Justia Civil Procedure Opinion Summaries

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

The plaintiffs in this case are trustees who own a property in Kīhei, Maui, which they use as a vacation home for personal use. In 2021, Maui County reclassified their property as a “short-term rental” based solely on zoning, not actual use, resulting in a higher property tax rate. The plaintiffs paid the assessed taxes but did not utilize the administrative appeals process available through the Maui County Board of Review. Instead, they filed a class action in the Circuit Court of the Second Circuit, seeking a refund and alleging that the County’s collection of the higher taxes was unconstitutional, violated due process, and resulted in unjust enrichment.The Circuit Court of the Second Circuit granted the County’s motion to dismiss, finding it lacked subject matter jurisdiction. The court determined that under Hawai‘i Revised Statutes chapter 232 and Maui County Code chapter 3.48, the proper procedure for contesting real property tax assessments—including constitutional challenges—requires first appealing to the County Board of Review and, if necessary, then to the Tax Appeal Court. Because the plaintiffs bypassed these required steps and missed the statutory deadline to appeal, the court dismissed the case with prejudice.On appeal, the Supreme Court of the State of Hawai‘i affirmed the circuit court’s dismissal. The Supreme Court held that the Tax Appeal Court has exclusive jurisdiction over appeals regarding real property tax assessments, including those raising constitutional issues, and found that the plaintiffs’ claims were time-barred due to their failure to timely pursue the established administrative remedies. As a result, the Supreme Court affirmed the circuit court’s judgment dismissing the plaintiffs’ claims for lack of subject matter jurisdiction. View "Piezko v. County of Maui" on Justia Law

The dispute centers on a Florida-based construction project, where Westerfeld Construction by Glick, LLC served as the general contractor. Westerfeld, a Florida company, retained Jessup Construction, LLC as a subcontractor. Jessup and GSH of Alabama, LLC entered into a joint venture to work on the project and later obtained a $5.8 million loan from Mobilization Funding, LLC, a company with operations in South Carolina. The loan contracts involved Mobilization Funding, Jessup, GSH, and individual guarantors, and included South Carolina choice-of-law and venue provisions. Westerfeld was not a party to these loan contracts. When Jessup allegedly defaulted, Mobilization Funding sued Jessup, GSH, and the guarantors in South Carolina, and GSH, joined by individual guarantors, brought third-party claims against Westerfeld, alleging conspiracy and fraud.After removal, the United States District Court for the District of South Carolina reviewed Westerfeld’s motion to dismiss for lack of personal jurisdiction. Applying the prima facie standard, the district court held that it lacked both general and specific jurisdiction over Westerfeld. The court found Westerfeld had no offices, employees, or business activities in South Carolina and was not party to any South Carolina-centered agreements. The court also determined that GSH’s conspiracy allegations were conclusory and did not plausibly tie Westerfeld to conduct in South Carolina sufficient to establish jurisdiction. The district court dismissed the third-party complaint against Westerfeld and certified its order as final.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s ruling de novo. The Fourth Circuit affirmed, holding that Westerfeld did not have sufficient minimum contacts with South Carolina to justify the exercise of personal jurisdiction under the Due Process Clause. The court rejected both direct and conspiracy-based theories of jurisdiction, concluding that GSH failed to present plausible, particularized facts to support jurisdiction over Westerfeld. The judgment of dismissal was affirmed. View "Stokes v. Westerfeld Construction by Glick, LLC" on Justia Law

A group of 169 individuals who worked at the Clark County Government Center in Las Vegas brought claims alleging that they suffered serious injuries due to exposure to toxic chemicals, including polychlorinated biphenyls (PCBs), at their workplace. The site of the Government Center had previously been used as a rail yard by Union Pacific Railroad, and plaintiffs alleged that Union Pacific dumped waste, including PCBs manufactured by the former Monsanto Company, at the site. Plaintiffs asserted that Monsanto’s corporate successors inherited liability for harms caused by the production, sale, and distribution of PCBs, which allegedly caused a range of health issues for those exposed.The plaintiffs initially filed suit in Nevada state court against multiple defendants, including Union Pacific, the Las Vegas Downtown Redevelopment Agency, and Monsanto’s successors. The claims sought compensatory and punitive damages for injuries stemming from the alleged contamination. Monsanto’s successors removed the action to the United States District Court for the District of Nevada under the Class Action Fairness Act (CAFA). The plaintiffs moved to remand the case back to state court, and the District Court granted the motion, finding that the local controversy exception to CAFA applied since the alleged injuries were localized to Clark County.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s remand order de novo. The Ninth Circuit held that CAFA’s local controversy exception did not apply because the principal injuries resulting from Monsanto’s conduct were not shown to have been incurred primarily in Nevada. The court found that plaintiffs’ allegations described nationwide distribution and harm from PCBs, with no facts indicating that Nevada experienced principal or unique injuries. Therefore, the Ninth Circuit reversed the District Court’s order remanding the case and ordered the case to proceed in federal court. View "EMPLOYEES AT THE CLARK COUNTY GOVERNMENT CENTER V. MONSANTO COMPANY" on Justia Law