Justia Civil Procedure Opinion Summaries

Two competing software companies specializing in business process management platforms were embroiled in a dispute after one company's employee, acting as a covert consultant, obtained confidential information about the other’s products. The employee, who had access through a third-party government contractor, provided the competitor with detailed tutorials, internal documentation, and live presentations designed to help the competitor improve its own offerings and target the rival’s weaknesses in sales efforts. The information was disseminated within the competitor’s organization and used both to inform product development and to shape competitive strategy. The aggrieved company discovered the espionage years later when the consultant’s handler joined its staff and disclosed the conduct. The company then pursued claims for trade secret misappropriation under the Virginia Uniform Trade Secrets Act, among other causes.The Circuit Court for Fairfax County oversaw a lengthy trial and issued several key evidentiary and instructional rulings: it excluded evidence about the number of users who had access to the alleged trade secrets, limited the competitor’s damages defense based on a discovery response, prohibited the competitor from authenticating certain software versions except on a specified laptop, and issued a damages instruction that shifted the burden of proof to the competitor. The jury found for the plaintiff and awarded substantial damages. The Court of Appeals of Virginia affirmed the jury’s finding of misappropriation but reversed the judgment, holding that the circuit court committed multiple errors in its evidentiary rulings and jury instructions, and remanded for a new trial on the trade secret claims.On further appeal, the Supreme Court of Virginia affirmed the Court of Appeals’ judgment. It held that the circuit court erred by shifting the burden of proof for damages to the defendant, by limiting the defendant’s damages evidence, by precluding authentication of software exhibits, and by instructing the jury that the number of people with access to the trade secrets was irrelevant. The Supreme Court ordered a remand for further proceedings consistent with its opinion. View "Appian Corporation v. Pegasystems" on Justia Law

Employees of a property management company reported to the Minnesota Attorney General that their employer had failed to pay legally required wages and overtime, allegedly using subsidiaries to evade wage laws. Acting on these complaints, the Attorney General issued a civil investigative demand (CID) to the company and its subsidiaries in October 2019, seeking documents relevant to wage practices. The company challenged the CID in court, resulting in over three years of litigation before it ultimately provided the requested documents in July 2022. Following the conclusion of the CID litigation, the Attorney General filed a civil enforcement action in June 2023, alleging violations of the Minnesota Fair Labor Standards Act (MFLSA) related to wage theft.The Ramsey County District Court granted the company’s motion to dismiss the MFLSA claim under Minnesota Rule of Civil Procedure 12.02(e), finding the claim was barred by the two-year statute of limitations set forth in Minn. Stat. § 541.07(5). The court determined the claim accrued by late 2019, when the employees first came forward. The Minnesota Court of Appeals affirmed, rejecting the Attorney General’s argument that litigation over the CID should toll the limitations period, and citing a lack of precedent for such tolling.On review, the Minnesota Supreme Court held that litigation over a civil investigative demand issued under Minn. Stat. § 8.31 tolls the statute of limitations for a subsequent civil enforcement action, provided the CID and the enforcement action concern the same alleged unlawful practice. The Supreme Court reversed the dismissal of the MFLSA claim and remanded the case to the district court for further proceedings, establishing a narrow rule that tolling applies specifically during CID litigation under the Attorney General’s investigative authority. View "State of Minnesota v. Madison Equities, Inc." on Justia Law

Ousmane Savane, a citizen of Côte d’Ivoire, entered the United States in 2012 through the Diversity Visa Program. During his initial application (the eDV), and in his subsequent Application for Immigrant Visa and Alien Registration (DS-230), Savane did not disclose that he had two children, despite both forms requiring such information. He later explained that he omitted his children on the advice of a “coach” who helped him complete the forms, believing that doing so would facilitate his entry for financial reasons. The consular officer who interviewed Savane did not ask about his children, and Savane was admitted as a lawful permanent resident.In 2020, Savane applied for naturalization and disclosed all four of his children. He initially denied, but later admitted, that he had previously lied to U.S. officials to gain immigration benefits. The United States Citizenship and Immigration Services (USCIS) denied his naturalization application, finding that his earlier omissions rendered him not “lawfully admitted for permanent residence.” Savane appealed administratively, arguing that the omissions were immaterial, but USCIS affirmed its denial. He then petitioned for review in the United States District Court for the Eastern District of Pennsylvania, which granted summary judgment for the government, holding that Savane’s omission was material because it shut off a line of inquiry relevant to his eligibility.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that, under 8 C.F.R. § 103.2(a)(2), an omission from an immigration application is material if it prevents investigation into a relevant aspect of eligibility, regardless of whether the omitted information would have led to denial. The court concluded that Savane’s failure to disclose his children precluded the consular officer from properly evaluating his eligibility, particularly regarding whether he was likely to become a public charge. The Third Circuit affirmed the District Court’s summary judgment for the government. View "Savane v. Secretary United States Department of Homeland Sec" on Justia Law

A group of patients civilly committed under Minnesota law challenged the state's sex offender treatment program, alleging inadequate treatment and unconstitutional conditions of confinement. The lawsuit was brought as a class action, initially filed pro se and later supported by counsel through the Minnesota Federal Bar Association’s Pro Se Project. During the litigation, the patients, citing indigence and the need for expert testimony, requested court-appointed experts under Federal Rule of Evidence 706. Both parties jointly nominated experts, and in 2013, they recommended a 50/50 split of expert costs. However, the court initially allocated all costs to the defendants, reserving the option to adjust later.After more than a decade of litigation, the United States District Court for the District of Minnesota ruled in favor of the state officials on all claims. The officials then sought to recover litigation costs, including expert fees, as prevailing parties under Federal Rule of Civil Procedure 54(d)(1). The district court declined to award any costs to the officials, citing the plaintiffs' indigence, good faith, public importance of the issues, vigorous litigation, difficulty and closeness of the issues, and potential chilling effect on future litigants.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court held that the district court failed to consider the plaintiffs’ 2013 recommendation to share expert costs and did not adequately weigh their acknowledged ability to pay half at that time. The Eighth Circuit vacated the district court’s cost judgment and remanded with instructions to award half of the expert costs to the prevailing defendants, to be assessed jointly and severally against the named plaintiffs. View "Karsjens v. Gandhi" on Justia Law

Indiana amended its laws in 2022 to prohibit and criminalize the use of telehealth and telemedicine for abortions, requiring that abortion-inducing drugs be dispensed and consumed in person by a physician in a hospital or qualified surgical center. The Satanic Temple, a Massachusetts-based religious nonprofit, operates a telehealth abortion clinic serving only patients in New Mexico but seeks to extend these services to its Indiana members. It does not run, nor intends to operate, an in-person abortion clinic in Indiana or maintain ties to Indiana hospitals or surgical centers. The Temple filed suit against the Indiana Attorney General and Marion County Prosecutor, seeking to enjoin enforcement of the criminal statute (§ 16-34-2-7(a)) and to obtain declaratory relief under Indiana’s Religious Freedom Restoration Act.The United States District Court for the Southern District of Indiana reviewed the case and granted the defendants’ motion to dismiss for lack of standing. The court found that the Satanic Temple failed to identify any specific member who suffered an injury from the challenged law, thus lacking associational standing. It also held that the Temple itself lacked standing, as it could not show an injury in fact and could not demonstrate that favorable relief would redress its alleged harms due to other Indiana laws independently barring its intended conduct.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The Seventh Circuit held that the Satanic Temple lacked both associational and individual standing. The Temple failed to identify a specific injured member and relied only on statistical probabilities and generalized claims of stigmatic injury, which were insufficient. Additionally, the Temple did not present concrete plans to violate the law, and even if § 16-34-2-7(a) were enjoined, other statutes would independently prevent its telehealth abortion services in Indiana. Thus, the Seventh Circuit affirmed the dismissal for lack of subject matter jurisdiction. View "Satanic Temple, Inc. v Rokita" on Justia Law

Several individuals and organizations sought to circulate a petition to place a campaign finance ordinance on Houston’s ballot, but the city’s charter at that time required petition circulators to be both residents and registered voters of Houston. The plaintiffs did not meet these requirements. They notified the city of their intent to circulate petitions and challenge the constitutionality of the residency and voter registration requirements. The city initially did not clarify its position but later stated it would not enforce the challenged provisions. Despite this, the plaintiffs filed suit in federal court, seeking injunctive and declaratory relief, arguing that the requirements were unconstitutional under Supreme Court precedent.The United States District Court for the Southern District of Texas first granted the plaintiffs a temporary restraining order barring enforcement of the requirements. After the petition circulation period ended, the court dismissed the claims as moot following a stipulation by the parties. The plaintiffs moved to alter or amend the judgment, which was denied. On appeal, the Fifth Circuit reversed, holding that the plaintiffs had standing and that the case was not moot, and remanded for further proceedings. On remand, the district court granted the plaintiffs declaratory relief and, after the city repealed the challenged provisions, awarded the plaintiffs attorneys’ fees as prevailing parties. However, in a subsequent appeal, a different Fifth Circuit panel concluded there was no case or controversy because all parties agreed the provisions were unconstitutional, vacated the judgment, and remanded for dismissal.On remand, the district court vacated the attorneys’ fees award and ordered reimbursement to the city. The United States Court of Appeals for the Fifth Circuit affirmed this ruling, holding that after the prior appellate decision vacated the underlying merits judgment for lack of a case or controversy, there was no basis for a fee award under Rule 60(b)(5). The court also clarified that the city was not required to appeal the fee award directly, and the plaintiffs’ claims of prejudice were unavailing. View "Pool v. City of Houston" on Justia Law

John Doe was a motivational speaker who, for nearly thirty years, was featured, promoted, and endorsed by the California Association of Directors of Activities (CADA) to intermediate and high school audiences. In 2022, CADA received an email from a former church youth group member alleging that Doe, under a different name in the 1990s, had engaged in an inappropriate sexual relationship with a 17-year-old student. After an independent investigation, CADA concluded that Doe was likely the person in question and terminated its association with him. CADA notified its members of the termination without disclosing the nature of the accusation.Doe filed suit in Santa Cruz County Superior Court against both CADA and the accuser, asserting tort and contractual claims. Both defendants filed special motions to strike under California’s anti-SLAPP statute. The trial court granted the accuser’s motion, finding Doe’s claims against her were protected by the common interest privilege and lacked evidence of malice. Regarding CADA, the trial court found the claims arose from protected activity but denied CADA’s motion to strike most of Doe’s claims, concluding Doe showed a sufficient probability of prevailing, particularly on contract-based claims.On appeal, the California Court of Appeal, Sixth Appellate District, reviewed the trial court’s order denying CADA’s anti-SLAPP motion. The appellate court held that all of Doe’s tort claims and contractual claims based on CADA’s communications were subject to the common interest privilege and must be stricken, as Doe did not show CADA acted with malice. However, the court affirmed the denial of the motion as to Doe’s contractual claims based on his termination, concluding Doe demonstrated minimal merit and that public policy did not bar enforcement. The appellate court reversed in part and remanded, directing the lower court to strike the specified claims and allegations. View "Doe v. California Assn. of Directors of Activities" on Justia Law

SoCal Lien Solutions, LLC attempted to serve process on a domestic corporation, BDB Properties, at the address listed in public records for its principal office, executive officers, and agent for service of process. After multiple unsuccessful attempts to serve BDB’s designated agent, SoCal obtained a court order under California Corporations Code section 1702 authorizing service by hand delivery of the summons and complaint to the Secretary of State. SoCal delivered the documents to the Secretary on June 10, 2022. The Secretary did not forward notice of service to BDB until October 24, 2022, which was after the court had entered a default and default judgment against BDB.BDB later sought to set aside the default and judgment, first by ex parte application, which was denied, and then by a noticed motion under Code of Civil Procedure section 473.5. The Superior Court of Los Angeles County found BDB’s motion untimely under section 473.5 but granted relief on the ground that service was not complete until the Secretary mailed notice of the documents to BDB, rendering the judgment void.The California Court of Appeal, Second Appellate District, Division One, reviewed the statutory language of Corporations Code section 1702 and determined that service is deemed complete ten days after the documents are delivered to the Secretary, regardless of when the Secretary forwards notice to the corporation. The court held that the lower court erred in ruling that service was incomplete until the Secretary mailed notice. The Court of Appeal reversed the order setting aside the default and default judgment and directed the trial court to vacate its order granting BDB’s motion. The main holding is that service on a corporation via the Secretary of State under section 1702 is complete ten days after delivery, and subsequent mailing of notice by the Secretary is not required to complete service. View "Socal Lien Solutions, LLC v. BDB Properties" on Justia Law

Rebecca Eisenberg, a director of the Santa Clara Valley Water District, was permitted to review two confidential investigation reports at the District’s facility in January 2024. These reports, prepared by outside counsel, addressed allegations of misconduct by Eisenberg and complaints she raised against staff. The District explicitly instructed Board members not to remove the reports from the premises. Eisenberg nevertheless left the facility with the reports, later admitting her actions at Board meetings. After repeated requests for their return and a formal censure by the Board, Eisenberg refused to return the reports.The District filed suit in Santa Clara County Superior Court, asserting claims including conversion and seeking prejudgment recovery of the reports. It successfully moved for a writ of possession and a turnover order, which Eisenberg temporarily stayed by posting a statutory undertaking. The District then sought a mandatory preliminary injunction compelling the return of the reports. Eisenberg opposed this, arguing that the claim and delivery law’s remedy (the writ of possession, now stayed) precluded further injunctive relief and that the District did not meet the requirements for an injunction.The California Court of Appeal, Sixth Appellate District, reviewed the trial court’s order granting the preliminary injunction. The appellate court held that Code of Civil Procedure section 516.050 expressly permits a party to seek injunctive relief for possession of personal property, even after pursuing relief under the claim and delivery law. The court further found no abuse of discretion: the District demonstrated a likelihood of prevailing on its conversion claim and showed that the harm to the District from denial of the injunction outweighed any harm to Eisenberg. The appellate court affirmed the order granting the preliminary injunction, requiring Eisenberg to return the confidential reports. View "Santa Clara Valley Water Dist. v. Eisenberg" on Justia Law

In September 2020, a college student alleged she was sexually assaulted by a man during a late-night traffic stop in Virginia. She reported the incident to local law enforcement and participated in multiple interviews with detectives, who investigated her claims but found surveillance footage that was low-quality and recorded at a different time than the alleged assault. During a subsequent interview, detectives pressured her about inconsistencies in the evidence and, after the interview, she received threatening text messages. The detectives later told university officials she had confessed to fabricating her report. The sheriff then directed detectives to use her confession as probable cause for an arrest warrant charging her with filing a false police report. After her arrest, officers issued a press release with her personal information and photo, which led to widespread public shaming and emotional distress.Initially, she was convicted in a bench trial in Washington County District Court, but after appealing, her conviction was annulled and she was acquitted in a de novo bench trial in Washington County Circuit Court. She then sued the officers and the sheriff in the United States District Court for the Western District of Virginia, alleging violations of her constitutional rights and state law torts.The district court dismissed the complaint under Rule 12(b)(6), relying on an audio recording of the key interview. The court found the recording contradicted her claims of coercion, ruling that it showed a civil discussion without coercion and that her confession appeared voluntary. It also found her allegation of having no choice but to confess was not credible based on the recording.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the district court erred by dismissing the complaint based on the audio recording, because the recording did not "blatantly contradict" her factual allegations as required by Fourth Circuit precedent. The appellate court vacated the dismissal and remanded the case for further proceedings. View "Bermeo v. Andis" on Justia Law