Justia Civil Procedure Opinion Summaries

This case involves a dispute between siblings Elizabeth and Jason Carter, who are both licensed dentists and co-owners of Carter Dental. In 2020, Jason accused Elizabeth of misusing the practice’s funds for her personal benefit. The parties agreed to mediation, which resulted in a settlement agreement that included a noncompete clause. Elizabeth later refused to sign a written mutual release, leading Jason to move to enforce the settlement agreement. The district court found the settlement agreement and noncompete clause enforceable and dismissed the case with prejudice. Elizabeth appealed, arguing that the noncompete clause and the settlement agreement were unenforceable.The Supreme Court of the State of Idaho affirmed the district court's judgments. The court found that Elizabeth was estopped from arguing that the settlement agreement was unenforceable because she had not appealed the district court’s dismissal of the case with prejudice. The court also held that the district court did not err in awarding attorney fees and costs to Jason and Carter Dental. The court concluded that Jason and Carter Dental were entitled to attorney fees and costs on appeal. View "Carter Dental v. Carter" on Justia Law

In a case involving the Pennsylvania Liquor Control Board (PLCB), the Supreme Court of Pennsylvania was asked to determine whether the PLCB is a "person" under Section 8303 of the Judicial Code and, if so, whether sovereign immunity bars mandamus damages sought under that provision. The case arose from the PLCB's failure to implement procedures to facilitate the direct shipment of special orders to customers, as required by law. The Commonwealth Court had issued a declaratory judgment to that effect and a writ of mandamus compelling the PLCB to comply. The Wine Vendors and Log Cabin subsequently applied for mandamus damages under Section 8303, which the PLCB contested, arguing that it was not a "person" under the statute and that sovereign immunity barred such damages.The Supreme Court of Pennsylvania held that the PLCB is a "person" within the meaning of Section 8303 and that sovereign immunity does not bar mandamus damages available under that provision. The court also held that attorneys’ fees awarded in relation to Section 8303 are not barred by sovereign immunity. The court affirmed the holdings of the Commonwealth Court and remanded for further proceedings. View "MFW WINE CO., LLC v. PENNSYLVANIA LIQUOR CONTROL BOARD" on Justia Law

In June 2020, a fire broke out at a warehouse in Fort Wayne, Indiana. Richard Dolsen, a professional firefighter, responded to the scene. While navigating through the smoke-filled, dark warehouse, Dolsen fell through an unguarded opening above a basement stairwell, sustaining injuries to his neck and right arm. The warehouse was owned by Sweet Real Estate – City Center, LLC, and leased to VeoRide, Inc., which stored electric scooters and other equipment on the premises. Dolsen sued both companies, alleging negligence in failing to fix the wall opening and in failing to warn the fire department of the hazard.The trial court granted summary judgment in favor of VeoRide and Sweet, holding that Dolsen's claims were barred under the firefighter's rule, which limits a firefighter's ability to recover damages for injuries sustained while responding to a fire. Dolsen appealed the ruling only as to VeoRide, and the court of appeals reversed the trial court's decision, holding that the firefighter's rule did not bar Dolsen's claim against VeoRide.The Indiana Supreme Court granted VeoRide's petition to transfer the case. The court clarified that the firefighter's rule and the first-responder's rule are two separate doctrines. The firefighter's rule applies only to firefighters and prescribes the duty owed for a premises-liability claim arising when a firefighter enters premises to extinguish a fire. The first-responder's rule limits the duty owed to all first responders during an emergency.In this case, the court held that the first-responder's rule did not bar Dolsen's claim as he did not allege that the negligence that caused his injuries also caused the fire. As for the firefighter's rule, the court found that disputed factual issues remained on whether VeoRide breached its duty to Dolsen. Therefore, the court reversed the trial court's entry of summary judgment for VeoRide and remanded the case for further proceedings. View "Dolsen v. Veoride, Inc." on Justia Law

The case involves a dispute over the Town of Bar Harbor's decision to present several proposed changes to its municipal charter as separate questions to voters, rather than as a single package. The changes were recommended by a charter commission and included modifications to various areas of the town's governance. A group of voters, led by Michael Good, challenged this approach, arguing that the changes were not "minor modifications" and should have been presented as a single "revision" of the charter.The Superior Court (Hancock County, Anderson, J.) agreed with Good and nullified the changes, ruling that they were not minor modifications and should have been presented as a single revision. The court also found procedural irregularities in how the changes were developed and submitted.On appeal, the Maine Supreme Judicial Court disagreed with the lower court's interpretation. The court held that the charter commission acted legally in determining that its recommendations constituted minor modifications and proposing that they be submitted to the voters in nine separate articles. The court also found that none of the claimed procedural irregularities nullified the vote. Therefore, the court vacated the lower court's judgment and remanded the case for the court to enter a judgment for the Town on Good’s complaint. View "Good v. Town of Bar Harbor" on Justia Law

In this case, a couple, Joseph R. and his wife, sought to adopt the wife's two minor children and terminate the parental rights of the children's biological father. The mother had been granted sole parental rights and responsibilities in a 2016 divorce judgment, and the biological father, who resides in Scotland, had not had contact with the children or the mother since the divorce. The couple married in 2017 and filed their petitions for adoption, change of name, and termination of parental rights in the York County Probate Court in April 2023.The York County Probate Court dismissed the couple's petitions, concluding that it lacked subject matter jurisdiction due to recent legislative changes. Specifically, the court cited the enactment of 19-A M.R.S. § 1658(1-A) in 2021, which it interpreted as giving exclusive jurisdiction to the District Court in cases involving one parent's attempt to terminate another parent's parental rights to a minor child. The couple appealed this decision.The Maine Supreme Judicial Court disagreed with the lower court's interpretation of the statute. The court noted that the Probate Court has exclusive jurisdiction over petitions for adoption and termination of parental rights proceedings brought pursuant to section 9-204. The court found that the language in section 1658(1-A) does not divest the Probate Court of subject matter jurisdiction in this matter. The court further examined the legislative history of section 1658 and concluded that section 1658(1-A) applies only to termination petitions brought pursuant to 19-A M.R.S. § 1658 and does not divest the Probate Court of its subject matter jurisdiction over termination petitions filed in conjunction with adoption proceedings under 18-C M.R.S. § 9-103. Therefore, the court vacated the judgment and remanded the case for further proceedings. View "Adoption by Joseph R." on Justia Law

The case revolves around a medical malpractice and hospital negligence claim filed by Jami Lynn Golden against Floyd Healthcare Management, Inc. Golden visited Floyd Emergency Care Center in July 2016, complaining of abdominal pain, fever, chills, and nausea. Despite a computer-generated sepsis alert, Golden was discharged with instructions to follow up in two to three days. Her condition worsened, and she was later admitted to Redmond Regional Medical Center Intensive Care Unit in septic shock. As a result, Golden suffered necrosis that required the amputation of parts of her fingers and toes.Floyd Healthcare Management moved to dismiss Golden's claim, arguing that the five-year medical malpractice statute of repose had expired. The trial court denied the motion, concluding that the repose statute was tolled by the "Order Declaring Statewide Judicial Emergency" issued in response to the COVID-19 pandemic. However, the Court of Appeals reversed this decision, holding that the repose statute was not tolled by the emergency order.The Supreme Court of Georgia reversed the Court of Appeals' decision. It held that the emergency order did indeed toll the repose statute, and that there was no impediment in the federal or Georgia Constitutions for the statute of repose to be tolled. The court concluded that Golden's claims were not time-barred, and that the application of the emergency order to toll the repose statute did not violate Floyd Healthcare Management's due process rights. View "GOLDEN v. FLOYD HEALTHCARE MANAGEMENT, INC." on Justia Law

A group of plaintiffs sued multiple defendants, including white nationalists, white supremacists, and neo-Nazis, for their roles in the violent "Unite the Right" rally in Charlottesville, Virginia, in 2017. The plaintiffs alleged that the defendants conspired to commit racially motivated violence. A jury awarded the plaintiffs over $26 million in damages, including a historic $24 million in punitive damages. However, the district court reduced the punitive damages to $350,000, applying Virginia's punitive damages cap across all plaintiffs.The defendants appealed, challenging the district court's decision to hold them jointly and severally liable for the compensatory damages award. The plaintiffs cross-appealed, challenging the district court's application of Virginia's punitive damages cap.The United States Court of Appeals for the Fourth Circuit affirmed the district court's imposition of joint-and-several liability for the compensatory damages. However, the court held that Virginia's punitive damages cap applies on a per-plaintiff basis, not across all plaintiffs. Therefore, the court vacated the district court's ruling on the punitive damages cap and remanded the case with instructions to apply the cap accordingly. View "Sines v. Hill" on Justia Law

The case revolves around a dispute over attorney's fees in a Social Security disability benefits case. The plaintiff, Christian Arnold, was represented by the law firm Binder & Binder. After Arnold was determined to be disabled and entitled to past-due benefits, the law firm requested attorney's fees under 42 U.S.C. § 406(b), based on a contingency fee agreement Arnold had signed. However, the district court reduced the requested fees by nearly sixty percent, arguing that the full request would result in a "windfall" for the law firm, which was prohibited by statute. Binder & Binder appealed this decision.The case was initially heard by an administrative law judge (ALJ) who concluded that Arnold was not disabled. Arnold appealed this decision to the district court, which remanded the case back to the ALJ. On remand, the ALJ ruled in Arnold's favor, and the Social Security Administration issued a Notice of Award to Arnold for past-due benefits. Binder & Binder then moved for attorney's fees in the district court under 42 U.S.C. § 406(b), based on their contingency fee agreement with Arnold. The district court, however, reduced the requested fees.The United States Court of Appeals for the Seventh Circuit reviewed the case and concluded that the district court had abused its discretion by not basing its analysis primarily on the contingency agreement before considering the reasonableness of the request. The Court of Appeals vacated the district court's decision and remanded the case for further proceedings consistent with its opinion. The court emphasized that the contingency fee agreement should be the starting point for determining reasonableness under § 406(b), and any reduction should be justified based on relevant factors such as the claimant's satisfaction with their attorney's representation, the attorney's expertise and efforts expended, and the uncertainty of recovery and risks of an adverse outcome. View "Arnold v. O'Malley" on Justia Law

This case involves a trademark infringement dispute between BillFloat Inc., a Delaware corporation using the "SmartBiz" trademark, and Collins Cash Inc., a New York corporation using the "Smart Business Funding" mark. BillFloat alleged that Collins Cash, its former business partner, infringed on its trademark.The case was initially heard in the United States District Court for the Northern District of California. The district court admitted Collins Cash's likelihood-of-confusion survey as expert evidence under Federal Rule of Evidence 702. After a jury trial, the court ruled in favor of Collins Cash, finding no likelihood of confusion between the marks. The district court also partially denied Collins Cash's motion for attorneys' fees.The case was then appealed to the United States Court of Appeals for the Ninth Circuit. The appellate court affirmed the district court's judgment. It held that the district court did not abuse its discretion in admitting Collins Cash's likelihood-of-confusion survey as expert evidence. The court also held that the district court did not abuse its discretion in declining to instruct the jury that it should not draw any inferences from BillFloat's lack of a similar survey. On cross-appeal, the appellate court held that the district court did not abuse its discretion in denying Collins Cash's motion for attorneys' fees for the trademark infringement claim, either under the parties' partnership agreement or under the Lanham Act. The court concluded that the trademark claim did not relate to the partnership agreement, and the case was not "exceptional" under the Lanham Act. View "BILLFLOAT INC. V. COLLINS CASH INC." on Justia Law

The case involves William Rios, a part-time security guard for Centerra Group LLC, who was fired after being found asleep at his post. Rios, who has diabetes, sued Centerra alleging violations of the Americans with Disabilities Act (ADA). He claimed that he had an episode of hypoglycemic shock which caused him to fall asleep on the job, and thus, Centerra should have accommodated his disability. However, Rios did not present any evidence that Centerra knew about his hypoglycemic episode when it fired him.The district court granted summary judgment to Centerra on all claims. Rios appealed, challenging the district court's decisions on his ADA discrimination claim, ADA claim for failure to provide a reasonable accommodation, ADA claim for hostile work environment, ADA claim for retaliation, and the denial of his Federal Rule of Civil Procedure 56(d) motion seeking additional discovery to respond to the motion for summary judgment.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that Rios failed to present evidence from which a reasonable jury could find that Centerra held a discriminatory animus toward him based on his disability. The court also found that Rios failed to provide any evidence of discriminatory animus that would allow a reasonable jury to infer that Centerra's reasons for firing Rios were pretextual. The court further held that the district court did not abuse its discretion in denying Rios's Rule 56(d) motion given his failure to show good cause or due diligence in pursuing discovery for information regarding similarly situated employees. View "Sheridan v. Centerra Group, LLC" on Justia Law