Justia Civil Procedure Opinion Summaries

The case involves Andris Pukke, Peter Baker, and John Usher, who were found liable for violations of the Federal Trade Commission Act, the Telemarketing Sales Rule, and a permanent injunction from a prior fraud case. They were involved in a real estate scam, selling lots in a development called "Sanctuary Belize" through deceptive practices. The district court issued an equitable monetary judgment of $120.2 million for consumer redress, imposed an asset freeze, and appointed a receiver.The United States District Court for the District of Maryland found the defendants liable after a bench trial and issued permanent injunctions against them. The court also held them in contempt for violating a prior judgment in a related case, ordering them to pay the same $120.2 million in consumer redress. The defendants appealed, and the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, except for vacating the monetary judgment to the extent it relied on FTC Act Section 13(b).The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision to maintain the receivership and asset freeze. The court held that the receivership and asset freeze were necessary to effectuate the injunctive relief and ensure that the defendants did not continue to profit from their deceptive practices. The court also found that the contempt judgment supported maintaining the receivership and asset freeze until the judgment was satisfied. The court emphasized the defendants' history of deceptive conduct and the need for a professional receiver to manage and distribute the assets to defrauded consumers. The judgment was affirmed. View "Federal Trade Commission v. Pukke" on Justia Law

R.A. filed a lawsuit against her son G.A.'s special education teacher, Robin Johnson, and several school officials, alleging that Johnson mistreated G.A. during the first and second grades. The complaint claimed that Johnson subjected G.A. to physical and emotional abuse and that the school officials negligently failed to intervene despite knowing about the abuse. The school officials moved to dismiss the negligence claims, arguing they were protected by public official immunity. The district court denied the motion, and the school officials filed an interlocutory appeal.The United States District Court for the Western District of North Carolina initially denied the school officials' motion to dismiss the state law claims, leading to an appeal. The Fourth Circuit Court of Appeals previously ruled that the school officials were entitled to public official immunity and that the state law claims against them should be dismissed. Despite this, the district court allowed R.A. to file an amended complaint with additional details from new evidence, which the school officials again moved to dismiss. The district court denied this motion, interpreting the appellate mandate as allowing dismissal without prejudice.The Fourth Circuit Court of Appeals reviewed the case again and held that the district court violated the mandate rule by not dismissing the claims with prejudice as instructed. The appellate court emphasized that its prior decision required dismissal with prejudice and that the district court's interpretation was incorrect. The court reiterated that the mandate rule requires lower courts to follow the appellate court's instructions precisely and that no exceptions to the mandate rule applied in this case. Consequently, the Fourth Circuit reversed the district court's decision, reaffirming that the state law claims against the school officials must be dismissed with prejudice. View "R.A. v. McClenahan" on Justia Law

Brandon Williams was involved in a series of interactions with Norfolk, Virginia police officers. Initially, Officer John D. McClanahan falsely charged Williams with misdemeanor trespassing and perjured himself at trial to secure a conviction. Williams appealed and used a recording to expose McClanahan's perjury, leading to the dismissal of the charge by the state appellate court. Two weeks later, Williams was hit by a speeding drunk driver, and responding officers, including McClanahan, allegedly falsified the accident report to deprive Williams of his right to sue the other driver.Williams filed a lawsuit in the United States District Court for the Eastern District of Virginia, asserting claims of retaliation for exercising his First and Sixth Amendment rights, conspiracy, and intentional infliction of emotional distress (IIED). The district court dismissed Williams' retaliation claim, finding he failed to plead an adverse action, and dismissed his conspiracy claim for lack of a constitutional violation. The court also dismissed Williams' state law IIED claims without prejudice, declining to exercise supplemental jurisdiction.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that Williams adequately alleged that the officers' intentional misrepresentation on the accident report would likely deter him from recording police activity and defending himself at trial in the future. Therefore, the court reversed the district court's dismissal of his retaliation claim. The court also vacated the dismissal of his conspiracy claim, finding a plausible constitutional violation, and remanded the claim for reconsideration. Finally, the court vacated the dismissal of Williams' IIED claims and remanded them for further consideration. View "Williams v. Mitchell" on Justia Law

Jay Folse, a pro se litigant, attempted to initiate a lawsuit by faxing a complaint to a federal district court. The court clerk stamped the complaint as "filed," created an electronic docket, and added the complaint to the docket. However, two weeks later, the district court dismissed the complaint without prejudice, citing local rules that did not permit filing complaints by fax and denying Folse's request for permission to do so.The United States District Court for the Northern District of West Virginia dismissed Folse's complaint without prejudice and without granting leave to amend. Folse appealed the decision, arguing that the district court's local rules should not have been enforced in a way that caused him to lose his right to file the complaint.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that Federal Rule of Civil Procedure 5(d)(3)(B)(i) allows pro se litigants to file electronically only if permitted by court order or local rule. The court found that the relevant local rule, N.D. W. Va. LR Gen. P. 5.05(a), explicitly excluded complaints or petitions from being filed by fax. The court also determined that Folse did not identify any local rule or court order that authorized him to file his complaint via fax. Additionally, the court noted that the district court had the discretion to permit fax filing but did not abuse its discretion in denying Folse's request. The court concluded that the district court's enforcement of the local rules did not cause Folse to lose any right due to a nonwillful failure to comply, as the complaint was dismissed without prejudice, allowing for refiling. The judgment of the district court was affirmed. View "Folse v. Hoffman" on Justia Law

The case involves the Republican National Committee (RNC) and the North Carolina Republican Party (NCGOP) filing two state law claims against the North Carolina State Board of Elections (State Board) and its members. The claims, one statutory and one constitutional, allege that the State Board failed to comply with the Help America Vote Act of 2002 (HAVA), which mandates certain voter registration and maintenance procedures. The Democratic National Committee (DNC) intervened as a defendant. The plaintiffs argue that the State Board's noncompliance with HAVA led to improper voter registrations, potentially affecting 225,000 voters.The United States District Court for the Eastern District of North Carolina initially reviewed the case. The district court found it had original jurisdiction over the state statutory claim but not the state constitutional claim. It dismissed the statutory claim, ruling that the relevant statutory provision did not provide a private right of action. Consequently, the district court declined to exercise supplemental jurisdiction over the state constitutional claim and remanded it to state court, also holding that Section 1443 did not provide a valid basis for removal.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court held that the district court's remand order was improper. It found that the district court possessed original jurisdiction over the state constitutional claim under Section 1331 because the claim contained an embedded federal question. The court also determined that removal was permissible under Section 1441. Additionally, the court held that the defendants validly removed the constitutional claim pursuant to Section 1443(2), which allows for removal in cases involving the refusal to perform an act on the grounds that it would be inconsistent with laws providing for equal rights. The court reversed the district court’s remand order and remanded the case for further proceedings consistent with its opinion. View "RNC v. North Carolina State Board of Elections" on Justia Law

The case involves eight multiemployer benefit plans (the "Funds") seeking to recover delinquent contributions from Stromberg Metal Works, Inc. for health, pension, and other benefits for sheet metal workers. The Funds allege that Stromberg underpaid contributions owed under a collective bargaining agreement (CBA) with the Sheet Metal, Air, Rail and Transportation Union (SMART Union) by hiring temporary workers through staffing agencies without making the required contributions.Initially filed in the Middle District of Tennessee, the case was transferred to the Eastern District of North Carolina. The district court denied Stromberg’s motion for summary judgment, granted the Funds’ cross-motion for summary judgment, and awarded the Funds over $823,000 in delinquent contributions and more than $430,000 in liquidated damages and interest. Stromberg appealed, challenging both the liability and damages rulings.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s liability ruling, agreeing that the 2019 Settlement between Stromberg and Local 5 did not preclude the Funds from seeking delinquent contributions. The court emphasized that multiemployer benefit plans have distinct interests from local unions and are not bound by settlements to which they are not parties.However, the Fourth Circuit vacated the district court’s damages ruling. The appellate court concluded that while the Funds could rely on the CBA’s default staffing ratio to approximate damages due to Stromberg’s failure to maintain adequate records, Stromberg had presented sufficient evidence to cast doubt on the accuracy of the Funds’ damages calculation. The case was remanded for further proceedings to address the disputed damages issue. View "Sheet Metal Workers' Health & Welfare Fund of North Carolina v. Stromberg Metal Works, Inc." on Justia Law

Tijuana Decoster, an African American, served as the Chief Grants Management Officer for the National Institute of Neurological Disorders & Stroke at the U.S. Department of Health and Human Services (HHS). Her working relationship with her supervisor, Robert Finkelstein, deteriorated in 2019, leading to allegations of racial discrimination. Decoster claimed Finkelstein singled her out, treated her with contempt, and threatened to fire her. She was issued a Letter of Expectation and placed on an Opportunity to Demonstrate Acceptable Performance plan. Despite her complaints to Human Resources and Finkelstein, the alleged harassment continued, leading Decoster to retire in February 2020.Decoster filed a formal discrimination complaint with the National Institutes of Health (NIH) in December 2019, alleging harassment, discrimination based on race, and retaliation. NIH's Final Agency Decision in November 2020 found that Decoster was subjected to retaliation but denied her other claims. Decoster then filed a complaint in the District of Maryland, raising three claims under Title VII: hostile work environment, constructive discharge, and retaliation. The district court dismissed her complaint for failure to state a claim under Fed. R. Civ. P. 12(b)(6).The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Decoster’s hostile work environment and constructive discharge claims, finding that her allegations did not establish severe or pervasive conduct or intolerable working conditions. However, the court reversed the dismissal of her retaliation claim, holding that Decoster had sufficiently stated a plausible claim of retaliation under Title VII. The case was remanded for further proceedings on the retaliation claim. View "Decoster v. Becerra" on Justia Law

Jonathan Eugene Brunson, an inmate in North Carolina, filed a § 1983 action against the North Carolina Attorney General and other state officials, seeking various forms of relief. Brunson acknowledged that he had previously filed four § 1983 suits that were dismissed under Heck v. Humphrey, which bars federal courts from entertaining § 1983 suits for damages that would undermine the legality of a conviction unless the conviction has been invalidated. Despite these dismissals, Brunson moved to proceed in forma pauperis.The United States District Court for the Eastern District of North Carolina initially granted Brunson’s request to proceed in forma pauperis but later vacated that order, citing the Prison Litigation Reform Act’s (PLRA) three-strikes rule. The district court determined that Brunson’s prior dismissals under Heck counted as strikes for failure to state a claim. Consequently, Brunson prepaid the filing fee, but his § 1983 complaint was eventually dismissed for reasons not relevant to the current appeal. Brunson then appealed and applied to proceed on appeal without prepaying fees, arguing that Heck dismissals should not count as PLRA strikes.The United States Court of Appeals for the Fourth Circuit reviewed the case to determine whether a dismissal under Heck constitutes a strike under the PLRA. The court held that a Heck dismissal is necessarily for failure to state a claim because it denies the existence of a cause of action unless the plaintiff can prove that the conviction or sentence has been invalidated. Therefore, such dismissals count as strikes under the PLRA. As Brunson had at least three prior Heck dismissals, the court denied his motion to proceed in forma pauperis on appeal. View "Brunson v. Stein" on Justia Law

Marco Fernandez applied to rent an apartment, and RentGrow, Inc. provided a tenant screening report to the property owner. The report inaccurately indicated that Fernandez had a "possible match" with a name on the OFAC list, which includes individuals involved in serious crimes. However, the property manager did not understand or consider this information when deciding on Fernandez's application. Fernandez sued RentGrow, alleging that the company violated the Fair Credit Reporting Act (FCRA) by not ensuring the accuracy of the OFAC information.The United States District Court for the District of Maryland certified a class of individuals who had similar misleading OFAC information in their reports. The court rejected RentGrow's argument that Fernandez and the class lacked standing because they did not demonstrate a concrete injury. The district court held that the dissemination of the misleading report itself was sufficient to establish a concrete injury.The United States Court of Appeals for the Fourth Circuit reviewed the case and disagreed with the district court's conclusion. The appellate court held that reputational harm can be a concrete injury, but only if the misleading information was read and understood by a third party. In this case, there was no evidence that anyone at the property management company read or understood the OFAC information in Fernandez's report. Therefore, Fernandez failed to demonstrate a concrete injury sufficient for Article III standing. The Fourth Circuit vacated the district court's class certification order and remanded the case for further proceedings. View "Fernandez v. RentGrow, Inc." on Justia Law

Two students receiving special education services filed a class action lawsuit against the Kanawha County Board of Education, alleging that the Board denied them and other similarly situated students a free appropriate public education (FAPE) as guaranteed by the Individuals with Disabilities Education Act (IDEA). The lawsuit also claimed violations of Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act. The district court certified a class of all Kanawha County Schools students with disabilities who need behavior supports and have experienced disciplinary removals from any classroom.The United States District Court for the Southern District of West Virginia granted the plaintiffs' motion to certify the class, reasoning that the plaintiffs had presented expert evidence of disproportionate rates of suspension for students with disabilities and a detailed qualitative analysis of student records. The court found that these factors revealed a cohesive pattern indicating the absence of an effective system for developing and implementing behavioral supports for students with disabilities. The Board appealed, arguing that the certification of the plaintiff class was inconsistent with Federal Rules of Civil Procedure 23(a) and (b)(2).The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s certification order. The Fourth Circuit held that the certified class failed to satisfy Rule 23(a)(2)’s commonality prerequisite. The court found that the plaintiffs did not identify a common contention central to the validity of all class members’ claims. The court noted that the claims were highly diverse and individualized, involving different practices at different stages of the special education process. The absence of a common contention foreclosed class treatment. The case was remanded for further proceedings consistent with the opinion. View "G.T. v. The Board of Education of the County of Kanawha" on Justia Law