Justia Civil Procedure Opinion Summaries

Two individuals applied for jobs at a retail liquor store chain in Washington after a new state law required employers to include wage and benefit information in all job postings. Both applicants submitted their applications through a third-party website, Indeed.com, where the postings did not include the required pay information. One of the applicants also interviewed in person and discussed pay with the store manager but ultimately declined a job offer. Both individuals then filed a class action lawsuit, seeking statutory damages for the employer’s failure to comply with the disclosure requirements.The case was initially brought in King County, Washington. The employer argued that the plaintiffs were not the type of “job applicants” the law was intended to protect, asserting that only those with a genuine or “bona fide” interest in the job should be eligible for remedies. The parties disagreed on the meaning of “job applicant” under the Washington Equal Pay and Opportunities Act (EPOA). The United States District Court for the Western District of Washington, faced with this dispute, certified a question to the Washington Supreme Court, asking what a plaintiff must prove to be considered a “job applicant” under the statute.The Supreme Court of the State of Washington held that, under RCW 49.58.110(4), a person qualifies as a “job applicant” if they apply to a specific job posting, regardless of their subjective intent or whether they are a “bona fide” or “good faith” applicant. The court concluded that the plain language of the statute does not require proof of genuine interest in the position, and that the legislature intentionally omitted such a requirement. The court’s answer clarified that subjective intent is irrelevant for eligibility to seek remedies under the EPOA. View "Branson v. Washington Fine Wine & Spirits, LLC" on Justia Law

The appellant alleged that, after attending Long Island University and New York University and repaying her student loans, her name was fraudulently used in 1993 to certify additional federal student loans without her consent. She claimed that the universities signed her name on false loan applications, withheld refunds, and that the United States Department of Education attempted to collect on these fraudulent loans through debt collectors who used unlawful practices. The Department of Education ultimately garnished her tax refund and threatened to garnish her Social Security checks. The appellant filed suit against the Department of Education, the universities, the debt collectors, and others.The United States District Court for the District of Columbia dismissed the claims against the universities and debt collectors for lack of personal jurisdiction, relying on the government-contacts exception. The court dismissed claims against other defendants on different grounds. On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the dismissal of the other defendants but, regarding the dismissal based on the government-contacts exception, certified questions to the District of Columbia Court of Appeals about the scope of that exception under District law.The District of Columbia Court of Appeals held that, under the District’s long-arm statute, the government-contacts exception to personal jurisdiction applies only if a defendant can establish that asserting jurisdiction based on the conduct at issue would violate the First Amendment. The court clarified that its prior decision in Rose v. Silver is binding and limits the exception to circumstances implicating First Amendment rights, even if this interpretation is arguably in tension with an earlier case, Environmental Research International, Inc. v. Lockwood Greene Engineers, Inc. The court declined to address whether the contacts alleged in this case fell within the exception, as that would depend on a First Amendment analysis. View "N'Jai v. U.S. Department of Education" on Justia Law

A dispute arose between two companies, one a contractor and the other a developer, over a construction project in Maui. The disagreement was submitted to binding arbitration, resulting in an award in favor of the developer. The developer sought to confirm the award in the Circuit Court of the First Circuit, but the contractor challenged the award, alleging the arbitrator was evidently partial due to undisclosed relationships. The circuit court initially confirmed the award, but on appeal, the Supreme Court of Hawai‘i remanded the case for an evidentiary hearing on the partiality claim. After the hearing, the circuit court found evident partiality, denied confirmation, vacated the award, and ordered a rehearing before a new arbitrator.Following this, the contractor moved for taxation of costs incurred on appeal, which the circuit court granted. The developer sought to appeal the costs order, but the circuit court denied an interlocutory appeal. A new arbitration was held, again resulting in an award for the developer, which was confirmed in a new special proceeding with a final judgment entered. The developer then appealed the earlier costs order from the first special proceeding.The Intermediate Court of Appeals (ICA) dismissed the appeal as untimely, reasoning that the circuit court’s order vacating the first arbitration award and ordering a rehearing was an appealable final order under Hawai‘i Revised Statutes (HRS) § 658A-28(a)(3), making the subsequent costs order also immediately appealable.The Supreme Court of Hawai‘i reviewed the case and held that an order vacating an arbitration award and directing a rehearing is not an appealable order under HRS § 658A-28(a). The court clarified that such orders lack finality, regardless of whether the rehearing is full or partial, and reaffirmed the majority rule previously adopted in State of Hawaii Organization of Police Officers (SHOPO) v. County of Kauai. The Supreme Court vacated the ICA’s dismissal and remanded the case for entry of a final judgment, so the merits of the appeal could be addressed. View "Nordic PCL Construction, Inc. v. LPIHGC, LLC" on Justia Law

In May 2022, Garry Douglas Seaman shot and killed James Preston Freeman and seriously wounded Heidi Gabert, following the end of his romantic relationship with Gabert, with whom he shares a minor child. Seaman was criminally charged, and Gabert and Dawn Freeman, James’s spouse, filed a civil suit for damages. To prevent Seaman from transferring or selling assets during the litigation, Gabert and Freeman successfully sought a receivership over all of Seaman’s property. After negotiations, the parties reached a settlement memorialized in a memorandum of understanding (MOU), which included $10 million judgments for Gabert and Freeman, liquidation of Seaman’s assets, and a homestead exemption for Seaman.The Nineteenth Judicial District Court, Lincoln County, approved the creation of a designated settlement fund (DSF) to facilitate asset liquidation. Initially, the court’s DSF Order required the Liquidation Receiver to reserve funds from asset sales to pay Seaman’s capital gains taxes, interpreting the MOU’s tax payment provision as unambiguous. Gabert and Freeman moved to amend this order under Montana Rule of Civil Procedure 59(e), arguing the court erred in its interpretation and that the parties did not intend to reserve funds for Seaman’s capital gains taxes. After an evidentiary hearing, the District Court agreed, finding the MOU ambiguous and, based on extrinsic evidence, concluded the parties did not intend to reserve such funds. The court amended its order, striking the provision requiring reservation for capital gains taxes.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in amending the DSF Order. The Supreme Court held that the District Court did not abuse its discretion, correctly found the MOU ambiguous, and its factual finding regarding the parties’ intent was not clearly erroneous. The Supreme Court affirmed the District Court’s amended order. View "Gabert v. Seaman" on Justia Law

After the death of the previous sheriff, the County Commissioners of Big Horn County appointed Jeramie Middlestead as interim sheriff in November 2023. Middlestead subsequently ran for election to retain the position. Lee A. Bartel filed a complaint in June 2024, alleging that Middlestead was ineligible to serve as sheriff because he was not a resident of, nor registered to vote in, Big Horn County, as required by Montana law. Bartel sought to prevent Middlestead from being sworn in, arguing that his appointment and potential election violated statutory requirements. Despite these allegations, Middlestead won the November 2024 election and was sworn in as sheriff in December 2024.The Twenty-Second Judicial District Court, Big Horn County, presided over by Judge Olivia Rieger after Judge Matthew J. Wald recused himself, considered Bartel’s motion for a preliminary injunction to prevent Middlestead from assuming office. The District Court denied the motion in February 2025, finding that while there were unresolved questions about Middlestead’s qualifications, Bartel had not demonstrated irreparable harm, the equities weighed against granting the injunction since Middlestead had already been sworn in, and that removing the sheriff would not serve the public interest. The court also determined that the statutory standards for granting a preliminary injunction had not been met.The Supreme Court of the State of Montana reviewed the case. It held that the matter was not moot because the District Court retained the authority to provide effective relief, including potentially ordering Middlestead’s removal if he was found ineligible. The Supreme Court further held that the District Court did not abuse its discretion in denying the preliminary injunction, affirming the lower court’s order and remanding the case for further proceedings. View "Bartel v. Middlestead" on Justia Law

Angel A. Perales-Muñoz was hired as a recruiter assistant by Document and Packaging Brokers, Inc. (Docupak), a contractor for the National Guard Bureau, to help recruit individuals for the Army National Guard. The Army Criminal Investigation Division (CID) began investigating possible fraud in the recruiting program, which led to Perales being indicted on multiple federal charges related to conspiracy and fraud. After two years, the government moved to dismiss the charges against Perales, and the indictments were dismissed with prejudice. Perales and his wife subsequently filed administrative claims and then a lawsuit under the Federal Tort Claims Act (FTCA), alleging that the CID’s investigation was negligent and caused them emotional distress.The United States District Court for the District of Puerto Rico reviewed the case. The government moved to dismiss, arguing that the discretionary function exception to the FTCA barred the claims, as the investigation involved policy discretion. The district court ordered limited jurisdictional discovery and referred the matter to a magistrate judge, who found that the CID’s investigation did not violate the Posse Comitatus Act or Army Regulation 195-2. The district court adopted the magistrate’s report and recommendation, dismissing the complaint for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s dismissal de novo. The appellate court held that the discretionary function exception applied because Perales failed to show that the CID’s investigation violated any binding federal law or regulation. The court found no violation of the Posse Comitatus Act or Army Regulation 195-2 and concluded that federal courts lacked jurisdiction over the claims. The judgment of the district court was affirmed. View "Perales-Munoz v. United States" on Justia Law

A religious association that supports abortion as a core tenet challenged Idaho’s laws criminalizing abortion. The organization, which operates a telehealth abortion clinic in New Mexico, alleged that its members in Idaho were harmed by the state’s abortion restrictions. The association claimed that it had members in Idaho who could become involuntarily pregnant and would seek abortions as part of their religious practice, and that it had diverted resources to open its New Mexico clinic in response to Idaho’s and other states’ abortion bans.The United States District Court for the District of Idaho granted the defendants’ motion to dismiss, finding that the association lacked both associational and organizational standing. The district court determined that the association had not identified any specific member in Idaho who was injured or imminently would be injured by the abortion laws, nor had it shown that its organizational activities were directly impeded by the statutes. The district court also addressed the merits of the association’s constitutional claims and dismissed the complaint with prejudice.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal on the grounds of lack of Article III standing. The Ninth Circuit held that the association failed to demonstrate associational standing because it did not identify any member who had suffered or would imminently suffer an injury in Idaho. The court also found no organizational standing, as the association’s diversion of resources to open a clinic in New Mexico and its claim of frustration of mission were insufficient under recent Supreme Court precedent. The Ninth Circuit did not reach the merits of the constitutional claims. The court remanded the case to the district court to determine whether the complaint could be saved by amendment, noting that dismissal for lack of jurisdiction should generally be without prejudice. View "THE SATANIC TEMPLE V. LABRADOR" on Justia Law

The Environmental Protection Agency (EPA) awarded $16 billion in grants to five nonprofit organizations to support the reduction of greenhouse gas emissions, as part of a larger $27 billion congressional appropriation under the Inflation Reduction Act. The grants were structured through agreements between the nonprofits and EPA, with Citibank acting as a financial agent to hold and disburse the funds. After concerns arose regarding conflicts of interest, lack of oversight, and last-minute amendments to the grant agreements, EPA terminated the grants in early 2025. Citibank, following an FBI recommendation, froze the accounts associated with the grants. The nonprofits sued, seeking to prevent the termination and to restore access to the funds.The United States District Court for the District of Columbia granted a preliminary injunction, ordering EPA and Citibank to continue funding the grants. The district court found it had jurisdiction, concluding the plaintiffs’ claims were not essentially contractual and thus did not need to be brought in the Court of Federal Claims. The court determined the plaintiffs were likely to succeed on their constitutional, regulatory, and arbitrary and capricious claims, and that the balance of harms and public interest favored the injunction.On appeal, the United States Court of Appeals for the District of Columbia Circuit held that the district court abused its discretion in issuing the injunction. The appellate court found that the plaintiffs’ regulatory and arbitrary and capricious claims were essentially contractual, meaning jurisdiction lay exclusively in the Court of Federal Claims, not the district court. The court also held that the constitutional claim was meritless. The equities and public interest, the appellate court concluded, favored the government’s need for oversight and management of public funds. Accordingly, the D.C. Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "Climate United Fund v. Citibank, N.A." on Justia Law

An elderly plaintiff with significant disabilities inherited her home and, facing a tax sale due to unpaid property taxes, responded to a flyer offering help. She met with the defendant, who had her sign documents that transferred ownership of her home to him, allegedly under the pretense of providing a loan. The documents did not provide for any payment to the plaintiff, only that the defendant would pay the back taxes. The plaintiff later attempted to cancel the transaction, believing it had been voided when the defendant returned her documents and she received no loan. Several years later, the defendant served her with an eviction notice, prompting her to file suit alleging fraud, undue influence, financial elder abuse, and other claims, seeking cancellation of the transfer and damages.The case was heard in the Superior Court of Los Angeles County. The defendant, representing himself, filed an answer and a cross-complaint, asserting that he had purchased the property and that the plaintiff had lived rent-free for years. The litigation was marked by extensive discovery disputes, with the plaintiff filing nine motions to compel and for sanctions due to the defendant’s repeated failures to provide timely and adequate discovery responses, appear for depositions, and pay court-ordered sanctions. The court issued incremental sanctions, including monetary and issue sanctions, before ultimately imposing terminating sanctions by striking the defendant’s answer and cross-complaint, leading to a default judgment in favor of the plaintiff.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. It held that the trial court did not abuse its discretion in imposing terminating sanctions after the defendant’s persistent and willful noncompliance with discovery orders. The court also found that the plaintiff’s complaint provided sufficient notice of damages, and that the award of damages and attorney fees was supported by substantial evidence. The judgment of the trial court was affirmed in all respects. View "Atlas v. Davidyan" on Justia Law

A pretrial detainee in the St. Tammany Parish Jail, who has had a prosthetic eye for decades, reported his chronic condition to jail medical staff upon intake. In June 2022, a jail doctor prescribed antibiotics and twice-weekly wound care for an infection in the detainee’s eye socket. Although the detainee was initially scheduled for wound care, he was not taken to his appointments, and his infection worsened over several weeks. The detainee filed multiple grievances, alleging that a deputy failed to escort him to medical care and that a refusal-of-treatment form was falsely completed without his knowledge or signature. After further investigation, jail officials determined that the medical records inaccurately reflected wound care visits, which were actually medication distributions, and ultimately found the detainee’s grievance substantiated.The detainee filed a pro se civil rights action under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Louisiana, naming jail officials and medical staff as defendants. The district court, through a magistrate judge, granted a motion to dismiss for some defendants and summary judgment for others, entering final judgment against the detainee and dismissing his claims with prejudice. The court denied the detainee’s motions to compel discovery and to amend his complaint, and did not address some discovery requests before entering judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the magistrate judge committed plain error by treating a report and recommendation as a final judgment before it was formally adopted, thereby denying the detainee a full and fair opportunity for discovery. The appellate court reversed the grant of summary judgment for the doctor-defendants, affirmed the dismissal of claims against most jail officials, but found that dismissal should have been without prejudice to allow for amendment. The case was remanded for further proceedings consistent with these holdings. View "James v. Smith" on Justia Law