Justia Civil Procedure Opinion Summaries

In October 2017, the FBI mistakenly raided the home of Hilliard Toi Cliatt, Curtrina Martin, and her 7-year-old son in suburban Atlanta, instead of the intended gang hideout. The error occurred due to Special Agent Guerra's reliance on a personal GPS device and the team's failure to notice the correct street sign and house number. The raid resulted in personal injuries and property damage. The plaintiffs sued the United States under the Federal Tort Claims Act (FTCA) for the officers' negligent and intentional actions.The district court granted summary judgment to the government, and the Eleventh Circuit affirmed. The Eleventh Circuit applied a unique approach to FTCA claims, holding that the law enforcement proviso in §2680(h) overrides all exceptions, including the discretionary-function exception, allowing intentional-tort claims to proceed without further analysis. The court also allowed the government to assert a Supremacy Clause defense, which it found valid, leading to summary judgment for the United States.The Supreme Court of the United States reviewed the case and held that the law enforcement proviso in §2680(h) overrides only the intentional-tort exception, not the discretionary-function exception or other exceptions in §2680. The Court also held that the Supremacy Clause does not afford the United States a defense in FTCA suits. The case was vacated and remanded to the Eleventh Circuit to reconsider whether the discretionary-function exception bars the plaintiffs' claims and to assess liability under Georgia state law without reference to a Supremacy Clause defense. View "Martin v. United States" on Justia Law

Donte Parrish, a federal inmate, was placed in restrictive segregated confinement for 23 months due to his suspected involvement in another inmate's death. After being cleared of wrongdoing by a hearing officer, Parrish filed a lawsuit in Federal District Court seeking damages for his confinement. The District Court dismissed his case on March 23, 2020, citing some claims as untimely and others as unexhausted. Parrish, who had been transferred to a different facility, received the dismissal order three months later and promptly filed a notice of appeal, explaining the delay.The Fourth Circuit recognized that Parrish's notice of appeal was filed after the 60-day appeal period for suits against the United States. The court construed his filing as a motion to reopen the time to appeal under 28 U.S.C. §2107(c). On remand, the District Court granted a 14-day reopening period, but Parrish did not file a second notice of appeal. Both Parrish and the United States argued that the original notice was sufficient, but the Fourth Circuit held that Parrish's failure to file a new notice within the reopened period deprived the court of jurisdiction.The Supreme Court of the United States reviewed the case and held that a litigant who files a notice of appeal after the original appeal deadline but before the court grants reopening does not need to file a second notice after reopening. The original notice relates forward to the date reopening is granted. The Court reversed the Fourth Circuit's decision, allowing Parrish's appeal to proceed. View "Parrish v. United States" on Justia Law

Plaintiffs, victims and families of victims of terrorist attacks carried out by Hamas between 2001 and 2003, sued BLOM Bank SAL under the Anti-Terrorism Act, alleging that the bank aided and abetted the attacks by providing financial services to Hamas-affiliated customers. BLOM argued that the complaint failed to state a claim, and plaintiffs affirmed they would not seek to amend their complaint if dismissed. The District Court dismissed the complaint with prejudice, finding that plaintiffs had not adequately alleged BLOM's general awareness for aiding-and-abetting liability and denied leave to amend due to plaintiffs' refusal to amend earlier.The Second Circuit affirmed the dismissal, noting that the District Court applied too stringent a standard for general awareness but concluded that plaintiffs' claims still failed under the correct standard. Plaintiffs then moved under Federal Rule of Civil Procedure 60(b)(6) to vacate the final judgment to file an amended complaint. The District Court denied the motion, ruling that the Second Circuit’s clarification did not constitute "extraordinary circumstances" required for Rule 60(b)(6) relief and that plaintiffs' prior choices not to amend counseled against relief. The Second Circuit reversed, holding that district courts must balance Rule 60(b)’s finality principles with Rule 15(a)’s liberal amendment policy.The Supreme Court of the United States held that relief under Rule 60(b)(6) requires extraordinary circumstances, and this standard does not become less demanding when the movant seeks to reopen a case to amend a complaint. A party must first satisfy Rule 60(b) before Rule 15(a)’s liberal amendment standard can apply. The Court reversed the Second Circuit’s decision, emphasizing that the District Court correctly applied the Rule 60(b)(6) standard and provided substantial justification for its conclusion. The case was remanded for further proceedings consistent with this opinion. View "BLOM Bank SAL v. Honickman" on Justia Law

The President invoked the Alien Enemies Act (AEA) to remove Venezuelan nationals identified as members of the Tren de Aragua (TdA), a designated foreign terrorist organization. Two detainees, along with a putative class of similarly situated detainees in the Northern District of Texas, sought injunctive relief against their summary removal under the AEA. The detainees were being held in U.S. detention facilities and were notified of their imminent removal.The District Court denied the detainees' motion for a temporary restraining order (TRO) against their removal. The detainees then moved for an emergency TRO, which was not promptly addressed by the District Court. Consequently, they appealed to the Fifth Circuit, which dismissed their appeal for lack of jurisdiction and denied their motion for an injunction pending appeal, citing insufficient time given to the district court to act. The detainees also applied to the Supreme Court for a temporary injunction.The Supreme Court of the United States reviewed the case and found that the Fifth Circuit erred in dismissing the detainees' appeal for lack of jurisdiction. The Court held that the District Court's inaction had the practical effect of refusing an injunction, given the extreme urgency and high risk of irreparable harm faced by the detainees. The Supreme Court vacated the judgment of the Fifth Circuit and remanded the case for further proceedings. The Court emphasized that due process requires adequate notice and time for detainees to seek habeas relief before removal. The Government was enjoined from removing the detainees under the AEA pending further proceedings and disposition of the petition for a writ of certiorari. View "A.A.R.P. v. Trump" on Justia Law

Monsalvo Velázquez, a Mexican national, entered the U.S. unlawfully and has lived in Colorado for about 20 years. The federal government initiated removal proceedings against him in 2011. He requested either suspension of removal due to potential persecution in Mexico or permission to leave voluntarily. An immigration judge found him removable but granted him 60 days to depart voluntarily. The Board of Immigration Appeals (BIA) upheld the removal order and granted a new 60-day voluntary departure period, which ended on a Saturday. Monsalvo filed a motion to reopen on the following Monday, but the BIA rejected it as untimely, stating the deadline expired on Saturday.The Tenth Circuit Court of Appeals agreed with the BIA, holding that the 60-day voluntary departure period in 8 U.S.C. §1229c(b)(2) refers to calendar days, with no extension for weekends or holidays. Monsalvo then petitioned for review by the Supreme Court.The Supreme Court of the United States reviewed the case and held that it has jurisdiction to review Monsalvo’s petition under §1252, which allows for judicial review of final orders of removal and all questions of law arising from them. The Court determined that the term “60 days” in §1229c(b)(2) should be interpreted to extend deadlines falling on weekends or legal holidays to the next business day, aligning with longstanding administrative practices and other similar statutory deadlines.The Supreme Court reversed the Tenth Circuit’s decision and remanded the case for further proceedings consistent with this interpretation. View "Velazquez v. Bondi" on Justia Law

The case involves the detention and removal of Venezuelan nationals believed to be members of Tren de Aragua (TdA), a group designated as a foreign terrorist organization by the State Department. The President issued a proclamation under the Alien Enemies Act (AEA) to detain and remove these individuals. Five detainees and a putative class sought injunctive and declaratory relief against their removal under the Proclamation, initially seeking relief in habeas but later dismissing those claims.The District Court for the District of Columbia issued two temporary restraining orders (TROs) preventing the removal of the named plaintiffs and a provisionally certified class of noncitizens subject to the Proclamation. The court extended the TROs for an additional 14 days. The D.C. Circuit denied the Government’s emergency motion to stay the orders, leading the Government to seek vacatur from the Supreme Court.The Supreme Court of the United States construed the TROs as appealable injunctions and granted the Government's application to vacate the orders. The Court held that challenges to removal under the AEA must be brought in habeas corpus, as the claims necessarily imply the invalidity of the detainees' confinement and removal. The Court also determined that venue for such habeas petitions lies in the district of confinement, which in this case is Texas, making the District of Columbia an improper venue. The detainees are entitled to notice and an opportunity to seek habeas relief in the proper venue before removal. The application to vacate the District Court's orders was granted, and the TROs were vacated. View "Trump v. J. G. G." on Justia Law

The United States District Court for the District of Massachusetts issued a temporary restraining order (TRO) on March 10, 2025, preventing the Government from terminating various education-related grants. The order also required the Government to pay past-due grant obligations and continue paying future obligations. The District Court concluded that the respondents were likely to succeed on the merits of their claims under the Administrative Procedure Act (APA).The Government filed an application to vacate the District Court's order on March 26, 2025, which was extended on March 24, 2025. The application was presented to Justice Jackson and referred to the Supreme Court. The Supreme Court noted that the District Court's order had characteristics of a preliminary injunction, making it appealable. The Government argued that the District Court lacked jurisdiction to order the payment of money under the APA, as the APA's waiver of sovereign immunity does not apply to claims seeking money damages or to orders enforcing contractual obligations to pay money.The Supreme Court of the United States granted the Government's application to stay the District Court's order pending the appeal in the United States Court of Appeals for the First Circuit and any subsequent petition for a writ of certiorari. The Court found that the respondents had not refuted the Government's claim that it would be unlikely to recover the grant funds once disbursed and that respondents would not suffer irreparable harm while the TRO is stayed. The stay will terminate automatically if certiorari is denied or upon the sending down of the judgment of the Supreme Court if certiorari is granted. The Chief Justice would have denied the application. View "Department of Education v. California" on Justia Law

Gary Waetzig, a former employee of Halliburton Energy Services, Inc., filed a federal age-discrimination lawsuit against the company. He later submitted his claims for arbitration and voluntarily dismissed his federal lawsuit without prejudice under Federal Rule of Civil Procedure 41(a). After losing in arbitration, Waetzig sought to reopen his dismissed lawsuit and vacate the arbitration award, citing Federal Rule of Civil Procedure 60(b) as the basis for reopening the case.The U.S. District Court for the District of Colorado reopened the case, ruling that a voluntary dismissal without prejudice counts as a "final proceeding" under Rule 60(b) and that Waetzig made a mistake by dismissing his case rather than seeking a stay. The District Court also granted Waetzig's motion to vacate the arbitration award. Halliburton appealed, and the Tenth Circuit reversed the District Court's decision, holding that a voluntary dismissal without prejudice does not count as a "final judgment, order, or proceeding" under Rule 60(b).The Supreme Court of the United States reviewed the case and held that a case voluntarily dismissed without prejudice under Rule 41(a) counts as a "final proceeding" under Rule 60(b). The Court reasoned that a voluntary dismissal is "final" because it terminates the case and aligns with the definitions and historical context of the term "final." The Court also concluded that a voluntary dismissal qualifies as a "proceeding" under Rule 60(b), encompassing all steps in an action's progression. The judgment of the Tenth Circuit was reversed, and the case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Waetzig v. Halliburton Energy Services, Inc." on Justia Law

Virginia drivers whose licenses were suspended for failing to pay court fines challenged the constitutionality of the statute under 42 U.S.C. §1983. The District Court granted a preliminary injunction preventing enforcement of the statute. Before the case reached final judgment, the Virginia General Assembly repealed the statute, requiring reinstatement of the suspended licenses. The parties agreed to dismiss the case as moot.The District Court declined to award attorney’s fees to the drivers under §1988(b), reasoning that obtaining a preliminary injunction did not qualify them as “prevailing parties.” A Fourth Circuit panel affirmed this decision, but the Fourth Circuit en banc reversed, holding that some preliminary injunctions can provide lasting, merits-based relief, qualifying plaintiffs as prevailing parties even if the case becomes moot before final judgment.The Supreme Court of the United States reviewed the case and held that the drivers, who only obtained preliminary injunctive relief before the action became moot, do not qualify as “prevailing parties” eligible for attorney’s fees under §1988(b). The Court reasoned that no court conclusively resolved their claims by granting enduring judicial relief on the merits that materially altered the legal relationship between the parties. The judgment of the Fourth Circuit was reversed, and the case was remanded for further proceedings consistent with this opinion. View "Lackey v. Stinnie" on Justia Law

Anastasia Wullschleger sued Royal Canin U.S.A., Inc. in state court, alleging deceptive marketing practices. Her original complaint included both federal and state law claims. Royal Canin removed the case to federal court based on the federal claims, which allowed the federal court to exercise supplemental jurisdiction over the state claims. Wullschleger then amended her complaint to remove all federal claims and requested the case be remanded to state court.The District Court denied Wullschleger’s request to remand the case. However, the Eighth Circuit Court of Appeals reversed this decision, concluding that the amended complaint, which no longer contained any federal claims, eliminated the basis for federal-question jurisdiction. Consequently, the federal court also lost its supplemental jurisdiction over the state-law claims.The Supreme Court of the United States reviewed the case and held that when a plaintiff amends her complaint to delete the federal-law claims that enabled removal to federal court, the federal court loses supplemental jurisdiction over the remaining state-law claims. The case must then be remanded to state court. The Court affirmed the Eighth Circuit’s decision, emphasizing that the jurisdictional analysis must be based on the amended complaint, which in this case contained only state-law claims. View "Royal Canin U.S.A. v. Wullschleger" on Justia Law