jacobs was the high bidder at the auction. The Bank recorded an affidavit of sale but the foreclosure deed lacked the required signature page. Tran filed a Chapter 13 bankruptcy petition and an adversary complaint to avoid the transfer of his interest in the property due to the improperly recorded deed.The U.S. Bankruptcy Court for the District of Massachusetts granted summary judgment against Tran, holding that the only transfer at foreclosure was of Tran's equity of redemption, which was extinguished at the foreclosure auction. The court found that the properly recorded affidavit of sale provided constructive notice, making the transfer unavoidable. The U.S. District Court for the District of Massachusetts affirmed this decision.The United States Court of Appeals for the First Circuit reviewed the case. The court held that Tran's equity of redemption was extinguished at the foreclosure auction when the memorandum of sale was executed. The court also held that the properly recorded affidavit of sale provided constructive notice of the foreclosure, making the transfer of Tran's equity of redemption unavoidable under Massachusetts law. Consequently, the court affirmed the judgment of the bankruptcy court. View "Tran v. Citizens Bank, N.A." on Justia Law