Justia Civil Procedure Opinion Summaries

G.M., a second-grade student with dyslexia and ADHD, was deemed ineligible for special education by Howard County Public Schools (HCPS) under the Individuals with Disabilities Education Act (IDEA). His parents, disagreeing with this determination, pursued the IDEA’s dispute resolution process, which included a state administrative hearing. The administrative law judge (ALJ) sided with HCPS, leading G.M.’s parents to file a lawsuit in federal district court. The district court upheld the ALJ’s decision, prompting an appeal to the United States Court of Appeals for the Fourth Circuit.The ALJ conducted a six-day hearing, considering evidence from both sides. G.M.’s parents presented private evaluations indicating deficiencies in reading and writing, while HCPS provided assessments showing average performance. The ALJ found HCPS’s evidence more persuasive, concluding that G.M. did not exhibit a pattern of strengths and weaknesses necessary to qualify as having a specific learning disability (SLD) under the IDEA. The ALJ also determined that although G.M. had an other health impairment (OHI) due to ADHD, he did not need special education because he was performing adequately relative to grade-level standards.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The court held that the ALJ’s factual findings and credibility determinations were regularly made and thus entitled to deference. The court agreed that G.M. did not qualify as a “child with a disability” under the IDEA because he did not exhibit the necessary pattern of strengths and weaknesses in reading and writing, and his ADHD did not necessitate special education. The court also found that G.M. received a free appropriate public education (FAPE) without special education services, as he was achieving passing marks and advancing from grade to grade. Consequently, HCPS did not substantively violate the IDEA, and G.M. was not entitled to the requested relief. View "G.M. v. Barnes" on Justia Law

A former employee of Credit Suisse, John Doe, filed a qui tam action under the False Claims Act (FCA) alleging that the bank failed to disclose ongoing criminal conduct to the United States, thereby avoiding additional penalties. This followed Credit Suisse's 2014 guilty plea to conspiracy charges for aiding U.S. taxpayers in filing false tax returns, which included a $1.3 billion fine. Doe claimed that Credit Suisse continued its illegal activities post-plea, thus defrauding the government.The United States District Court for the Eastern District of Virginia granted the government's motion to dismiss the case. The government argued that Doe's allegations did not state a valid claim under the FCA and that continuing the litigation would strain resources and interfere with ongoing obligations under the plea agreement. The district court dismissed the action without holding an in-person hearing, relying instead on written submissions from both parties.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court held that the "hearing" requirement under 31 U.S.C. § 3730(c)(2)(A) of the FCA can be satisfied through written submissions and does not necessitate a formal, in-person hearing. The court found that Doe did not present a colorable claim that his constitutional rights were violated by the dismissal. The court emphasized that the government has broad discretion to dismiss qui tam actions and that the district court properly considered the government's valid reasons for dismissal, including resource conservation and the protection of privileged information. The Fourth Circuit concluded that the district court's dismissal was appropriate and affirmed the judgment. View "United States ex rel. Doe v. Credit Suisse AG" on Justia Law

CSX Transportation, Inc. sued Norfolk Southern Railway Company and Norfolk & Portsmouth Belt Line Railroad Company in 2018, alleging that they conspired to exclude CSX from competing in the international shipping market at the Norfolk International Terminal by imposing an exclusionary switch rate starting in 2010. CSX claimed this rate caused ongoing injury to its business. The key issue was whether the Sherman Act’s four-year statute of limitations barred CSX’s claims or if an exception applied.The United States District Court for the Eastern District of Virginia granted summary judgment to the defendants, finding CSX’s claims time-barred. The court held that the continuing-violation doctrine did not apply because the decision to maintain the switch rate did not constitute a new act causing new injury within the limitations period. The court also found that CSX failed to show specific damages resulting from any acts within the limitations period.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment. The Fourth Circuit agreed that the continuing-violation doctrine did not apply because maintaining the switch rate was not a new act but a continuation of the initial decision. The court also found that CSX did not provide sufficient evidence of new antitrust injury within the limitations period. The court emphasized that for the continuing-violation doctrine to apply, there must be an overt act within the limitations period that causes new injury, which CSX failed to demonstrate. Therefore, the court held that CSX’s claims were time-barred and affirmed the district court’s judgment. View "CSX Transportation, Incorporated v. Norfolk Southern Railway Company" on Justia Law

Alexis Guerrero, a Black Dominican-American, sued Ollie’s Bargain Outlet under 42 U.S.C. § 1981 for race discrimination. Guerrero alleged that while shopping for flowerpots at an Ollie’s store in Salisbury, Maryland, an employee named Richard Murray threatened him with a knife and shouted racial slurs, preventing him from purchasing the items. Guerrero claimed that this discriminatory conduct interfered with his right to make and enforce contracts.The United States District Court for the District of Maryland granted Ollie’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6). The court reasoned that Guerrero failed to sufficiently allege that he was denied the opportunity to contract for goods or services that was otherwise afforded to white customers. Specifically, the court found that Guerrero did not claim that Ollie’s actually prevented him from purchasing a flowerpot and noted that he voluntarily left the store without attempting to make a purchase.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court concluded that Guerrero sufficiently alleged a contractual interest by demonstrating his intent to purchase the flowerpots and that Murray’s actions, including wielding a knife and shouting racial slurs, interfered with this interest. The court found that Guerrero’s allegations were enough to show that he was denied the opportunity to contract based on his race. Consequently, the Fourth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Guerrero v. Ollie's Bargain Outlet, Inc." on Justia Law

In 2013, Johnny Ray Penegar, Jr. was diagnosed with mesothelioma, and Medicare partially covered his treatment costs. He filed a workers' compensation claim against his employer, UPS, and its insurer, Liberty Mutual. After his death, his wife, Carra Jane Penegar, continued the claim and added a death benefits claim. The North Carolina Industrial Commission (NCIC) ruled in her favor, ordering Liberty Mutual to cover all medical expenses related to the mesothelioma and reimburse any third parties, including Medicare. The NCIC's decision was affirmed by the North Carolina Court of Appeals and the Supreme Court of North Carolina denied further review. In 2020, Penegar and Liberty Mutual settled, with Liberty Mutual agreeing to pay $18,500 and to handle any Medicare liens.Penegar filed a class action lawsuit in the Western District of North Carolina under the Medicare Secondary Payer Act (MSP Act), alleging that Liberty Mutual failed to reimburse Medicare, leading to a collection letter from the Centers for Medicare and Medicaid Services (CMS) demanding $18,500. Liberty Mutual moved to dismiss, arguing Penegar lacked standing and that the settlement precluded her claims. The district court agreed, finding Penegar lacked standing and dismissed the case.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court held that Penegar did not suffer a cognizable injury in fact at the time she filed the lawsuit. The NCIC had ordered Liberty Mutual to reimburse Medicare directly, not Penegar, distinguishing her case from Netro v. Greater Baltimore Medical Center, Inc. Additionally, the CMS letter only posed a risk of future harm, which is insufficient for standing in a damages suit. Finally, any out-of-pocket expenses Penegar incurred were already compensated by Liberty Mutual before she filed the lawsuit, negating her claim of monetary injury. View "Penegar v. Liberty Mutual Insurance Co." on Justia Law

Sheila Ann Trantham filed a Chapter 13 bankruptcy plan proposing that the property of the bankruptcy estate vest in her at the time of plan confirmation. The Trustee objected, arguing that the local form plan required the property to vest only when the court entered a final decree. The bankruptcy court agreed with the Trustee, holding that a debtor could not propose a plan that contradicted the local form’s default vesting provision. Trantham amended her plan to conform with the local form but reserved her right to appeal.The United States District Court for the Western District of North Carolina affirmed the bankruptcy court’s decision. The district court reasoned that vesting property in the debtor at confirmation could lead to various risks and practical problems, such as the property being vulnerable to creditors and the trustee lacking sufficient oversight. The court also held that Trantham lacked standing to appeal because she had not shown any injury from having to conform to the local form’s default vesting provision.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court’s order. The Fourth Circuit held that Trantham had standing to appeal because the bankruptcy court’s order diminished her property and increased her procedural burdens. The court also found that the bankruptcy court erred in requiring Trantham to conform to the local form’s default vesting provision. The court emphasized that the Bankruptcy Code allows debtors to propose nonstandard provisions, including vesting provisions, and that the bankruptcy court’s decision to reject Trantham’s proposed vesting provision was not supported by the Code.The Fourth Circuit reversed the district court’s order and remanded the case for further proceedings, instructing the bankruptcy court to assess whether Trantham’s proposed vesting provision should be confirmed or rejected for a reason permitted by the Code. View "Trantham v. Tate" on Justia Law

Sherita Hicks was mistakenly identified and arrested for an assault she did not commit. Detective Gregory Pamer, leading the investigation, showed the victim, Devante Allen, a photo lineup that included Hicks, whom Allen incorrectly identified as the female assailant. Pamer also discovered that a van used in the assault was registered to Hicks and that the attack was retribution for a prior break-in at her home. Despite later receiving exculpatory information implicating another woman, Pamer proceeded with Hicks' arrest. Hicks was jailed for one night before posting bond, and the charges against her were eventually dismissed.Hicks filed a civil rights lawsuit under 42 U.S.C. § 1983 against multiple parties, including Pamer and Anne Arundel County, alleging unlawful arrest, detention, and malicious prosecution. The case proceeded to trial against Pamer and the County on claims of malicious prosecution and gross negligence. During the trial, a juror was dismissed for violating court instructions by speaking to Hicks, despite objections from Hicks' counsel. The jury ultimately found in favor of Pamer on all counts, leading Hicks to file a motion for a new trial, which was denied.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the district court did not abuse its discretion in dismissing the juror for good cause under Federal Rule of Civil Procedure 47(c). The court also found no reversible error in the jury instructions, which adequately stated the controlling law. The jury's verdict in favor of Pamer on all counts was upheld, and the court did not need to address issues related to punitive damages or the inclusion of the County on the verdict sheet, as there was no underlying liability. View "Hicks v. Anne Arundel County" on Justia Law

The case involves a court-appointed receiver tasked with distributing funds recovered from a Ponzi scheme orchestrated by Kevin Merrill, Jay Ledford, and Cameron Jezierski. The scheme defrauded over 230 investors of more than $345 million. The appellants, comprising institutional and individual investors, were among the victims. The institutional investors, known as the Dean Investors, frequently withdrew and reinvested their funds, while the individual investors, known as the Connaughton Investors, invested through a third-party fund and later received settlements from that fund.The United States District Court for the District of Maryland approved the receiver's distribution plan, which used the "Rising Tide" method to allocate funds. This method ensures that no investor recovers less than a certain percentage of their principal investment, but it deducts pre-receivership withdrawals from the recovery amount. The Dean Investors objected to this method, arguing that their reinvested withdrawals should not be counted against them. The Connaughton Investors objected to the plan's "Collateral Offset Provision," which counted third-party settlements as withdrawals, reducing their distribution from the receiver.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The court found no abuse of discretion in the district court's approval of the distribution plan. It held that the Rising Tide method without the Maximum Balance approach was appropriate, as it ensured a fair distribution to more claimants. The court also upheld the Collateral Offset Provision, reasoning that it prevented the Connaughton Investors from receiving a disproportionately higher recovery compared to other victims. The court emphasized the need for equitable distribution and the administrative feasibility of the receiver's plan. View "CCWB Asset Investments, LLC v. Milligan" on Justia Law

Law enforcement officers executed a search warrant at Lee Marvin Harris, Sr.'s home, discovering a significant amount of cocaine in an old Cadillac parked in the yard. Harris, Sr. was arrested for possession with intent to distribute and spent five months in pretrial detention before charges were dismissed. He then sued the Town of Southern Pines and the officers involved, alleging malicious prosecution under the Fourth Amendment and fabrication of evidence under the Fourteenth Amendment, claiming officers omitted material evidence from prosecutors and grand juries.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of the defendants. The court found that probable cause existed for Harris, Sr.'s arrest based on the discovery of cocaine on his property and dismissed the fabrication of evidence claim, reasoning that such claims are not viable if the plaintiff was not convicted. Harris, Sr. appealed the decision.The United States Court of Appeals for the Fourth Circuit reviewed the case and found genuine disputes of material fact regarding whether Harris, Sr. was arrested and charged without probable cause. The court held that the officers were not entitled to qualified immunity for the Fourth Amendment malicious prosecution claim. Additionally, the court determined that a plaintiff who was arrested and detained but not convicted could still state a Fourteenth Amendment fabrication of evidence claim. Consequently, the court reversed the district court's summary judgment on the Fourth Amendment malicious prosecution claim, vacated the summary judgment on the Fourteenth Amendment fabrication of evidence claim, and remanded for further proceedings. The court affirmed the district court's summary judgment on the state law malicious prosecution claim, the failure to intervene claim, and the Monell claim against the Town of Southern Pines and the Chief of Police. View "Harris v. Town of Southern Pines" on Justia Law

The plaintiffs, property owners in West Virginia, filed a lawsuit against the current and former owners of abandoned oil and gas wells on their properties. They sought damages for the defendants' failure to plug the wells, alleging common law nuisance, trespass, and negligence. The defendants argued that the West Virginia Department of Environmental Protection (WVDEP) was responsible for well plugging and that WVDEP had approved transactions between the defendants, which purportedly relaxed their statutory duty to plug the wells. They claimed WVDEP was an indispensable party under Federal Rule of Civil Procedure 19 and, because it could not be joined due to sovereign immunity, sought judgment in their favor under Rule 12(c).The United States District Court for the Northern District of West Virginia denied the defendants' motion, ruling that WVDEP was not a necessary and indispensable party under Rule 19. The court concluded that it could grant the plaintiffs damages on their common law claims without implicating the State’s interests. The defendants then filed an interlocutory appeal, arguing that the district court's order was reviewable under the collateral order doctrine, as it effectively denied WVDEP sovereign immunity.The United States Court of Appeals for the Fourth Circuit reviewed the case and determined that the district court's order did not rule on any immunity issue but only on whether WVDEP was a necessary and indispensable party under Rule 19. The appellate court found that the order did not satisfy the requirements of the collateral order doctrine and was not a final decision. Consequently, the court granted the plaintiffs' motion to dismiss the appeal for lack of jurisdiction. View "McEvoy v. Diversified Energy Company PLC" on Justia Law