Justia Civil Procedure Opinion Summaries

A property in Hollis was owned by a trust with Wisarat Manutsom as trustee. The trustee, often traveling abroad, provided various mailing addresses—including in California, Manchester (New Hampshire), and later Maine—as well as an email address, to the town for tax-related correspondence. Mark Copp was authorized to act for the trust and provided his Manchester address. Over several years, the town sent multiple certified mail notices regarding unpaid property taxes and impending tax liens and deeds to these addresses; some were signed for and received, but several were returned as undeliverable. The town also communicated about the delinquent taxes by email. In 2019, after more undelivered certified mailings and no payment for 2016 taxes, the town executed a tax deed transferring ownership to itself, then sent post-deed notices by regular mail and, years later, by certified mail and email.The plaintiff sued in the Superior Court, alleging the town’s notice regarding the 2016 and 2018 tax liens and the 2016 tax deed was constitutionally deficient under the Fourteenth Amendment. The Superior Court granted summary judgment to the town, finding the notice sufficient. The plaintiff's motion for reconsideration was denied, and she appealed.The Supreme Court of New Hampshire reviewed the case de novo. It held that the town’s failure to take additional reasonable steps—such as emailing notice—after certified notices of the impending 2016 tax deed were returned undelivered, and before executing the deed, violated the plaintiff’s due process rights. The court also found the town’s notice of the 2016 tax lien insufficient because it relied on an address that had repeatedly failed. However, notice of the 2018 tax lien, sent to both Manchester and Maine addresses, was deemed sufficient. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Manutsom v. Town of Hollis" on Justia Law

A group of plaintiffs, represented by the same counsel as earlier litigants, alleged injuries caused by cellphone radiation exposure. Their complaints were nearly identical to those in a previous set of cases involving similar claims. The plaintiffs agreed, through joint stipulations filed in their cases, that the outcome of expert admissibility litigation in the earlier cases would apply to their own. This agreement included being bound by both the substantive ruling on whether expert testimony about general causation was admissible and all procedural rulings leading up to that determination. The stipulations were signed by counsel for both sides, and subsequent court orders stayed the plaintiffs’ cases pending the resolution of expert admissibility in the earlier litigation.The Superior Court of the District of Columbia managed the earlier cases by first resolving whether the plaintiffs had admissible expert testimony on general causation, limiting discovery to that issue. After several hearings and rulings, the court ultimately excluded the plaintiffs’ expert testimony under the Daubert/Rule 702 standard, and granted summary judgment to the defendants because the plaintiffs lacked the necessary expert evidence to support their claims. The Brooks plaintiffs later moved to lift the stays in their cases, arguing for broader discovery and the opportunity to present new expert witnesses, but the court denied this motion.The District of Columbia Court of Appeals reviewed whether the Brooks plaintiffs were bound by their agreements and the trial court’s rulings. The court held that the plaintiffs had agreed—expressly or implicitly—to be bound by both the outcome of the expert admissibility litigation and the procedural rulings in the earlier cases. The court affirmed the Superior Court’s grant of summary judgment to the defendants, holding that the plaintiffs lacked admissible expert testimony required to prove their claims. View "Brooks v. Mitsubishi Electric & Electronics US, Inc." on Justia Law

The case involves a lawsuit filed in March 2024 by the City of Chicago against several major fossil fuel companies and a trade association. Chicago alleges the defendants misrepresented the effects of fossil fuel emissions on climate change, leading consumers to use more fossil fuels, which resulted in harm to the city such as increased illness, property damage, and environmental degradation. The city seeks damages only for harm attributable to increased fossil fuel usage due to the alleged misinformation, and specifically excludes claims related to federal property or specialized fuel sales to the federal government.After the complaint was filed in Illinois state court, the defendants removed the case to the United States District Court for the Northern District of Illinois, invoking the federal officer removal statute (28 U.S.C. § 1442(a)(1)). They argued that their work producing and supplying fossil fuels for the federal government brought the case within federal jurisdiction. The district court disagreed, finding the connection between the alleged misconduct and the defendants’ federal work too attenuated, and remanded the case to state court.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s remand order de novo. The Seventh Circuit held that the federal officer removal statute did not support removal here because the defendants’ federal work was not sufficiently connected to Chicago’s claims, which focus on alleged misrepresentations to consumers and resulting non-federal harm. The court noted that the city’s complaint expressly disclaimed injuries related to federal activities, and agreed with the reasoning of other circuits in similar cases. The Seventh Circuit therefore affirmed the district court’s remand order. View "City of Chicago v BP P.L.C." on Justia Law

On August 12, 2014, Eva Pena was injured while attempting to board a Rhode Island Public Transit Authority (RIPTA) bus in Providence. She alleged that the bus driver closed the doors on her, causing her to fall and sustain serious injuries. After her death in 2019, her estate continued the suit, claiming negligence by RIPTA. At trial, testimony was presented from multiple witnesses, including Pena’s deposition, the bus driver, a RIPTA supervisor, and Pena’s son. Central to the dispute was the supervisor’s account of a conversation with Pena, which had been facilitated by an unidentified Spanish interpreter at the scene.The Providence County Superior Court admitted the supervisor’s testimony and report about what Pena allegedly said through the interpreter, overruling objections that this constituted inadmissible hearsay. The jury returned a verdict for RIPTA, finding that the plaintiff had not proven negligence. The plaintiff moved for a new trial, arguing that the trial justice erred in allowing hearsay testimony via the unidentified interpreter. The trial court denied the motion, finding the issue unsettled under Rhode Island law and suitable for appellate clarification.The Supreme Court of Rhode Island reviewed the case and reversed the Superior Court’s denial of a new trial. The Supreme Court held that admitting the supervisor’s testimony and report regarding Pena’s statements, relayed through the unidentified interpreter, was an abuse of discretion because it constituted inadmissible hearsay lacking reliability and trustworthiness. The Court found that this evidence was not cumulative and its admission affected the substantial rights of the parties. The case was remanded for a new trial consistent with the Supreme Court’s opinion. View "Fernandez v. Rhode Island Public Transit Authority" on Justia Law

A large New York healthcare provider participated for decades in the Blue Cross Blue Shield insurance network through contracts with the New York Blue Cross licensee, Empire. Under this arrangement, the provider offered negotiated pricing and direct billing for Blue Cross patients. The Blue Cross network comprises thirty-four independent companies, each licensed to operate in a specific region. The provider’s current dispute concerns claims for care provided to patients insured by Blue Cross entities based in Washington, D.C., Maryland, and Virginia. These out-of-state insurers, although not directly contracted with the provider and not operating in New York, used the BlueCard Program to facilitate claims processing in New York and relied on Empire’s network to obtain discounted rates. The provider alleged that these insurers underpaid over $5.5 million in claims.After unsuccessful resolution attempts under the Provider Agreement, the provider brought suit in New York state court. The defendants removed the case to the United States District Court for the Eastern District of New York, which dismissed the case for lack of personal jurisdiction and failure to state a claim. The district court also denied leave to amend the complaint.The United States Court of Appeals for the Second Circuit reviewed the case. It found diversity jurisdiction proper, holding that the D.C.-based insurer’s federal charter made it a D.C. citizen for jurisdictional purposes. The court held that the out-of-state insurers’ purposeful business dealings with Empire and exploitation of New York’s healthcare market established personal jurisdiction under both New York’s long-arm statute and the Due Process Clause. On the merits, the Second Circuit held that the provider adequately stated claims for contract liability based on ratification and for quasi-contract, but affirmed dismissal of the provider’s third-party beneficiary claims. The court affirmed in part, reversed in part, and remanded for further proceedings. View "Northwell Health, Inc. v. Group Hospitalization and Medical Services, Inc." on Justia Law

Dougherty Electric, Inc. sought a refund from the IRS for fraud penalties and interest it paid in connection with employment tax liabilities arising from a payroll scheme orchestrated by its sole shareholder between 2001 and 2005. After the shareholder pleaded guilty to tax evasion and was ordered by the U.S. District Court for the Eastern District of Pennsylvania to pay restitution, the IRS audited Dougherty Electric, assessed employment taxes and fraud penalties, and Dougherty Electric paid over $1.5 million. The deadline for filing a refund claim with the IRS was December 11, 2017.Dougherty Electric submitted a timely letter to the IRS on December 7, 2017, asserting a refund claim based on the theory that penalties and interest could not be assessed on criminal restitution, referencing Klein v. Commissioner, 149 T.C. 341 (2017). After the deadline passed, it submitted another letter raising a new theory—that the fraud penalties lacked supervisor approval required by 26 U.S.C. § 6751(b)(1. In 2018, Dougherty Electric submitted formal refund claims and supporting documentation, but the IRS rejected the claims. Dougherty Electric then sued in the United States Court of Federal Claims, which dismissed the complaint for lack of subject-matter jurisdiction, concluding that Dougherty Electric had not timely filed a proper refund claim with the IRS.On appeal, the United States Court of Appeals for the Federal Circuit reviewed the dismissal de novo. The court held that failure to comply with the pre-suit filing requirement of 26 U.S.C. § 7422(a) did not deprive the Court of Federal Claims of subject-matter jurisdiction but did require dismissal for failure to state a claim. The court found that Dougherty Electric’s timely claim satisfied the statutory requirement regarding the Klein theory, but not as to the supervisor approval theory. The court affirmed dismissal as to the supervisor theory, vacated dismissal as to the Klein theory, and remanded for further proceedings. View "DOUGHERTY ELECTRIC, INC. v. US " on Justia Law

This case involved a decades-long school desegregation lawsuit in which, after more than sixty years of litigation, all remaining parties—the United States, Delta Charter Group, and the School Board of Concordia Parish—filed a joint stipulation of dismissal with prejudice under Federal Rule of Civil Procedure 41(a)(1)(A)(ii). Previously, the United States District Court for the Western District of Louisiana had dismissed the long-absent private plaintiffs in 2025. The key fact is that every party with an ongoing interest in the case agreed to end the litigation through this self-executing mechanism.Despite the jointly filed stipulation, the district court issued a memorandum ruling refusing to recognize the dismissal, reasoning that it was not required to accept and enter the proposed stipulation, particularly when public policy concerns or the protection of others might be implicated. The court then scheduled evidentiary hearings to determine if the school system had achieved “unitary status,” referencing the Green factors from Green v. School Board of New Kent County. In response, the School Board appealed the district court’s orders and, as a precaution, also filed a petition for a writ of mandamus with the United States Court of Appeals for the Fifth Circuit.The United States Court of Appeals for the Fifth Circuit held that it lacked appellate jurisdiction over the School Board’s direct appeal because the challenged orders were neither final decisions nor appealable injunctions. However, the Fifth Circuit granted mandamus relief, ruling that once a Rule 41(a)(1)(A)(ii) stipulation of dismissal is filed by all appearing parties, the case is immediately dismissed without need for a court order. Any further action by the district court is a nullity. The Fifth Circuit ordered the district court to vacate its orders and end the proceedings. View "In Re: School Board of Concordia Parish" on Justia Law

The dispute centers on the development of a parenting plan for a minor child, following years of litigation between the parents. As part of the proceedings, both parties agreed to appoint a parenting evaluator, who was to receive all relevant mental health treatment records from the mother’s providers within ten days. Despite this stipulation, the mother's long-term counselor refused to provide updated treatment records to the evaluator, citing personal distrust, and the mother did not take steps to supplement discovery or seek a protective order. The absence of these records prevented the evaluator from obtaining current information about the mother's mental health status, which was a central issue in determining the child’s best interests.The Ninth Judicial District Court of Pondera County found that both the mother and her counselor had intentionally violated discovery rules and the court-approved stipulation by failing to produce the requested records. As a sanction, the District Court precluded the counselor from testifying about any treatment or records created after the evaluator’s report date. The court allowed testimony regarding earlier treatment but limited further testimony to address the scope of the violation, prevent prejudice, and maintain the integrity of the proceedings.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in imposing this sanction. Applying the standards for discovery sanctions under Montana Rule of Civil Procedure 37, the Supreme Court found that the violation was intentional and prejudicial, and that the sanction was proportional and carefully tailored. The Supreme Court affirmed the District Court’s decision, holding that the exclusion of the counselor’s testimony about undisclosed treatment was proper and within the lower court’s broad discretion. View "In re Parenting of C.R.J." on Justia Law

A mother brought suit on behalf of herself and her minor son, alleging that the son developed leukemia after attending school near and residing close to a manufacturing plant operated by General Electric Company. The plant, located in Pittsfield, Massachusetts, produced electrical transformers and capacitors containing polychlorinated biphenyls (PCBs) for decades. The plaintiff claimed that GE’s use, disposal, and storage of PCBs caused the son’s illness, and sought recovery under various legal theories, including strict liability, negligence, fraudulent misrepresentation, nuisance, improper transportation of hazardous material, and loss of consortium. The complaint included claims related to the defective design and use of PCB materials, as well as their disposal and remediation.The plaintiff originally filed suit in Massachusetts state superior court. GE removed the case to the United States District Court for the District of Massachusetts, asserting federal officer removal jurisdiction under 28 U.S.C. § 1442(a)(1), based on its wartime production of PCB-containing devices for the federal government and its later remediation efforts pursuant to a consent decree with the EPA. The plaintiff moved to remand the case to state court, arguing that GE failed to meet the requirements for federal officer removal. The district court agreed, ordered remand, and stayed that order pending appeal.The United States Court of Appeals for the First Circuit reviewed the district court’s jurisdictional determination de novo. It held that GE satisfied both the “acting under” and “for or relating to” elements of the federal officer removal statute, due to its extensive work producing PCB-containing devices for the federal government. The court reversed the district court’s remand order and remanded the case for the district court to determine whether GE has a colorable federal defense. View "Czerno v. General Electric Company" on Justia Law

A plaintiff was injured while riding in an autonomous vehicle operated by a ride-hailing company. At the time of the incident, the plaintiff was employed by the defendant company, but was using the service as a customer rather than in the scope of employment. The plaintiff sued the ride-hailing company and two related entities, including the vehicle manufacturer. The defendants sought to compel arbitration, arguing that the plaintiff had agreed to arbitration both through an employment agreement and through acceptance of the Terms of Service when signing up for the ride-hailing service as a user. The defendants relied on the sign-in process in the mobile app, which included conspicuous notice and hyperlinks to the Terms of Service containing an arbitration provision.The San Francisco City and County Superior Court denied the motion to compel arbitration. The trial court found the defendants failed to show that the plaintiff agreed to the arbitration provision in the Terms of Service, relying on a recent appellate case. The court also ruled that even if the Terms of Service were enforceable, they did not cover the related entities, and denied arbitration to prevent inconsistent rulings under California Code of Civil Procedure section 1281.2, subdivision (c).The California Court of Appeal, First Appellate District, Division One, reviewed the case de novo. The court held that the sign-in wrap agreement used by the ride-hailing service provided sufficiently conspicuous notice of the Terms of Service, including the arbitration provision. It further held that the related entities were not “third parties” for purposes of section 1281.2, subdivision (c), due to the plaintiff’s own allegations of agency and joint venture among the defendants. The appellate court reversed the trial court’s order and remanded with instructions to grant the motion to compel arbitration. View "Wilkins v. Cruise, LLC" on Justia Law