Justia Civil Procedure Opinion Summaries

A healthcare provider and several of its employees became involved in a dispute after the Idaho Department of Health and Welfare took protective custody of a child suffering from severe malnutrition. Following the hospital’s treatment of the child, a relative of the child, using media platforms and political organizations, publicly accused the hospital and its staff of participating in a conspiracy to kidnap, traffic, and harm children. These accusations led to public protests, threats, and disruptions at the hospital. The healthcare provider and its employees then sued the relative, his associates, and affiliated entities, alleging defamation, invasion of privacy, intentional infliction of emotional distress, trespass, and civil conspiracy, among other claims. They sought compensatory and punitive damages, injunctive relief, and removal of false statements.During proceedings in the District Court of the Fourth Judicial District, the defendant repeatedly failed to comply with discovery orders, missed depositions, and did not attend court hearings, despite multiple warnings and opportunities to comply. The court imposed escalating sanctions, culminating in striking the defendant’s pleadings and entering default as to liability. The court held a jury trial solely on damages, at which the defendant did not appear in person despite being given the opportunity. The jury awarded $52.5 million in compensatory and punitive damages, and the court issued a permanent injunction preventing further defamatory statements or harassment.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in imposing sanctions, entering default, and excluding evidence not properly disclosed. The court found that the defendant’s due process rights were not violated given repeated, willful noncompliance with court orders. The Supreme Court affirmed the district court’s judgment, including the damages award and the injunction, and awarded attorney fees and costs on appeal to the respondents. View "St. Luke's Health System, LTD v. Rodriguez" on Justia Law

An individual was convicted in 1997 of indecent assault and battery on a child under fourteen and served a sentence of incarceration. Before his release, the Commonwealth petitioned to have him civilly committed as a sexually dangerous person (SDP) under Massachusetts law. Two qualified examiners evaluated him but, misunderstanding the scope of evidence they could consider, both opined that he did not meet the statutory criteria for an SDP. Despite this, the case proceeded to trial, and, based on other expert testimony and additional evidence, a judge found him to be an SDP and ordered his civil commitment in 2002. The individual unsuccessfully attempted to appeal, and over the years, filed and withdrew several discharge petitions.A Superior Court judge had denied his original motion for summary judgment, finding that a fact finder could rely on other expert testimony, not just that of the qualified examiners. After his commitment, his attempt to appeal the judgment was dismissed as untimely. Years later, he filed a petition for a writ of habeas corpus, arguing that, following the Massachusetts Supreme Judicial Court’s decision in Johnstone, petitioner, 453 Mass. 544 (2009), his commitment was unlawful because neither qualified examiner had opined that he was an SDP. The Superior Court granted the writ, but the Appeals Court reversed, holding that habeas corpus was not available since alternative remedies existed.The Supreme Judicial Court of Massachusetts reviewed the case and held that, under the statutory scheme, the individual was entitled to a required finding of not sexually dangerous where neither qualified examiner so opined. However, the court concluded that habeas corpus was not available because he had alternative remedies, specifically a motion for relief from judgment. The court vacated the grant of habeas corpus and remanded the case to the Superior Court with instructions to treat the petition as a motion for relief from judgment, which must be allowed. View "Pierce, Petitioner" on Justia Law

A Texas nonprofit health center, CentroMed, experienced a data breach in 2024 that exposed the personal information of its patients. Arturo Gonzalez, representing himself and others affected, filed a class action in Bexar County, Texas, alleging that CentroMed failed to adequately protect their private information. CentroMed, which receives federal funding and has occasionally been deemed a Public Health Service (PHS) employee under federal law, sought to remove the case to federal court, claiming removal was proper under 42 U.S.C. § 233 and 28 U.S.C. § 1442.After CentroMed was served, it notified the Department of Health and Human Services (HHS) and the United States Attorney, seeking confirmation that the data breach claims fell within the scope of PHS employee immunity. The United States Attorney appeared in state court within the required 15 days, ultimately informing the court that CentroMed was not deemed a PHS employee for the acts at issue because the claims did not arise from medical or related functions. Despite this, CentroMed removed the case to the United States District Court for the Western District of Texas 37 days after service. The district court granted Gonzalez’s motion to remand, concluding that removal was improper under both statutes: the Attorney General had timely appeared, precluding removal under § 233, and removal under § 1442 was untimely.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s remand. The Fifth Circuit held that CentroMed could not remove under § 233 because the Attorney General had timely appeared and made a case-specific negative determination. The court further held that removal under § 1442 was untimely, as CentroMed did not remove within 30 days of receiving the initial pleading. Thus, the remand to state court was affirmed. View "Gonzalez v. El Centro Del Barrio" on Justia Law

Several plaintiffs brought suit against a court-appointed receiver and his company, alleging breach of fiduciary duty. The underlying facts involve a criminal prosecution against one of the plaintiffs, Simon Semaan, for insurance fraud. In connection with the prosecution, the criminal court issued a temporary restraining order that froze certain assets and appointed the receiver to manage them. Later, the court ordered the receiver to liquidate specific stock holdings “as soon as practicable.” The receiver did not immediately liquidate the assets, citing ongoing settlement negotiations and concerns about account closure requirements. Plaintiffs alleged that, as a result of the receiver’s delay, the value of the investment accounts declined, causing them over $1.1 million in damages.After the receiver was replaced, the plaintiffs filed a civil lawsuit for breach of fiduciary duty in the Superior Court of Orange County. The defendants responded with an anti-SLAPP motion, arguing the claims arose from protected activity and that quasi-judicial immunity applied. The trial court granted the anti-SLAPP motion. The court found that the receiver’s conduct occurred within the scope of his appointment, that the litigation privilege applied, and that the receiver was protected by quasi-judicial immunity.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court affirmed the trial court’s order. It held that a court-appointed receiver is protected by quasi-judicial immunity for discretionary acts and decisions performed in the course of carrying out court orders. The court found that the plaintiffs’ claims arose out of the receiver’s discretionary decisions as receiver, which are constitutionally protected activities under the anti-SLAPP statute. Because of this immunity, the plaintiffs failed to show that their claims had the minimal merit necessary to survive an anti-SLAPP motion. The court thus affirmed the order striking the complaint. View "Semaan v. Mosier" on Justia Law

The parties in this case are neighbors whose homes are situated with their backyards facing one another, separated by a narrow commons area. Prior to the events at issue, there was significant animosity between them. In December 2024, one party filed petitions for harassment protection orders against the other parties, alleging ongoing disputes including the use of police resources to gather information, failure to restrain their dogs after warnings, installation of a bright work light shining into her home, and incidents that made her feel she was being watched or followed. The district court issued ex parte harassment protection orders the same day, effective for one year.After the orders were issued, the subjects of the orders requested a show cause hearing before the District Court for Lancaster County. At this hearing, they presented evidence and explained their actions, asserting lawful purposes for their conduct, including security and documenting a potential ordinance violation. The district court found their explanations unpersuasive, concluded that their actions were intended to intimidate, and affirmed the harassment protection orders to remain in effect for one year. The parties subject to the orders appealed, and the appeals were consolidated and moved to the Nebraska Supreme Court’s docket.While the appeal was pending before the Nebraska Supreme Court, the harassment protection orders expired, rendering the appeals moot. However, the court determined that the issue of interpreting the phrase “which serves no legitimate purpose” under Neb. Rev. Stat. § 28-311.02(2)(a) presented a matter of public interest warranting review despite mootness. The Nebraska Supreme Court held that, under this statute, determining whether conduct serves a legitimate purpose requires (1) a genuine, justifiable purpose and (2) a logical connection between the conduct and that purpose under the circumstances. The court dismissed the appeals as moot. View "Flinn v. Strode" on Justia Law

A woman died after a rapid health decline while receiving emergency and critical care at a West Des Moines hospital. Her husband, who was appointed as the administrator of her estate, filed a wrongful-death medical malpractice lawsuit against various medical providers. He brought the suit both on behalf of the estate and in his individual capacity, alleging multiple claims including negligence and seeking damages for emotional and financial loss. The husband, a nonlawyer, filed the petition without legal counsel and argued that, as the sole beneficiary, he should be allowed to proceed pro se or, alternatively, be given time to retain an attorney if one was required.The Iowa District Court for Polk County dismissed the lawsuit, ruling that the petition was a legal nullity because a nonlawyer cannot represent an estate or other parties in court, and denied the husband’s request for more time to secure counsel. The court also denied his motion to amend the petition. On appeal, the Iowa Court of Appeals affirmed the dismissal, agreeing that the wrongful-death action could not proceed without a lawyer and finding that the request for additional time had not been properly preserved for appeal. Two appellate judges dissented, concluding the husband was entitled to a warning and additional time to obtain counsel.The Supreme Court of Iowa granted further review. The court held that a nonlawyer cannot represent an estate or other persons in a wrongful-death action in district court. However, it found that the district court abused its discretion by not granting the husband reasonable time to retain counsel before dismissing the case. The Supreme Court vacated the court of appeals’ decision, reversed the district court’s judgment, and remanded the case with instructions to allow at least thirty days for the husband to secure trial counsel. View "Estate of Tornell v. Trinity Health Corporation" on Justia Law

Lanesborough 2000, LLC and Nextres, LLC entered into a loan agreement for the funding of a self-storage facility in Corning, New York. The deal included an arbitration agreement that required disputes to be resolved by binding arbitration. Lanesborough alleged that Nextres breached the agreement by failing to disburse loan funds as promised. An arbitrator found in favor of Lanesborough, awarding consequential damages, declaratory and injunctive relief, and attorney’s fees based on Nextres’s bad faith conduct. The arbitration agreement contained a waiver of the “right to appeal,” but did not specify its scope.The United States District Court for the Southern District of New York partially confirmed the arbitrator’s awards. It confirmed the awards of consequential damages, declaratory relief, and attorney’s fees, finding that the fee award was permissible because it was based on a finding of bad faith. The District Court also granted Lanesborough’s requests for injunctive relief by ordering Nextres to comply with the loan agreement and enjoining Nextres from pursuing foreclosure actions, including a pending state court foreclosure against a related party. The District Court awarded Lanesborough post-award prejudgment interest and stayed enforcement of its judgment pending appeal.On appeal, the United States Court of Appeals for the Second Circuit first held that the parties’ contractual waiver of the “right to appeal” was ambiguous and not sufficiently clear or unequivocal to preclude appellate review. On the merits, the Second Circuit affirmed the district court’s confirmation of the arbitrator’s awards and its grant of post-award prejudgment interest. However, it vacated the district court’s injunction barring the state-court foreclosure action because the lower court had not considered whether the injunction was consistent with the Anti-Injunction Act. The case was remanded for further proceedings on that issue. View "Lanesborough 2000, LLC v. Nextres, LLC" on Justia Law

A Pennsylvania-based company operating an online marketplace for firearms was sued under New Hampshire law by a former Boston police officer and his wife. Their claims alleged that the company’s website facilitated the sale of a firearm in New Hampshire in 2015, which was later used to shoot the officer in Boston in 2016. The plaintiffs asserted causes of action including negligence, aiding and abetting tortious conduct, public nuisance, loss of consortium, and loss of support, based on the website’s alleged design and operation in encouraging illegal gun sales.Previously, the plaintiffs had filed a similar suit in the Massachusetts Superior Court against the company and other defendants, but that court dismissed the claims against the company based on Section 230 of the Communications Decency Act, without ruling on personal jurisdiction. After jurisdictional discovery, the Massachusetts Superior Court subsequently dismissed the claims for lack of personal jurisdiction. The plaintiffs then filed the present action in the United States District Court for the District of New Hampshire, which denied their request for jurisdictional discovery and dismissed their claims for lack of personal jurisdiction, finding the company had not purposefully availed itself of the protections of New Hampshire’s laws.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s ruling in part and vacated it in part. The First Circuit held that the plaintiffs failed to make a prima facie case of purposeful availment based on contacts up to 2016, but concluded that evidence of thousands of “New Hampshire” firearm listings on the website from 2018 onward, when considered with other evidence, sufficed for a prima facie showing of purposeful availment. The court remanded for consideration of relatedness and reasonableness and affirmed denial of jurisdictional discovery. View "Stokinger v. Armslist, LLC" on Justia Law

A religious organization planned to build a large temple in Heber Valley, Utah, and Wasatch County approved the project through a legislative development agreement. Several nearby property owners, concerned about adverse impacts on their health, welfare, privacy, and enjoyment of their property, filed a lawsuit against Wasatch County. They alleged that the county’s approval violated local land-use regulations and state law. The plaintiffs sought a declaration invalidating the ordinance and requested injunctive relief to halt construction.The Church of Jesus Christ of Latter-day Saints intervened, and both the Church and Wasatch County moved for summary judgment. The Fourth District Court granted summary judgment fully to the Church and partially to the County, finding that the ordinance was neither preempted nor contrary to law, and that plaintiffs had not overcome the highly deferential standard of review for land use actions. The court dismissed the case, prompting an appeal from the plaintiffs. After the Church began construction, the plaintiffs moved for an injunction to stop construction during the appeal. The district court granted the injunction, reasoning that plaintiffs would suffer irreparable harm if construction proceeded and was later found unlawful.The Supreme Court of Utah reviewed the district court’s order, focusing solely on whether the injunction should remain pending appeal. Applying Utah Rule of Appellate Procedure 8, the Court found that the plaintiffs had not identified specific irreparable harm that would result from construction during the appeal. The Court concluded that inconvenience or temporary changes to the land did not constitute irreparable harm absent clear evidence of injury that could not be remedied. Therefore, the Supreme Court of Utah granted the Church’s motion and suspended the injunction pending resolution of the appeal. View "VAN DUSEN v. WASATCH COUNTY" on Justia Law

Andrew Sangster, on behalf of a class of flight instructors, filed suit against the University of North Dakota alleging that instructors were not paid for all hours worked. Sangster claimed the university compensated instructors only for student contact hours and excluded other work-related tasks such as scheduling, pre- and post-flight procedures, recordkeeping, and waiting at the airport. He sought damages for violations of the Fair Labor Standards Act (FLSA), North Dakota wage laws, unjust enrichment, and conversion.The District Court for Cass County reviewed the university’s motion to dismiss, which argued the court lacked jurisdiction because Sangster failed to give timely notice to the Office of Management and Budget as required by North Dakota law. Sangster admitted he had not provided this notice but contended his claims were contractual and thus exempt from the notice requirement. The district court denied the motion to dismiss with respect to the FLSA, state wage law, and unjust enrichment claims, finding them contractual in nature. The conversion claim was dismissed because Sangster conceded the notice requirement applied.The Supreme Court of the State of North Dakota subsequently reviewed the district court’s decision upon the University’s petition for a supervisory writ. The Supreme Court exercised its discretionary supervisory jurisdiction, holding that Sangster’s claims for relief under the FLSA, North Dakota wage laws, and unjust enrichment were not contractual in nature and therefore not authorized by N.D.C.C. ch. 32-12. The Supreme Court concluded that because Sangster had not complied with the statutory notice requirements for noncontractual claims, the district court lacked subject matter jurisdiction. The court granted the supervisory writ and directed the district court to dismiss Sangster’s case for lack of jurisdiction. View "UND v. Whelan" on Justia Law