Justia Civil Procedure Opinion Summaries

Sergeant Jatonya Clayborn Muldrow, a police officer in the St. Louis Police Department, alleged that she was transferred from her position in the Intelligence Division to a uniformed job in another department because of her gender. Despite maintaining her rank and pay, Muldrow's responsibilities, perks, and schedule were significantly altered. She filed a Title VII suit against the City of St. Louis, claiming that the transfer constituted sex discrimination with respect to her employment terms and conditions.The District Court granted the City summary judgment, and the Eighth Circuit affirmed, holding that Muldrow had to show that the transfer caused her a "materially significant disadvantage." The courts ruled that since the transfer did not result in a reduction to her title, salary, or benefits and only caused minor changes in working conditions, Muldrow's lawsuit could not proceed.The Supreme Court of the United States disagreed with the lower courts' interpretation of Title VII. The Court held that an employee challenging a job transfer under Title VII must show that the transfer brought about some harm with respect to an identifiable term or condition of employment, but that harm need not be significant. The Court rejected the City's arguments based on statutory text, precedent, and policy, and vacated the judgment of the Eighth Circuit, remanding the case for further proceedings under the correct Title VII standard. The Court clarified that Muldrow only needed to show some injury respecting her employment terms or conditions, not that the harm was significant. View "Muldrow v. City of St. Louis" on Justia Law

The Supreme Court of the United States considered whether an Immigration Judge's (IJ) determination of "exceptional and extremely unusual hardship" for the cancellation of removal of a noncitizen was reviewable by an appellate court. The case arose when Situ Kamu Wilkinson, a noncitizen from Trinidad and Tobago, applied for cancellation of removal, arguing that his removal would cause exceptional and extremely unusual hardship to his U.S.-born son. The IJ denied Wilkinson's application, and the Board of Immigration Appeals affirmed. The Third Circuit then dismissed Wilkinson's petition for review, holding it lacked jurisdiction to review the IJ's hardship determination.However, the Supreme Court held that the Third Circuit erred in its decision. It held that the IJ's determination is a mixed question of law and fact, and therefore reviewable under §1252(a)(2)(D), as per the precedent set in Guerrero-Lasprilla v. Barr. The Court emphasized that the “exceptional and extremely unusual hardship” standard is a legal standard applied to facts, not a factual inquiry.However, the Court also noted that while the question of whether established facts satisfy the statutory eligibility standard is subject to judicial review, the underlying facts in any determination on cancellation of removal remain unreviewable. The Court reversed the Third Circuit's decision, vacated its judgment, and remanded the case for further proceedings consistent with its opinion. View "Wilkinson v. Garland" on Justia Law

The case involves Yonas Fikre, a U.S. citizen and Sudanese emigree, who brought a lawsuit alleging that the government unlawfully placed him on the No Fly List. Fikre claimed that the government violated his rights to procedural due process and placed him on the list for constitutionally impermissible reasons related to his race, national origin, and religious beliefs. In 2016, the government removed Fikre from the No Fly List, and argued in court that this action rendered Fikre's lawsuit moot. The district court agreed with the government's assessment, but the Ninth Circuit reversed, stating that a party seeking to moot a case based on its own voluntary cessation of challenged conduct must show that the conduct cannot “reasonably be expected to recur.”The Supreme Court of the United States affirmed the Ninth Circuit's decision. It held that the government failed to demonstrate that the case was moot. The Court stated that a defendant's "voluntary cessation of a challenged practice" will moot a case only if the defendant can prove that the practice cannot "reasonably be expected to recur." The Court found that the government's declaration that it will not relist Fikre based on "currently available information" did not suffice to demonstrate that Fikre will not be placed on the No Fly List in the future if he engages in the same or similar conduct. Therefore, the government has not borne its burden of proving that the dispute is moot. View "FBI v. Fikre" on Justia Law

Before the resumption of federal student-loan repayments that had been suspended during the coronavirus pandemic, the Secretary of Education announced a Plan that would discharge $10,000-$20,000 of an eligible borrower’s debt. The Secretary invoked the 2003 Higher Education Relief Opportunities for Students Act (HEROES Act), which authorizes the Secretary “to waive or modify any provision” applicable to federal student financial assistance programs as “necessary” to ensure that recipients of student financial assistance are no worse off “financially in relation to that financial assistance because” of a national emergency or disaster, 20 U.S.C. 1098. The Act exempts rules promulgated under it from otherwise-applicable negotiated rulemaking and notice-and-comment processes. Borrowers who did not qualify for the Plan's maximum relief alleged that the Secretary was required to follow those rulemaking procedures.The Supreme Court held that the borrowers lacked Article III standing, having failed to establish that any injury they suffer from not having their loans forgiven is fairly traceable to the Plan.The Department also claims authority to forgive loans under the Higher Education Act (HEA), 20 U.S.C. 1082(a)(6). The borrowers cannot show that their purported injury of not receiving HEA loan relief is fairly traceable to the Department’s decision to grant relief under the HEROES Act. They are not claiming that they are injured by not being sufficiently included among the Plan’s beneficiaries but argue the Plan is unlawful and instead seek HEA debt forgiveness. The Department’s authority to grant HEA loan relief is not affected by whether the Plan is lawful. Any incidental effect of the Plan on the likelihood that the Department will undertake loan forgiveness under a different statute is too speculative to show that the absence of HEA-based loan forgiveness is fairly traceable to the Plan. View "Department of Education v. Brown" on Justia Law

Mallory worked as a Norfolk mechanic for 20 years in Ohio and Virginia. After leaving the company, Mallory moved to Pennsylvania, then returned to Virginia. He attributed his cancer diagnosis to his work and sued Norfolk under the Federal Employers’ Liability Act, in Pennsylvania state court. Norfolk, incorporated and headquartered in Virginia, challenged the court’s exercise of personal jurisdiction. Mallory noted that Norfolk manages over 2,000 miles of track, operates 11 rail yards, runs locomotive repair shops in Pennsylvania, and has registered to do business in Pennsylvania in light of its "regular, systematic, extensive” operations there. Pennsylvania requires out-of-state companies that register to do business to agree to appear in its courts on “any cause of action” against them. 42 Pa. Cons. Stat. 5301(a)(2)(i), (b). The Pennsylvania Supreme Court held that the Pennsylvania law violated the Due Process Clause.The Supreme Court vacated. Pennsylvania law is explicit that qualification as a foreign corporation shall permit state courts to exercise general personal jurisdiction over a registered foreign corporation. Norfolk has complied with this law since 1998 when it registered to do business in Pennsylvania. Norfolk's “Certificate of Authority” from the Commonwealth conferred both the benefits and burdens shared by domestic corporations, including amenability to suit in state court on any claim. For more than two decades, Norfolk has agreed to be found in Pennsylvania and answer any suit there. Suits premised on these grounds do not deny a defendant due process of law. Regardless of whether any other statutory scheme and set of facts would establish consent to suit, this state law and these facts fall within Supreme Court precedent. View "Mallory v. Norfolk Southern Railway Co." on Justia Law

Bielski filed a putative class action, alleging that Coinbase, an online currency platform, failed to replace funds fraudulently taken from its users’ accounts. Coinbase’s User Agreement provides for binding arbitration. The district court denied Coinbase’s motion to compel arbitration. Coinbase then filed an interlocutory appeal under the Federal Arbitration Act, 9 U.S.C. 16(a), and moved the district court to stay its proceedings. The district court and Ninth Circuit denied stay motions.The Supreme Court reversed. A district court must stay its proceedings while an interlocutory appeal on the question of arbitrability is ongoing. Section 16(a) does not say whether district court proceedings must be stayed pending resolution of an interlocutory appeal but an appeal, including an interlocutory appeal, “divests the district court of its control over those aspects of the case involved in the appeal.” Because the question on appeal is whether the case belongs in arbitration or in court, the entire case is essentially “involved in the appeal,” and precedent requires that the court stay its proceedings while the interlocutory appeal on arbitrability is ongoing. If the court could move forward with proceedings while the appeal was ongoing, many of the asserted benefits of arbitration (efficiency, less expense, less intrusive discovery) would be irretrievably lost. Absent a stay, parties could be forced to settle to avoid discovery and trial that they contracted to avoid through arbitration. When Congress wants to authorize an interlocutory appeal, but not to automatically stay district court proceedings pending that appeal, Congress typically says so. View "Coinbase, Inc. v. Bielski" on Justia Law

The False Claims Act (FCA) imposes civil liability on those who present false or fraudulent claims for payment to the federal government, 31 U.S.C. 3729–3733, and authorizes private parties (relators) to bring “qui tam actions” in the name of the government. A relator may receive up to 30% of any recovery. The relator must file his complaint under seal and serve a copy and supporting evidence on the government, which has 60 days to decide whether to intervene. As a “real party in interest,” the government can intervene after the seal period ends, if it shows good cause.Polansky filed an FCA action alleging Medicare fraud. The government declined to intervene during the seal period. After years of discovery, the government decided that the burdens of the suit outweighed its potential value, and moved under section 3730(c)(2)(A) (Subparagraph (2)(A)), which provides that the government may dismiss the action notwithstanding the objections of the relator if the relator received notice and an opportunity for a hearing.The Third Circuit and Supreme Court affirmed the dismissal of the suit. The government may move to dismiss an FCA action whenever it has intervened, whether during the seal period or later. It may not move to dismiss if it has never intervened. A successful motion to intervene turns the movant into a party; it can assume primary responsibility for the case’s prosecution, which triggers the Subparagraph (2)(A) right to dismiss, consistent with the FCA’s government-centered purposes. The government’s motion to dismiss will satisfy FRCP 41 in all but exceptional cases. The government gave good grounds for believing that this suit would not vindicate its interests. Absent extraordinary circumstances, that showing suffices for the government to prevail. View "United States ex rel. Polansky v. Executive Health Resources, Inc." on Justia Law

Younger claims that during his pretrial detention in a Maryland state prison, Lieutenant Dupree ordered guards to attack him. Younger sued Dupree for damages under 42 U.S.C. 1983. The district court denied Dupree’s summary judgment motion, finding no dispute that the Maryland prison system had internally investigated Younger’s assault, which satisfied Younger’s exhaustion obligation. At trial, Dupree did not present evidence relating to his exhaustion defense. The jury found Dupree and four codefendants liable and awarded Younger $700,000 in damages. The Fourth Circuit—bound by its prior holding that any claim or defense rejected at summary judgment is not preserved for appellate review unless it was renewed in a post-trial motion—dismissed an appeal.The Supreme Court vacated. A post-trial motion under Federal Rule of Civil Procedure 50 is not required to preserve for appellate review a purely legal issue resolved at summary judgment. The factual record developed at trial supersedes the record existing at the time of the summary-judgment motion; that is not true for pure questions of law resolved on summary judgment, which are not “supersede[d]” by later developments in the litigation and merge into the final judgment. A reviewing court does not benefit from having a district court reexamine a purely legal pretrial ruling. While an interlocutory order denying summary judgment is typically not immediately appealable, 28 U.S.C. 1291 does not insulate interlocutory orders from appellate scrutiny but rather delays their review until final judgment. The Court did not decide whether Dupree's issue on appeal was purely legal, and remanded for the Fourth Circuit to evaluate that question. View "Dupree v. Younger" on Justia Law

Following the 2007-2009 “Great Recession,” the Federal Deposit Insurance Corporation (FDIC) brought an enforcement action against Calcutt, the former CEO of a Michigan-based community bank, for mismanaging one of the bank’s loan relationships. The FDIC ultimately ordered Calcutt removed from office, prohibited him from further banking activities, and assessed $125,000 in civil penalties.The Sixth Circuit agreed that Calcutt had proximately caused the $30,000 charge-off on one loan because he had “participated extensively in negotiating and approving” the transaction. The court concluded that $6.4 million in losses on other loans were a different matter and that none of the investigative, auditing, and legal expenses could qualify as harm to the bank, because those expenses occurred as part of its “normal business.” Despite identifying these legal errors in the FDIC analysis, the Sixth Circuit affirmed the FDIC decision, finding that substantial evidence supported the sanctions determination, even though the FDIC never applied the proximate cause standard itself or considered whether the sanctions against Calcutt were warranted on the narrower set of harms that it identified.The Supreme Court reversed. It is a fundamental rule of administrative law that reviewing courts must judge the propriety of agency action solely by the grounds invoked by the agency. An agency’s discretionary order may be upheld only on the same basis articulated in the order by the agency itself. By affirming the FDIC’s sanctions against Calcutt based on a legal rationale different from that adopted by the FDIC, the Sixth Circuit violated these commands. View "Calcutt v. Federal Deposit Insurance Corporation" on Justia Law

The Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), 48 U.S.C. 2101, creates the Financial Oversight and Management Board, an “entity within the territorial government” of Puerto Rico. The Board approves and enforces the Commonwealth’s fiscal plans, supervises its borrowing, and represents Puerto Rico in Title III cases, modeled on federal bankruptcy proceedings. PROMESA does not explicitly abrogate sovereign immunity but incorporates, as part of its mechanism for restructuring debt, the Bankruptcy Code’s express abrogation of sovereign immunity. PROMESA contemplates other legal claims and sets limits on litigation targeting the Board, its members, and its employees for “actions taken to carry out” PROMESA. It provides that no district court will have jurisdiction over challenges to the Board’s “certification determinations.”CPI, a media organization, requested materials, including communications between Board members and Puerto Rican and U.S. officials. The request went unanswered. CPI sued the Board, citing the Puerto Rican Constitution as guaranteeing a right of access to public records. The district court concluded that PROMESA abrogated the Board’s immunity. The First Circuit affirmed.The Supreme Court reversed. PROMESA does not abrogate the Board’s immunity. Congress must make its intent to abrogate sovereign immunity “unmistakably clear.” PROMESA does not do so. Except in Title III debt-restructuring proceedings, the statute does not provide that the Board or Puerto Rico is subject to suit. PROMESA’s judicial review provisions are not incompatible with sovereign immunity but serve a function without an abrogation of immunity. Litigation against the Board can arise even though the Board enjoys sovereign immunity generally. Statutes other than PROMESA abrogate its immunity from particular claims; the Board could decide to waive its immunity from particular claims. Providing for a judicial forum and shielding the Board, its members, and employees from liability do not make the requisite clear statement. View "Financial Oversight and Management Board for Puerto Rico v. Centro De Periodismo Investigativo, Inc." on Justia Law