Justia Civil Procedure Opinion Summaries

Plaintiff filed suit against Matt Holten and Jeff Ellis under 42 U.S.C. 1983, alleging that defendants, law enforcement officers, used excessive force while taking plaintiff into custody. Plaintiff subsequently filed a notice of appeal, and he eventually filed a brief challenging only the district court’s dismissal of the claim against Holten. The notice of appeal, however, specified that plaintiff was appealing only a different order in the case. Where an appellant specifies one order of the district court in his notice of appeal, but fails to identify another, the notice is not sufficient to confer jurisdiction to review the unmentioned order. Where a district court dismisses one claim at an early stage of the case, and later enters an order and judgment dismissing a second claim, a notice of appeal that cites only the later order and judgment does not confer appellate jurisdiction to review the earlier order. In this case, the court concluded that it lacked jurisdiction to review the order not mentioned in plaintiff's notice of appeal. Because plaintiff failed to raise any arguments in regard to the order he did mention, the court determined that plaintiff has abandoned any challenge to that order. View "Rosillo v. Holten" on Justia Law

ERISA Plaintiffs, administrators of Employee Benefit Plans governed by the Employees Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., who entered into securities lending agreements with Wells Fargo, seek to reverse the district court's judgment that it was bound by collateral estoppel and thus required to find against ERISA Plaintiffs and in favor of Wells Fargo on their ERISA claims. Other plaintiffs brought state common law claims. ERISA Plaintiffs and common-law plaintiffs were represented by the same law firm. Following the trial, the parties simultaneously submitted Proposed Findings of Fact and Conclusions of Law with respect to the ERISA claims. In its submission, Wells Fargo asserted that collateral estoppel should apply and that based on the jury verdict, the court was bound to find that there was no breach of fiduciary duty. The district court determined that it was constrained by collateral estoppel to render judgment on ERISA Plaintiffs’ claims consistent with the jury’s determination and issued judgment, dismissing the ERISA Plaintiffs’ ERISA claims with prejudice. ERISA Plaintiffs appeal, arguing that the district court erred in failing to find that Wells Fargo waived any right to assert that the district court was bound by the jury’s findings. The court vacated because the district court failed to consider whether the parties waived the application of collateral estoppel. The court remanded for the district court determine whether waiver occurred. View "Blue Cross Blue Shield of MN v. Wells Fargo Bank, N.A." on Justia Law

Plaintiffs filed suit seeking damages from American Family for their individual insurance claims, and the district court later granted American Family's motion to dismiss. The district court denied plaintiffs' motion to amend. Plaintiffs' motion to amend sought to change their theory of the case because the class action petition had challenged the contents of all American Family insurance policies in a declaratory judgment pleading while the proposed second amended petition claimed that American Family breached the contents of the insurance contract. Furthermore, the class action petition sought a class wide injunction, not individual damages, while the proposed second amended petition sought individual damages instead of a class wide injunction. Therefore, the court concluded that the district court did not abuse its discretion because plaintiffs sought to change their theory of liability after their class action petition had been dismissed. Accordingly, the court affirmed the judgment. View "Adams v. American Family Mutual Ins. Co." on Justia Law

Plaintiff, a former special agent with the FBI, filed suit against the DOJ under the Administrative Procedures Act, 5 U.S.C. 706(2)(A), alleging that the Deputy Attorney General’s decision affirming the OARM's finding that she had not been constructively discharged and denying her back pay was arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with the law. Plaintiff had previously filed a suit in district court alleging that OPR had not conducted its investigation as required by the applicable regulations and seeking injunctive and declaratory relief under the APA. The court concluded that both of plaintiff's suits relied on the same basis of subject matter jurisdiction and so the issues are the same for collateral estoppel purposes. Factual differences between the two underlying causes of action are immaterial, because those differences do not affect the common question, namely, whether Congress intended the CSRA to proscribe unique and exclusive remedial procedures for FBI employees alleging retaliation. Even if the court were to construe application of different sections of the APA as raising potentially different issues, collateral estoppel would still bar the action because both actions involve application of the same legal standard. Accordingly, the court affirmed the judgment. View "Turner v. DOJ" on Justia Law

Plaintiff filed suit against defendants, alleging employment discrimination and retaliation in violation of federal laws. The district court granted summary judgment in favor of defendants. The court agreed with the district court that plaintiff's failure to disclose her claims in her Chapter 13 bankruptcy proceedings judicially estopped her from pursuing them. Accordingly, the court affirmed the judgment. View "Van Horn v. Martin" on Justia Law

Plaintiffs filed a class action against Riceland, requesting the district court compel Riceland to contribute a portion of its recoveries in various cases to the common benefit fund established by the district court to compensate plaintiffs for their legal work. The district court dismissed Riceland's counterclaims of breach of contract and tortious interference and certified the dismissal as a final judgment under FRCP 54(b). The court agreed with its sister circuits and held that a res judicata effect can properly be considered as a “miscellaneous factor” under the Hayden factor analysis. In this case, the district court did not err in considering the res judicata ramification in the Arkansas state court case. The district court found that plaintiffs and the district court itself would suffer injustice if entry of final judgment was delayed. On the merits, the court concluded that the claims regarding genetically-modified rice were released by the Settlement Agreement and Release, but the Release does not govern plaintiffs’ unjust enrichment and quantum meruit claims against Riceland for its failure to contribute to the fund. Accordingly, the court affirmed the district court's judgment. View "Riceland Foods v. Downing" on Justia Law

Plaintiff filed suit against defendants for copyright infringement and conversion. The district court granted defendants' motion to dismiss plaintiff's claim for copyright infringement and denied plaintiff's motion for leave to file an amended complaint. Then the district court entered final judgment dismissing with prejudice the copyright infringement claim under Federal Rule of Civil Procedure 54(b). The court concluded that the district court abused its discretion by entering final judgment under Rule 54(b) where the district court did not properly weigh the Rule 54(b) factors. In this case, the district court cited no hardship or injustice which would result if plaintiff is not able to immediately appeal the order dismissing the copyright infringement claim, and none is apparent from the record. Even if the court were to accept as a valid Rule 54(b) factor the interest in avoiding further litigation, it is not apparent that accepting jurisdiction and reaching the merits of plaintiff's appeal would further this interest. There remains a chance that plaintiff will later appeal the measure of damages for conversion, which would create precisely the type of piecemeal appeal the court seeks to avoid. Accordingly, the court dismissed the appeal for lack of jurisdiction. View "Jones v. West Plains Bank & Trust Co." on Justia Law

The US filed suit on behalf of the USDA to enjoin dissolution of the Benton County Sewer District No. 1. A Voter Representative Group seeks to intervene. The district court denied the motion. The court affirmed, concluding that the Group does not have Article III standing. The court rejected the Group's claims that it has an interest in upholding the vote to dissolve the District and immediately dissolving the District; an interest in opposing the repayment of the revenue bond the District issued to the USDA; an interest in opposing the State’s claims under the Missouri law; and an interest in proposing on-site sewage treatment alternatives. View "United States v. Geranis" on Justia Law

Plaintiffs filed suit against the Arkansas State Board of Dental Examiners's executive director and members of the Board, alleging that the Board’s enforcement of the Arkansas Dental Practice Act, Ark. Code Ann. 17-82-305(g)(2), violates his rights under the Federal Constitution. The district court concluded that it should abstain from deciding the case pursuant to the doctrine established by Railroad Commission of Texas v. Pullman Co. The court concluded that, because there is no ambiguity and thus no unsettled question of state law, Pullman abstention is not appropriate here. Accordingly, the court reversed and remanded for the district court to consider the arguments in the first instance. View "Burris v. Cobb" on Justia Law

Plaintiff appealed the MDHS Commissioner's decision to the state district court, claiming that Minn. Stat. 256L.07 violates federal laws, as well as Minnesota state law. While his state court action was pending, plaintiff filed his complaint in federal court alleging the same discrimination claims and also an equal protection violation. The state court dismissed his state cases and then the federal court dismissed his federal claims. On appeal, plaintiff challenged the dismissal of his federal claims. The court concluded that claim preclusion bars plaintiff from asserting his discrimination and equal protection claims in federal court and affirmed the judgment. View "Scheffler v. MN Dept. of Human Serv." on Justia Law