Justia Civil Procedure Opinion Summaries

Lena Johnson and her daughter, Katherine Grundhauser, died in a car accident in 2006. They co-owned a property in Butte, Montana, as joint tenants with the right of survivorship. Lena's estate was informally probated, and her son, Kenneth Johnson, was appointed personal representative. The estate's assets were distributed among Johnson's children and three of Katherine's children, with the remainder going to Johnson and Katherine's husband, Steven Grundhauser. The property in question was not resolved, and Johnson's children lived there rent-free.In 2020, Lena's will was discovered, which stated that all property should be divided equally between Katherine and Johnson or held in trust for their children if they predeceased Lena. This will contradicted the earlier distribution and indicated that the joint ownership of the property was for convenience only. Katherine's children and Steven Grundhauser petitioned for informal probate of Lena's estate, which was denied. Formal probate was opened in 2021 with Johnson as the personal representative. A mediation in 2022 led to a settlement agreement to buy out the interests of Katherine's children in the property.The Second Judicial District Court, Butte-Silver Bow County, denied Katherine's estate's motion to intervene and for relief from judgment, finding that the estate was bound by the settlement agreement and that the doctrine of laches barred the motions. The court concluded that Grundhauser, as a petitioner, was aware of the settlement terms and had agreed to them.The Supreme Court of the State of Montana reversed and remanded the case. It held that Katherine's estate should have been allowed to intervene as it had a valid legal interest in the property. The court found that the settlement agreement was based on a mutual mistake of law and that the district court's order was void for lack of jurisdiction and due process. The court also held that the doctrine of laches did not apply, as the delay in asserting the estate's rights was reasonable under the circumstances. View "In re Estate of Johnson" on Justia Law

The plaintiffs, former residents of a federally subsidized housing complex, alleged that the defendants, the complex's owner and management company, failed to maintain the property in a safe and habitable condition. They claimed the defendants delayed inspections, concealed hazards, and violated housing laws. The plaintiffs sought class certification for all residents from 2004 to 2019, citing issues like a 2019 sewage backup and systemic neglect.The Superior Court in Hartford, transferred to the Complex Litigation Docket, denied the motion for class certification. The court found that the proposed class did not meet the predominance and superiority requirements under Practice Book § 9-8 (3). It reasoned that determining whether each unit was uninhabitable required individualized proof, making a class action unsuitable. The court noted that while some claims might support class certification for specific events, the broad class definition over many years was too extensive.The Connecticut Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the proposed class was too broad and lacked generalized evidence for the entire period. It emphasized that the trial court had no obligation to redefine the class sua sponte. The plaintiffs did not request a narrower class definition, and the trial court was not required to do so on its own. The court concluded that the trial court did not abuse its discretion in denying class certification. View "Collier v. Adar Hartford Realty, LLC" on Justia Law

Armando P. Ibanez, a Mexican-American male, was employed by Texas A&M University–Kingsville (TAMUK) as an Assistant Professor of Communications/Radio-Television-Film. After five years, he applied for tenure and promotion to associate professor. TAMUK's requirements included the completion of at least two juried creative activities. Ibanez produced several creative works, but only one, a film titled "Men of Steel," was labeled as juried. His application for tenure and promotion was initially recommended by his departmental committee but was subsequently denied by the department chair, college committee, college dean, and provost, who cited his failure to meet the minimum requirements for juried creative activities.Ibanez appealed the decision, and an advisory committee found a prima facie case for reconsideration. The tenure appeals committee supported him, but the promotion appeals committee did not. Ultimately, the university president denied his tenure and promotion based on the negative recommendations and perceived lack of scholarship. Ibanez then sued TAMUK, alleging racial and national origin discrimination under Title VII of the Civil Rights Act of 1964. The United States District Court for the Southern District of Texas granted summary judgment in favor of TAMUK, dismissing Ibanez’s claims.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court found that Ibanez failed to establish a prima facie case of discrimination because he did not meet TAMUK’s baseline tenure requirements of two juried creative activities. Additionally, the court found no genuine dispute of material fact suggesting that Ibanez was denied tenure under circumstances permitting an inference of discrimination. The court affirmed the district court’s grant of summary judgment in favor of TAMUK. View "Ibanez v. Texas A&M" on Justia Law

Kiefer Production Company (KPC), a non-party, appealed adverse discovery orders related to a subpoena duces tecum issued by the Keetons, co-trustees and co-personal representatives of Noma Rongey's estate. The Court of Civil Appeals (COCA) dismissed the appeal, stating the orders were not appealable. KPC then petitioned for certiorari, which was granted by the Supreme Court of Oklahoma.The district court had previously denied the Owners' motion to quash the subpoena and ordered KPC to produce financial documents to determine the value of Rongey's interest in KPC. The district court also placed Rongey's interest in pay status. COCA partially affirmed the district court's order but remanded the case to address the implications of Rongey's death and the scope of the documents requested. On remand, the district court denied KPC's renewed motion to quash and granted the Keetons' motion to compel the production of documents.The Supreme Court of Oklahoma held that the discovery orders were appealable and that the district court did not abuse its discretion in ordering KPC to produce the documents. The court found that KPC, as a non-party, had a substantial right affected by the orders and that the orders conclusively determined the issue of document production. The court also held that KPC's financial documents, including tax returns, were relevant to determining the value of Rongey's interest in KPC and were therefore discoverable.The Supreme Court vacated COCA's opinion and affirmed the district court's judgment, requiring KPC to comply with the subpoena. The court also held that KPC did not have standing to appeal the order placing Rongey's interest in pay status, as this issue was not final and was subject to further proceedings. View "ROYAL HOT SHOT INVESTMENTS v. KIEFER PRODUCTION CO." on Justia Law

In 2015, American Acceptance Co. sued Timothy Mayberry in small claims court for an unpaid balance of $2,084.48. Mayberry did not respond, leading to a default judgment against him. In 2022, Mayberry, who is incarcerated, moved to set aside the default judgment, claiming he was never served with the complaint or judgment and only learned about it during a prison review. The small claims court denied his motion, deeming it untimely and meritless.Mayberry appealed the decision. However, the trial court clerk failed to file a Notice of Completion of Clerk’s Record by the required deadline, and Mayberry did not move to compel the clerk to file the notice. Consequently, the Indiana Court of Appeals dismissed the appeal sua sponte based on Appellate Rule 10(F), which states that failure to move to compel the clerk “shall subject the appeal to dismissal.” Mayberry’s subsequent motion to correct the error was denied by a divided motions panel.The Indiana Supreme Court reviewed the case and held that the phrase “shall subject the appeal to dismissal” grants appellate courts discretion to dismiss an appeal but does not mandate dismissal. The court emphasized that cases should be decided on their merits rather than minor procedural violations unless the appellant acts in bad faith, the violation is egregious, or the appellee is prejudiced. Finding no sufficient basis for dismissal under these criteria, the Indiana Supreme Court vacated the dismissal and remanded the case to the Court of Appeals for further proceedings. View "Mayberry v. American Acceptance Co LLC" on Justia Law

Salvadoran nationals Julio Alvarado-Reyes, his wife Glenda Garmendia-Ardona, and their minor son J.A.G. fled to the United States after being threatened by the MS-13 gang. Alvarado-Reyes was repeatedly stopped by gang members who demanded he use his truck for their activities, threatening his family when he refused. Garmendia-Ardona also received threatening calls. Fearing for their lives, they did not report to the police and eventually left El Salvador in August 2021. The Department of Homeland Security initiated removal proceedings against them in November 2021.An Immigration Judge (IJ) denied their applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The IJ found that the harm Alvarado-Reyes experienced did not amount to persecution and that his proposed particular social group (PSG) of "Salvadoran men who resist gang recruitment" was not legally cognizable. The IJ also determined that the harm was not on account of his membership in the "Reyes family" or "Salvadoran men" PSGs. The Board of Immigration Appeals (BIA) affirmed the IJ's decision without opinion, making the IJ's decision the final agency decision.The United States Court of Appeals for the First Circuit reviewed the case. The court upheld the IJ's findings, agreeing that the proposed PSG of "Salvadoran men who resist gang recruitment" lacked particularity and that there was no sufficient nexus between the harm and Alvarado-Reyes' membership in the "Reyes family" or "Salvadoran men" PSGs. The court also found that the BIA's affirmance without opinion was a valid exercise of discretion. Consequently, the petition for review was denied. View "Alvarado-Reyes v. Garland" on Justia Law

The case involves a challenge to New York City's Guaranty Law, which was enacted in response to the COVID-19 pandemic. The law rendered personal guaranties of commercial lease obligations arising between March 7, 2020, and June 30, 2021, permanently unenforceable and identified efforts to collect on such guaranties as proscribed commercial tenant harassment. Plaintiffs, a group of New York City landlords, argued that the law violated the Contracts Clause of the U.S. Constitution.Initially, the United States District Court for the Southern District of New York dismissed the plaintiffs' constitutional challenges, but the United States Court of Appeals for the Second Circuit reversed the dismissal of the Contracts Clause challenge and remanded the case for further consideration. On remand, the district court granted summary judgment in favor of the plaintiffs, finding that the Guaranty Law was unconstitutional.The City of New York appealed, arguing that the plaintiffs lacked standing because the City did not enforce the Guaranty Law. The Second Circuit found that while the plaintiffs had standing at the pleadings stage due to the presumption of enforcement, they failed to meet the heightened burden on summary judgment to show a credible threat of imminent enforcement by the City. The City had unequivocally disavowed any intent to enforce the Guaranty Law against the plaintiffs.The United States Court of Appeals for the Second Circuit vacated the district court's award of summary judgment and remanded the case with instructions to dismiss for lack of subject matter jurisdiction. The court denied the City's request to vacate its earlier judgment reversing the dismissal of the Contracts Clause challenge and denied the City costs on the appeal due to its negligent delay in raising the enforcement-based standing challenge. View "Bochner v. City of New York" on Justia Law

A company that leased space to a government agency lost its bid to renew that lease to another landowner in a different zoning district. The new lessor requested the municipal planning department to approve the government agency’s proposed use of its space, which the planning department determined was appropriate for the property’s zoning designation. The former lessor challenged this determination by appealing to the municipal zoning board, which affirmed the planning department’s decision.The former lessor then appealed the zoning board’s decision to the Superior Court of the State of Alaska, Third Judicial District. The superior court, on its own initiative, questioned the former lessor’s standing to appeal. After briefing, the court determined that the former lessor was a “party aggrieved” and therefore had standing. On the merits, the court found the zoning board’s findings insufficient and remanded the case for reconsideration. The new lessor petitioned for review, which was granted.The Supreme Court of the State of Alaska reviewed the case and concluded that the former lessor’s interest as a business competitor was insufficient to show that it was a “person aggrieved” with standing to appeal a zoning decision to the superior court. The court held that a general interest in upholding the zoning plan is not sufficient for aggrievement and that the former lessor’s competitive interest did not meet the statutory requirement of being a “person aggrieved.” Consequently, the Supreme Court reversed the superior court’s decision and remanded with instructions to dismiss the former lessor’s appeal for lack of standing. View "Winco Anchorage Investors I, LP v. Huffman Building P, LLC" on Justia Law

A mother and son co-owned a property in Kodiak and hired an excavation company to build a retaining wall. The son made a $15,000 payment to the contractor by credit card. Disputes arose over the contract terms, leading both parties to sue each other for breach of contract. The superior court found that the contractor breached the contract and awarded damages to the mother and son, assuming the $15,000 payment would be reversed by the credit card company.The superior court's final judgment was issued on July 13, 2021. The contractor appealed, and the Alaska Supreme Court reversed several aspects of the superior court’s decision unrelated to the $15,000 payment. More than a year after the final judgment, the mother and son moved for relief from the judgment under Alaska Civil Rule 60(b), arguing that the court mistakenly assumed the $15,000 charge would be reversed. The superior court granted relief under Rule 60(b)(1), finding it had made a mistake about the credit card payment and adjusted its damages award accordingly.The contractor appealed to the Alaska Supreme Court, arguing that the superior court abused its discretion in granting relief under Rule 60(b)(1) because the motion was filed more than a year after the final judgment, making the delay unreasonable. The Alaska Supreme Court agreed, noting that Rule 60(b)(1) motions must be made within one year of the judgment and that this period cannot be tolled or extended. The court found that the superior court erred in tolling the one-year limitation period and that the Bishops' motion was untimely.The Alaska Supreme Court reversed the superior court’s order granting the Rule 60(b)(1) motion for relief from judgment and remanded for disbursement of the supersedeas bond consistent with its decision. View "Red Hook Construction, LLC v. Bishop" on Justia Law

Hannah Hekel received a letter from Hunter Warfield, Inc., a debt-collection agency hired by her landlord to collect past-due rent. The letter offered to forgive the debt in exchange for payment of about half of what she owed but included utility fees that may not have been collectible, failed to provide information on how to verify and dispute the debt on the front of the letter, and mentioned an interest rate that was allegedly too high. Hekel claimed these issues violated the Fair Debt Collection Practices Act and alleged harms including procedural injuries, emotional distress, and financial losses.The United States District Court for the District of Minnesota granted summary judgment in favor of Hunter Warfield on all claims. Although the agency mentioned standing as a defense, the district court did not address it.The United States Court of Appeals for the Eighth Circuit reviewed the case and focused on the issue of standing, which is a jurisdictional requirement. The court found that Hekel did not demonstrate a concrete injury. Allegations of statutory violations, informational injuries, risk of future harm, emotional distress, and financial losses were deemed insufficient or too conclusory to establish standing. The court emphasized that without a concrete injury, there is no standing, and without standing, the court lacks jurisdiction.The Eighth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss for lack of jurisdiction. View "Hekel v. Hunter Warfield, Inc." on Justia Law