Justia Civil Procedure Opinion Summaries

Charles and Yvette Whittier sued Ocwen Loan Servicing, Deutsche Bank National Trust Company, Merscorp, and Mortgage Electronic Registration System to prevent the foreclosure of their home mortgage loan. The parties reached a settlement and notified the district court, which issued an interim order of dismissal pending final documentation. The parties then filed a Joint Stipulation to Dismiss Action under Rule 41(a)(1)(A)(ii) and a proposed Order of Dismissal With Prejudice, which stated that the court would retain jurisdiction to enforce the settlement agreement. However, the court's dismissal order did not explicitly retain jurisdiction or incorporate the settlement terms.The Whittiers later filed a motion to enforce the settlement agreement and sought attorneys' fees. The defendants argued that the court lacked ancillary jurisdiction to enforce the agreement. A magistrate judge recommended enjoining foreclosure proceedings, and the district judge adopted this recommendation, issuing an injunction in April 2020. Over two years later, PHH and Deutsche Bank moved to reopen the case and dissolve the injunction, claiming the Whittiers were in default. A different magistrate judge found that the court lacked ancillary jurisdiction to enforce the settlement and recommended dissolving the injunction. The district judge agreed, dissolved the injunction, and dismissed the suit with prejudice in May 2024, explicitly declining jurisdiction over the settlement agreement.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the district court lacked ancillary jurisdiction to enforce the settlement agreement because the dismissal order did not expressly retain jurisdiction or incorporate the settlement terms. The court affirmed the district court's decision to dissolve the injunction and dismiss the case with prejudice. View "Whittier v. Ocwen Loan Servicing" on Justia Law

In 2016, the DOJ sued Hinds County, Mississippi, under the Civil Rights of Institutionalized Persons Act, alleging unconstitutional conditions in the county's detention facilities. A consent decree was established to address these issues, but disputes over compliance led to ongoing litigation. The DOJ claimed the county failed to comply, citing worsening conditions, while the county sought to terminate the decree. The district court found partial compliance, held the county in contempt, and issued a new injunction focusing on the Raymond Detention Center (RDC). As a sanction, the court appointed a receiver to oversee compliance.The district court's decision was based on findings of ongoing constitutional violations at RDC, including inmate violence, inadequate staffing, and poor conditions. The court noted that despite some improvements, many issues persisted, such as severe understaffing and inadequate supervision, contributing to violence and unsafe conditions. The court also found deficiencies in use-of-force training, incident reporting, and investigations, which exacerbated the problems.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision to retain the new injunction, finding that ongoing constitutional violations justified continued prospective relief. However, the appeals court found the new injunction overly broad in some respects and held that the district court did not abuse its discretion in appointing a receiver. The court also noted that the district court failed to make sufficient need-narrowness-intrusiveness findings for each of the receiver's duties as required under the Prison Litigation Reform Act. Consequently, the appeals court affirmed the district court's decision in part, reversed in part, and remanded for further proceedings to address these issues. View "United States v. Hinds County Board of Supervisors" on Justia Law

Jennifer Virden, a small business owner in Austin, Texas, ran for city council in 2020 and for mayor in 2022. The City of Austin has a regulation that prohibits candidates from fundraising outside a one-year period before the general election. Virden announced her candidacy for the 2022 election in March 2021, which was seven months before she could start fundraising under the ordinance. She filed a lawsuit challenging the one-year fundraising window as unconstitutional under the First Amendment.The United States District Court for the Western District of Texas initially denied Virden's request for a preliminary injunction, finding no irreparable harm. Virden's interlocutory appeal was dismissed as moot after the fundraising window opened. The district court later granted summary judgment in part, ruling that the one-year fundraising window was unconstitutional and awarding nominal damages to Virden and her donor, William Clark. The court found that the claims for declaratory and injunctive relief were moot since the 2022 election had ended and there were no concrete plans for future campaigns. The court also refused to consider evidence regarding Virden's desire to contribute to another candidate in the 2024 election, deeming the submission untimely.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's ruling that the one-year fundraising window was unconstitutional, agreeing that it violated the First Amendment. The court also upheld the award of nominal damages to Virden and Clark. Additionally, the court found that the district court did not abuse its discretion in refusing to consider the late evidence regarding the 2024 election. The Fifth Circuit concluded that the suit was timely, Virden had standing, and the city's arguments were without merit. The court affirmed the district court's decision in its entirety. View "Virden v. City of Austin" on Justia Law

Following public outcry over "Pride Month" displays in St. Tammany Parish's public libraries, the Parish Council passed a resolution that vacated the terms of the Library Board of Control members, staggered those terms in accordance with Louisiana law, and appointed new Board members. Three ousted Board members—Anthony Parr, Rebecca Taylor, and William McHugh, III—sued under 42 U.S.C. § 1983, asserting viewpoint-discrimination, free-speech, retaliation, and substantive-due-process claims against the Council and Councilman David Cougle. They sought declaratory and injunctive relief to prevent the resolution from taking effect.The United States District Court for the Eastern District of Louisiana ruled that the legislative privilege was inapplicable because the resolution was not "legislative" in nature. Defendants brought an interlocutory appeal challenging this ruling. Before addressing the legislative privilege issue, the United States Court of Appeals for the Fifth Circuit examined whether the plaintiffs had standing to bring their claims.The Fifth Circuit concluded that the plaintiffs lacked standing. The court found that the plaintiffs' alleged speech-related injuries were not particularized, as they were tied to their positions as Board members and affected all members equally. Additionally, the court determined that the plaintiffs' alleged reputational injuries were neither fairly traceable to the defendants' conduct nor redressable by a favorable decision. Consequently, the court vacated the district court's order and remanded with instructions to dismiss the plaintiffs' claims for lack of subject matter jurisdiction. View "Parr v. Cougle" on Justia Law

Great Lakes Dredge & Dock Company (Great Lakes) sought a letter ruling from the U.S. Customs and Border Protection (CBP) regarding the application of the Jones Act to its offshore wind farm project. CBP's initial ruling required Jones Act-qualified vessels for transporting scour protection rock from U.S. points to the Outer Continental Shelf (OCS). However, a modified ruling stated that the first delivery of rock to the OCS did not require a Jones Act-qualified vessel, but subsequent deliveries did. Great Lakes appealed this modified ruling, which CBP denied.Great Lakes then filed a lawsuit in the Southern District of Texas, claiming the modified ruling was contrary to law and would expose its planned Jones Act-compliant vessel to unlawful competition. The American Petroleum Institute (API) intervened, arguing that Great Lakes lacked standing as it had no actual or imminent injury. The district court agreed with API and dismissed the case, finding Great Lakes' injury hypothetical since it did not have a vessel capable of handling the Vineyard Project and no current contract for the project.The United States Court of Appeals for the Fifth Circuit reviewed the case. Great Lakes argued it had competitor standing due to the potential for increased competition from foreign vessels. However, the court found no evidence of actual or imminent increased competition, as the Vineyard Project was completed and there was no indication that future projects would source rock from U.S. points. The court also rejected CBP's argument that the ruling applied to identical future projects, as there was no record evidence of such projects involving U.S.-sourced rock.The Fifth Circuit affirmed the district court's judgment, concluding that Great Lakes lacked standing to challenge the CBP's modified ruling. View "Great Lakes Dredge v. Magnus" on Justia Law

Pie Development, L.L.C. was formed to develop an application to streamline the process of purchasing workers compensation insurance. The company alleged that Dax Craig, a consultant, stole the idea and shared it with John Swigart. Craig and Swigart then used the idea to create Pie Insurance Holdings, Inc. and other affiliated entities, generating significant profits. Pie Development sued Craig, Swigart, Pie Insurance Holdings, and Pie Insurance Services, alleging misappropriation of trade secrets under the Mississippi Uniform Trade Secrets Act (MUTSA) and the federal Defend Trade Secrets Act (DTSA), among other claims.The United States District Court for the Southern District of Mississippi dismissed the complaint for failing to provide sufficient detail on each claim, but allowed Pie Development to amend its complaint within thirty days. Pie Development chose not to amend and instead appealed. The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision, noting that Pie Development did not sufficiently plead that it took reasonable measures to protect its business plan's secrecy.While the appeal was pending, Pie Development filed a new lawsuit against additional defendants, including Pie Carrier Holdings, Gallatin Point Capital, Sirius Point Ltd., and Pie Casualty Insurance Company, and later added the original defendants. The district court dismissed the new claims, citing res judicata, as the claims were identical to those in the first lawsuit. Pie Development appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's dismissal. The court held that res judicata applied because the prior action was concluded by a final judgment on the merits when Pie Development chose to appeal rather than amend its complaint. The court also found that Pie Development failed to state a claim against Gallatin and Sirius, as the complaint did not plausibly allege that they knew or should have known about the misappropriation of trade secrets. View "Pie Development v. Pie Carr Holdings" on Justia Law

The City of New Orleans filed a lawsuit against several pipeline operators and Entergy New Orleans LLC, alleging that their oil and gas production and transportation activities caused damage to the City's coastal zone. The City claimed that Entergy allowed its pipeline canals to widen and erode, threatening the City's storm buffer. The lawsuit was filed under Louisiana’s State and Local Coastal Resources Management Act of 1978 (SLCRMA).The defendants removed the case to federal court, arguing that Entergy, the only in-state defendant, was improperly joined to defeat diversity jurisdiction. Entergy consented to the removal and argued that it was exempt from SLCRMA’s permit requirements because its activities commenced before the statute's effective date. The City moved to remand the case to state court, but the United States District Court for the Eastern District of Louisiana denied the motion, dismissed Entergy as a party, and stayed the case pending appeal.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that Entergy was improperly joined because its activities were exempt under SLCRMA’s Historical-Use Exception, which applies to uses legally commenced before the statute's effective date. The court found no reasonable basis for the City to recover against Entergy, thus disregarding Entergy's citizenship and establishing complete diversity among the parties. The court also rejected the City's argument that it was merely a nominal party representing Louisiana, concluding that the City filed the suit on its own behalf and stood to benefit from a favorable ruling. Consequently, the appellate court affirmed the district court's denial of the City's motion to remand. View "New Orleans City v. Aspect Energy" on Justia Law

Stephen Cook, a trustee of two charitable trusts, sued Preston Marshall, both personally and in his capacity as a trustee of a related trust, alleging that Preston's failures caused the charitable trusts to incur debt and tax penalties. The district court denied Preston's motion to dismiss and later granted Cook partial summary judgment. Preston appealed, arguing that the suit should be dismissed because Cook's unnamed co-trustees lacked diversity of citizenship.The United States District Court for the Eastern District of Louisiana initially ruled in Cook's favor, ordering Preston to authorize payments from the Peroxisome Trust to the Marshall Heritage Foundation and holding that Preston breached his fiduciary duties. Cook later moved to enforce this judgment, claiming Preston continued to refuse to authorize payments and failed to file tax returns. The district court held Preston in contempt but did not remove him as co-trustee. Cook then filed a new suit against Preston, seeking damages and Preston's removal as co-trustee. The district court denied Preston's motion to dismiss, which argued that the claims were barred by res judicata and that necessary parties were not joined.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that complete diversity of citizenship existed because the trusts themselves were not parties, and only the citizenship of Cook and Preston mattered. The court also found that the district court did not abuse its discretion in proceeding without joining Elaine and Pierce as parties. Additionally, the court determined that res judicata did not bar Cook's claims because the new claims arose from Preston's post-judgment conduct. Finally, the court rejected Preston's arguments regarding comparative fault and failure to mitigate damages, affirming the district court's judgment. View "Cook v. Marshall" on Justia Law

The Fifth Circuit held that, because the matter was not ripe at the time the district court entered judgment in this case, the district court's judgment was void for lack of subject matter jurisdiction. Therefore, the court vacated the judgment. The court explained that, even though subsequent intervening events have created a controversy that was now ripe, the court could not retroactively resurrect the district court's void judgment under the facts of this case. Nevertheless, because the basic underlying controversy, originally raised and pursued by these same parties, was now ripe, the court remanded the case to the district court for such orders and proceedings as the district court deemed necessary and appropriate. View "Lower Colorado River Authority v. Papalote Creek II LLC" on Justia Law

Brickhouse appealed a default judgment in a trademark dispute between the parties. The court held that it had appellate jurisdiction in this case because a motion to recall the mandate and a motion to reopen the case have the same effect; the clerk had the power to recall the mandate here; and its order reopening the case did recall the mandate. The court rejected Brickhouse's claim that service of process was invalid; held that service was unremarkable in this case; and affirmed the default judgment. View "BHTT Entertainment v. Brickhouse Cafe & Lounge" on Justia Law