Justia Civil Procedure Opinion Summaries

A 13-year-old juvenile pleaded guilty to fourth degree assault and was placed under community supervision with several conditions, including abstaining from alcohol. Over several months, she repeatedly violated these conditions, including using alcohol, failing to report to her probation officer, and leaving her home. The State sought multiple bench warrants, ultimately arguing that her actions, including a suicide attempt while intoxicated, posed a serious threat to public safety. The juvenile court issued a bench warrant, finding that her conduct met the “serious threat to public safety” standard required by a court rule, JuCR 7.16.On appeal, the Washington Court of Appeals determined that the facts did not meet JuCR 7.16’s “serious threat to public safety” requirement, as the connection between her actions and a threat to public safety was too attenuated. However, the appellate court also held that JuCR 7.16 irreconcilably conflicted with RCW 13.40.040, a statute with less restrictive prerequisites for issuing juvenile arrest warrants. The majority concluded that JuCR 7.16 was substantive, not procedural, and therefore invalid because it conflicted with the legislature’s authority over substantive law. A dissenting judge disagreed, viewing the rule as procedural.The Supreme Court of the State of Washington reversed the Court of Appeals. It held that JuCR 7.16 is a procedural rule governing the issuance of warrants and falls within the court’s inherent, constitutional, and statutory authority. The court further held that JuCR 7.16 and RCW 13.40.040 can be harmonized, requiring courts to satisfy both sets of prerequisites before issuing a warrant. The court also clarified that “serious threat to public safety” under JuCR 7.16 does not include threats solely to the juvenile’s own safety. The Supreme Court declined to recuse itself from the case. View "State v. A.M.W." on Justia Law

An employee of a California corporation, who was represented by a union and covered by two successive collective bargaining agreements (CBAs), brought two lawsuits in state court against her employer. She alleged violations of various California labor and business statutes, including claims for unpaid wages, overtime, meal and rest breaks, sick leave, wage statement inaccuracies, expense reimbursement, and retaliation. The CBAs included provisions regarding pay, leave, breaks, and a dispute resolution process for grievances.The employer removed both cases to the United States District Court for the Eastern District of California, arguing that the employee’s claims were preempted by § 301 of the Labor Management Relations Act (LMRA), which would create federal jurisdiction. The district court determined that only the claims related to untimely wage payments were preempted and thus converted to federal claims under § 301. These federal claims were dismissed because the employee had not exhausted the grievance procedures required by the CBAs. The court found that the remaining state law claims were not preempted, declined to exercise supplemental jurisdiction over them, and remanded those claims to state court. The employer appealed the remand orders.The United States Court of Appeals for the Ninth Circuit held that it had jurisdiction to review the remand orders because the district court’s remand was not based on a lack of subject matter jurisdiction or a defect in removal procedure. The Ninth Circuit affirmed the district court’s conclusion that the remaining state law claims were not preempted by § 301, as they arose from California statutes rather than the CBAs and did not require interpretation of the CBAs. The court also held that the district court did not abuse its discretion in remanding the non-preempted claims to state court. The judgment was affirmed. View "RENTERIA-HINOJOSA V. SUNSWEET GROWERS, INC." on Justia Law

Anthony Schmitt, a Christian volunteer, taught a program called “The Quest for Authentic Manhood” at the Minnesota Correctional Facility from 2012 until 2020, when all religious programming was suspended due to the COVID-19 pandemic. The Quest program, which is based on biblical teachings about manhood, was popular among inmates and had been offered voluntarily. In 2023, after religious programming resumed, the Minnesota Department of Corrections (MDOC) decided to discontinue Quest, citing concerns that its content conflicted with the department’s diversity, equity, and inclusivity values. The MDOC specifically objected to the program’s biblical perspective on masculinity, its treatment of sexual orientation, and its portrayal of gender roles.Schmitt filed suit in the United States District Court for the District of Minnesota, alleging that the MDOC’s decision violated his First Amendment rights to free speech and free exercise of religion, and constituted a denominational preference in violation of the Establishment Clause. He sought a preliminary injunction to reinstate the Quest program. The district court denied the motion, applying the standard from Turner v. Safley, and found that the MDOC’s decision was rationally related to legitimate penological interests, was neutral, and did not violate Schmitt’s constitutional rights.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the denial of the preliminary injunction. The court held that, even assuming the Turner standard applied, the MDOC’s action was not neutral because it targeted Schmitt’s religious viewpoint. The court found that Schmitt was likely to succeed on the merits of his First Amendment claims and that the other factors for a preliminary injunction also favored him. The Eighth Circuit reversed the district court’s denial of the preliminary injunction and remanded with instructions to reinstate the Quest program pending further proceedings. View "Schmitt v. Rebertus" on Justia Law

A child was born in 2012 to Kendra and Christopher, but due to concerns about Kendra’s fitness as a parent, the child was placed with her paternal grandmother, Denise, and Denise’s long-term partner, David Lemaster, under a Cabinet safety plan. Denise was later granted permanent custody of the child, and the child lived with Denise and Lemaster for her entire life. Kendra, the child’s mother, was initially denied visitation but later received supervised and then unsupervised visitation. Denise and Lemaster jointly raised and financially supported the child, functioning as a family unit. In 2022, Denise died, and Lemaster sought to intervene in the ongoing custody case, claiming de facto custodian status and seeking custody or visitation.The Greenup Family Court granted emergency custody to Kendra and, without holding an evidentiary hearing, later awarded her full custody, denying Lemaster’s motion to intervene as untimely and finding he could not qualify as a de facto custodian. Lemaster’s motion to alter or amend was denied. On appeal, the Kentucky Court of Appeals affirmed, holding that Lemaster’s intervention was untimely and that he could not be a de facto custodian since he co-parented with Denise, the legal custodian.The Supreme Court of Kentucky reversed and remanded. It held that Lemaster had standing to intervene as a “person acting as a parent” under the Uniform Child Custody Jurisdiction and Enforcement Act and had sufficiently alleged a basis for de facto custodian status, even though he was not married to Denise. The Court found that Lemaster’s motion to intervene, filed two days after Denise’s death, was timely, as his interest was previously protected by Denise. The Court ordered the family court to allow Lemaster to intervene and to hold an evidentiary hearing to determine his status as a de facto custodian. View "LEMASTER V. STILTNER" on Justia Law

A mobilehome park owner challenged the constitutionality of a California statute that limits annual rent increases for certain mobilehome parks located within the jurisdictions of two or more incorporated cities. The owner argued that the statute is facially unconstitutional because it lacks a procedural mechanism allowing property owners to seek rent increases above the statutory cap to ensure a fair return, which the owner claimed is required by the California and U.S. Constitutions. The owner asserted that the absence of such a mechanism results in a violation of due process, equal protection, and the prohibition against uncompensated takings.The Superior Court of Orange County granted the owner’s motion for judgment on the pleadings, finding that the statute’s failure to provide a process for seeking exceptions to the rent cap violated due process and rendered the statute unconstitutional. The court rejected the owner’s takings argument but concluded that the legal issue was dispositive and denied the State’s request for leave to amend its answer. Judgment was entered in favor of the owner, and the State appealed.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The appellate court held that the owner failed to establish that the statute is facially unconstitutional, as the relevant legal precedents do not require a fair return adjustment mechanism in every rent control law. The court also found that the State’s general denial in its answer placed the owner’s standing at issue, precluding judgment on the pleadings. The court reversed the judgment of the trial court, holding that the absence of a fair return adjustment mechanism does not, by itself, render the statute facially unconstitutional, and that the State’s answer raised material issues that should have prevented judgment on the pleadings. View "Anaheim Mobile Estates v. State" on Justia Law

Two minor plaintiffs attended a four-day overnight science camp operated by a private entity and organized by their public school district. After returning home, they and their parents alleged that, during the camp, they were exposed to discussions and lessons about gender identity, including being introduced to counselors who used “they/them” pronouns and being asked to state their own preferred pronouns. The plaintiffs also claimed they were not allowed to contact their parents to discuss these matters due to a camp policy prohibiting calls home. They asserted that these experiences caused them severe emotional distress and initiated professional therapy.The plaintiffs filed suit in the Superior Court of Orange County, asserting claims for intentional infliction of emotional distress (IIED) and negligent infliction of emotional distress (NIED) against both the camp operator and the school district. The camp operator responded with a special motion to strike under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16), arguing that the claims arose from protected speech on matters of public interest—specifically, gender identity discussions. The trial court denied the anti-SLAPP motion, finding that the claims were not based on protected activity but rather on the lack of disclosure to parents and the prohibition on contacting them. The court also denied the plaintiffs’ request for attorney fees, finding the anti-SLAPP motion was not frivolous.On appeal, the California Court of Appeal, Fourth Appellate District, Division Three, held that the trial court erred in denying the anti-SLAPP motion in its entirety. The appellate court found that the IIED and NIED claims, to the extent they were based on exposure to gender identity discussions, arose from protected activity and lacked minimal merit, both factually and legally, under California public policy. However, claims based solely on the prohibition of calls home or sleeping arrangements did not arise from protected activity and could proceed. The order was affirmed in part, reversed in part, and remanded with directions. View "Sandoval v. Pali Institute" on Justia Law

A property owner purchased a lot in a Wyoming subdivision governed by two homeowners’ associations, each enforcing its own set of covenants. The owner sought to demolish an existing structure and build a new residence with an attached hangar, submitting construction plans for approval as required. Disputes arose over whether his application was complete and whether the associations unreasonably delayed or withheld approval, resulting in increased construction costs due to inflation. Complicating matters, one association (AVR I) had been dissolved years earlier, but its board continued to act as if it existed, later forming a new entity (AVR II) that purported to enforce covenants recorded after AVR I’s dissolution but before AVR II’s formal creation.The property owner initially sued AVR I, believing it to be the proper party, and later sued the other association, AAA. During discovery, he learned that AVR I had been defunct and that AVR II was the actual entity acting as the homeowners’ association. He moved to amend his complaint to add AVR II and assert new claims, including that the covenants were invalid. The District Court of Lincoln County denied the motion to amend, finding the amendments would be futile, and granted summary judgment to AVR I, reasoning that the covenants automatically approved the owner’s plans by default and any delay was self-imposed.The Supreme Court of Wyoming reviewed the case and held that the district court abused its discretion in denying leave to amend the complaint. The Supreme Court found that the proposed claims against AVR II were not futile, as there were unresolved factual and legal questions regarding the validity and enforceability of the covenants and AVR II’s authority. The court also held that summary judgment for AVR I was premature. The orders denying amendment and granting summary judgment were reversed, and the case was remanded for further proceedings. View "Conger v. AVR Homeowner's Association, Inc." on Justia Law

Several individuals with developmental disabilities, along with Disability Rights New York (DRNY), an advocacy organization, alleged that New York State agencies responsible for services to people with developmental disabilities caused them to remain in restrictive institutional settings for extended periods, despite being eligible for community-based residential placements. The individual plaintiffs claimed they waited from nine months to six years for such placements, resulting in physical and psychological harm. DRNY, as the state’s designated Protection and Advocacy System, joined the suit, asserting authority to represent the interests of individuals with disabilities under federal law.The United States District Court for the Southern District of New York first addressed the defendants’ motion to dismiss DRNY’s claims for lack of standing, agreeing that DRNY had not suffered an injury in fact and rejecting its argument that federal statutes conferred “congressionally authorized representational standing.” The district court also dismissed the individual plaintiffs’ claims as moot, based on pre-motion letters from the defendants indicating that all individual plaintiffs had since been moved out of institutional facilities. Additionally, the court denied a motion by other individuals seeking to intervene as plaintiffs, finding the motion untimely.On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court’s dismissal of DRNY’s claims, holding that DRNY lacked standing because it had not suffered a concrete injury and that Congress could not override Article III’s standing requirements by statute. The Second Circuit also affirmed the denial of the motion to intervene, finding no abuse of discretion in the district court’s timeliness determination. However, the Second Circuit vacated the dismissal of the individual plaintiffs’ claims as moot, holding that the district court erred by dismissing those claims based solely on pre-motion letters without full briefing or a hearing. The case was remanded for further proceedings on the individual plaintiffs’ claims. View "A.H. v. N.Y. State Dep't of Health" on Justia Law

Two drivers, McGee and Hudgins, were involved in a road-rage incident that ended with McGee crashing into Green’s vehicle, causing her injuries. Green and her husband sued both drivers. Before filing suit, Green received $100,000 from McGee’s insurer in exchange for a covenant not to execute judgment against McGee. Green’s underinsured motorist (UIM) carrier, Progressive, defended the suit in McGee’s name. The jury found McGee 60% at fault and Hudgins 40% at fault, and determined both acted recklessly, willfully, and wantonly. The jury awarded Green $88,546.78 in actual damages and $35,000 in punitive damages against each defendant.The Circuit Court for Spartanburg County combined the actual and punitive damages for a total of $158,546.78, subtracted the $100,000 payment from McGee’s insurer, and allocated the remaining $58,546.78 between McGee and Hudgins based on their respective percentages of fault. On appeal, the South Carolina Court of Appeals altered the setoff calculation, allocating the $100,000 payment first to McGee’s share, then applying any remainder to Hudgins’ share, resulting in a net judgment of $58,546.78 against Hudgins and $0 against McGee.The Supreme Court of South Carolina reviewed the setoff calculation. It held that, because the jury found both defendants acted recklessly, willfully, and wantonly, joint and several liability applied to the actual damages, making the percentage allocation of fault irrelevant. The court further held that the $100,000 payment could only be set off against the actual damages, not the punitive damages, as punitive damages are not for the “same injury.” The court reversed the Court of Appeals, holding Green is entitled to a net judgment of $23,546.78 against McGee and $35,000 against Hudgins, and remanded for entry of judgment in those amounts. View "Green v. McGee" on Justia Law

Kevin Rhodes, a former employee of the Missouri Highways and Transportation Commission, was terminated in December 2019 following an investigation into allegations of workplace misconduct, including the use of a racial slur. Rhodes filed grievances about his treatment during the investigation and, after his termination, brought charges of discrimination with the Missouri Commission on Human Rights. He subsequently received notices of right to sue and filed a lawsuit in circuit court alleging sex discrimination, retaliation, and hostile work environment under the Missouri Human Rights Act.A jury in the Circuit Court of Jackson County found in favor of the commission on the sex discrimination claim but ruled for Rhodes on his retaliation and hostile work environment claims, awarding him various damages. The circuit court applied a statutory damages cap and entered judgment accordingly. The commission moved for judgment notwithstanding the verdict, which the circuit court denied. Both parties appealed: Rhodes challenged the constitutionality of the damages cap, while the commission argued that Rhodes had not made a submissible case. The case was transferred to the Supreme Court of Missouri due to the constitutional issues raised.The Supreme Court of Missouri determined that the circuit court’s judgment was not final because it failed to address Rhodes’s requests for equitable relief and prejudgment interest. The court explained that a final judgment must dispose of all claims and forms of relief sought. Because the judgment did not resolve all aspects of Rhodes’s claims, the Supreme Court of Missouri dismissed the appeal for lack of a final judgment, declining to address the merits of the parties’ arguments. View "Rhodes v. Missouri Highways and Transportation Commission" on Justia Law