Justia Civil Procedure Opinion Summaries

Hanzada, an Egyptian company that imports and exports beef, appealed the jury verdict and judgment against it on plaintiff's breach of contract claim. The district court relied on the Seventh Circuit's widely adopted Sadat v. Mertes rule that only the American nationality of the dual citizen should be recognized for purposes of 28 U.S.C. 1332(a). The court concluded that the district court properly found diversity jurisdiction because plaintiff was a U.S. citizen and his Egyptian citizenship did not defeat jurisdiction. The court also concluded that the district court properly exercised personal jurisdiction over Hanzada where there was sufficient minimum contacts with Missouri for the Missouri long-arm statute to authorize personal jurisdiction. Finally, the district court properly found the statute of frauds inapplicable in this case where, under Missouri law, an oral contract for an indefinite period of time does not violate the statute of frauds. Accordingly, the court affirmed the judgment. View "Aly v. Hanzada for Import & Export Co." on Justia Law

Great Lakes filed suit against ESML for breach of contract. ESML later filed a motion to dismiss based on lack of subject matter jurisdiction, but the district court denied the motion. The case proceeded to trial and judgment was entered for Great Lakes. The court agreed with the district court that the Natural Gas Act (NGA), 15 U.S.C. 717u, does not create an express cause of action under which Great Lakes may sue for breach of contract; the NGA also does not create an implied cause of action where there is no indication of legislative intent to create a federal cause of action displacing traditional state law breach of contract causes of action; and assuming that the district court correctly held that federal issues were “necessarily raised” and “actually disputed,” the court concluded that the federal issues in this case are not “substantial,” and the federal courts cannot exercise federal question jurisdiction “without disturbing any congressionally approved balance of federal and state judicial responsibilities.” Accordingly, the court vacated and remanded with instructions to dismiss for lack of jurisdiction. View "Great Lakes Gas Transmission v. Essar Steel Minnesota LLC" on Justia Law

In 2013, the IRS seized $32,820.56 from Carole Hinders’s business bank account based on allegations that Hinders had unlawfully “structured” deposits to avoid federal currency reporting requirements. The government then filed a civil forfeiture complaint against the seized currency, and Hinders filed claims to the seized property. The district court eventually dismissed the action without prejudice. The district court then denied Hinder's motion for fees under the Civil Asset Forfeiture Reform Act (CAFRA), 28 U.S.C. 2465(b)(1), and declined to reconsider its prior dismissal without prejudice. The court concluded, however, that Hinders has not “substantially prevailed” in this action where the district court’s dismissal without prejudice did not materially alter the legal relationship of the parties. Therefore, Hinders is not eligible for an award of attorney fees, costs, or interest under CAFRA. The court also concluded that the district court did not abuse its discretion in dismissing the case without prejudice rather than with prejudice. In this case, the district court considered each of the relevant factors in deciding to grant the government’s motion and Hinders had not shown that she would be prejudiced by a dismissal without prejudice. Accordingly, the court affirmed the judgment. View "United States v. Hinders" on Justia Law

Plaintiffs (the Associations) challenged the district court's ruling that they lack Article III standing to bring a "reverse" Freedom of Information Act (FOIA), 5 U.S.C. 552, 706(2)(A), claim against the EPA. Plaintiffs challenge the EPA's disclosure of certain information about concentrated animal feeding operations, contending that this disclosure is an unlawful release of their members’ personal information. The court concluded that, assuming that plaintiffs' claim would be successful on the merits, the associations have established a concrete and particularized injury in fact traceable to the EPA’s action and redressable by judicial relief. Therefore, the court concluded that the district court erred in dismissing this case for lack of standing. The court also concluded that the EPA abused its discretion in deciding that the information at issue was not exempt from mandatory disclosure under Exemption 6 of FOIA. Accordingly, the court reversed and remanded for the district court to consider the associations’ request for injunctive relief. View "American Farm Bureau v. EPA" on Justia Law

Plaintiff filed suit against Charter, alleging that Charter retained his personally identifiable information in violation of a section of the Cable Communications Policy Act, 47 U.S.C. 551(e). The district court granted Charter's motion to dismiss. The court concluded that plaintiff's notice of appeal was timely where plaintiff filed his notice of appeal thirty-seven days after the district court’s judgment dismissing the case was entered in the docket, well before the district court’s judgment was deemed “entered” and the time for filing a notice of appeal began to run. With the benefit of Spokeo v. Robin's guidance, the court concluded that plaintiff has not alleged an injury in fact as required by Article III. In Spokeo, the Supreme Court explained that Article III standing requires a concrete injury even in the context of a statutory violation. In this case, plaintiff failed to allege a concrete harm and failed to allege an economic injury. Accordingly, the court affirmed the judgment. View "Braitberg v. Charter Communications" on Justia Law

Plaintiff filed suit against defendants alleging that they violated various provisions of the Fair Credit Reporting Act (FCRA), 15 U.S.C. 1681-1681x, by obtaining copies of her credit report. The district court granted the city and the law firm's motion to dismiss. The district court ordered the city and firm to give their copies to the clerk of court for safekeeping and for the clerk to destroy the copies after thirty days unless directed otherwise. Plaintiff appealed. The court concluded that the district court's order did not grant an injunction for purposes of 28 U.S.C. 1292(a)(1), so the court lacked jurisdiction to review the order at this stage. The court also denied mandamus relief with respect to the district court's order dismissing some of the defendants because an appeal from the district court’s eventual final judgment is the proper vehicle for plaintiff's challenges to the order. View "Auer v. City of Minot" on Justia Law

Plaintiffs filed suit alleging that Beresford breached the terms of an option contract by selling their former farm to the Gords. Plaintiffs also claim that the Gords tortiously interfered with their contract with Beresford. The district court granted summary judgment for Beresford and the Gords based on the preclusive effect of a prior state-court judgment. The court concluded that the doctrine of claim preclusion bars plaintiffs' claims against Beresford where the state court's grant of summary judgment in Finstad I was on the merits, this federal case involves the same parties as Finstad I, and plaintiffs' claim of judicial estoppel was rejected. Plaintiffs brought two claims in Finstad I and the state district court entered separate conclusions of law on these two claims. These two conclusions were not alternative holdings; each resolved a separate claim in the complaint. Therefore, in affirming the grant of summary judgment for the Gords on all claims, the state supreme court affirmed both conclusions. Because the Finstad I court necessarily decided that plaintiffs lacked a contractual interest in the farmland, plaintiffs are barred from relitigating that issue here. Accordingly, the court affirmed the judgment. View "Finstad v. Beresford Bancorporation, Inc." on Justia Law

A class of plaintiffs filed suit against the Rams in the Twenty-Second Circuit Court in the city of St. Louis, alleging state-law violations that arose out of the Rams' relocation of their professional football team to Los Angeles, California. The Rams removed the case to federal court under the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d). Once before the federal district court, plaintiffs moved to remand to the state court based predominantly on a lack of minimal diversity necessary to support CAFA jurisdiction. On appeal, the Rams challenged the district court's decision to remand the case to the Missouri state court. The court concluded that the Rams properly removed the case to federal court by filing a notice of removal; the district court's refusal to consider postremoval evidence effectively denied the Rams the opportunity for jurisdictional discovery to establish their claim of federal jurisdiction; and the district court's refusal to consider postremoval evidence prejudiced the Rams by limiting their ability to prove their statutory right to a federal forum. Accordingly, the court vacated the district court's order remanding the case to the Missouri state court and remanded to the district court for further proceedings. View "Pudlowski v. The St. Louis Rams LLC" on Justia Law

Relator filed a qui tam action alleging that Bi-State and Eager Road made false claims to receive federal public-transit funds through the Department of Transportation and the Federal Transit Administration. The district court denied Bi-State’s motion for summary judgment. The court dismissed the appeal for lack of jurisdiction. The court concluded that the issue of Bi-State's immunity is not properly before the court. At no point during the proceedings before the district court did Bi-State claim that it was entitled to sovereign immunity. Bi-State’s motion for summary judgment argued only that it is not a “person” under the False Claims Act (FCA), 31 U.S.C. 3729-3733, and the district court’s denial of summary judgement addressed only that question. View "United States ex rel Fields v. Bi-State Dev. Agency" on Justia Law

Plaintiff, on behalf of D.S., a minor student with intellectual disabilities, filed suit against the school district and others, in state court, seeking damages for premises liability and negligent supervision because D.S. was raped by another student in an unsupervised area of Southwest during the school day, and because D.S. was repeatedly bullied and sexually harassed by her classmates and peers. Defendants removed to federal court, claiming that plaintiff's causes of action arose under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., and then moved to dismiss under FRCP 12(b)(1) and (6). The district court denied plaintiff's motion to remand and dismissed the suit for failure to exhaust IDEA administrative remedies. The court concluded that plaintiff’s theories of liability arise out of Missouri statutory and common law, and the disposition of claims for premises liability and negligent supervision is not dependent on resolution of a substantial question of federal law. Even if the relief plaintiff requested were available under both state law and the IDEA, the well-pled complaint rule protects plaintiff's right to choose a state law cause of action. The court agreed with the Ninth Circuit that non-IDEA claims that do not seek relief available under the IDEA are not subject to the exhaustion requirement, even if they allege injuries that could conceivably have been redressed by the IDEA. Finally, the court denied plaintiff's request for attorney fees because defendants had a reasonable basis for their removal request. The court reversed and remanded to state court. View "Moore v. Kansas City Public Sch." on Justia Law