Justia Civil Procedure Opinion Summaries

In December 2015, sixteen-year-old Isaiah Taylor was stopped by Milwaukee police officers Justin Schwarzhuber and Jasen Rydzewski while running through his neighborhood to deliver a turkey. The officers frisked him, searched his bag, and detained him in their police car to check for outstanding warrants and recent robberies. Taylor later sued the officers under 42 U.S.C. § 1983, claiming an unreasonable search and seizure in violation of the Fourth Amendment and racial profiling in violation of the Equal Protection Clause of the Fourteenth Amendment.The United States District Court for the Eastern District of Wisconsin granted qualified immunity and summary judgment to the officers on Taylor’s Fourteenth Amendment claim and on the Fourth Amendment claim regarding the initial stop and frisk. However, the court denied qualified immunity on the issue of Taylor’s continued detention, sending it to trial. The jury found the officers not liable, and the court denied Taylor’s motion for post-trial relief under Federal Rule of Civil Procedure 59.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the grant of summary judgment on Taylor’s Fourteenth Amendment claim, finding insufficient evidence of racial profiling. However, it vacated the summary judgment on the Fourth Amendment claims related to the initial stop and frisk, concluding that the officers lacked reasonable suspicion for the stop and frisk based on clearly established law. The court also vacated the jury verdict on the continued detention issue, as it was intertwined with the initial stop's constitutionality, and remanded the case for a new trial on all Fourth Amendment claims. View "Taylor v. Schwarzhuber" on Justia Law

Gurparas Singh, a native and citizen of India, sought asylum, withholding of removal, and protection under the Convention Against Torture (CAT) in the United States, claiming persecution by members of the ruling BJP party due to his involvement with the Mann political party. Singh recounted two specific incidents of persecution: one in July 2017, where BJP members threatened him while he was placing posters, and another in December 2017, where he was attacked by BJP members while returning from a blood drive. Singh entered the U.S. without valid documents in April 2018 and was charged with removability. He admitted the allegations and applied for asylum and related relief.The Immigration Judge (IJ) found Singh not credible due to significant linguistic and factual similarities between his declaration and those of other asylum applicants from India, suggesting a fabricated claim. The IJ also found that Singh knowingly filed a frivolous asylum application and denied his CAT claim, concluding that the remaining evidence did not establish a likelihood of torture upon his return to India. The Board of Immigration Appeals (BIA) upheld the IJ's findings and dismissed Singh's appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case and denied Singh's petition for review. The court held that substantial evidence supported the BIA's adverse credibility determination, noting the identical language and narrative structure in Singh's declaration compared to other applicants. The court also found that the IJ followed proper procedural safeguards in making the frivolous application finding. Additionally, the court concluded that the denial of CAT protection was supported by substantial evidence, as Singh failed to provide sufficient individualized evidence of a likelihood of torture. View "SINGH V. BONDI" on Justia Law

Three former employees of Amazon filed a class action complaint seeking payment for straight-time and overtime wages under Connecticut’s wage laws for time spent undergoing mandatory security screenings after clocking out. The employees argued that this time should be compensable under state law. Amazon required employees to pass through security screenings when exiting the secured area of their fulfillment centers, but not upon entry. The screenings involved metal detectors and varied based on the personal belongings employees carried. Employees were not compensated for the time spent in these screenings.The United States District Court for the District of Connecticut granted summary judgment in favor of Amazon, dismissing the employees' complaint. The court relied on the United States Supreme Court’s decision in Integrity Staffing Solutions, Inc. v. Busk, which held that time spent in mandatory security screenings is not compensable under federal law. The employees appealed the decision and moved to certify a question to the Connecticut Supreme Court regarding the applicability of Connecticut’s wage laws to their case.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the question of whether Connecticut’s wage laws require compensation for time spent in mandatory security screenings is unresolved. The court decided to certify this question to the Connecticut Supreme Court for a definitive resolution. Additionally, the court asked the Connecticut Supreme Court to address whether a de minimis exception applies to such compensable time and, if so, what amount of time is considered de minimis. The Second Circuit reserved its decision and dismissed the employees' motion to certify as moot, pending the Connecticut Supreme Court's response. View "Del Rio v. Amazon.com.DECE, LLC" on Justia Law

Gina Burt filed a lawsuit against Playtika, Ltd. and Playtika Holding Corporation in Tennessee state court, seeking to recover alleged gambling losses incurred by Tennessee residents who played Playtika’s online games. Burt's claim was based on Tennessee Code Ann. § 29-19-105, which allows recovery of gambling losses. Playtika removed the case to federal court, invoking jurisdiction under the Class Action Fairness Act (CAFA) and traditional diversity jurisdiction.The United States District Court for the Eastern District of Tennessee remanded the case to state court. The district court determined that it lacked jurisdiction because Burt’s suit was not a “class action” under CAFA, and the losses of the Tennessee players could not be aggregated to meet the amount in controversy requirement for traditional diversity jurisdiction. Playtika appealed the remand order under CAFA’s expedited removal appeal provision.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s remand order. The appellate court held that Burt lacked Article III standing to proceed in federal court because she did not allege that she personally suffered any gambling loss. The court found that Burt’s claim to recover losses on behalf of other Tennessee residents did not satisfy the injury-in-fact requirement for standing. Additionally, the court rejected Burt’s argument that she had standing under a qui tam theory, concluding that Tennessee Code Ann. § 29-19-105 is not a qui tam statute. Consequently, the court affirmed the district court’s decision to remand the case to state court. View "Burt v. Playtika, Ltd." on Justia Law

Kevin Brooks, an inmate at a federal prison camp, suffered from appendicitis, which was misdiagnosed by medical personnel as constipation and COVID-19. Despite his worsening condition, he was not sent to a hospital for over ten days, resulting in a ruptured appendix and peritonitis. Brooks eventually recovered but experienced severe pain during the ordeal. He filed a lawsuit seeking damages from five federal employees, three of whom treated him and two who were supervisors.The United States District Court for the Northern District of Illinois dismissed Brooks's suit, ruling that it presented a new context to which the doctrine of Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics does not extend. The court reasoned that Brooks's case differed from previous Bivens cases, particularly Carlson v. Green, due to the duration of his medical issue and the involvement of supervisory personnel.The United States Court of Appeals for the Seventh Circuit reviewed the case and disagreed with the district court's reasoning. The Seventh Circuit held that Brooks's claim did not present a new context, as it was similar to Carlson v. Green, where a prisoner alleged constitutionally inadequate medical care. The court found that the distinctions made by the district court regarding the duration of the medical issue and the involvement of supervisors were not sufficient to create a new context. The Seventh Circuit affirmed the dismissal of claims against the two supervisors but vacated the dismissal of claims against the three treating personnel, remanding the case for further proceedings. View "Brooks v. Richardson" on Justia Law

Plaintiffs filed a complaint in Arizona district court challenging the state's voting system, claiming it did not adequately protect voters' rights and should be replaced with a hand-counted paper ballot system. The district court dismissed the complaint for lack of standing, and the Ninth Circuit affirmed the dismissal. Subsequently, the district court imposed sanctions on the plaintiffs' attorneys, including Alan Dershowitz, for filing a frivolous complaint.The United States District Court for the District of Arizona dismissed the plaintiffs' complaint and granted the defendants' motion for sanctions under Federal Rule of Civil Procedure 11. The district court found that the complaint contained false and misleading statements and ordered the plaintiffs' attorneys to pay a portion of the defendants' legal fees. Dershowitz, who signed the complaint as "of counsel," was held jointly and severally liable for a portion of the sanctions.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's holding that "of counsel" attorneys can be sanctioned under Rule 11 for signing frivolous complaints. The Ninth Circuit rejected Dershowitz's argument that the sanctions violated the First Amendment and found that the district court imposed sanctions to deter frivolous actions, not to silence speech. However, the Ninth Circuit reversed the imposition of sanctions on Dershowitz, as the liability of "of counsel" attorneys under Rule 11 had not been clearly articulated in previous case law. The court declined to apply the rule retroactively but stated that it would apply to any signed pleadings after the publication of this opinion. View "Lake v. Gates" on Justia Law

Paul Grosz was injured while helping his friend Gregory Kisling hang a crucifix in Kisling’s home. Grosz fell from a homemade scaffolding when the wire holding the crucifix broke, resulting in significant injuries including broken ribs, a spinal fracture, and a traumatic brain injury. Grosz sued Kisling for negligence, and the jury awarded Grosz $1.2 million in noneconomic damages but found Kisling only 25% at fault, attributing 75% of the fault to Grosz.The Superior Court of Alaska, Third Judicial District, Anchorage, presided over by Judge Josie Garton, handled the case. After the jury's verdict, Grosz requested the court to determine if his injuries qualified for a higher statutory cap on noneconomic damages due to severe permanent physical impairment or severe disfigurement. The court denied this request, stating it was a jury issue that Grosz had not properly raised during the trial. The court then applied the comparative fault percentages, reducing the $1.2 million award to $300,000 (25% of $1.2 million). The court found this amount was below the $400,000 statutory cap on noneconomic damages and did not reduce it further.The Supreme Court of the State of Alaska reviewed the case. The main issue on appeal was whether the superior court should have first applied the statutory cap on noneconomic damages before apportioning fault. The Supreme Court affirmed the superior court’s decision, holding that the correct sequence is to first allocate fault and then apply the statutory cap if necessary. The court reasoned that this approach respects the jury’s role in determining the actual loss and aligns with legislative intent to cap a defendant’s exposure without further reducing an already capped amount. Thus, Grosz’s recovery of $300,000 was upheld, as it was below the statutory cap. View "Kisling v. Grosz" on Justia Law

Jeffrey Herrera filed a pro se complaint alleging that he was detained for several months beyond his maximum release date, which he claimed violated the Eighth Amendment. Herrera was arrested in September 2012, sentenced in March 2013 to 36 to 72 months’ imprisonment, and released on parole in December 2014. After violating parole, his sentence was reduced in January 2017 to 30 to 66 months, with credit for time served. Despite this, Herrera claimed he was detained until October 2019, seven months past his maximum release date of March 2019.The United States District Court for the Middle District of Pennsylvania dismissed Herrera’s complaint under 28 U.S.C. § 1915(e), reasoning that his claim must be brought as a habeas corpus petition under 28 U.S.C. § 2254 and that his claim for damages was barred by Heck v. Humphrey, 512 U.S. 477 (1994). The court also found that any amendment to the complaint would be futile. Herrera’s motions for reconsideration and relief from judgment were denied, with the court maintaining that his claim was barred by Heck and the statute of limitations.The United States Court of Appeals for the Third Circuit reviewed the case and determined that Heck does not apply to Herrera’s overdetention claim because it does not imply that his conviction or sentence were invalid. The court found that Herrera plausibly pleaded an Eighth Amendment overdetention claim, as he alleged that prison officials were aware of his overdetention and failed to act, resulting in his prolonged detention. However, the court noted that the claim might be time-barred under Pennsylvania’s two-year statute of limitations but remanded the case to allow Herrera to amend his complaint to address potential tolling of the statute of limitations. The Third Circuit vacated the District Court’s order and remanded for further proceedings. View "Herrera v. Pennsylvania Board of Probation and Parole" on Justia Law

Elizabeth Perez, a former employee of Rose Hills Company, filed a class action lawsuit on behalf of herself and similarly situated employees, alleging violations of California wage-and-hour laws. The complaint did not specify the amount in controversy or the frequency of the alleged violations. Rose Hills removed the case to federal court under the Class Action Fairness Act (CAFA), which allows removal if the amount in controversy exceeds $5 million.The United States District Court for the Central District of California remanded the case to state court, stating that Rose Hills did not meet CAFA’s $5 million amount-in-controversy requirement. The district court found that Rose Hills failed to provide evidence justifying its assumed violation rate, which was used to calculate the amount in controversy.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that a removing defendant under CAFA is permitted to rely on reasonable assumptions based on the plaintiff’s complaint to calculate the amount in controversy. The court found that Rose Hills’ approach, which included assumptions about the violation rate tethered to the language of the complaint, was reasonable. The district court erred by requiring Rose Hills to provide evidence supporting its assumed violation rate.The Ninth Circuit vacated the district court’s remand order and remanded the case for further proceedings, instructing the district court to evaluate whether Rose Hills’ violation-rate assumption was a reasonable interpretation of the complaint. The court emphasized that assumptions need not be proven with evidence if they are reasonable interpretations of the complaint’s allegations. View "Perez v. Rose Hills Company" on Justia Law

The plaintiff, Alexandria Kazarian, filed a negligence lawsuit against New London County Mutual Insurance Company after a trip-and-fall accident near property owned by the defendant’s insured, Irene Swiney. Kazarian alleged that Swiney allowed a vehicle to be parked in a manner that obstructed the sidewalk, causing her to walk into the street and trip over an unsecured gas cap, resulting in injury. After Swiney passed away, New London was substituted as the defendant.In the Superior Court, a jury trial resulted in a verdict in favor of New London. Kazarian’s motion for a new trial was denied. She argued that Swiney was negligent for allowing the vehicle to obstruct the sidewalk and that a master-servant relationship existed between Swiney and the vehicle owner, making Swiney liable. The trial justice denied the motion, stating it was within the jury’s purview to evaluate the evidence and witness credibility.The Rhode Island Supreme Court reviewed the case. Kazarian contended that the trial justice erred in denying her motions for judgment as a matter of law and a new trial. She also argued that the trial justice’s use of the word “redacted” in response to a jury question was prejudicial. The Supreme Court found that reasonable minds could differ on whether the vehicle obstructed the sidewalk and whether it was a reasonable and necessary use of the sidewalk. The Court also noted that Kazarian failed to object contemporaneously to the alleged golden rule violation and the grass-growth argument during the trial, thus waiving those issues.The Supreme Court affirmed the Superior Court’s judgment, concluding that the trial justice conducted an appropriate analysis and did not err in his decisions. The case was remanded to the Superior Court. View "Kazarian v. New London County Mutual Insurance Co." on Justia Law