Justia Civil Procedure Opinion Summaries

Phoenix Capital Group Holdings, LLC (Phoenix Capital) sought to recover mineral royalties as a life tenant and alternatively to reform the deed that established its life estate. The dispute arose from a series of property transfers beginning in 1977, when Mr. and Mrs. Peterson transferred a parcel of real property to Alva and Velma Woods, retaining a life estate in the mineral estate. In 2003, Alva and Velma deeded the property to their son Paul and his wife Cheryl, intending to retain a life estate in the mineral estate. However, the 2003 deed did not reserve this life estate, leading to a 2006 deed that conveyed a life estate in one-half of the mineral estate to Alva and Velma. Subsequent leases were executed, and in 2021, Velma sold her life estate to Phoenix Capital.The District Court of Laramie County dismissed Phoenix Capital’s claims. It concluded that under the doctrine of waste, a life tenant does not have the right to receive royalties unless expressly stated in the deed or agreed upon with the remainderman. The court also found that the claim to reform the deed was barred by the statute of limitations, which began when the deed was recorded in 2006.The Wyoming Supreme Court reviewed the case and affirmed the lower court’s decisions. The court held that the doctrine of waste precludes a life tenant from receiving royalties without an agreement with the remainderman or express language in the deed. The court also held that the statute of limitations for reformation claims begins when the deed is recorded, making Phoenix Capital’s 2022 reformation claim untimely. The court found no error in the district court’s application of settled law and affirmed the dismissal of Phoenix Capital’s claims. View "Phoenix Capital Group Holdings, LLC v. Woods" on Justia Law

The case involves the Schrivers, who sought damages after their cat, Gypsy, died following a veterinary procedure and was subjected to an unauthorized necropsy by Dr. Raptosh and Lakeshore Animal Hospital. The Schrivers claimed non-economic damages for emotional distress and loss of companionship, arguing that the emotional bond between pet and owner should be compensable. They also sought economic damages based on the pet's value to them.The District Court of the Third Judicial District of Idaho granted summary judgment in favor of Dr. Raptosh and Lakeshore on several claims, including negligent infliction of emotional distress, intentional infliction of emotional distress, and lack of informed consent. The court denied the Schrivers' claim for emotional distress damages related to trespass to chattels/conversion but allowed the "value to owner" measure of economic damages for the loss of Gypsy.The Supreme Court of Idaho affirmed the district court's decision in part and reversed in part. The court upheld the denial of emotional distress damages for trespass to chattels/conversion, agreeing that such damages are limited to independent torts of negligent or intentional infliction of emotional distress. The court also affirmed the summary judgment on the negligent infliction of emotional distress claim, holding that veterinarians do not have a duty to prevent emotional harm to pet owners. However, the court reversed the summary judgment on the intentional infliction of emotional distress claim related to the unauthorized necropsy, finding that a jury should decide if the conduct was extreme and outrageous. The court affirmed the use of the "value to owner" measure of damages, excluding sentimental value.The case was remanded for further proceedings on the intentional infliction of emotional distress claim. The Schrivers were awarded costs on appeal, but attorney fees were not granted to Dr. Raptosh and Lakeshore, as the primary issue of liability remains unresolved. View "Schriver v. Raptosh" on Justia Law

Heide Montoya, a former Superintendent of On-Board Services at Amtrak, was discharged in 2020 and later rehired to a different position. Montoya filed a lawsuit alleging sex discrimination and other state-law claims. The litigation became complicated due to a dispute over arbitration. Amtrak argued that Montoya had agreed to arbitration by continuing to work after receiving an email notice. Montoya denied receiving the arbitration agreement, and the district judge could not resolve the issue due to a lack of definitive evidence.The United States District Court for the Northern District of Illinois, Eastern Division, held a status hearing where the judge indicated that the evidence was insufficient to determine if an arbitration agreement existed. The judge suggested that the parties confer and possibly provide a joint statement on how to proceed. Instead of following these steps, Amtrak filed a notice of appeal, relying on §16(a)(1) of the Federal Arbitration Act (FAA), which allows interlocutory appeals from orders bypassing arbitration.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that §16 of the FAA only applies when the Act as a whole is applicable. Section 1 of the FAA excludes contracts of employment for railroad employees, among others, from its scope. Since Montoya was an Amtrak employee, the case falls outside the FAA. The court referenced similar cases and legal precedents, including Southwest Airlines Co. v. Saxon and Bissonnette v. LePage Bakeries Park St., LLC, to support its conclusion. Consequently, the Seventh Circuit dismissed Amtrak's appeal for lack of jurisdiction, noting that the district court still needs to resolve whether Montoya agreed to arbitrate disputes under state law. View "Montoya v. National Railroad Passenger Corp." on Justia Law

A 17-year-old, M.L., challenged a civil harassment restraining order issued to protect E.G., a former romantic partner of M.L.’s mother. E.G. sought the order after M.L. posted E.G.’s personal information on social media, alleging E.G. supported M.L.’s mother in abusive conduct against M.L. and her younger brother. The restraining order prohibited M.L. from publishing E.G.’s contact information online and from defaming or harassing her. M.L. contended there was no clear and convincing evidence of harassment and argued that the trial court failed to consider circumstances making future harassment unlikely.The Santa Cruz County Superior Court issued a temporary restraining order and later a three-year civil harassment restraining order against M.L. The court found that M.L.’s social media posts, which included E.G.’s contact information and accusations of supporting child abuse, constituted harassment. The court concluded that E.G. had met her burden of proof by clear and convincing evidence and that the harassment was likely to continue without a restraining order.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court found substantial evidence supporting the restraining order, including M.L.’s repeated social media posts and the resulting threats and harassment E.G. received from third parties. The court concluded that M.L.’s conduct was not for a legitimate purpose and was not constitutionally protected. However, the court modified the restraining order to expire on M.L.’s 18th birthday, reasoning that the circumstances leading to the harassment were tied to M.L.’s status as a minor and her parents' custody dispute. The order was affirmed as modified. View "E.G. v. M.L." on Justia Law

Timothy Hall participated in a protest in Detroit, where he was tackled and injured by a City of Detroit officer. Later, another officer ticketed him for disorderly conduct. Hall filed two lawsuits: one against the City of Detroit and another against the officers, claiming retaliation for exercising his First Amendment rights. The district court consolidated the suits, denied Hall’s request to extend the discovery period, granted summary judgment to the City, but denied the ticketing officer’s claim of qualified immunity.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the City of Detroit, dismissing Hall’s claims against the City. However, the court denied the ticketing officer’s motion for summary judgment on the grounds of qualified immunity, allowing Hall’s First Amendment retaliation claim to proceed. Hall appealed the denial of his motion to extend the discovery period and the summary judgment in favor of the City, while the ticketing officer appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of Hall’s motion to extend the discovery period and the grant of summary judgment to the City. However, the appellate court reversed the district court’s decision denying the ticketing officer’s motion for summary judgment on the grounds of qualified immunity. The court held that the officer was entitled to qualified immunity because it was not clearly established that issuing a ticket under the circumstances violated Hall’s First Amendment rights. The court emphasized that the officer acted on plausible instructions from a superior and had no reason to doubt the legitimacy of the order. View "Hall v. Navarre" on Justia Law

The case involves eight multiemployer benefit plans (the "Funds") seeking to recover delinquent contributions from Stromberg Metal Works, Inc. for health, pension, and other benefits for sheet metal workers. The Funds allege that Stromberg underpaid contributions owed under a collective bargaining agreement (CBA) with the Sheet Metal, Air, Rail and Transportation Union (SMART Union) by hiring temporary workers through staffing agencies without making the required contributions.Initially filed in the Middle District of Tennessee, the case was transferred to the Eastern District of North Carolina. The district court denied Stromberg’s motion for summary judgment, granted the Funds’ cross-motion for summary judgment, and awarded the Funds over $823,000 in delinquent contributions and more than $430,000 in liquidated damages and interest. Stromberg appealed, challenging both the liability and damages rulings.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court’s liability ruling, agreeing that the 2019 Settlement between Stromberg and Local 5 did not preclude the Funds from seeking delinquent contributions. The court emphasized that multiemployer benefit plans have distinct interests from local unions and are not bound by settlements to which they are not parties.However, the Fourth Circuit vacated the district court’s damages ruling. The appellate court concluded that while the Funds could rely on the CBA’s default staffing ratio to approximate damages due to Stromberg’s failure to maintain adequate records, Stromberg had presented sufficient evidence to cast doubt on the accuracy of the Funds’ damages calculation. The case was remanded for further proceedings to address the disputed damages issue. View "Sheet Metal Workers' Health & Welfare Fund of North Carolina v. Stromberg Metal Works, Inc." on Justia Law

Aletha Porcaro was admitted to The Heights of Summerlin, a skilled nursing facility, for rehabilitation after surgery. Upon her discharge, she contracted COVID-19 and died eight days later. Her daughter, Rachelle Crupi, filed a lawsuit against The Heights and its parent companies, alleging that they failed to implement effective COVID-19 safety protocols. The claims included negligence, wrongful death, and other related causes of action.The Heights removed the case to federal court, which remanded it back to state court. In state court, The Heights moved to dismiss the case, arguing that the federal Public Readiness and Emergency Preparedness Act (PREP Act) and Nevada’s Emergency Directive 011 granted them immunity from Crupi’s claims. The district court dismissed the professional negligence claim but allowed the other claims to proceed.The Heights then petitioned the Supreme Court of Nevada for a writ of mandamus, seeking to dismiss the remaining claims based on the same immunity arguments. The Supreme Court of Nevada reviewed the petition and concluded that the PREP Act does not apply to a lack of action or failure to implement COVID-19 policies. The court also determined that Directive 011 does not grant immunity to health care facilities, as it applies to individual medical professionals, not facilities.The Supreme Court of Nevada denied the petition for a writ of mandamus, holding that neither the PREP Act nor Directive 011 provided immunity to The Heights for the claims brought by Crupi. The court affirmed the district court’s decision to allow the remaining claims to proceed. View "The Heights of Summerlin, LLC v. District Court" on Justia Law

In 1983, an Arkansas rural electric distribution cooperative, Carroll Electric, entered into a lease agreement with the City of Berryville and constructed a telecommunications tower. In 1994, Carroll Electric subleased the tower to Northwest Arkansas RSA Limited Partnership, allowing them to install and maintain radio communications equipment. The sublease was renewed multiple times, and in 2011, a Second Amendment was added, extending the agreement for additional terms unless terminated with six months' notice. In 2015, Northwest Arkansas was dissolved, and Alltel Corporation became its successor. In 2022, Alltel notified Carroll Electric of its intent to terminate the agreement, effective October 2022.Carroll Electric filed a breach of contract lawsuit in Arkansas state court, alleging wrongful termination. Alltel removed the case to the Western District of Arkansas, citing diversity jurisdiction. The district court granted Alltel's motion to dismiss, concluding that the contract unambiguously allowed Alltel to terminate the agreement. The court also awarded attorney’s fees to Alltel as the prevailing party under Arkansas law.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, agreeing that the contract provisions were unambiguous and did not conflict. The court held that Section 8(c) of the initial sublease allowed termination with six months' notice, while the Second Amendment dealt with automatic renewal, not termination. The court also upheld the award of attorney’s fees, finding no abuse of discretion by the district court. The judgment of the district court was affirmed. View "Carroll Electric Cooperative v. Alltel Corporation" on Justia Law

Tijuana Decoster, an African American, served as the Chief Grants Management Officer for the National Institute of Neurological Disorders & Stroke at the U.S. Department of Health and Human Services (HHS). Her working relationship with her supervisor, Robert Finkelstein, deteriorated in 2019, leading to allegations of racial discrimination. Decoster claimed Finkelstein singled her out, treated her with contempt, and threatened to fire her. She was issued a Letter of Expectation and placed on an Opportunity to Demonstrate Acceptable Performance plan. Despite her complaints to Human Resources and Finkelstein, the alleged harassment continued, leading Decoster to retire in February 2020.Decoster filed a formal discrimination complaint with the National Institutes of Health (NIH) in December 2019, alleging harassment, discrimination based on race, and retaliation. NIH's Final Agency Decision in November 2020 found that Decoster was subjected to retaliation but denied her other claims. Decoster then filed a complaint in the District of Maryland, raising three claims under Title VII: hostile work environment, constructive discharge, and retaliation. The district court dismissed her complaint for failure to state a claim under Fed. R. Civ. P. 12(b)(6).The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Decoster’s hostile work environment and constructive discharge claims, finding that her allegations did not establish severe or pervasive conduct or intolerable working conditions. However, the court reversed the dismissal of her retaliation claim, holding that Decoster had sufficiently stated a plausible claim of retaliation under Title VII. The case was remanded for further proceedings on the retaliation claim. View "Decoster v. Becerra" on Justia Law

Provisur Technologies, Inc. owns patents related to food-processing machinery, specifically high-speed mechanical slicers and a fill and packaging apparatus. Provisur sued Weber, Inc. and its affiliates, alleging that Weber's food slicers and SmartLoader products infringed on these patents. The case was tried before a jury, which found that Weber willfully infringed several claims of Provisur's patents and awarded Provisur approximately $10.5 million in damages.The United States District Court for the Western District of Missouri denied Weber's motions for judgment as a matter of law (JMOL) on noninfringement and willfulness, as well as a motion for a new trial on infringement, willfulness, and damages. Weber appealed these decisions.The United States Court of Appeals for the Federal Circuit reviewed the case. The court affirmed the district court's denial of JMOL for noninfringement regarding the '812 and '436 patents, as Weber conceded its noninfringement arguments were no longer available due to an intervening decision. However, the court reversed the district court's denial of JMOL for noninfringement of the '936 patent, finding that Provisur failed to provide sufficient evidence that Weber's SmartLoader could be readily configured to infringe the patent.The court also reversed the district court's denial of JMOL on willfulness, ruling that the evidence presented, including testimony about Weber's failure to consult a third party, was insufficient to establish willful infringement. Additionally, the court found that the district court abused its discretion in allowing Provisur to use the entire market value rule for calculating damages without sufficient evidence that the patented features drove customer demand for the entire slicing line. Consequently, the court reversed the denial of a new trial on damages.The case was remanded for further proceedings consistent with the Federal Circuit's decision. View "PROVISUR TECHNOLOGIES, INC. v. WEBER, INC. " on Justia Law