Justia Civil Procedure Opinion Summaries

A former employee initiated a class action lawsuit against her prior employer, alleging violations of various California Labor Code provisions and other employment-related statutes. After the lawsuit was filed, the employer entered into individual settlement agreements with approximately 954 current and former employees, offering cash payments in exchange for waivers of wage and hour claims. The total settlement payments exceeded $875,000. The named plaintiff did not sign such an agreement, but many potential class members did.The Superior Court of San Bernardino County partially granted the plaintiff’s motion to invalidate these individual settlement agreements, finding them voidable due to allegations of fraud and duress. The trial court ordered that a curative notice be sent to all affected employees, informing them of their right to revoke the agreements and join the class action. The court, however, declined to require that the notice include language stating that those who revoked their settlements might be required to repay the settlement amounts if the employer prevailed. The court instead indicated that settlement payments could be offset against any recovery and that the issue of repayment could be addressed later.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the trial court’s order after the employer petitioned for writ relief. The appellate court held that, under California’s rescission statutes (Civil Code sections 1689, 1691, and 1693), putative class members who rescind their individual settlement agreements may be required to repay the consideration received if the employer prevails, but actual repayment can be delayed until judgment. The court instructed the trial court to revise the curative notice to inform employees that repayment may be required at the conclusion of litigation, and clarified that the trial court retains discretion at judgment to adjust the equities between the parties. The order of the trial court was vacated for reconsideration consistent with these principles. View "The Merchant of Tennis, Inc. v. Superior Ct." on Justia Law

A Canadian citizen married an American citizen in 2017. The couple lived in Canada until 2020, then moved to Hawaii, where the American spouse began working as a physician. The Canadian spouse entered the United States on a tourist visa and soon applied for lawful permanent residency. To support this application, the American spouse signed a federal Affidavit of Support, committing to maintain the non-citizen’s income above 125% of the federal poverty line. The Canadian spouse obtained permanent residency in 2021. Around that time, the marriage ended, and the American spouse moved to Michigan and filed for divorce. In 2022, the parties entered into a settlement agreement and consented divorce judgment in Michigan, in which they resolved all issues—including spousal support—and released any claims against each other.The Canadian spouse later filed suit in the United States District Court for the Eastern District of Michigan, alleging that his former spouse had failed to provide the financial support required by the Affidavit of Support. The former spouse moved to dismiss, arguing that the district court lacked jurisdiction under the Rooker-Feldman doctrine and that the divorce judgment precluded the claim. The district court rejected the jurisdictional argument but agreed that claim preclusion under Michigan law barred the lawsuit, and dismissed the action.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The court held that federal courts must give state court judgments the same preclusive effect they would have under state law, pursuant to the Full Faith and Credit Act. The court ruled that Michigan claim preclusion law applied, and that the prior divorce judgment barred the new lawsuit because the claim could have been raised in the divorce proceedings. The court also rejected arguments that federal law or preemption required a different result. View "Ramgoolam v. Gupta" on Justia Law

A private individual brought a qui tam action under the California False Claims Act (CFCA) against two construction-related entities, alleging they submitted false claims to local government agencies in connection with airport construction projects. The plaintiff followed the statutory procedure by filing the complaint under seal in the Superior Court of Los Angeles County and mailing a copy to the Attorney General, as required by the CFCA. The complaint involved local (political subdivision) funds. The Attorney General, however, did not forward the complaint to the relevant local authorities and took no steps to intervene or extend the seal. After the 60-day sealing period expired without government action, the plaintiff served the defendants.The Superior Court of Los Angeles County sustained the defendants’ demurrer without leave to amend, holding that the plaintiff failed to comply with the CFCA’s sealing and service requirements. The trial court concluded the complaint should have remained under seal until the government notified the court of its decision to intervene, and that the plaintiff’s actions in unsealing and serving the complaint were premature. The court entered judgment dismissing the action with prejudice.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. It held that a qui tam plaintiff is not required to allege compliance with the CFCA’s sealing and service requirements to state a cause of action, nor does failure to comply automatically require dismissal. The court further held that the statutory scheme creates a default 60-day seal period, which lifts automatically unless the government requests an extension. Because the plaintiff filed the complaint under seal, served the Attorney General, and waited until after the seal lifted to serve the defendants, the plaintiff complied with the statute. The judgment was reversed and the case remanded with directions to overrule the demurrer. View "Albarghouti v. LA Gateway Partners, LLC" on Justia Law

A dispute arose between neighbors in Illinois over a property line, with one party, Mr. Barker, seeking to quiet title to land upon which the Boettchers had built a garage. The Boettchers counterclaimed, asserting adverse possession and contesting the property’s boundaries. During this litigation, the Boettchers issued subpoenas to two employees of the United States Department of Agriculture for documents and testimony relating to farm acreage. The Department refused compliance, citing federal regulations, and when the Boettchers would not withdraw the subpoenas, the Department removed only the subpoena proceeding—not the entire case—to federal court under the federal officer removal statute.The Boettchers subsequently attempted to remove the entire state case to federal court, invoking both the general removal statute and federal question jurisdiction, arguing that federal law originally defined the disputed property lines. Mr. Barker moved to remand, arguing that the property dispute was governed by Illinois law. The United States District Court for the Central District of Illinois retained jurisdiction over the subpoena proceeding but remanded the property dispute to state court. The court later granted summary judgment to the Department of Agriculture, quashing the subpoenas.On appeal, the United States Court of Appeals for the Seventh Circuit held that it had jurisdiction to review the remand order under 28 U.S.C. § 1447(d), since federal officer jurisdiction was invoked. The court affirmed the district court’s decision, concluding that the Department’s removal of only the subpoena proceeding was proper under the statute, and that there was no independent federal jurisdiction over the property dispute. The court also held that the district court properly quashed the subpoenas, as neither the state nor federal court had jurisdiction to enforce them against federal employees under the circumstances. The judgment was affirmed. View "Barker v Boettcher" on Justia Law

A condominium unit was owned by Diane Marchetti, who did not reside in the unit but allowed her daughter, Caroline Thibeault, and Thibeault’s son to occupy it. The condominium’s association initiated a foreclosure action against Marchetti alleging she was in default for failing to pay assessments, fines, and fees—some of which related to Thibeault’s alleged commercial use of the unit. Thibeault’s son has a disability, and both Thibeault and Marchetti asserted that the association had failed to provide reasonable accommodation under federal and state disability laws.After the foreclosure action commenced in the Sagadahoc County Superior Court, Marchetti filed an answer and raised several defenses, including alleged violations of the Americans with Disabilities Act and the Maine Human Rights Act. Thibeault, who was not a party to the action, then moved to intervene, claiming both a direct interest in the property and statutory civil rights at stake. She sought intervention as of right or, alternatively, permissive intervention, arguing her interests were not adequately represented and that her defenses raised common questions of law and fact with the main action. The Superior Court denied her motion to intervene on both grounds, finding her interest insufficient and noting that her mother’s defenses already encompassed her concerns.The Maine Supreme Judicial Court reviewed the order denying intervention. The court held that Thibeault did not satisfy the criteria for intervention as of right under Maine Rule of Civil Procedure 24(a)(2) because she lacked a direct, legally protectable interest in the foreclosure action, her ability to protect her interests would not be impaired by denial, and her interests were adequately represented by Marchetti. The court also found no abuse of discretion in denying permissive intervention under Rule 24(b) because Thibeault’s participation would be duplicative and cause undue delay. The order denying intervention was affirmed. View "Oak Hill Condominiums v. Marchetti" on Justia Law

A group of students, their parents or guardians, and local school boards from several low-wealth and urban school districts in North Carolina brought suit against the State and the State Board of Education in 1994. They claimed that the State’s method of funding education deprived students in their districts of their constitutional right to the opportunity for a sound basic education, focusing on perceived inadequacies in the implementation and funding of the Basic Education Program (BEP) as it then existed. The plaintiffs did not allege that the statewide education system was unconstitutional on its face, but rather that it was unconstitutional as applied to their specific districts due to disparities in resource allocation.After various procedural developments, including intervention by additional parties and the dismissal of some claims, the case reached the Supreme Court of North Carolina, which previously clarified that the right at issue belonged only to students, not school boards. The Supreme Court held in Leandro v. State that the constitution guarantees every child the opportunity for a sound basic education, and remanded the case for as-applied determinations regarding whether that right was denied in the named districts. In Hoke County Board of Education v. State, the Supreme Court affirmed a trial court finding that at-risk students in Hoke County had been deprived of their right, but otherwise found the statewide education system generally constitutional as then structured. The Supreme Court remanded for further as-applied proceedings in the other named districts, but no further trials occurred.Over time, the case’s subject matter shifted, and the trial court, with the parties’ acquiescence, began addressing a statewide, facial challenge to the current education system, including ordering the implementation of a statewide remedial plan without a new or amended complaint raising such a claim. The Supreme Court of North Carolina, reviewing an order entered on 17 April 2023, held that the trial court lacked subject matter jurisdiction to adjudicate a facial challenge to the statewide education system, since no party had properly invoked jurisdiction over such a claim by amending the pleadings or following the statutory procedure. The Court vacated the trial court’s order and dismissed the action with prejudice, concluding that any orders entered after 24 July 2017, when the litigation’s nature changed, were void for lack of subject matter jurisdiction. View "Hoke Cnty. Bd. of Educ. v. State" on Justia Law

After Jet Midwest International Co., Ltd. made a $6.5 million loan to Jet Midwest Group, LLC (JMG) for the purchase of a Boeing 737-700, JMG defaulted on repayment. Jet Midwest sued for breach of contract, and when it could not collect on its judgment due to JMG’s lack of funds, Jet Midwest brought claims under the Missouri Fraudulent Transfer Act against several individuals and entities (the Ohadi/Woolley defendants), alleging the improper transfer of assets to avoid payment. Following a bench trial, Jet Midwest prevailed on its claims, and the district court awarded money damages, interest, and set a schedule for further motions on attorney’s fees and costs.Previously, the United States District Court for the Western District of Missouri awarded Jet Midwest over $6.5 million in attorney’s fees and costs. The United States Court of Appeals for the Eighth Circuit vacated this award, finding the district court had not properly performed a lodestar calculation for attorney’s fees and had not analyzed which costs were recoverable under federal law. On remand, Jet Midwest reduced its fee request but sought a multiplier; the district court ultimately awarded $5.8 million in attorney’s fees, granted prejudgment interest at 14 percent, and included expert witness fees and other litigation costs. Both sides appealed aspects of this award.The United States Court of Appeals for the Eighth Circuit held that the district court properly calculated and awarded $5.8 million in attorney’s fees but erred in awarding expert witness fees as part of attorney’s fees, as Jet Midwest failed to provide sufficient evidence that such fees were recoverable under the relevant standards. The Eighth Circuit also held that the district court erred in applying a 14 percent prejudgment interest rate and ordered that Missouri’s statutory rate of nine percent should apply. Additionally, the court clarified that, after August 6, 2020, the federal postjudgment interest rate under 28 U.S.C. § 1961(a) governs. The case was affirmed in part, reversed in part, and remanded for further proceedings consistent with these rulings. View "Jet Midwest International Co., Ltd v. Ohadi" on Justia Law

A mother and her minor daughter, both citizens of El Salvador, entered the United States in 2017 without valid entry documents. The mother applied for asylum, withholding of removal, and protection under the Convention Against Torture, claiming that a criminal gang in El Salvador had repeatedly threatened her family with violence and kidnapping in attempts to extort money. Although her family partially complied with the gang’s demands and was not physically harmed, she asserted that returning to El Salvador would put her and her children at risk, as the gang had widespread influence and the Salvadoran government could not protect them.An immigration judge found the mother's testimony not credible due to inconsistencies and determined that, even if her testimony were credible, the threats did not amount to past persecution, the alleged social groups were not cognizable, and she could relocate within El Salvador. The judge denied all claims for relief. The Board of Immigration Appeals (BIA) affirmed, concluding that she had not established past persecution or a well-founded fear of future persecution. The BIA also determined that her argument that the immigration judge was biased was waived because she raised it only in a conclusory manner and abandoned it in her appellate brief.The United States Court of Appeals for the Eighth Circuit reviewed the BIA’s decision as the final agency action. The court held that the BIA properly applied its waiver rule and did not err in finding the due process claim waived, as the argument was inadequately raised and not meaningfully pursued. The court also concluded it lacked jurisdiction to review the Department of Homeland Security’s exercise of prosecutorial discretion regarding enforcement priorities. The petition for review was denied. View "Quijano-Duran v. Bondi" on Justia Law

Several plaintiffs, including a truck driver and employees, alleged that their employers or associated companies collected their biometric data, such as fingerprints or hand geometry, without complying with the requirements of the Illinois Biometric Information Privacy Act (BIPA). Each plaintiff claimed that every instance of data collection constituted a separate violation, resulting in potentially massive statutory damages. Some claims were brought as class actions, raising the possibility of billions in liability for the defendants.In the United States District Court for the Northern District of Illinois, the district judges addressed whether a 2024 amendment to BIPA Section 20, which clarified that damages should be assessed per person rather than per scan, applied retroactively to cases pending when the amendment was enacted. The district courts determined that the amendment did not apply retroactively and certified this question for interlocutory appeal under 28 U.S.C. § 1292(b).The United States Court of Appeals for the Seventh Circuit reviewed the certified question de novo. The court considered Illinois’s established law of statutory retroactivity, which distinguishes between substantive and procedural (including remedial) changes. The Seventh Circuit held that the BIPA amendment was remedial because it addressed only the scope of available damages and did not alter the underlying substantive obligations or standards of liability. The court reasoned that, under Illinois law, remedial amendments apply to pending cases unless precluded by constitutional concerns, which were not present here.The Seventh Circuit concluded that the 2024 amendment to BIPA Section 20 applies retroactively to all pending cases. The court reversed the district courts’ rulings and remanded the cases for further proceedings consistent with its holding. View "Clay v Union Pacific Railroad Company" on Justia Law

A company that designs and manufactures interactive technology products entered into reseller agreements with another company, granting the latter exclusive rights to sell its products in certain territories. Several years later, the manufacturer revoked the exclusivity, after which the reseller’s owner and his son developed a competing product. The manufacturer then terminated the reseller relationship. Subsequently, the reseller sued the manufacturer in South Carolina state court for various business torts and contract claims. The parties settled and executed a written agreement that broadly released and dismissed any and all claims and counterclaims that could have been brought in the litigation, including through a specific handwritten provision. Nevertheless, shortly after, the manufacturer initiated a federal lawsuit, alleging intellectual property violations related to the competing product.The state court dismissed the original action with prejudice, including all possible claims and counterclaims. In the federal action, the defendants argued that the settlement agreement and res judicata barred the new claims. The United States District Court for the District of South Carolina initially allowed certain claims to proceed, but after further evidence and reconsideration, it granted summary judgment for the defendants, finding the claims precluded by the settlement and the state court’s dismissal. A jury was then impaneled for trial on the defendants’ counterclaims.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s rulings. The Court of Appeals held that the manufacturer’s claims were barred by res judicata based on the settlement and state court order, as the language of the agreement and the parties’ intent encompassed the intellectual property claims. The appellate court also found no abuse of discretion in the district court’s evidentiary rulings, its reconsideration of summary judgment, or the conduct of the trial, and affirmed the judgment in full. View "Clear Touch Interactive, Inc. v. The Ockers Company" on Justia Law