Justia Civil Procedure Opinion Summaries

The case involves Mike Govender Hatchet, a Sierra Leone citizen who sought to adjust his immigration status to that of a lawful permanent resident in the United States. Hatchet applied for discretionary relief multiple times, but the United States Citizenship and Immigration Services (USCIS) denied each application, citing facts that rendered Hatchet ineligible for discretionary relief. Hatchet challenged the agency's actions in federal district court, arguing that the agency relied on facts clearly at odds with the record.The case was initially heard in the United States District Court for the Middle District of Tennessee. The district court dismissed Hatchet's case for lack of subject-matter jurisdiction, agreeing with the defendants' argument that the Supreme Court's recent decision in Patel demonstrated that Hatchet's claims were not subject to judicial review due to a jurisdiction-stripping statute.The case was then appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court's dismissal for lack of subject-matter jurisdiction. The court held that the district court lacked jurisdiction to review the factual findings of USCIS, and because Hatchet's arguments were entirely fact-bound, the court agreed that the district court properly dismissed the case for lack of subject-matter jurisdiction. The court's decision was based on the Supreme Court's recent decision in Patel, which held that federal courts are without jurisdiction to review both discretionary and non-discretionary judgments related to the granting of relief, including factual findings. View "Hatchet v. Andrade" on Justia Law

In 1987, Michael Kitchen, a seventeen-year-old, was sentenced to forty-two to sixty years in prison by a Michigan state court for his involvement in a home invasion. Under Michigan law, Kitchen is not eligible for parole until he completes his minimum sentence, which means he will not be considered for parole until he is nearly sixty. Kitchen filed a pro se § 1983 suit challenging the statute against Michigan’s governor, the Department of Corrections Director, and the chair of the Parole Board. He alleges that Michigan’s parole statute violates his Eighth Amendment rights because it effectively keeps him in prison for life without parole. The district court sided with Kitchen.The district court agreed with Kitchen and ruled against Defendants in an opinion and order on August 16, 2019. The court concluded that, despite the “legal and factual support” for Defendants’ position, “Kitchen is not required to bring his federal constitutional claims via a petition for a writ of habeas corpus,” and he could pursue them under § 1983. The district court thus rejected Defendants’ Heck argument. The Heck issue was not litigated any further.The United States Court of Appeals for the Sixth Circuit disagreed with the district court's decision. The court held that Kitchen's claim, if successful, would necessarily imply the invalidity of his sentence. Therefore, his claim must be brought through habeas corpus, not § 1983. The court reversed the district court's decision and remanded the case for further proceedings. View "Kitchen v. Whitmer" on Justia Law

The case involves the Tennessee Conference of the National Association for the Advancement of Colored People (NAACP) challenging a state policy that requires some convicted felons to submit additional documentation to confirm their eligibility to vote. The NAACP argued that this policy violated the National Voter Registration Act (NVRA). A district court agreed with the NAACP and permanently enjoined the policy in the middle of the 2024 election cycle. Tennessee's Secretary of State and Coordinator of Elections appealed this decision and sought a stay of the injunction pending appeal.The district court's decision was based on the finding that the NAACP had standing to challenge the policy and that the policy violated the NVRA. The court held that the policy was unnecessary for determining the eligibility of those with felony convictions as the state had other information at its disposal to make that decision.The United States Court of Appeals for the Sixth Circuit granted the stay for two reasons. First, the injunction triggered the Supreme Court’s “Purcell principle,” which instructs federal courts not to disrupt state election rules close to an election. Second, the court found that the NAACP likely did not present enough evidence to prove its standing to challenge the Documentation Policy. The court concluded that the NAACP's claim that the policy forced it to divert its resources to help those convicted of felonies track down the records they need to register was not supported by specific facts. View "Tennessee Conference of the NAACP v. Lee" on Justia Law

This case involves a catastrophic wildfire that occurred in 2016 in the Great Smoky Mountains National Park in Eastern Tennessee. The fire spread into Gatlinburg and Sevier County, resulting in the destruction of over 2,500 structures and the death of 14 people. The appellant insurance companies paid claims to policy holders and then filed claims under the Federal Tort Claims Act (FTCA) against the National Park Service (NPS), alleging negligence for failure to follow multiple mandatory fire-management protocols and for the failure to issue mandatory warnings to the public.The government moved to dismiss the case for lack of subject-matter jurisdiction, arguing that it was immune from suit under the discretionary-function exception to the FTCA. The district court granted the motion on all three claims relating to fire-management protocols, but denied the motion on claims relating to the duty to warn. The insurance companies appealed, and the government cross-appealed.The United States Court of Appeals for the Sixth Circuit reversed the district court's order granting the government's motion to dismiss the insurance companies' incident-command claim. The court affirmed the district court's dismissal of the fire-monitoring claim and the Wildland Fire Decision Support System (WFDSS) claim as part of the discretionary fire-suppression decision-making process. The court also affirmed the district court's denial of the government's facial challenge to the insurance companies' duty-to-warn claims, and remanded these claims for further proceedings. View "American Reliable Insurance Co. v. United States" on Justia Law

The case involves Shannon Blick, a former principal of an elementary school in the Ann Arbor Public School District. In 2019, Blick was placed on paid leave while the school district investigated her role in a custodian's over-billing scheme. The leave lasted two years, and the school district eventually terminated Blick's contract. Blick filed a lawsuit while still on leave, alleging that various officials violated her freedoms of speech and association under the First Amendment. She also brought race-discrimination, due-process, and conspiracy claims against these officials. The district court rejected Blick's First Amendment claims at the summary-judgment stage and dismissed the other claims on the pleadings.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that Blick failed to show a reversible error. She argued that the school district violated the First Amendment by imposing a prior restraint that barred her from speaking during her leave and by taking harmful actions against her in retaliation for her speech. However, the court found that Blick's lawyers did not provide sufficient information about what she wanted to say or what she did say. The court also found that Blick's opening brief did not preserve her challenges to much of the district court's motion-to-dismiss decision. As a result, the court affirmed the district court's decision. View "Blick v. Ann Arbor Public School District" on Justia Law

The case involves Benjamin Stanley, who was employed by Western Michigan University (WMU) for about a month before his employment was terminated. Stanley, who has severe ADHD, claimed that WMU and certain supervisors discriminated and retaliated against him in violation of the Americans with Disabilities Act (ADA). He also brought a claim under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), as well as a claim for intentional infliction of emotional distress. The district court dismissed Stanley’s federal claims for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and dismissed his state-law claims for failure to comply with the Michigan Court of Claims Act’s notification statute.The district court's dismissal of Stanley's claims was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court’s dismissal of Stanley’s federal claims and the denial of Stanley’s motion for leave to amend his complaint. However, the court vacated the judgment in part and remanded to the district court to dismiss Stanley’s federal and state-law claims without prejudice. The court found that the district court lacked subject-matter jurisdiction to adjudicate Stanley’s ADA claims because the defendants were entitled to Eleventh Amendment immunity, and Stanley lacked standing to request injunctive relief from the individual defendants. The court also found that the district court lacked jurisdiction to decide Stanley’s state-law claims because it lacked subject matter jurisdiction over any federal issues. View "Stanley v. Western Michigan University" on Justia Law

Brent Adkins, a crew member on one of Marathon Petroleum Company’s inland river barges, claimed that his service on the barge caused his lung function to deteriorate. He brought claims against Marathon under the Jones Act and general maritime law. Adkins worked on the barge from 2008 to 2012. During this time, he underwent several medical examinations which showed a decline in his Forced Vital Capacity (FVC), a measure of lung function. Despite this, Marathon cleared Adkins to work without restriction. In March 2012, Adkins fell ill and was diagnosed with an irregular heartbeat and heat intolerance. He never returned to work for Marathon and subsequently sued the company.The case was initially filed in Louisiana state court but was dismissed on forum non conveniens grounds. Adkins then sued Marathon in the Southern District of Ohio. He claimed that repeated exposure to hydrogen sulfide and other hydrocarbon fumes while working on the barge caused his pulmonary function to deteriorate. He also claimed that Marathon failed to pay maintenance and cure for the injuries and illnesses he sustained while working on the barge. Marathon moved for summary judgment on all of Adkins’s claims. The district court granted Marathon’s motion for summary judgment and denied Adkins’s.The United States Court of Appeals for the Sixth Circuit affirmed in part, reversed in part, and remanded to the district court. The court held that Adkins needed expert medical proof to show causation on his Jones Act negligence claims. However, the court reversed the district court’s grant of summary judgment to Marathon on Adkins’s maintenance-and-cure claim, finding that Adkins presented evidence that created a genuine dispute of material fact about whether his lung problems manifested while he was in Marathon’s service. The case was remanded for further proceedings. View "Adkins v. Marathon Petroleum Co., LP" on Justia Law

The case involves the Michigan Attorney General's attempt to shut down Enbridge’s Line 5 Pipeline, which runs underwater across the Straits of Mackinac between Michigan’s Lower and Upper Peninsulas. The Attorney General filed the case in Michigan state court in 2019, alleging violations of three state laws. Enbridge responded by moving for summary disposition, arguing that the complaint failed to state a claim on which relief could be granted. The state court held oral argument on those dispositive motions, focusing on preemption issues, including whether the Attorney General’s claims were preempted by either the Pipeline Safety Act or the federal Submerged Lands Act.In 2020, Michigan Governor Gretchen Whitmer issued a notice of revocation of the 1953 easement, calling for Line 5 to be shut down by May 2021, and simultaneously filed a complaint in state court to enforce the notice. Enbridge timely removed the Governor’s case to the United States District Court for the Western District of Michigan. The district court denied the Governor’s motion to remand, holding that it had federal-question jurisdiction. The Governor subsequently voluntarily dismissed her case.Enbridge removed the Attorney General’s case to federal court in December 2021, citing the district court’s order denying the motion to remand in the Governor’s case. The Attorney General moved to remand this case to state court on grounds of untimely removal and lack of subject-matter jurisdiction. The district court denied the motion on both grounds, excusing Enbridge’s untimely removal based on equitable principles and estopping the Attorney General from challenging subject-matter jurisdiction.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision, holding that Enbridge failed to timely remove the case to federal court under 28 U.S.C. § 1446(b), and there are no equitable exceptions to the statute’s deadlines for removal. The case was remanded to Michigan state court. View "Nessel v. Enbridge Energy, LP" on Justia Law

The case revolves around Yvonne Craddock, an African American woman who was terminated from her employment at FedEx Corporate Services following a workplace altercation. Craddock alleged that her termination was racially motivated, in violation of Title VII of the Civil Rights Act of 1964. The case was presented to a jury, which concluded that FedEx's reason for termination was pretextual, but that Craddock had failed to demonstrate that FedEx intentionally discriminated against her because of her race. Craddock appealed, arguing that the district court had made several errors, including forcing her to bifurcate the liability and damages portions of her trial and excluding testimony and evidence pertaining to events post-termination.The district court had granted FedEx’s motion to dismiss Craddock’s libel claim, Family Medical Leave Act claim, 42 U.S.C. § 1981 claim, and spoliation claim, but denied dismissal of her Title VII claims. After discovery, the court granted FedEx’s motion for summary judgment on Craddock’s Title VII claims. The case was then taken to the United States Court of Appeals for the Sixth Circuit.The Court of Appeals held that the district court did not abuse its discretion regarding the claims raised by Craddock, and affirmed the jury’s verdict. The court found that the district court's decision to bifurcate the trial was not an abuse of discretion, and that the court's exclusion of testimony and exhibits postdating the termination was not erroneous. The court also found no error in the district court's trial rulings and case management decisions, and concluded that the jury verdict form was not plainly erroneous. The court further held that the cumulative effect of the alleged errors did not deprive Craddock of a trial consistent with constitutional guarantees of due process. View "Craddock v. FedEx Corporate Services, Inc." on Justia Law

The case involves the Mackinac Center for Public Policy and the Cato Institute (Plaintiffs) who sued the U.S. Department of Education and its officials (Defendants) over a one-time account adjustment announced by the Department. The adjustment was intended to count months or years that student-loan borrowers spent in excessive forbearance status towards debt forgiveness. The Plaintiffs, being nonprofit, tax-exempt organizations and qualified public service employers under the Public Service Loan Forgiveness (PSLF) program, argued that this adjustment would harm their ability to recruit and retain employees.The case was initially heard in the United States District Court for the Eastern District of Michigan, where the court dismissed the Plaintiffs' complaint for lack of subject-matter jurisdiction, concluding that the Plaintiffs lacked standing. The Plaintiffs appealed this decision.The United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision. The court held that the Plaintiffs failed to demonstrate that they suffered an injury in fact, a requirement for establishing standing. The court rejected the Plaintiffs' arguments that they had competitor standing and that they were deprived of a procedural right. The court found that the Plaintiffs' claims were speculative and unsupported by specific facts. Consequently, the court affirmed the dismissal of the Plaintiffs' complaint for lack of subject-matter jurisdiction. View "Mackinac Center for Public Policy v. Cardona" on Justia Law