Justia Civil Procedure Opinion Summaries

A private fencing coach alleged that during a flight, a university’s assistant fencing coach sexually harassed and assaulted her. She reported the incident to the university’s head coach, who discouraged her from reporting it further and, along with the assistant coach, allegedly retaliated against her within the fencing community. The university later investigated and confirmed the harassment but found no policy violation. The coach sued the university, the two coaches, and the Title IX coordinator, claiming violations of Title IX and state-law torts.The United States District Court for the Middle District of North Carolina transferred the case to the Middle District of Pennsylvania due to improper venue and judicial efficiency. After the transfer, the plaintiff amended her complaint, and the defendants moved to dismiss. The transferee court dismissed the entire suit, holding that the plaintiff, as neither a student nor an employee, was outside the zone of interests protected by Title IX. It also dismissed the state-law tort claims as untimely or implausible.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the zone-of-interests test applies to Title IX claims and that the plaintiff’s claims related to her exclusion from university-hosted fencing events and retaliation manifesting on campus were within that zone. The court affirmed the dismissal of the state-law tort claims against the university and its employees, except for the claims against the assistant coach, which were not time-barred under North Carolina’s three-year statute of limitations. The case was vacated in part, affirmed in part, and remanded for further proceedings. View "Oldham v. Penn State University" on Justia Law

Micayla Augustyn, a student at Wall High School, received special education services under an individualized education plan (IEP). As she neared the end of her fourth year, a dispute arose between her mother and the Wall Township Board of Education regarding her graduation. The Board wanted her to graduate, while her mother believed she needed another year due to the Board's failure to implement required accommodations. Mediation failed, and Augustyn filed a Petition for Due Process before an Administrative Law Judge (ALJ), claiming the Board failed to provide a free and appropriate education (FAPE) as required by the Individuals with Disabilities Education Act (IDEA).The ALJ dismissed her grade revision claim, stating it was not suitable for a special education due process hearing. Augustyn appealed to the United States District Court for the District of New Jersey, which ruled in her favor, stating that a due process hearing was the appropriate venue for her grade revision claim. The District Court remanded the matter for further proceedings and awarded Augustyn attorneys' fees as a prevailing party under the IDEA, but significantly reduced the fee amount.The United States Court of Appeals for the Third Circuit reviewed the case. The court affirmed that Augustyn was a prevailing party entitled to attorneys' fees, as she successfully vindicated her statutory right to a due process hearing. However, the court found that the District Court erred in reducing the fee award based on improper considerations, such as the Board's financial ability to pay and the procedural nature of Augustyn's victory. The Third Circuit vacated the District Court's order and remanded for a recalculation of the appropriate lodestar reductions. View "Augustyn v. Wall Township Board of Education" on Justia Law

Mesabi Metallics Company LLC (Mesabi) filed for Chapter 11 bankruptcy in 2016 and emerged successfully in 2017. During the bankruptcy proceedings, Mesabi initiated an adversary proceeding against Cleveland-Cliffs, Inc. (Cliffs), alleging tortious interference, antitrust violations, and other claims. Mesabi sought to unseal certain documents obtained from Cliffs during discovery, which had been filed under seal pursuant to a protective order. Cliffs opposed the motion, arguing that the documents should remain sealed under Bankruptcy Code § 107, not the common law right of access.The United States Bankruptcy Court for the District of Delaware applied the common law standard from In re Avandia Marketing, Sales Practices & Products Liability Litigation, concluding that Cliffs had not met the burden to keep the documents sealed. The court recognized the potential for a different interpretation and certified the question for direct appeal to the United States Court of Appeals for the Third Circuit.The Third Circuit held that the sealing of documents in bankruptcy cases is governed by § 107 of the Bankruptcy Code, not the common law right of access. The court clarified that § 107 imposes a distinct burden for sealing documents, requiring protection of trade secrets or confidential commercial information if disclosure would cause competitive harm. The court vacated the Bankruptcy Court's order and remanded for application of the correct standard.Additionally, the Third Circuit addressed a separate motion by Greg Heyblom to intervene and unseal the documents. The court concluded that the Bankruptcy Court lacked jurisdiction to grant Heyblom's motions while the appeal was pending, as it would interfere with the appellate court's jurisdiction. The orders granting Heyblom's motions were vacated. View "In re: ESML Holdings Inc v. Mesabi Metallics Company LLC" on Justia Law

B-R Penn Realty defaulted on a $46 million loan backed by a mortgage on its Philadelphia apartment building. U.S. Bank, the lender, sued to foreclose in federal court, invoking diversity jurisdiction. After a bench trial, the District Court ruled that Penn Realty had breached the loan agreement and entered a money judgment in U.S. Bank’s favor for $51,392,086.96. U.S. Bank then sought a foreclosure sale of the building to recover the judgment amount. Penn Realty moved twice to halt the sale, but the District Court denied both motions, and the building was sold.The United States District Court for the Eastern District of Pennsylvania initially ruled in favor of U.S. Bank, issuing a money judgment for the amount owed by Penn Realty. Penn Realty appealed the judgment but did not obtain a stay. Subsequently, U.S. Bank renewed its foreclosure efforts, and the District Court denied Penn Realty’s emergency motion to quash the writ of execution and cancel the sale. The sale was rescheduled, and Penn Realty filed a second motion to quash, which was also denied by the District Court.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that the sale of the building was an execution sale governed by Federal Rule of Civil Procedure 69(a), not a judicial sale under 28 U.S.C. § 2001. The court determined that U.S. Bank complied with the requirements of Rule 69(a), which imports Pennsylvania law for execution sales. The court also found that service of the writ was proper under Pennsylvania law. Consequently, the Third Circuit upheld the sale and affirmed the District Court’s denial of Penn Realty’s motion to quash. View "US Bank NA v. B R Penn Realty Owner LP" on Justia Law

Chenault-Vaughan Family Partnership ("Chenault"), a royalty interest holder in a Texas mineral estate, sued Centennial Resources Operating, LLC ("Centennial"), the site operator, for wrongly withholding royalties. The Bankruptcy Court awarded summary judgment to Centennial. Chenault appealed to the District Court, where the parties consented to proceed before a Magistrate Judge. The Magistrate Judge affirmed the Bankruptcy Court’s judgment, and Chenault appealed to the United States Court of Appeals for the Third Circuit.The Third Circuit first addressed whether the Magistrate Judge had jurisdiction to enter final judgment in the bankruptcy appeal. The court concluded that, with the consent of the parties and a referral by the district court, a magistrate judge may enter final judgment in a bankruptcy appeal. This conclusion was supported by the broad consent authority granted to magistrate judges under 28 U.S.C. § 636(c), the repeal of the statutory provision that previously prohibited such referrals, and the supervisory authority retained by Article III judges.On the merits, the Third Circuit reviewed the Bankruptcy Court’s summary judgment on two claims: trespass to try title and royalties under the Texas Natural Resources Code ("TNRC"). The court affirmed the summary judgment for Centennial on the trespass-to-try-title claim, finding that Centennial did not unlawfully enter the land and dispossess Chenault, as Luxe, a cotenant, had the right to extract minerals and permit Centennial to operate.However, the court vacated the summary judgment on the TNRC claim. The court found that there were genuine disputes of material fact regarding whether Centennial was obligated to pay Unit B royalties to Chenault, particularly concerning the Division Order and Centennial’s knowledge of MDC’s non-signature on the Unit B JOA. The case was remanded to the Magistrate Judge with instructions to remand to the Bankruptcy Court for further proceedings on the TNRC claim. View "In re: MTE Holdings LLC" on Justia Law

Plaintiffs, who are probationers, sued several Pennsylvania judges, probation officers, and the county warden, alleging they were detained without a finding that such detention was necessary to prevent flight or further crimes. They claimed their due process rights were violated as they were held for months without adequate preliminary hearings or credible probable-cause findings.The United States District Court for the Western District of Pennsylvania denied a preliminary injunction and later granted summary judgment for the defendants on both claims. The court held that the plaintiffs' novel claim for a new procedural right conflicted with Supreme Court precedent and found no genuine dispute of material fact regarding the county's adherence to existing constitutional rules in initial hearings.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that probationers do not have a due process right to a finding of necessity before being detained between preliminary and revocation hearings. The Supreme Court's decisions in Morrissey v. Brewer and Gagnon v. Scarpelli established that a finding of probable cause at a preliminary hearing is sufficient to warrant continued detention for a reasonable time until the revocation hearing.However, the Third Circuit found material factual disputes regarding whether the county followed due process rules, particularly concerning the adequacy of notice given to probationers before preliminary hearings. The court reversed and remanded the case in part, allowing plaintiffs to proceed with their claim that the county did not follow established due process procedures. View "Horton v. Rangos" on Justia Law

The Public Interest Legal Foundation (PILF) requested records from the Secretary of the Commonwealth of Pennsylvania under the National Voter Registration Act of 1993 (NVRA). PILF sought documents related to a "glitch" in the Pennsylvania Department of Transportation's system that allowed ineligible persons to register to vote. The Secretary denied the request, leading PILF to file a lawsuit claiming an informational injury due to the denial of access to the records.The United States District Court for the Middle District of Pennsylvania initially dismissed the suit for lack of statutory notice but found that PILF had standing based on an informational injury. After PILF provided the required notice and refiled the suit, the District Court granted and denied parts of both parties' summary judgment motions, ruling that PILF was entitled to some records but not others. The District Court did not reassess PILF's standing in light of the Supreme Court's decision in TransUnion v. Ramirez.The United States Court of Appeals for the Third Circuit reviewed the case and concluded that PILF lacked standing. The court held that PILF did not demonstrate a concrete harm or adverse effects from the denial of information, as required by TransUnion. The court emphasized that PILF's inability to study and analyze the records or produce educational materials did not constitute a concrete injury related to the NVRA's purpose of increasing voter participation. Consequently, the Third Circuit vacated the District Court's orders and remanded the case with instructions to dismiss it. View "The Public Interest Legal Foundation v. Secretary Commonwealth of Pennsylvania" on Justia Law

The appellants, Robin and Louie Joseph Aquilino, filed for Chapter 7 bankruptcy in April 2020 and retained the law firm Spector Gadon Rosen & Vinci P.C. (Spector Gadon) as their counsel. They agreed to pay a flat fee of $3,500 and a $335 filing fee, which Spector Gadon disclosed to the Bankruptcy Court. However, due to the complexity of the case, Spector Gadon billed the Aquilinos for additional post-petition services, resulting in a fee agreement of $113,000, which was not disclosed to the Bankruptcy Court as required by 11 U.S.C. § 329(a) and Bankruptcy Rule 2016(b).The Bankruptcy Court for the District of New Jersey found that Spector Gadon violated the disclosure requirements and sanctioned the firm by ordering the disgorgement of collected fees and cancellation of the remaining fee agreement. Spector Gadon appealed, and the United States District Court for the District of New Jersey reversed the Bankruptcy Court's decision, concluding that Spector Gadon was entitled to a jury trial under the Seventh Amendment.The United States Court of Appeals for the Third Circuit reviewed the case and determined that the Bankruptcy Court had "core" jurisdiction over the fee disclosure issue under 28 U.S.C. § 157(b)(1). The Third Circuit held that the Seventh Amendment did not entitle Spector Gadon to a jury trial in the § 329(a) proceeding because the sanctions imposed were equitable in nature, designed to restore the status quo, and did not involve legal claims. The Third Circuit also found that the Bankruptcy Court did not abuse its discretion in imposing sanctions, as it considered all relevant factors, including the Debtors' misconduct.The Third Circuit reversed the District Court's judgment and reinstated the Bankruptcy Court's sanctions order. View "In re Aquilino" on Justia Law

Mesabi Metallics Company LLC (Mesabi) filed for Chapter 11 bankruptcy in 2016 and emerged successfully in 2017. During the bankruptcy proceedings, Mesabi initiated an adversary proceeding against Cleveland-Cliffs, Inc. (Cliffs), alleging tortious interference, antitrust violations, and civil conspiracy. Mesabi claimed Cliffs engaged in anti-competitive conduct to impede Mesabi's business operations. To facilitate discovery, the parties entered a stipulated protective order allowing documents to be designated as confidential. Mesabi later moved to unseal certain documents filed under seal to support a petition in the Minnesota Court of Appeals.The United States Bankruptcy Court for the District of Delaware, applying the common law right of access, held that Cliffs had not met the burden to keep the documents sealed. The court relied on the Third Circuit's precedent in In re Avandia, which requires a showing that disclosure would cause a clearly defined and serious injury. Recognizing potential ambiguity in the law, the Bankruptcy Court certified the question for direct appeal to the United States Court of Appeals for the Third Circuit.The Third Circuit clarified that the sealing of documents in bankruptcy cases is governed by 11 U.S.C. § 107, not the common law right of access. Section 107 imposes a distinct burden, requiring protection of trade secrets or confidential commercial information without the need for balancing public and private interests. The court vacated the Bankruptcy Court's decision and remanded for application of the correct standard under § 107. Additionally, the Third Circuit held that the Bankruptcy Court lacked jurisdiction to grant a third party's motion to intervene and unseal documents while the appeal was pending, vacating those orders as well. View "ESML Holdings Inc v. Mesabi Metallics Compay LLC," on Justia Law

Plaintiffs alleged that an automobile manufacturer designed, manufactured, and sold defective vehicles, specifically Dodge "muscle" cars with defective rear differentials. They filed a complaint asserting state and federal causes of action based on fraud and breach of warranty. The District Court dismissed the fraud counts and some warranty counts, allowing plaintiffs to amend their complaint. After amending, the District Court dismissed the fraud counts again and some warranty counts, but allowed two warranty counts to proceed.The United States District Court for the District of Delaware initially dismissed the complaint without prejudice, allowing plaintiffs to amend it. After the plaintiffs amended their complaint, the District Court dismissed the fraud counts and some warranty counts with prejudice, but allowed two warranty counts to proceed. The plaintiffs then moved to certify the dismissal of their fraud counts for appeal under 28 U.S.C. § 1292(b) or for final judgment under Rule 54(b). The District Court denied the request for certification under § 1292(b) but granted the request for final judgment under Rule 54(b) for the fraud counts.The United States Court of Appeals for the Third Circuit reviewed the case and determined that the District Court's Rule 54(b) judgment was not final. The Court of Appeals held that the fraud and warranty counts constituted a single claim for purposes of Rule 54(b) because they were alternative theories of recovery based on the same factual situation. As a result, the judgment did not dispose of all the rights or liabilities of one or more of the parties. Consequently, the Court of Appeals dismissed the appeal for lack of jurisdiction and instructed the District Court to vacate its order directing the entry of a partial final judgment. View "Diaz v. FCA US LLC" on Justia Law