Justia Civil Procedure Opinion Summaries

In November 2022, Anderson Aldrich entered Club Q, an LGBTQIA+ nightclub in Colorado Springs, and shot patrons, killing five people and injuring twenty-five others. Survivors and families of victims sued multiple defendants: the El Paso County Board of County Commissioners, the Sheriff, and Club Q’s owners and associated entities. Against the County Defendants, plaintiffs raised federal substantive due process claims under 42 U.S.C. § 1983, alleging county policies prevented law enforcement from seeking emergency protection orders (ERPOs), thereby increasing vulnerability to private violence. Against Club Q Defendants, plaintiffs brought claims under the Colorado Premises Liability Act (CPLA), as well as negligence and wrongful-death claims, alleging inadequate security and safety measures.The United States District Court for the District of Colorado granted the County Defendants’ motion to dismiss all federal claims, finding plaintiffs had not plausibly alleged affirmative danger-creating conduct required under the state-created-danger theory. The court also dismissed the CPLA claims against Club Q Defendants due to lack of causation, but denied dismissal of negligence and wrongful-death claims, reasoning the exclusivity of the CPLA was a fact-intensive issue not suitable for resolution at the pleading stage. Once federal claims were dismissed, the court declined to exercise supplemental jurisdiction over remaining state claims and entered judgment.On appeal, the United States Court of Appeals for the Tenth Circuit affirmed dismissal of the § 1983 claims, holding plaintiffs failed to allege that county conduct placed them at immediate risk, thus not satisfying the affirmative-conduct requirement. The court also affirmed dismissal of the CPLA claims, concluding Aldrich’s actions were the predominant cause of injury under Colorado law. However, it reversed the district court’s denial of dismissal for negligence and wrongful-death claims, holding the CPLA provides the exclusive remedy for injuries arising from Club Q’s conditions and precludes those common-law claims. View "Vance v. Aldrich" on Justia Law

Two college football players began their collegiate athletic careers at junior colleges in 2019 before transferring to NCAA Division I institutions. Both completed the maximum five years of collegiate eligibility allowed by the NCAA’s “Five-Year Rule,” which includes time spent at any full-time collegiate institution, including junior colleges. In 2025, each player sought a preliminary injunction in the United States District Court for the District of Nevada, arguing that the NCAA’s five-year limitation on eligibility was anticompetitive under Section 1 of the Sherman Act and seeking to play an additional, sixth year of college football. The players also challenged the NCAA’s “Rule of Restitution,” which allows the NCAA to penalize member schools that permit ineligible athletes to compete pursuant to court orders later vacated or reversed.Both district courts granted the plaintiffs’ requests for preliminary injunctions, permitting them to play in the 2025 college football season. After the season concluded, the NCAA appealed the injunctions to the United States Court of Appeals for the Ninth Circuit. The plaintiffs moved to dismiss the appeals as moot because the 2025 season was over and their collegiate eligibility had ended.The United States Court of Appeals for the Ninth Circuit held that the appeals were moot, as the injunctions had expired and the players’ collegiate careers were over, making it impossible to provide any effective relief to the NCAA. The court further determined that the NCAA did not meet its burden to show that the case fit the “capable of repetition yet evading review” exception to mootness, because there was no reasonable expectation that these plaintiffs would again be subject to the same NCAA actions. Accordingly, the Ninth Circuit dismissed the NCAA’s appeals as moot and vacated the district courts’ orders. View "BRAHAM V. NATIONAL COLLEGIATE ATHLETIC ASSOCIATION" on Justia Law

Twin brothers, both Black international students, were enrolled as doctoral candidates at the University of Mississippi’s Department of Pharmacy Administration. One brother, Bennard, disagreed with changes to his faculty mentorship arrangement, objected to mandatory in-person meetings, and declined to complete a required program assessment called the Abilities Transcript. After being repeatedly warned and given extensions, he was placed on provisional status for failing to complete the requirement, which also caused the loss of his graduate assistantship. Bennard and his brother each filed lawsuits against the University and several faculty members, alleging constitutional, statutory, and contract violations related to academic sanctions and alleged discriminatory treatment.The United States District Court for the Northern District of Mississippi consolidated the brothers’ cases. It dismissed Bennard’s claims against the University on sovereign-immunity grounds, dismissed his remaining federal claims under Rule 12(b)(6) for failure to state a claim, and declined to exercise supplemental jurisdiction over his individual-capacity state contract claims. Bennard appealed, while his brother’s appeal was dismissed for failure to prosecute.The United States Court of Appeals for the Fifth Circuit reviewed Bennard’s remaining claims. The court held that sovereign immunity barred claims against the University, claims against one defendant in her official capacity, and official-capacity state-law contract claims; those dismissals must be without prejudice. The court further found that Bennard failed to plausibly allege First or Fourteenth Amendment violations, and that the faculty defendants were entitled to qualified immunity on individual-capacity claims. The court affirmed the district court’s refusal to exercise supplemental jurisdiction over the remaining contract claims and upheld consolidation of the cases and dismissal of moot preliminary injunction motions. The judgment was affirmed as modified to clarify the proper form of dismissal for sovereign-immunity-barred claims. View "Eriakha v. University of MS" on Justia Law

The dispute concerned ownership of a strip of land at the boundary between two neighboring properties. The petitioner initiated litigation to resolve title to this land, and the respondents answered and asserted counterclaims. With both parties’ consent, a special master reviewed the title issues. The trial court adopted part of the special master’s recommendation, rejected the petitioner’s claims, and vested title in the respondents. Before the respondents’ counterclaims could be tried, they voluntarily dismissed those claims. Subsequently, the petitioner filed a notice of appeal challenging the trial court’s order on title.The Court of Appeals of Georgia reviewed the case and determined that the petitioner’s appeal was untimely. The court reasoned that the notice of appeal was filed more than 30 days after the entry of the trial court’s order and held that the voluntary dismissal of the counterclaims did not render the earlier order appealable as a final judgment. The majority relied on Dykes v. Atlanta Paving & Concrete Construction, which held that the date of entry of the original order determines its finality for appeal purposes, not subsequent dismissals of remaining claims. A dissent argued that an order could become final due to subsequent events, such as dismissal of remaining claims.The Supreme Court of Georgia granted certiorari and concluded that the appeal was timely. The Court held that when all remaining claims were dismissed, the prior order became a final judgment, triggering the 30-day period to file a notice of appeal. The Court overruled Dykes and similar precedents, clarifying that a judgment can become final due to subsequent events and not solely upon original entry. The Supreme Court vacated the Court of Appeals’ dismissal and remanded the case for consideration of the merits. View "NEELY v. PARSELL" on Justia Law

A dispute arose regarding the right to use a private roadway, Forgotten Lane, which crosses property owned by Shan and Dana Tompkins and abuts parcels owned by Christine Brock as co-trustee of a family trust. The properties, all originally part of a single tract, were divided over several decades by a series of conveyances beginning in the 1940s. The parties disagreed about whether Brock held an easement over Forgotten Lane, the nature of historical use of the road, and whether any rights to use the road continued to exist after the division of the property. In 2016–2017, physical barriers were placed on the disputed road, leading to this litigation after Brock claimed an easement and sought to remove the obstructions.The Twenty-First Judicial District Court, Ravalli County, first considered only Brock’s claim of an express easement based on a certificate of survey, ultimately denying summary judgment to both sides but inviting Brock to amend her complaint to include implied, prescriptive, and public easement theories. The court permitted the amendment and later bifurcated the proceedings, assigning the express, implied, and public easement claims to a bench trial, while reserving the prescriptive easement and trespass counterclaims for a potential jury trial. After a bench trial, the District Court found Brock did not prove an express easement but held she had established an implied easement across the Tompkins’ property and issued a permanent injunction. When the implied easement was found to provide the relief sought, the District Court dismissed the remaining claims and counterclaims as moot and denied Brock’s request for attorney fees on procedural grounds.The Supreme Court of the State of Montana reviewed the case and held that the District Court erred by not granting summary judgment to the Tompkins on the original express-easement claim, but that this error did not affect the fairness of proceedings on the amended complaint. The Supreme Court reversed the judgment finding an implied easement, vacated the permanent injunction, and remanded for further proceedings on any unresolved alternative theories, including public and prescriptive easements, and the trespass counterclaim. It also reversed the procedural denial of Brock’s request for costs and fees, remanding for a new determination after final judgment. Other procedural and bifurcation orders were affirmed. View "Brock v. Tompkins" on Justia Law

In this case, a dispute arose over membership interests in Freedom Pass Partners, LLC, which owns undeveloped property near Big Sky, Montana. Carol Hudson, through her estate and beneficiaries Alan and Jeffrey Johnson, claimed that Hudson funded the purchase of the property based on assurances she would be a member of Freedom Pass. After Hudson’s death, her sons, acting as trustees and beneficiaries of her trust, filed suit asserting multiple claims including breach of contract, fraud, unjust enrichment, and conversion, alleging Hudson’s investment entitled her to membership or ownership interests.The Eighteenth Judicial District Court reviewed the claims and granted summary judgment for Freedom Pass Partners, LLC. It found that the Johnsons lacked standing because the estate’s personal representative had not joined the litigation, and concluded that all claims were time-barred based on the statute of limitations. The court also denied Johnsons’ motions to amend the complaint, to compel discovery identifying a prospective property buyer, and for relief from judgment regarding the dissolution of a lis pendens notice.The Supreme Court of the State of Montana reviewed the District Court’s decisions de novo for summary judgment and for abuse of discretion on the remaining motions. It held that genuine disputes of material fact existed about whether Hudson knew or should have known she was not a member of Freedom Pass, particularly given conflicting evidence and potential concealment or fiduciary duties. The Supreme Court also found the denial of leave to amend the complaint was an abuse of discretion because adding the estate’s personal representative could cure the standing defect. The denial of discovery and failure to consider mootness regarding the lis pendens were also found to be abuses of discretion. The Supreme Court reversed the District Court’s rulings and remanded the case for further proceedings. View "Hudson Revocable Trust v. Freedom Pass" on Justia Law

A dispute arose between a company and a port authority over responsibility for securing permits to dredge a ship channel in Lake Charles, Louisiana. The company had leased the channel to develop a grain terminal, but the lease did not specify which party was responsible for obtaining the dredging permit. After the terminal was built but could not be fully used without dredging, the company and the port disagreed over who bore this responsibility. The company sued in federal court, and, by consent of both parties, a U.S. Magistrate Judge presided over a bench trial and awarded the company nearly $125 million.After the trial and the entry of judgment, the port discovered that the magistrate judge and the company’s lead trial counsel had been close family friends for four decades—a relationship that was not fully disclosed. The only disclosure had been that the lead counsel’s daughter was the judge’s law clerk, who would be screened from the case. Upon learning about the undisclosed relationship, the port moved to vacate the magistrate judge referral. The United States District Court for the Western District of Louisiana held an evidentiary hearing and found that the port’s consent to the referral had not been knowing, as it had lacked crucial information about the judge’s conflict, and vacated the referral.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision for abuse of discretion. The Fifth Circuit held that a party’s consent to magistrate judge jurisdiction waives a fundamental constitutional right and, therefore, must be knowing, voluntary, and intelligent. The court rejected the argument that constructive knowledge by the party’s counsel—rather than actual knowledge—could suffice to establish valid consent. Because the district court applied the correct standard and found no actual knowledge, the Fifth Circuit affirmed the vacation of the referral. View "I F G Port v. Lake Charles Harbor" on Justia Law

A national firearms industry trade association challenged the constitutionality of a New Jersey statute enacted in 2022, which imposes civil liability on gun industry members for certain “public nuisance” conduct related to the sale, manufacture, distribution, import, or marketing of firearms and related products. The law allows the state to bring enforcement actions against gun industry members for actions deemed unlawful or unreasonable, as well as for failing to implement “reasonable controls.” The association argued that the statute is unconstitutional under the Interstate Commerce Clause, the First and Second Amendments, and is preempted by the federal Protection of Lawful Commerce in Arms Act (PLCAA).Initially, the United States District Court for the District of New Jersey granted a preliminary injunction against enforcement of the law, but the United States Court of Appeals for the Third Circuit vacated that injunction, holding that the association lacked Article III standing because enforcement of the law was speculative at that time. After the state initiated several enforcement actions under the statute—including suits against two members of the association—the association moved to reopen the case, amend its complaint, and again seek a preliminary injunction. The District Court found standing but abstained from ruling on the merits under the Younger abstention doctrine, which generally prohibits federal courts from interfering with certain ongoing state proceedings.The United States Court of Appeals for the Third Circuit reviewed the case and held that the association now has standing due to the substantial risk of imminent enforcement against its members, evidenced by the state’s recent lawsuits. The court further held that Younger abstention does not apply because the association is not a party to any ongoing state proceeding and does not have the type of control or relationship with its members that would warrant abstention. Accordingly, the Third Circuit reversed the District Court’s order. View "National Shooting Sports Foundation v. Attorney General New Jersey" on Justia Law

A jury found that the defendant was negligent and awarded the plaintiff over $18.5 million in damages, which, after adding costs and interest, resulted in a judgment of more than $20 million. To stay enforcement of this judgment pending appeal, the defendant was required to post a bond under California law. The defendant, despite having about $1.75 million in assets, asserted that he could not obtain a bond in the statutorily required amount, which was over $30 million, and requested the trial court to waive or reduce the bond to the limit of his insurance policy ($1.25 million).The Superior Court of Sacramento County considered the defendant’s financial declaration and a supplemental declaration detailing the costs and collateral requirements for various bond levels from a bond broker. After evaluating these submissions and hearing arguments, the trial court found the defendant qualified for relief under Code of Civil Procedure section 995.240 and ordered him to post a reduced bond of $1.25 million. The plaintiff then filed a petition for writ of mandate or prohibition, challenging the trial court’s interpretation of “indigent” within the statute and the sufficiency of the evidence supporting the bond reduction.The Court of Appeal of the State of California, Third Appellate District, reviewed the trial court’s decision for abuse of discretion. The appellate court held that “indigent” under section 995.240 is not limited to those in extreme poverty but includes any person unable to obtain sufficient sureties, considering access to the judicial process. The trial court retains discretion to weigh all relevant factors, including the nature of the obligation and the potential harm to the beneficiary. The appellate court also found no evidentiary error in the trial court’s consideration of the defendant’s declarations. Accordingly, the petition was denied, and the trial court’s order was affirmed. View "Guzman v. Super. Ct." on Justia Law

A nonprofit organization dedicated to gun violence prevention filed several administrative complaints with the Federal Election Commission (FEC) in 2018, alleging violations of the Federal Election Campaign Act by two entities associated with a national advocacy group. After the FEC failed to act within the statutory 120-day period, the nonprofit filed suit in the United States District Court for the District of Columbia, seeking an order compelling the FEC to act. Due to a lack of quorum, the FEC remained inactive for an extended period. Eventually, the District Court granted summary judgment to the nonprofit, ordered the FEC to act within 30 days, and later determined the FEC had not complied, thereby allowing the nonprofit to file a citizen suit against the NRA-associated entities.The national advocacy group sought to dismiss the citizen suit, arguing the District Court lacked jurisdiction. It also moved to intervene in the original action, but only for the limited purpose of unsealing the judicial record. Subsequently, after the District Court’s final judgment, the advocacy group filed a motion under Rule 60(b)(4) seeking relief from the orders and judgment, contending that the District Court lacked subject-matter jurisdiction due to mootness and lack of adversity. The District Court denied this motion, holding that the group, as a nonparty, lacked standing to seek relief under Rule 60(b).The United States Court of Appeals for the District of Columbia Circuit reviewed the appeal from the denial of the Rule 60(b) motion. The Court held that only parties to a lawsuit, or those who properly become parties, may appeal an adverse judgment. Since the advocacy group had not used any procedural mechanism to become a party to the underlying suit, it lacked the procedural ability to appeal. Accordingly, the Court dismissed the appeal as impermissible under binding precedent. View "Giffords v. FEC" on Justia Law