Justia Civil Procedure Opinion Summaries

Robert Gallagher borrowed money from Santander Consumer USA to purchase a car. After making the final payment via electronic funds transfer, Santander, following its standard practice, waited 15 days before sending the car title. Missouri law requires lienholders to release their lien within five business days after receiving full payment, including electronic funds transfers, or pay liquidated damages. Gallagher filed a lawsuit in Missouri state court on behalf of a potential class of borrowers affected by Santander's 15-day policy.The case was removed to the United States District Court for the Eastern District of Missouri, which granted summary judgment in favor of Santander. Gallagher appealed the decision, seeking to reverse the summary judgment.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court focused on whether Gallagher had standing to bring the case in federal court, specifically whether he had suffered an injury-in-fact. The court determined that Gallagher had not identified a concrete harm resulting from the delay in receiving the car title. The court noted that a statutory violation alone is insufficient for standing; there must be a concrete harm related to the violation. Gallagher did not demonstrate any monetary harm, such as a failed sale or impaired credit rating, nor did he show any ongoing injury to his property rights.The Eighth Circuit concluded that Gallagher lacked standing because he did not suffer a concrete injury. As a result, the court vacated the district court's judgment and instructed the district court to remand the case to state court. View "Gallagher v. Santander Consumer USA, Inc." on Justia Law

While incarcerated at Woodborne Correctional Facility, Antonio Mallet sought medical care for urinary obstruction and painful urination, symptoms indicative of prostate cancer. Despite a cystoscopy revealing concerning results, prison doctors did not conduct further tests for prostate cancer, instead prescribing medication for a benign enlarged prostate. Mallet was released on parole in January 2019 and was diagnosed with late-stage prostate cancer in May 2021. He filed a lawsuit on February 25, 2022, against the State of New York, the New York State Department of Corrections and Community Supervision (DOCCS), its acting commissioner, and three medical providers, alleging deliberate indifference to his medical needs and other constitutional violations, as well as state law claims for malpractice and negligence.The United States District Court for the Southern District of New York dismissed Mallet’s constitutional claims as untimely, reasoning that the claims accrued by the time he was released from custody in January 2019, thus falling outside the three-year statute of limitations for Section 1983 claims in New York. The court declined to exercise supplemental jurisdiction over the state law claims.The United States Court of Appeals for the Second Circuit found it plausible that Mallet’s deliberate indifference claim had not accrued by February 25, 2019, making his complaint potentially timely. The court reversed the district court’s dismissal of the deliberate indifference claims against Dr. Makram and Dr. Stellato, finding them plausible, but affirmed the dismissal of the claim against Professor Ritaccio and the constitutional claims against New York State, DOCCS, and Annucci due to sovereign immunity. The court vacated the dismissal of the remaining constitutional claims and state law claims, remanding the case for further proceedings. View "Mallet v. New York State Department of Corrections and Community Supervision" on Justia Law

Deborah Jane Clapp, a Minneapolis homeowner and taxpayer, filed a declaratory judgment action against the Minneapolis Public Schools and its officials. Clapp challenged the constitutionality of racial and ethnic preference provisions in a collective bargaining agreement between the school district and its teachers' union. She sought to stop the school district from implementing and spending public money on these provisions, alleging they violated the Minnesota Constitution's Equal Protection Guarantee.The district court dismissed Clapp's complaint, ruling that she lacked standing and that her claims were not ripe. Clapp appealed, and the Minnesota Court of Appeals reversed the district court's decision, concluding that Clapp had taxpayer standing and that her claims were ripe for judicial review. The school district then petitioned for review by the Minnesota Supreme Court.The Minnesota Supreme Court reviewed the case and focused on the issue of taxpayer standing. The court held that taxpayer standing exists only when the central dispute involves alleged unlawful disbursements of public funds. In this case, the court found that the alleged unlawful disbursements were merely incidental to the central dispute, which was the constitutionality of the racial and ethnic preference provisions in the collective bargaining agreement. Therefore, Clapp lacked taxpayer standing to bring her claims. The court reversed the decision of the court of appeals, upholding the district court's dismissal of Clapp's complaint. View "Clapp vs. Sayles-Adams" on Justia Law

Christopher Meek purchased a universal life insurance policy from Kansas City Life Insurance Company, which combined a standard life insurance policy with a savings account. Meek alleged that Kansas City Life improperly included profits and expenses in the cost of insurance, which was not mentioned in the policy, leading to a lower cash value in his account. Meek filed a federal lawsuit for breach of contract and conversion, and the district court certified a class of about 6,000 Kansans with Meek as the lead plaintiff.The United States District Court for the Western District of Missouri found that Meek's lawsuit was timely for payments going back five years under Kansas’s statute of limitations. The court granted partial summary judgment in favor of Meek on the breach-of-contract claim, interpreting the policy against Kansas City Life. The conversion claim was dismissed. A jury awarded over $5 million in damages, which was reduced to $908,075 due to the statute of limitations. Both parties appealed.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s class certification, finding that common questions of law and fact predominated. The court also upheld the application of Kansas law for both the conversion claim and the statute of limitations. The court agreed with the district court’s interpretation of the insurance policy, concluding that the cost of insurance should not include profits and expenses. The court found that the jury’s damages award was supported by reasonable evidence and did not warrant an increase.The Eighth Circuit affirmed the district court’s judgment, including the class certification, the application of Kansas law, the partial summary judgment in favor of Meek, and the damages award. View "Meek v. Kansas City Life Ins. Company" on Justia Law

Betty Callens, an 81-year-old woman, underwent left-hip-replacement surgery on September 23, 2019, at Grandview Medical Center. After her discharge on September 27, 2019, she was transferred to Brookdale Skilled Nursing Facility for rehabilitation. Callens alleged that she received poor nursing care at Brookdale, leading to a fall on October 3, 2019, which resulted in another fracture of her left hip and a fractured left femur. She was readmitted to Grandview for further surgeries and was later diagnosed with Clostridioides difficile. On October 15, 2019, Callens was transferred to St. Martin's for rehabilitation. On October 21, 2019, while being bathed by a nurse at St. Martin's, Callens alleged that the nurse applied excessive pressure to her healing hip, causing another dislocation.The Jefferson Circuit Court granted summary judgment in favor of St. Martin's, concluding that Callens failed to provide medical-expert testimony to establish a breach of the standard of care or causation of her injuries. Callens's motion to strike the affidavit of St. Martin's expert, Michael Britton, R.N., was denied. The court found that Britton was qualified as a similarly situated health-care provider.The Supreme Court of Alabama reviewed the case and affirmed the lower court's decision. The court held that Callens's case did not fall under the "layman" exception, which allows for the absence of expert testimony in cases where the lack of skill is apparent to a layperson. The court determined that the care provided to Callens involved complex medical procedures beyond the understanding of an average layperson, thus requiring expert testimony. The court also upheld the qualification of Britton as a similarly situated health-care provider, noting that he had provided hands-on care in the relevant field during the year preceding Callens's injuries. Consequently, the summary judgment in favor of St. Martin's was affirmed. View "Callens v. Episcopal Foundation of Jefferson County" on Justia Law

Chester “Chet” Lake contested the probate of his mother’s will, which his sister Mary Chesnutt had filed. Lake doubted the will’s validity, claiming undue influence, and requested a jury trial to determine the issue of devisavit vel non. The Madison County Chancery Court entered a scheduling order but did not specify whether the trial would be a bench or jury trial. After the discovery and motions deadlines passed, Lake filed a Notice of Jury Trial. Chesnutt moved to strike the notice, arguing that Lake had waived his right to a jury trial by participating in pretrial proceedings and that the notice was untimely.The Madison County Chancery Court granted Chesnutt’s motion to strike, finding that Lake had waived his right to a jury trial by agreeing to the scheduling order and that his notice was untimely. Lake appealed this decision.The Supreme Court of Mississippi reviewed the case and held that Lake had not waived his right to a jury trial. The court found that under Mississippi Code Section 91-7-19, Lake was entitled to a jury trial upon request before any hearing on the issue of devisavit vel non. The court determined that the entry of the scheduling order did not constitute a hearing on the matter and that Lake’s notice, filed thirty-two days before the trial date, was timely. The court reversed the chancery court’s decision and remanded the case for further proceedings consistent with its opinion. View "In the Matter of the Estate of Lake v. Chesnutt" on Justia Law

Laura Latimer and Egan Walker divorced in 2002 after 13 years of marriage. During their marriage, Walker earned 8.54 years of PERS credits. The divorce decree included a marital settlement agreement (MSA) that awarded Latimer half of Walker's PERS retirement benefits, secured by a qualified domestic relations order (QDRO) allowing Latimer to elect Option 2. Walker later remarried, reentered public employment as a judge, and transferred his PERS credits to JRS, designating his current wife as the beneficiary. Walker sought judicial confirmation to designate both Latimer and his current wife as Option 2 beneficiaries.The Second Judicial District Court found that Walker could designate two different Option 2 beneficiaries for his PERS and JRS accounts. The court ordered that Latimer was entitled to 4.25 years of PERS credits but not to any of Walker's JRS account. Latimer filed a motion for a new trial, which was denied. She then appealed, arguing that Nevada law permits only one Option 2 beneficiary and that her community interest in Walker's retirement benefits should not be defeated by his transfer to JRS.The Supreme Court of Nevada reviewed the case and concluded that NRS 1A.450(1)(a) allows a JRS member to designate more than one Option 2 beneficiary. The court held that both Latimer and Walker's current wife could be designated as Option 2 beneficiaries, with each receiving their respective portion of the benefits if Walker predeceases them. The court affirmed the district court's decision to allow two beneficiaries but reversed and remanded the order regarding Latimer's entitlement to service credits from Walker's JRS account, ensuring her protected interest in the retirement benefits is maintained. View "WALKER VS. WALKER" on Justia Law

In late 2019, a hospital sent letters to over a thousand patients, including Linda Gierek, informing them of potential exposure to infectious diseases due to a technician's failure to fully sterilize surgical instruments. Gierek filed a class-action complaint against the hospital, asserting claims of negligent infliction of emotional distress, negligence, and medical malpractice. She sought class certification for similarly situated patients and their spouses. The trial court consolidated Gierek’s action with a similar class-action claim filed by Cheyanne Bennett.The Indiana Patient’s Compensation Fund intervened, arguing that the claims sounded in ordinary negligence and thus the Medical Malpractice Act (MMA) did not apply. The hospital argued the opposite. The trial court ruled in favor of the hospital, stating the MMA applied, and denied the motion for class certification, citing lack of subject-matter jurisdiction while a proposed complaint was pending before a medical-review panel. On appeal, the Court of Appeals affirmed the MMA’s applicability but reversed the trial court’s decision on class certification jurisdiction.The Indiana Supreme Court reviewed the case and held that the MMA covers all claims for medical malpractice, not limited to bodily injury or death. The court also held that class certification is a proper preliminary determination under the MMA. The court affirmed in part, reversed in part, and remanded the case for the trial court to consider the plaintiffs’ motion for class certification. View "Gierek v. Anonymous 1" on Justia Law

Nicholas Hull sued North Lincoln Hospital District and several medical professionals for negligence in the death of his newborn son, Eli Hull. Canessa Hull, Nicholas's wife, went into labor on August 9, 2021, and was admitted to Star Valley Health. Due to complications during labor, Eli was born with a double-knotted nuchal cord and did not survive. The Hulls were initially informed by the attending doctors that the nuchal cord was the sole cause of Eli's death. However, in April 2023, Dr. Burk, an anesthesiologist, revealed that Eli's death was preventable and due to the failure to follow safety protocols during labor.The District Court of Lincoln County dismissed Mr. Hull’s complaint, ruling that his notice of governmental claim was untimely. The court found that the two-year period for filing the notice expired in September 2023, and Mr. Hull’s notice, submitted in July 2023, was defective. Mr. Hull argued that the period should be equitably extended due to the defendants' fraudulent concealment of the true cause of Eli’s death.The Supreme Court of Wyoming reviewed the case and affirmed the lower court's decision. The court held that Mr. Hull’s complaint did not adequately allege the elements required for equitable estoppel or equitable tolling. Specifically, the complaint failed to show that the delay in filing the notice was induced by the defendants' misinformation and that Mr. Hull acted on this misinformation in good faith, resulting in his failure to file a timely notice. Additionally, the complaint did not establish that the fraudulent concealment prevented Mr. Hull from complying with the statutory deadline, as he had over four months remaining to file a proper notice after discovering the concealment. Therefore, the court concluded that neither equitable estoppel nor equitable tolling applied, and the dismissal of the complaint was affirmed. View "Hull v. North Lincoln Hospital District" on Justia Law

Sentinel Energy Center, LLC owns a power plant in North Palm Springs and hired DGC Operations, LLC (OPS) to manage and operate the plant. In 2017, during annual maintenance, five OPS employees failed to follow the new depressurization protocol for the fuel filter skid, leading to an explosion that killed Daniel Collins. Collins's family sued Diamond Generating Corporation (DGC), which has a 50% indirect ownership in Sentinel and is the parent company of OPS, claiming DGC's negligence in safety oversight led to Collins's death.The Superior Court of Riverside County denied DGC's request to instruct the jury on the Privette doctrine, which generally shields a hirer from liability for injuries to an independent contractor's employees. The jury found DGC 97% at fault and awarded the plaintiffs over $150 million. DGC's motions for nonsuit and judgment notwithstanding the verdict, based on the Privette doctrine, were also denied.The Court of Appeal of the State of California, Fourth Appellate District, Division Three, reviewed the case. The court declined to grant judgment notwithstanding the verdict to DGC, citing unresolved factual questions about whether DGC retained control over the plant and negligently exercised that control. However, the court found that the trial court erred in not instructing the jury on the Privette doctrine and its exceptions, which could have led to a more favorable outcome for DGC. Consequently, the appellate court reversed the judgment and remanded the case for a new trial with instructions to include the Privette doctrine and its exceptions. View "Collins v. Diamond Generating Corp." on Justia Law