Justia Civil Procedure Opinion Summaries

Two infrastructure companies formed a joint venture to bid on a Colorado highway express lane project, relying on engineering designs from a subsidiary of one partner. After winning the contract, the joint venture entered a subcontract with the engineering firm that incorporated many of their earlier terms but added a liability cap. During the project, disputes arose over the design work, resulting in multiple redesigns and delays. The engineering firm submitted change orders for additional work, but the joint venture either failed to process them according to contract procedures or “shelved” them as litigation began.The engineering firm sued the joint venture in the United States District Court for the District of Colorado, claiming breach of contract and unjust enrichment. The joint venture counterclaimed for breach of both the subcontract and the original teaming agreement, and later added a negligent misrepresentation claim. The district court dismissed the negligent misrepresentation counterclaim under the economic-loss rule and later granted summary judgment to the engineering firm on the teaming agreement counterclaim, holding that the subcontract superseded the earlier agreement and imposed a liability cap. The joint venture sought to add fraud counterclaims more than a year after the final pretrial order, but the district court denied this as untimely and prejudicial. The court also rejected the joint venture’s attempt to concede liability and assume the plaintiff’s role at trial, and denied its Rule 50 motions.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s rulings. The appellate court held that the district court did not err in denying the joint venture’s various motions, including its attempt to add new counterclaims, to instruct the jury on an implied duty of good faith and fair dealing, or to enter judgment against itself. The Tenth Circuit affirmed the district court’s judgment in favor of the engineering firm on all claims and counterclaims. View "AECOM Technical Services v. Flatiron | AECOM" on Justia Law

A fatal car accident involving an eighteen-year-old driving a 2013 Toyota Scion led to a lawsuit by the driver’s estate against Toyota and Subaru, who had jointly developed the vehicle. The plaintiff alleged negligence, product liability, and violations of North Carolina’s Unfair and Deceptive Trade Practices Act, claiming that design defects caused the occupant compartment to collapse and a fire to spread, ultimately resulting in the driver’s death. During discovery, the plaintiff requested extensive documents and depositions, including English translations of Japanese-language materials. Toyota and Subaru objected to several document requests and deposition topics, and disputes arose regarding the timing and sufficiency of their responses.The Superior Court of Robeson County granted the plaintiff’s motions to compel, ordered the production of additional documents (including English translations), and mandated that Toyota and Subaru’s corporate representatives testify to all noticed deposition topics without further objection. When the defendants failed to comply as ordered, the trial court imposed sanctions, deeming certain facts established against them—including elements of duty and breach in the plaintiff’s product liability claim—and struck their regulatory compliance defense. Toyota and Subaru appealed, challenging the discovery and sanctions orders.The North Carolina Court of Appeals vacated the sanctions order and reversed the requirement to translate documents but otherwise affirmed the discovery order, holding that most of the trial court’s actions were not an abuse of discretion. The Supreme Court of North Carolina reviewed only the remaining issues in the discovery order. It held that the trial court erred by enforcing a fourteen-day deadline for objections to document requests in deposition notices (rather than the seven days required by the rules), and by waiving defendants’ objections to deposition topics for not seeking a protective order. Accordingly, the Supreme Court reversed the relevant portions of the Court of Appeals’ decision, instructed it to vacate the discovery order, and remanded for further proceedings. View "Sessoms v. Toyota Motor Sales, U.S.A., Inc" on Justia Law

A married couple created a revocable trust during their marriage, transferring three properties into it. Both spouses were designated as co-trustees, sole beneficiaries, and settlors of the trust, retaining the right to amend or revoke it together. Following their separation and eventual divorce, they sold two of the properties and retained the third in the trust. Each party then asserted claims for equitable distribution of marital property. In a pretrial order, both parties stipulated that all necessary parties were properly before the court, that the three properties were marital property, and agreed on how the properties and proceeds would be divided.The District Court, Brunswick County, entered an equitable distribution order based on these stipulations. The defendant appealed, arguing that the revocable trust was a necessary party under Rule 19 of the North Carolina Rules of Civil Procedure and that the court lacked subject matter jurisdiction because the trust was not joined. The trial court denied the defendant’s motion to set aside the order. The North Carolina Court of Appeals affirmed the trial court’s actions, holding that the trust was not a necessary party because, through their stipulations, the parties effectively revoked the trust. The Court of Appeals also found a clerical error in the order, remanding for correction.The Supreme Court of North Carolina reviewed whether a revocable trust must be joined in an equitable distribution proceeding when all settlors are already parties. The court held that Rule 19 does not require joinder of a revocable trust in such circumstances, as a judgment against the settlors binds the trust without affecting others’ rights. The decision of the Court of Appeals was modified and affirmed on this basis. View "Face v. Face" on Justia Law

A married couple enrolled their children at a private school that, until the 2020–2021 academic year, offered a traditional curriculum. Following the events of summer 2020, the school shifted its curriculum to emphasize issues of race and gender identity. The parents became concerned after learning their sixth-grade child was exposed to controversial teachings and age-inappropriate materials. They joined a group of parents to express their concerns to the school’s leadership. After the parents met with school officials, the school abruptly expelled their children and accused the parents of making racist remarks, which the parents deny.The parents filed suit in Superior Court, Mecklenburg County, alleging breach of contract, fraud, unfair and deceptive trade practices, defamation, and other claims. The trial court, Judge Lisa C. Bell presiding, dismissed all claims except for breach of the implied covenant of good faith and fair dealing. The parents voluntarily dismissed that remaining claim to appeal. The North Carolina Court of Appeals affirmed the trial court’s dismissal of all other claims.The Supreme Court of North Carolina reviewed the case to determine whether the parents’ complaint satisfied the state’s “notice pleading” standard for surviving a motion to dismiss under Rule 12(b)(6). The court held that the parents adequately alleged claims for breach of contract, fraud, unfair and deceptive trade practices based on their fraud allegations, and defamation. The court found that their breach of contract claim was viable because they alleged the school expelled their children under a false pretext, in violation of the contract. The fraud and defamation claims also survived due to sufficient factual allegations. The Court reversed the Court of Appeals in part and remanded for further proceedings on these claims, but affirmed or declined to review the dismissal of other claims. View "Turpin v. Charlotte Latin Schools, Inc" on Justia Law

A group of Cuban doctors alleged that they were coerced by the Cuban government to participate in Brazil’s Mais Médicos program, which placed healthcare professionals in underserved communities. The doctors claimed that the Pan American Health Organization (PAHO) enabled the Cuban government’s actions by acting as a financial intermediary, moving funds from Brazil to Cuba, while retaining a 5% fee. They asserted that PAHO’s conduct facilitated a human trafficking scheme, and they brought claims under the Trafficking Victims Protection Act on behalf of themselves and similarly situated Cuban medical professionals.The United States District Court for the District of Columbia initially denied PAHO’s motion to dismiss, finding that the doctors’ allegations, if true, would bring the case within the “commercial activity” exception to immunity under the International Organizations Immunities Act (IOIA). The United States Court of Appeals for the District of Columbia Circuit affirmed this denial, allowing the case to proceed. PAHO then filed a second, “factual” motion to dismiss, contesting the factual basis of the doctors’ claims and submitting evidence to support its immunity argument. In response, the district court granted the doctors’ request for limited jurisdictional discovery to resolve the factual disputes relevant to the immunity question. PAHO appealed the discovery order.The United States Court of Appeals for the District of Columbia Circuit concluded that it lacked jurisdiction to review the district court’s discovery order at this stage. The court held that immediate appellate review under the collateral order doctrine does not extend to jurisdictional discovery orders issued after a judicial finding that the complaint adequately pleads an immunity exception, where discovery is directly related to those pleaded theories. The appeal was dismissed, and the case was remanded for further proceedings. View "Rodriguez v. Pan American Health Organization" on Justia Law

A couple alleged that their home in Union Springs suffered significant roof damage from a storm in January 2024. They had a homeowners’ insurance policy with an insurer and submitted a repair estimate of $9,112.02 to the company, which responded with a significantly lower settlement offer. The couple sued the insurer in the Bullock Circuit Court, claiming breach of contract and bad faith, and alleged a systematic practice by the insurer of underpaying roof claims. During discovery, the couple requested documents relating to the handling of roof claims. The insurer objected, citing concerns over the breadth of the requests and the confidential nature of certain documents.After both sides submitted competing motions for protective orders, the circuit court entered an order that allowed some confidential materials produced by the insurer to be used not only in the couple’s case but also in other cases handled by their counsel involving similar claims against the insurer. The order also permitted sharing information with governmental agencies under certain conditions. The insurer petitioned the Supreme Court of Alabama for a writ of mandamus, seeking to vacate the protective order and require a more restrictive, non-sharing version.The Supreme Court of Alabama held that there is no per se prohibition against sharing provisions in protective orders, provided there are adequate safeguards. The court concluded that the circuit court did not exceed its discretion in allowing sharing with government entities. However, it required the protective order to be modified to (1) specify the exact cases in which sharing is permitted, (2) require all recipients to agree in writing to be bound by the order and submit to the circuit court’s jurisdiction, and (3) clarify obligations for returning or destroying confidential materials at the conclusion of each case. The petition for mandamus was granted in part and denied in part, and the writ was issued accordingly. View "Ex parte State Farm Fire and Casualty Company" on Justia Law

A healthcare technology company formed in 2016 included the appellant as a founding member. The company’s operating agreement was modified several times, and in August 2020, the appellant assigned his membership interest to another member and a separate entity, ceasing to receive further distributions. Two years later, the appellant, through counsel, alleged that the assignment was executed under duress and fraud, and that there were improprieties with the amended operating agreements. In February 2024, the appellant, joined initially by another individual, filed suit against several members and the company, alleging negligent misrepresentation, securities violations, interference with contractual relations, conspiracy, conversion, and breach of fiduciary duty.The Harrison County Circuit Court, upon motion from the defendants, granted summary judgment, determining that all of the appellant’s claims were barred by Mississippi’s three-year statute of limitations. The court held that the appellant’s injury accrued at the time of the assignment in August 2020, and that the complaint filed in February 2024 was untimely. Arguments regarding forgery of an earlier operating agreement were found irrelevant to the assignment. Subsequent efforts by the appellant to supplement the appellate record with new evidence were denied after a limited remand from the Supreme Court of Mississippi.On appeal, the Supreme Court of Mississippi reviewed only the appellant’s arguments concerning the denial of record supplementation, as he failed to challenge the grant of summary judgment in his primary brief. The Court held that issues not raised in the appellant’s initial brief are waived, and the pro se status of the appellant did not excuse this failure. The Court also found no abuse of discretion in denying the request to supplement the record. Accordingly, the Supreme Court of Mississippi affirmed the trial court’s grant of summary judgment. View "Johnson v. Nichols" on Justia Law

Three Venezuelan nationals, alleged by the government to be members of the Tren de Aragua gang, were detained in Texas following a presidential proclamation under the Alien Enemies Act (AEA). This proclamation, issued in March 2025, authorized immediate removal of Venezuelan citizens aged fourteen or older, residing in the United States, who were not naturalized or lawful permanent residents and were identified as members of the gang. The petitioners challenged the proclamation, arguing that it exceeded the President’s authority under the AEA and violated due process rights. They sought class certification and injunctive relief to prevent removal under the AEA.The United States District Court for the Northern District of Texas denied temporary restraining orders and class certification. On appeal, the Fifth Circuit initially dismissed the case for lack of jurisdiction. The Supreme Court, in A.A.R.P. v. Trump, vacated that dismissal and remanded, instructing the Fifth Circuit to address two issues: whether the petitioners were entitled to a preliminary injunction against removal under the AEA, and whether the notice provided for due process claims was sufficient for the putative class. The Supreme Court also allowed the government to remove the petitioners under other lawful authorities.After remand, the three named petitioners were removed from the United States under the Immigration and Nationality Act (INA), not the AEA. The United States Court of Appeals for the Fifth Circuit concluded that, because the petitioners were no longer in the country and no class had been certified, it was impossible to grant any effectual relief. The Fifth Circuit dismissed the appeal as moot for lack of jurisdiction, declining to substitute new class representatives on appeal but leaving open the possibility for future proceedings in the district court. View "W.M.M. v. Trump" on Justia Law

Reginald Chapman was convicted by an Illinois state court jury of murdering Angela Butler and her son, C.B., in 1998. After his conviction, Chapman sought post-conviction DNA testing on evidence collected during the investigation that had not been tested or could be tested with new technology. He filed a motion under 725 Ill. Comp. Stat. 5/116-3, the Illinois statute governing post-conviction DNA testing. Although the county prosecutor’s office initially agreed to DNA testing, the state court rejected the agreement and dismissed Chapman’s motion, finding the evidence at trial was overwhelming and that further testing would not have altered the verdict. Chapman appealed, but the Illinois Appellate Court affirmed the dismissal, and the Illinois Supreme Court denied his request for review.Following the denial in state court, Chapman filed a suit in the United States District Court for the Northern District of Illinois against the Cook County State’s Attorney, Eileen O’Neill Burke. He challenged the constitutionality of the Illinois post-conviction DNA testing statute on its face under the Fourteenth Amendment’s Due Process Clause and the Sixth Amendment’s right to a jury trial. The district court dismissed the case for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine, which bars lower federal courts from reviewing state court judgments.On appeal, the United States Court of Appeals for the Seventh Circuit found that Chapman had standing to sue, as his injury was fairly traceable to Burke’s refusal to allow DNA testing. The court also held that the Rooker-Feldman doctrine did not bar Chapman’s federal claim because he was challenging the constitutionality of the statute itself, not seeking to overturn the state court judgment. Therefore, the Seventh Circuit reversed the district court’s dismissal and remanded the case for further proceedings. View "Chapman v Burke" on Justia Law

Underwood Towers Limited Partnership leased land from the city of Hartford to build apartment buildings and financed the project with a mortgage loan. After defaulting, Underwood executed additional notes and a second mortgage in favor of HUD. Following further defaults and transfers, LPP Mortgage Inc. acquired the second mortgage and notes but did not receive the original of one note—only a lost note affidavit. LPP Mortgage then brought a foreclosure action, seeking not only to foreclose the mortgage but also damages against Underwood and its management agent, CDC Management Corporation.The Superior Court, Complex Litigation Docket, denied Underwood and CDC’s motion to dismiss, ruling that LPP Mortgage had standing to foreclose as the owner of the debt, even without possession of the lost note, relying on New England Savings Bank v. Bedford Realty Corp. Judgment of strict foreclosure and damages was entered. On appeal, the Connecticut Appellate Court affirmed, concluding that LPP Mortgage had standing to pursue foreclosure as the debt owner, despite not being able to enforce the note under the UCC. The case was remanded for setting new law days. After remand, Underwood and CDC again moved to dismiss, arguing that the Connecticut Supreme Court’s later decision in Bank of New York Mellon v. Tope changed the law, requiring possession of the note to foreclose.The Connecticut Supreme Court reviewed the case after transfer from the Appellate Court. The Court held that res judicata barred Underwood and CDC from relitigating LPP Mortgage’s standing, as the issue had already been fully litigated and decided by the Appellate Court. The Supreme Court further held that Bank of New York Mellon v. Tope did not overrule Bedford Realty Corp., and thus the law had not changed. The trial court’s denial of the motions to dismiss was affirmed, and the case was remanded for further proceedings. View "LPP Mortgage Ltd. v. Underwood Towers Ltd. Partnership" on Justia Law