Justia Civil Procedure Opinion Summaries

Carol Lewis and Douglas Sargent, both diabetics and Medicare beneficiaries, sought reimbursement for continuous glucose monitors and related supplies from 2015 to 2017. After the Department of Health and Human Services (HHS) denied their claims, they pursued judicial review and sought to represent a class of individuals with similar claims. The district court denied their motion for class certification, noting that most putative class members had unexhausted or untimely claims. The court concluded that neither waiver of the exhaustion requirement nor equitable tolling of the limitations period was appropriate, reducing the putative class to seventeen individuals, which was too small to meet the numerosity requirement for class certification. After the Centers for Medicare & Medicaid Services (CMS) issued new guidance in 2022, the district court granted partial judgment in favor of Lewis and Sargent, setting aside the denials of their claims and declaring that continuous glucose monitors are durable medical equipment.Lewis and Sargent appealed the denial of class certification to the United States Court of Appeals for the District of Columbia Circuit. They did not challenge the favorable merits judgment but focused solely on the class certification issue. The Court of Appeals, however, dismissed their appeal for lack of constitutional standing. The court held that their desire to serve as class representatives did not create a cognizable Article III interest, as they did not allege any concrete individual injury resulting from the denial of class certification. The court emphasized that an abstract interest in representing a class is insufficient to satisfy the requirements of Article III standing. Consequently, the appeal was dismissed for lack of jurisdiction. View "Lewis v. Becerra" on Justia Law

The Department of Homeland Security (DHS) issued a rule allowing certain H-4 visa holders, who are dependent spouses of H-1B visa holders, to work in the United States. Save Jobs USA challenged this rule, arguing that DHS exceeded its authority under the Immigration and Nationality Act (INA). The INA includes provisions that grant the Secretary of Homeland Security the power to set conditions for nonimmigrants' stay in the U.S. and to establish necessary regulations. DHS relied on these provisions to justify the rule.The United States District Court for the District of Columbia granted summary judgment in favor of DHS, citing the precedent set by the D.C. Circuit in Washington Alliance of Technology Workers v. DHS (Washtech). In Washtech, the court upheld a DHS rule allowing certain foreign students to work in the U.S. based on similar INA provisions. The district court found that Save Jobs USA did not meaningfully distinguish its case from Washtech and thus ruled in favor of DHS.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the INA provisions cited by DHS indeed grant the agency the authority to issue employment-related rules for nonimmigrants. The court noted that Save Jobs USA did not effectively challenge the applicability of the Washtech precedent. Additionally, the court rejected Save Jobs USA's argument that the major questions doctrine should apply, stating that Washtech had already interpreted the relevant statutory provisions post-West Virginia v. EPA. Therefore, the appellate court upheld the district court's summary judgment in favor of DHS. View "Save Jobs USA v. DHS" on Justia Law

David Efron and Madeleine Candelario were involved in a divorce proceeding in Puerto Rico, during which Efron was ordered to pay Candelario $50,000 per month. After the divorce was finalized, Candelario began a relationship with Judge Cordero, and Efron alleges that Candelario, her attorney, and Judges Cordero and Aponte conspired to reinstate the payments through a corrupt scheme. Efron claims this resulted in Candelario receiving approximately $7 million. Efron filed a federal lawsuit against Candelario and her attorney, asserting claims for deprivation of procedural due process, conspiracy to deny civil rights, civil conspiracy, and unjust enrichment.The United States District Court for the Southern District of Florida dismissed Efron’s complaint for lack of subject matter jurisdiction, citing the Rooker-Feldman doctrine. The court found that Efron’s claims were inextricably intertwined with the Puerto Rico court’s judgment and that granting relief would effectively nullify that judgment. The district court also rejected Efron’s argument that his claims fell under a fraud exception to the Rooker-Feldman doctrine.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s dismissal. The Eleventh Circuit held that the Rooker-Feldman doctrine barred Efron’s claims because they essentially sought to challenge the state court’s judgment. The court concluded that Efron’s claims for damages were not independent of the state court’s decision but were directly related to it, as they required the federal court to review and reject the state court’s judgment. Therefore, the district court correctly dismissed the complaint for lack of subject matter jurisdiction. View "Efron v. Candelario" on Justia Law

The case involves Edgar Reyes-Colón, who was subjected to an involuntary Chapter 11 bankruptcy petition filed by Banco Popular de Puerto Rico in 2006. The bankruptcy court dismissed the petition in 2016, finding that Banco Popular failed to join the requisite number of creditors. Reyes-Colón subsequently filed a motion for attorney's fees and costs under 11 U.S.C. § 303(i)(1) and initiated an adversary proceeding alleging bad faith under 11 U.S.C. § 303(i)(2).The bankruptcy court denied Reyes-Colón's motion for attorney's fees, ruling it lacked subject-matter jurisdiction as the motion was filed after the case was closed. Reyes-Colón appealed to the District Court for the District of Puerto Rico, which affirmed the bankruptcy court's decision, adding that the motion was untimely under local rules requiring such motions to be filed within fourteen days after the issuance of the mandate. Reyes-Colón then appealed to the United States Court of Appeals for the First Circuit.The First Circuit held that the bankruptcy court had jurisdiction over post-dismissal § 303(i) motions, as such motions necessarily require post-dismissal jurisdiction. However, the court affirmed the denial of the attorney's fees motion on the grounds that it was untimely, as it was filed 365 days after the mandate issued, far exceeding the fourteen-day limit set by local rules.Regarding the adversary proceeding, Reyes-Colón filed a motion for withdrawal of reference to have the district court adjudicate the case. The district court denied the motion as untimely, conflating the timeliness of the motion for withdrawal with the timeliness of the § 303(i) motion. The First Circuit vacated this decision, clarifying that the timeliness of the motion for withdrawal should be measured from the filing of the adversary proceeding, not the dismissal of the involuntary petition. The case was remanded for further consideration of whether there is cause to withdraw the reference. View "Reyes-Colon v. Banco Popular de Puerto Rico" on Justia Law

Eric Cohen, experiencing a psychotic episode, attacked his girlfriend and fled into the cold waters of Portland's Back Cove, where he eventually drowned from hypothermia. His estate sued the City of Portland and several members of its police and fire departments, alleging violations of Cohen's substantive due process rights due to a failure to rescue him from a state-created danger and inadequate crisis intervention training.The United States District Court for the District of Maine dismissed the state-created danger claims against two police officers, Sergeants Christopher Gervais and Michael Rand, under Federal Rule of Civil Procedure 12(b)(6). The court found that the officers' actions did not create or enhance the danger to Cohen. After discovery, the court granted summary judgment to a firefighter, Ronald Giroux, and the City of Portland. The court concluded that Giroux's actions did not cause Cohen's death and that the City could not be held liable for failure to train its employees since no individual defendant was found to have violated Cohen's constitutional rights.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's rulings. The appellate court held that neither Gervais nor Rand's actions constituted an affirmative act that created or enhanced the danger to Cohen. The court also found that Giroux's threat did not factually or legally cause Cohen's death. Finally, the court affirmed the summary judgment in favor of the City of Portland, as there was no predicate constitutional violation by any individual defendant to support a failure-to-train claim. View "Cohen v. City of Portland" on Justia Law

The case involves Michelle Gilbank, who lost custody of her daughter, T.E.H., in state court proceedings in Wisconsin. Gilbank alleged that various officials involved in those proceedings violated her federal constitutional rights. The events began when Gilbank, who had a history of drug use, moved into her ex-partner Ian Hoyle's apartment. Following an anonymous tip, police and social workers investigated and found evidence of Gilbank's drug use. On August 21, 2018, Gilbank was arrested for drug possession, and her daughter was temporarily placed with Hoyle. Subsequent state court hearings resulted in the continued placement of T.E.H. with Hoyle until Gilbank regained custody in March 2020.In the United States District Court for the Western District of Wisconsin, the court granted summary judgment for the defendants. The court found that some of Gilbank’s claims were barred by the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court also ruled that the remaining claims failed on the merits, including claims of unreasonable search, denial of due process, and unlawful eviction.The United States Court of Appeals for the Seventh Circuit reviewed the case en banc. The court affirmed the district court's judgment, agreeing that the Rooker-Feldman doctrine barred claims based on injuries caused by state court judgments. The court also affirmed summary judgment on the merits for claims not barred by Rooker-Feldman, including those related to the urinalysis, interrogation without an attorney, and the removal of T.E.H. The court found that Gilbank had consented to the urinalysis, that her Fifth Amendment rights were not violated as her statements were not used in a criminal proceeding, and that there was no seizure of T.E.H. by government actors. The court also rejected the existence of a "fraud exception" to the Rooker-Feldman doctrine. View "Gilbank v. Wood County Department of Human Services" on Justia Law

In August 2019, Eric Toon led Lieutenant Christopher Zerkle on a high-speed chase before returning to his home, where his girlfriend, Taylor Quinn, was sleeping. Zerkle and other officers, including Sergeants Paxton Lively and Rick Keglor, and Deputies Brandon Kay and Jamie Miller, arrived at Toon’s residence. The officers knocked on the door, which eventually opened outward, leading them to enter the home. Toon then broke a window, jumped out with an AR-15, and was fatally shot by Zerkle and another officer. Quinn, who followed Toon out of the window, was also injured.The United States District Court for the Southern District of West Virginia dismissed some claims and granted summary judgment in favor of the officers on the remaining claims. The court found that the officers reasonably believed they had consent to enter the home when the door opened and that Zerkle’s use of deadly force against Toon was justified. The court also concluded that Quinn’s injuries were accidental and not the result of intentional excessive force.The United States Court of Appeals for the Fourth Circuit reviewed the case and found that factual disputes precluded summary judgment on the warrantless entry claims and Quinn’s excessive force, battery, and trespass claims. The court held that the officers could not assume consent to enter the home merely because the door opened. The court also determined that there was sufficient evidence for a jury to find that Zerkle intentionally shot Quinn. The court affirmed the district court’s decision on the remaining claims, including the excessive force claim related to Toon and the failure to intervene claim against Zerkle. The case was reversed in part, affirmed in part, and remanded for further proceedings. View "Quinn v. Zerkle" on Justia Law

In response to the COVID-19 pandemic, the Governor of Delaware issued a series of emergency orders that included restrictions on religious services. These restrictions, which were lifted by June 2020, limited in-person worship to ten people and imposed various other mandates. Over 18 months later, two religious leaders filed suit in the Court of Chancery seeking injunctive relief against these restrictions, which were no longer in effect. The Court of Chancery dismissed the case for lack of subject matter jurisdiction, concluding that the plaintiffs could not demonstrate a reasonable apprehension of future harm.The plaintiffs then transferred their action to the Superior Court, seeking declaratory judgment and damages for alleged violations of their constitutional rights. The Superior Court dismissed the claims, ruling that the requests for declaratory relief were not justiciable because the restrictions had been lifted and there was no ongoing controversy. Additionally, the court found that the Governor was immune from the damages claims under the State Tort Claims Act and the doctrine of qualified immunity.On appeal, the Delaware Supreme Court affirmed the lower courts' decisions. The Court agreed that the plaintiffs failed to show a reasonable apprehension of future harm, which is necessary for injunctive relief. The Court also held that the plaintiffs' claims for declaratory judgment were not justiciable because there was no ongoing controversy and the alleged harm could not be redressed by a declaratory judgment. Finally, the Court upheld the Superior Court's finding that the Governor was immune from damages claims, as his actions were discretionary and taken in good faith during an unprecedented public health crisis. View "In re Covid-Related Restrictions on Religious Services" on Justia Law

Bilal Hankins, a passenger in a car with two other youths, was driving slowly at night looking for a neighbor’s lost dog. Hankins asked Officer Kevin Wheeler, who was on patrol for a local private security district, for assistance in finding the dog. Later, Officer Wheeler and another officer, Officer Ramon Pierre, stopped the car without reasonable suspicion and approached it with guns drawn. Hankins brought claims under Sections 1983 for unreasonable seizure, excessive force, constitutional conspiracy, supervisory liability, and Monell claims, along with related state-law claims.The United States District Court for the Eastern District of Louisiana limited discovery to the issue of qualified immunity. The district court concluded that there was no question of material fact as to whether there was an underlying constitutional violation of either Hankins’ right to be free from an unlawful seizure or his right to be free from excessive, unlawful force. Consequently, the district court granted summary judgment to the defendants on all federal claims, as each federal claim relied on an underlying constitutional violation. The court also declined supplemental jurisdiction over the state-law claims and dismissed those without prejudice.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that material fact disputes precluded summary judgment on the seizure claim. The court held that the factors relied upon by the district court, such as the car’s registration information, the time of night, and the car driving slowly, did not amount to reasonable suspicion when considered in the totality of the circumstances. The court also noted that Hankins’ testimony that Officer Wheeler said, “you know, three young men, in a nice car, in this neighborhood,” if credited, would undermine the officers’ justification for the stop. The Fifth Circuit reversed the summary judgment on the seizure claim, vacated the summary judgment on the other federal claims, and remanded for further proceedings. View "Hankins v. Wheeler" on Justia Law

The case involves three Lyft drivers, Tina Turrieta, Brandon Olson, and Million Seifu, who each filed separate lawsuits under the California Labor Code Private Attorneys General Act of 2004 (PAGA) against Lyft, Inc. for alleged labor violations. Turrieta settled her case with Lyft, but before the settlement was approved, Olson and Seifu sought to intervene and object to the settlement, arguing it was unfair and that they had overlapping claims. The trial court denied their motions to intervene, approved the settlement, and later denied their motions to vacate the judgment.Olson and Seifu appealed the trial court's decisions. The Court of Appeal affirmed the trial court's rulings, holding that Olson and Seifu lacked standing to intervene or to challenge the settlement because they were not aggrieved by the judgment. The appellate court reasoned that PAGA actions are representative actions on behalf of the state, and thus, Olson and Seifu did not have a personal interest in the settlement of Turrieta’s PAGA claim.The California Supreme Court reviewed the case and agreed with the Court of Appeal. The Supreme Court held that PAGA does not authorize one aggrieved employee to intervene in another employee’s PAGA action asserting overlapping claims. The Court reasoned that allowing such intervention would be inconsistent with the statutory scheme of PAGA, which provides for oversight of settlements by the Labor and Workforce Development Agency (LWDA) and the courts, but does not mention intervention by other PAGA plaintiffs. The Court emphasized that the statutory language and legislative history indicate that the Legislature intended for the LWDA and the courts to ensure the fairness of PAGA settlements, not other PAGA plaintiffs.The Supreme Court affirmed the judgment of the Court of Appeal, concluding that Olson and Seifu did not have the right to intervene, object to, or move to vacate the judgment in Turrieta’s PAGA action. View "Turrieta v. Lyft, Inc." on Justia Law