Justia Civil Procedure Opinion Summaries

Michael Mogan, a condominium owner, challenged the City of Chicago's Shared Housing Ordinance, which prevented him from listing his unit on short-term rental platforms like Airbnb. Mogan claimed that the Ordinance constituted an unconstitutional taking and inverse condemnation under Illinois law. He also sought a declaratory judgment against the City and his homeowners association, Roscoe Village Lofts Association, to allow him to lease his unit on a short-term basis.The United States District Court for the Northern District of Illinois dismissed Mogan's takings and inverse condemnation claims and declined to exercise jurisdiction over any remaining state law claims. Mogan appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that Mogan lacked standing to challenge the Ordinance because he failed to demonstrate a concrete and particularized injury. The court also found that Mogan's property rights were subject to the Declaration of Condominium Ownership, which prohibited leases of less than 30 days. Therefore, Mogan could not claim that the Ordinance interfered with any reasonable investment-backed expectations or caused any economic impact. The court concluded that the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over the remaining state law claims. View "Mogan v. City of Chicago" on Justia Law

Two sisters from Guatemala fled to the United States in 2015 after gang members threatened to maim and kill them. They entered the U.S. without inspection and were placed in removal proceedings by the Department of Homeland Security (DHS). The sisters applied for asylum and withholding of removal, claiming they were targeted due to their membership in two particular social groups (PSGs): "Guatemalan female children without parental protection" and "the Rodas family."An immigration judge (IJ) denied their applications, finding that the harm they suffered did not rise to the level of persecution, that their proposed PSGs were not cognizable, and that there was no nexus between the harm and their family membership. The Board of Immigration Appeals (BIA) affirmed the IJ's decision, assuming without deciding that the harm constituted persecution but agreeing that the gang members were motivated by financial gain rather than animus toward the family.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Petitioners' arguments regarding due process and the "Guatemalan female children without parental protection" PSG were unreviewable because they were not raised before the BIA. However, the court held that the BIA's no-nexus determination regarding the "Rodas family" PSG was inconsistent with precedents. The court emphasized that persecutors can have mixed motives, and the BIA failed to consider whether the gang members' financial motives were intertwined with the Petitioners' family membership.The Sixth Circuit granted the petition for review in part, dismissed it in part, vacated the BIA's denial of asylum and withholding of removal, and remanded the case for further proceedings consistent with its opinion. The court instructed the BIA to reconsider the nexus between the harm and the Petitioners' family membership and to address whether the Guatemalan government was unable or unwilling to control the persecutors. View "Mazariegos-Rodas v. Garland" on Justia Law

In this case, three plaintiffs—Christian Healthcare Centers, Sacred Heart of Jesus Parish, and St. Joseph Parish St. Johns—challenged aspects of Michigan’s antidiscrimination laws, alleging that these laws violated their First and Fourteenth Amendment rights. The plaintiffs argued that the laws chilled their speech and conduct, particularly regarding their religious beliefs and practices related to gender identity and sexual orientation.The United States District Court for the Western District of Michigan dismissed each case for lack of standing. The court reasoned that none of the plaintiffs had shown that Michigan’s laws arguably proscribed their speech or conduct, nor had they demonstrated a credible threat of enforcement against them. Consequently, the district court granted the defendants' motions to dismiss.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. The appellate court agreed in part, finding that Michigan’s laws arguably forbade several of the plaintiffs’ pleaded activities. The court concluded that Christian Healthcare and Sacred Heart had plausibly established a credible threat of enforcement against them for some of the challenged provisions of Michigan’s laws. However, the court found that St. Joseph Parish had not plausibly established standing, as it failed to show a credible threat of enforcement.The Sixth Circuit affirmed the district court’s dismissal of the claims related to the Equal Accommodations Act (EAA) but reversed the dismissal of the claims related to the Elliot-Larsen Civil Rights Act (ELCRA) for Christian Healthcare and Sacred Heart. The court remanded the cases to the district court to evaluate the plaintiffs’ requests for injunctive relief. The district court’s decisions were thus affirmed in part, reversed in part, and remanded for further proceedings. View "Christian Healthcare Centers v. Nessel" on Justia Law

Craig Reichel, a businessperson from Rochester, Minnesota, and his companies, including Reichel Foods, Inc., filed a legal malpractice lawsuit against the law firm Wendland Utz, LTD, and its former lawyer, Jerrie Hayes. Reichel alleged that despite an ultimately favorable outcome in prior litigation, the law firm’s negligence caused him to incur substantial attorney fees and costs. The underlying litigation involved a lawsuit filed by Craig’s brother, Bryan Reichel, claiming an equity interest in one of Craig’s companies. The district court issued several adverse rulings against Craig and his companies, leading to significant legal expenses. Eventually, the bankruptcy court confirmed Craig’s sole ownership of the companies, and the district court granted summary judgment in Craig’s favor.The Olmsted County District Court granted partial summary judgment in favor of Wendland Utz, dismissing Reichel Foods’ professional negligence claim on the grounds that Reichel Foods could not demonstrate that, but for the law firm’s conduct, it would have been successful in the underlying litigation. The district court did not address Reichel Foods’ other claims for breach of contract and breach of fiduciary duty, nor did it resolve the claims brought by Craig Reichel and his other companies.The Minnesota Supreme Court reviewed the case and concluded that the court of appeals lacked jurisdiction to decide claims still pending in the district court. The Supreme Court vacated the court of appeals’ rulings on those claims. Regarding the professional negligence claim of Reichel Foods, the Supreme Court held that a successful outcome in the underlying litigation does not categorically bar a legal malpractice claim. The court reversed the decision of the court of appeals affirming summary judgment on Reichel Foods’ professional negligence claim and remanded the case for further proceedings. View "Reichel vs. Wendland Utz, LTD" on Justia Law

The case involves the National Infusion Center Association (NICA) and other plaintiffs challenging the constitutionality of the Drug Price Negotiation Program established by the Inflation Reduction Act. This program requires the Department of Health and Human Services (HHS) to negotiate drug prices with manufacturers, setting a "maximum fair price" between 40% and 75% of the market price. Manufacturers who do not comply face significant fines or must withdraw from Medicare coverage entirely.The United States District Court for the Western District of Texas dismissed NICA's lawsuit for lack of subject-matter jurisdiction. The district court reasoned that NICA's claims had to be "channeled" through HHS as required by 42 U.S.C. § 405, which mandates that claims arising under the Medicare Act be decided by the relevant agency before being brought to federal court. The district court also dismissed the remaining plaintiffs due to improper venue without NICA.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that NICA had standing based on both economic and procedural injuries. The court determined that NICA's claims did not arise under the Medicare Act but rather under the Inflation Reduction Act, and thus did not require channeling through HHS. The court held that the district court had subject-matter jurisdiction over NICA's claims and reversed the lower court's dismissal, remanding the case for further proceedings. View "Natl Infusion Center v. Becerra" on Justia Law

Three nonprofit organizations challenged two Arizona election law amendments: one allowing the cancellation of a voter’s registration if they move to another county (the “Cancellation Provision”) and another making it a felony to provide a voting mechanism to someone registered in another state (the “Felony Provision”). The plaintiffs argued these laws would jeopardize voting rights in Arizona.The United States District Court for the District of Arizona preliminarily enjoined the enforcement of both provisions, agreeing with the plaintiffs that the laws could harm voters and were likely unconstitutional. The defendants, including the Arizona Attorney General and the Yuma County Republican Committee, appealed the decision.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that the plaintiffs lacked Article III standing to challenge the Cancellation Provision because they only alleged a frustrated mission and diverted resources, failing to show direct harm to their core activities. The court emphasized that organizational standing requires more than just a diversion of resources; it requires a direct impact on the organization’s core activities.Regarding the Felony Provision, the court found that the plaintiffs had standing because they faced a realistic possibility of prosecution, which could chill their voter outreach activities. However, the court concluded that the plaintiffs were unlikely to succeed on the merits of their vagueness challenge. The court interpreted the phrase “mechanism for voting” narrowly, determining it referred only to unlawful acts of voting, not voter outreach or registration.The Ninth Circuit vacated the district court’s preliminary injunction and remanded the case for further proceedings consistent with its opinion. View "ARIZONA ALLIANCE FOR RETIRED AMERICANS V. MAYES" on Justia Law

Absolute Essence LLC sought to enter the medical marijuana market in Arkansas but was unable to secure a license. The company invested over a million dollars in the application process, including finding a location and addressing zoning issues. The Arkansas Medical Marijuana Commission outsourced the review process to Public Consulting Group, Inc., which scored 197 applications in two weeks. Absolute Essence received a low score and alleged that the scoring process was manipulated, with conflicts of interest among the scorers favoring larger, established players and resulting in racial disparities in license awards.The case was initially filed in state court, alleging tortious interference, fraud, racial discrimination, and civil conspiracy. The defendants removed the case to the United States District Court for the Eastern District of Arkansas, which dismissed the case for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6).The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court found that Absolute Essence's tortious interference claim failed because it did not establish a precise business expectancy with a specific third party. The fraud claim was dismissed due to a lack of justifiable reliance, as the company’s actions predated the involvement of the outside scorers. The race-discrimination claims were dismissed for failing to allege intentional discrimination, as the complaint only suggested a disparate impact without sufficient factual support. Finally, the civil conspiracy claim was dismissed because it could not stand without an underlying tort.The Eighth Circuit affirmed the district court's judgment, concluding that Absolute Essence did not plead enough facts to support any of its claims. View "Absolute Essence LLC v. Public Consulting Group LLC" on Justia Law

In this case, Universal Development Corporation ("Universal"), Hatti Group RE, LLC ("Hatti Group"), and Harsha Hatti separately appealed judgments entered by the Jefferson Circuit Court in favor of Robbie Dellinger following a jury trial. The trial involved consolidated cases with claims asserted by Hatti, the Hatti Group, and Dellinger.The Jefferson Circuit Court had previously dismissed Universal from Dellinger's initial action against Hatti and the Hatti Group. However, Universal was later brought back into the litigation when Hatti and the Hatti Group filed a separate action against Dellinger, Universal, and others. The cases were consolidated, and Dellinger asserted a breach-of-contract cross-claim against Universal. The jury found in favor of Dellinger on his claims against Universal and Hatti, awarding him compensatory and punitive damages.The Supreme Court of Alabama reviewed the appeals. It dismissed the appeals of Hatti Group and Hatti, noting that Hatti's appeal in Hatti v. Universal was invalid because no adverse judgment was entered against Hatti in that case. Hatti's appeal in Dellinger v. Hatti was dismissed as untimely because it was filed more than 42 days after the final judgment.Regarding Universal's appeal, the court reversed the judgment against Universal and rendered a judgment in its favor. The court held that Dellinger's breach-of-contract claim against Universal was void because it was based on work performed without a general contractor's license, violating Alabama's licensure statutes. The court concluded that Dellinger acted as a general contractor under the Personal Services Agreement with Hatti, and since Dellinger was unlicensed, the contract was void as a matter of public policy. Consequently, Universal had no legal obligation to support Dellinger in seeking payments under an unenforceable contract. View "Universal Development Corporation v. Dellinger" on Justia Law

The appellants, Meredith O'Neil, Jessica Svedine, Deanna Corby, and Roberto Silva, sued various officials from the Canton Police Department and the Town of Canton, Massachusetts, seeking declaratory and injunctive relief to prevent the enforcement of Massachusetts witness intimidation statutes, Mass. Gen. Laws ch. 268 §§ 13A and 13B. They claimed that these statutes violated their First Amendment rights, fearing prosecution for their actions during a November 5, 2023 protest and alleging that their speech would be chilled for a planned protest on November 12, 2023. The appellants moved for emergency relief to enjoin the enforcement of these statutes.The United States District Court for the District of Massachusetts denied the emergency motion on November 10, 2023. The court assumed the plaintiffs had standing but found they did not demonstrate a reasonable likelihood of success on the merits of their claims. The court held that the statutes served compelling interests in protecting the administration of justice and were narrowly tailored. The court also found that the plaintiffs had not shown they faced a risk of irreparable harm, noting that the plaintiffs had other public forums to express their views. The balance of harms and public interest considerations also weighed against granting the injunction.The United States Court of Appeals for the First Circuit reviewed the case and dismissed the appeal as moot. The court noted that the state court had dismissed the charges against the appellants for lack of probable cause, and no ongoing conduct remained for the court to enjoin. The court also found that the appellants' general allegations of future protests did not show a credible threat of prosecution, failing to establish standing for their pre-enforcement challenges. The case was remanded to the district court for further proceedings as appropriate. View "O'Neil v. Canton Police Department" on Justia Law

A school bus owned by First Student, Inc., and insured by National Union Fire Insurance Company of Pittsburgh, PA, collided with two underinsured vehicles in Rhode Island, injuring Tiffany Briere and her minor daughter. Briere submitted a claim for underinsured motorist benefits to National Union, which was denied on the grounds that First Student had rejected such coverage. Briere then sued National Union, arguing that Rhode Island law required the policy to offer underinsured motorist coverage.The United States District Court for the District of Rhode Island granted summary judgment to National Union and First Student. The court found that the Rhode Island statute requiring underinsured motorist coverage did not apply because the insurance policy was not "delivered or issued for delivery" in Rhode Island. The policy had been issued by a New York-based broker and delivered to FirstGroup's headquarters in Ohio. Consequently, the court ruled that the policy was exempt from the statutory requirement.The United States Court of Appeals for the First Circuit reviewed the case and vacated the district court's summary judgment. The appellate court held that National Union had waived its defense based on the delivery requirement because it had not mentioned this ground in its initial denial letter to Briere. The court emphasized that insurers must notify their insureds of all grounds for denying coverage in their denial letters. Since National Union failed to do so, it could not later rely on the delivery requirement defense. The case was remanded for further proceedings to address other potential defenses and issues not considered by the district court. View "Briere v. National Union Fire Insurance Co. of Pittsburgh, PA" on Justia Law