Justia Civil Procedure Opinion Summaries

In this case, Bayer U.S. LLC, a pharmaceutical company, recalled millions of dollars’ worth of Lotrimin and Tinactin spray products in October 2021 after discovering benzene contamination in products dating back to 2018. The plaintiffs, who purchased these products during the recall period, did not allege physical injuries but sought compensation for economic losses, claiming the contaminated products were worth less than uncontaminated ones.The United States District Court for the District of New Jersey dismissed the plaintiffs' complaint for lack of standing, concluding that the plaintiffs failed to sufficiently allege economic loss or harm from increased risk of future physical injury. The court found the plaintiffs' allegations too conclusory and lacking in specific facts to support their claims.On appeal, the United States Court of Appeals for the Third Circuit reviewed the case. The appellate court concluded that the District Court erred in applying a heightened standard for standing. The Third Circuit held that the plaintiffs plausibly alleged economic injury under the benefit-of-the-bargain theory, as the contaminated products were unusable and therefore worth less than the uncontaminated products they had bargained for. The court noted that the plaintiffs need not show that all products in the recall were contaminated but must plausibly allege that their specific products were contaminated.The Third Circuit reversed the District Court's dismissal of the complaint for lack of standing as to some plaintiffs and remanded the case for further proceedings consistent with its opinion. The appellate court emphasized that the plaintiffs' allegations, supported by the recall and additional testing data, were sufficient to establish standing at the motion-to-dismiss stage. View "Huertas v. Bayer US LLC" on Justia Law

Randy Ethan Halprin, a member of the "Texas Seven," escaped from prison in December 2000 and was involved in the murder of Irving Police Officer Aubrey Hawkins during a robbery. Halprin was charged with capital murder and, in 2003, was convicted and sentenced to death by Judge Vickers Cunningham. Halprin's conviction and sentence were affirmed on direct appeal, and his initial habeas application was denied. Subsequent applications were dismissed. In 2019, Halprin filed a new writ application alleging that Judge Cunningham was biased against him because he is Jewish, violating his right to due process and the free exercise of his religion.The Texas Court of Criminal Appeals reviewed Halprin's claim after the trial court held an evidentiary hearing. The trial court found that Judge Cunningham exhibited actual bias against Halprin due to his Jewish faith and recommended granting Halprin a new trial. The State agreed that the evidence showed Cunningham's bias. The Texas Court of Criminal Appeals independently reviewed the record and confirmed that Cunningham's anti-Semitic remarks and behavior demonstrated actual bias.The Texas Court of Criminal Appeals concluded that Halprin had shown by a preponderance of the evidence that Judge Cunningham was biased against him at the time of the trial. This bias constituted a structural due process violation, entitling Halprin to a new trial. The court granted Halprin a new trial and dismissed his second claim challenging the constitutionality of the future dangerousness special issue as an abuse of the writ. View "In re Halprin" on Justia Law

The case involves a claim by Mitchell against Race under the Florida Security of Communications Act, which prohibits recording phone calls without the consent of all parties. Mitchell alleged that Race, while out of state, recorded phone calls with him, a Florida resident, without his consent. The central issue was whether Florida courts have personal jurisdiction over Race, a nonresident defendant.The trial court focused on whether Race committed a tortious act in Florida, concluding that he did because the interceptions occurred where Mitchell's statements were made. The court also found that exercising personal jurisdiction over Race did not violate due process. On appeal, the Fourth District Court of Appeal reversed the trial court's decision, concluding that Race lacked sufficient minimum contacts with Florida to justify personal jurisdiction. The Fourth District did not address whether Race committed a tortious act in Florida but certified conflict with a previous case, France v. France, which addressed the first step of the jurisdictional test.The Supreme Court of Florida initially accepted jurisdiction to resolve the certified conflict. However, after further consideration, the court concluded that the conflict was not clear and that the record was insufficient to address the due process issue analyzed by the Fourth District. Consequently, the Supreme Court of Florida decided to discharge jurisdiction and dismiss the proceeding, determining that the issues presented were largely academic given the unique procedural history of the case. View "Mitchell v. Race" on Justia Law

Leroy Williams, a special police officer with the D.C. Department of General Services (DGS), was terminated in August 2019 for conduct related to unauthorized traffic stops. He was given three options to appeal: filing an appeal with the Office of Employee Appeals, having his union (Fraternal Order of Police, FOP) file a grievance, or filing a grievance personally. Williams chose the second option, and FOP filed a grievance on his behalf. When the grievance could not be settled, it was advanced to arbitration, where the arbitrator upheld Williams's termination.FOP then sought review from the Public Employee Relations Board (PERB), which upheld the arbitrator's decision. FOP subsequently petitioned the Superior Court of the District of Columbia for review, which affirmed PERB's decision. After FOP's counsel withdrew, Williams filed an appeal to the District of Columbia Court of Appeals on his own.The District of Columbia Court of Appeals reviewed whether Williams had standing to bring the appeal. The court noted that the collective bargaining agreement granted the union the sole authority to arbitrate grievances and, consequently, the sole authority to appeal arbitration decisions. The court found that Williams lacked standing to appeal because only the union could pursue such an appeal unless the union breached its duty of fair representation, which was not argued in this case.The court dismissed Williams's appeal for lack of standing, concluding that he could not independently challenge the arbitration award under the terms of the collective bargaining agreement. View "Williams v. Department of General Services" on Justia Law

CorpCar Services Houston, Ltd. (CorpCar) entered into a franchise license agreement with Carey Licensing, Inc., and Carey International, Inc. (collectively Carey) to operate a chauffeur-driven service under the Carey brand in Houston, Texas. In 2015, CorpCar was found liable for punitive damages for creating a racially hostile work environment, which led Carey to terminate the franchise agreement in 2016. CorpCar argued that the termination was wrongful because it did not materially breach the agreement and, even if it had, Carey did not provide an opportunity to cure the violation as required by the agreement.The Superior Court of the District of Columbia granted summary judgment to Carey, finding that CorpCar’s breach was incurable as a matter of law and that CorpCar had an opportunity to cure but failed to do so. The court also denied CorpCar’s cross-motion for summary judgment, concluding that issues of material fact remained for the jury to decide.The District of Columbia Court of Appeals reviewed the case and agreed with the lower court that CorpCar’s breach was material. However, the appellate court disagreed with the finding that the breach was incurable as a matter of law. The court held that the language of the franchise agreement was clear and precluded the application of the incurable breach doctrine. The court also found that there was a dispute of material fact as to whether Carey repudiated the franchise agreement, effectively denying CorpCar an opportunity to cure.The appellate court reversed the grant of summary judgment to Carey and remanded the case for further proceedings. The court instructed that a jury must decide whether Carey repudiated the agreement, whether CorpCar had cured or could have cured its breach, and whether affording an opportunity to cure would have been futile. The denial of CorpCar’s cross-motion for summary judgment was affirmed. View "CorpCar Services Houston, LTD v. Carey Licensing, Inc." on Justia Law

Plaintiffs Chris Robles and the California Voting Rights Initiative sued the City of Ontario, alleging violations of the Voting Rights Act and the California Voting Rights Act due to the city's at-large method of electing council members, which they claimed diluted Latino electoral influence. The parties settled, agreeing to transition to district-based elections by 2024 and included a provision for attorney fees incurred up to that point.The Superior Court of San Bernardino County initially sustained the city's demurrer but later entered a stipulated judgment based on the settlement. Plaintiffs later filed a motion to enforce the stipulated judgment, claiming the city violated several statutory requirements during the districting process. The court found the city had not complied with the stipulated judgment but questioned the validity of the settlement terms. Eventually, the city adopted the plaintiffs' proposed district map.Plaintiffs sought additional attorney fees for enforcing the stipulated judgment. The trial court denied this request, interpreting the stipulated judgment as precluding further fees and deeming plaintiffs' enforcement efforts unnecessary. Plaintiffs appealed this decision.The California Court of Appeal, Fourth Appellate District, Division Three, reversed the trial court's order. The appellate court held that the plain language of the stipulated judgment allowed plaintiffs to seek attorney fees for enforcing its terms. The case was remanded for the trial court to determine if plaintiffs were prevailing parties and, if so, the appropriate amount of attorney fees. The appellate court clarified that the determination of the prevailing party should be based on whether the party achieved its litigation objectives, not on the perceived necessity of their actions. View "Robles v. City of Ontario" on Justia Law

Richard Shreves, while incarcerated at the Montana State Prison, received medical care and subsequently filed a complaint against Dr. Paul Rees with the Board of Medical Examiners at the Montana Department of Labor and Industry (DLI). The Correctional Health Care Review Team (CHCRT) reviewed the complaint and found no violation of law or practice rules by Dr. Rees, leading to the closure of the complaint without forwarding it to the Board of Medical Examiners. Shreves then petitioned for judicial review, challenging the CHCRT's decision and the lack of detailed findings in their response.The First Judicial District Court dismissed Shreves's petition, concluding that he lacked standing. The court reasoned that the CHCRT process did not implicate Shreves's legal rights, as it was designed to screen complaints for potential disciplinary action against the healthcare provider, not to adjudicate the complainant's rights.The Supreme Court of the State of Montana affirmed the District Court's dismissal. The court held that Shreves did not have standing to petition for judicial review because the statute governing the CHCRT process did not authorize judicial review at the behest of the complainant. The court also found that Shreves's constitutional challenge to the CHCRT's authority did not confer standing, as he lacked a personal stake in the outcome. Additionally, the court determined that any alleged mishandling of filings by the District Court did not affect the outcome, as the legal conclusions regarding standing were correct. View "Shreves v. Montana Dept. of Labor" on Justia Law

Casey and Janae Ruppert entered into a contract to purchase ranch property from Judith Merrill. Before closing, Merrill indicated she would not proceed with the sale. The Rupperts filed a complaint seeking specific performance and damages. The district court found Merrill breached the contract and denied her affirmative defenses. It awarded the Rupperts damages and attorneys’ fees but declined to order specific performance. The Rupperts appealed the denial of specific performance, and Merrill cross-appealed the attorneys’ fees award.The District Court of Laramie County found Merrill breached the contract but declined to order specific performance, citing Merrill’s personal circumstances and misunderstandings about the contract. It awarded the Rupperts $22,342 in damages and granted their motion for attorneys’ fees without explanation, awarding $55,258.50 in fees and $3,082.60 in costs.The Wyoming Supreme Court reviewed the case and found the district court abused its discretion by denying specific performance. The court noted the district court’s findings contradicted its decision, as it found the contract valid, the price reasonable, and no undue influence or unconscionability. The Supreme Court held that specific performance was the appropriate remedy given the circumstances and the equities involved.Regarding attorneys’ fees, the Supreme Court agreed with both parties that the district court erred by awarding fees without explanation. The Supreme Court independently assessed the reasonableness of the fees, concluding that the rates charged were excessive for the local market. It reduced the hourly rate to $250, resulting in a total fee award of $28,425.00, plus the previously awarded costs of $3,082.60.The Wyoming Supreme Court reversed the district court’s orders denying specific performance and awarding attorneys’ fees, remanding the case for entry of an order consistent with its opinion. View "Merrill v. Ruppert" on Justia Law

Jessica Goodman, the Saline County Assessor, filed a lawsuit seeking a declaration regarding the correct classification of Saline County under Missouri law. Goodman argued that Saline County should be classified as a third-class county based on its assessed valuation over five years, rather than its current classification as a second-class county. The County moved to dismiss the petition, arguing that the statute in question, section 48.020.1, exempts Saline County from reclassification regardless of changes in assessed valuation.The Circuit Court of Saline County dismissed Goodman’s petition. Goodman appealed the decision to the Missouri Court of Appeals, Western District. The Court of Appeals transferred the case to the Supreme Court of Missouri, believing that the case involved the validity of a state statute, which would fall under the Supreme Court's exclusive jurisdiction.The Supreme Court of Missouri determined that it did not have exclusive appellate jurisdiction because Goodman did not properly raise a constitutional challenge to the statute in question. Goodman’s arguments against the County’s interpretation of the statute did not amount to a direct claim that the statute was unconstitutional. As a result, the Supreme Court of Missouri retransferred the case back to the Missouri Court of Appeals, Western District, for further proceedings. View "Goodman vs. Saline County Commission" on Justia Law

Condominium owners Gregory and Kathleen Haidet filed a lawsuit against their homeowners association, Del Mar Woods Homeowners Association (the HOA), alleging that their upstairs neighbors' improperly installed floors constituted a nuisance. The HOA filed a demurrer to the Haidets' initial complaint, which the trial court sustained, dismissing one cause of action without leave to amend and two with leave to amend. The Haidets chose not to amend their claims against the HOA and instead filed an amended complaint naming only other defendants. Subsequently, the Haidets filed a motion to dismiss the HOA without prejudice, while the HOA filed a motion to dismiss with prejudice. The trial court granted the HOA's request for dismissal with prejudice and awarded the HOA attorney fees.The Haidets appealed, arguing that the trial court should have dismissed the HOA without prejudice because they filed a timely amended complaint and could have stated valid claims against the HOA. The trial court found these arguments unpersuasive, citing Code of Civil Procedure section 581, subdivision (f)(2), and related authorities. The Haidets also challenged the trial court's determination that the HOA was the "prevailing party" for purposes of Civil Code section 5975 and its award of $48,229.08 in attorney fees. The trial court found no abuse of discretion in its determination.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case and affirmed the trial court's judgment. The appellate court held that the trial court was permitted to dismiss the HOA with prejudice under section 581, subdivision (f)(2), as the Haidets failed to amend their claims against the HOA within the time allowed. The court also upheld the trial court's award of attorney fees to the HOA, concluding that the HOA was the prevailing party as it had achieved its litigation objectives by means of its successful demurrer and the Haidets' omission of the HOA from their amended complaint. View "Haidet v. Del Mar Woods Homeowners Assn." on Justia Law