Justia Civil Procedure Opinion Summaries

The plaintiff, a New Hampshire-based corporation, acquired patents and software from a military contractor and sought to adapt the technology for consumer telecommunications. The defendant, a Finnish multinational, manufactures cellular base stations. In 2015, the parties began discussions about integrating the plaintiff’s software into the defendant’s products. By February 2017, negotiations focused on two main points: a fee for integration work and a lump sum for a perpetual software license. On June 6, 2017, the plaintiff alleges both parties orally agreed to a $3 million integration fee and a $20 million license fee. The defendant disputes whether such an oral agreement occurred. The plaintiff continued work based on this understanding. Later, the defendant offered a lower license fee in a draft written contract, which the plaintiff rejected. Eventually, the defendant canceled the project.After cancellation, the plaintiff sued the defendant in the United States District Court for the District of New Hampshire. Following a ten-day trial, the jury found in favor of the plaintiff on breach of contract and promissory estoppel, awarding $23 million in damages. The district court, considering the defendant’s statute-of-frauds defense, determined that the core issue was whether the perpetual license agreement could be performed within one year. The court found this, along with other issues, raised novel questions of New Hampshire law without binding precedent, and certified three questions to the Supreme Court of New Hampshire.The Supreme Court of New Hampshire reviewed the certified questions. It held that, under New Hampshire law, obligations imposed by a perpetual intellectual property license can be performed within one year, because, absent express language to the contrary, the licensor’s obligations are fulfilled upon granting the license. The court declined to answer the other two certified questions, as its answer to the first resolved the determinative legal issue. The case was remanded to the district court. View "Collision Commc'ns v. Nokia Solutions and Networks OY" on Justia Law

A nonmember landowner sought to install a high-capacity surface water pump on his fee land within the reservation of the White Earth Nation in Minnesota. He obtained a permit from the Minnesota Department of Natural Resources but did not apply for a tribal permit as required by an ordinance enacted by the reservation’s governing body. The tribal Division of Natural Resources sued him in Tribal Court, alleging the pump would negatively affect reservation resources, and obtained a preliminary injunction prohibiting installation. The Tribal Court of Appeals remanded the case for a hearing to determine the Tribal Court’s jurisdiction.The landowner then sued the Tribal Court judge and the director of the Division of Natural Resources in the United States District Court for the District of Minnesota, seeking a declaration that the Tribal Court lacked subject matter jurisdiction under the tribal sovereignty exception established in Montana v. United States, and moved for a preliminary injunction to halt tribal litigation. The district court denied the injunction and stayed the federal case, requiring exhaustion of tribal remedies—meaning the landowner must litigate jurisdictional issues to completion in the Tribal Court and, if necessary, in the Tribal Court of Appeals. The district court found that tribal jurisdiction was not plainly lacking or frivolous under established law.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s application of the tribal exhaustion doctrine de novo. It held that exhaustion was appropriate because the assertion of tribal jurisdiction was not obviously invalid or frivolous, and the law regarding the tribal sovereignty exception was unsettled in these circumstances. The court affirmed the district court’s denial of a preliminary injunction and stay of proceedings, requiring completion of tribal adjudication before federal intervention. View "Vipond v. DeGroat" on Justia Law

After her criminal charge for false reporting was dismissed, Rebeca Hinds filed a civil complaint in county court against Corrine Foreman, alleging that Foreman knowingly made false and defamatory statements to law enforcement, which led to Hinds being charged. Foreman responded by filing a special motion to dismiss under Colorado's anti-SLAPP statute, arguing that her statements to police were protected as they related to a public issue and were made in an official proceeding. The county court found that while Hinds met her burden to show the statements’ falsity, she failed to provide sufficient evidence of actual malice. The court granted Foreman's motion to dismiss, entered a final judgment dismissing the case with prejudice, and awarded Foreman fees and costs.Hinds appealed the county court’s judgment to the Colorado Court of Appeals, relying on statutory provisions that appeared to authorize appeals of anti-SLAPP dismissals directly to that court. The Court of Appeals noted a jurisdictional issue because the Colorado Constitution and relevant statutes generally require appeals from county courts’ final judgments to be made to the district court or the Colorado Supreme Court, not the Court of Appeals. The division requested a determination of jurisdiction from the Supreme Court of Colorado.The Supreme Court of Colorado held that the statutes authorizing the Court of Appeals to review final judgments from county courts in anti-SLAPP cases are unconstitutional to the extent they conflict with article VI, section 17 of the Colorado Constitution. The court ruled that appellate review of a county court’s final judgment must be by the district court or the Supreme Court, not the Court of Appeals. The Supreme Court remanded the case with instructions to dismiss the appeal for lack of jurisdiction and granted Hinds leave to refile her appeal out of time in district court. View "Hinds v. Foreman" on Justia Law

A municipal tax collector initiated a bank execution action against an individual to collect unpaid personal property taxes owed by a business with which the individual was previously associated. The individual had moved to California years earlier and claimed that she never received notice of the tax debt or an opportunity to contest it, despite providing her new address to the tax collector. Previous bank executions had been initiated, but the individual continued to assert lack of notice. In the 2021 action, the trial court found that the tax collector failed to comply with statutory notice requirements and that the individual had not been afforded due process, leading the court to grant her exemption from the execution.Following the 2021 judgment, the tax collector withdrew its appeal and attempted a new bank execution after sending written demand to the individual's California address, but did not provide a new tax bill or opportunity to challenge it. The individual again moved for exemption. The Superior Court concluded that the new execution was a collateral attack on the previous judgment and was barred by doctrines of res judicata and collateral estoppel. The Appellate Court affirmed, finding that the issue of notice and opportunity to challenge the tax debt had been actually litigated and necessarily determined in the prior action.Upon review, the Connecticut Supreme Court held that collateral estoppel barred the municipal tax collector from relitigating whether it could execute on the individual's funds without first providing adequate notice and an opportunity to challenge the underlying tax debt. The Court determined that both independent, alternative grounds supporting the earlier judgment were entitled to preclusive effect and declined to create a public policy exception for municipal tax collection actions. The Supreme Court affirmed the judgment of the Appellate Court. View "Torrington Tax Collector, LLC v. Riley" on Justia Law

The plaintiff leased and later purchased a 2013 vehicle from the defendant, which subsequently developed engine problems. After experiencing issues like rattling and crunching noises and receiving a safety recall notice, the plaintiff sought repairs and eventually requested that the defendant repurchase the car due to unresolved defects. The defendant did not respond to these repurchase requests.The plaintiff sued for violations under the Song-Beverly Consumer Warranty Act, breach of warranties, fraud by omission, and the Consumer Legal Remedies Act (CLRA). The Superior Court of San Diego County sustained the defendant’s demurrer to the CLRA claim without leave to amend, citing the plaintiff’s failure to file a required venue affidavit with the complaint. During discovery, the defendant repeatedly objected to producing documents related to engine defects and verified, under penalty of perjury, that no responsive documents existed. The plaintiff challenged the adequacy of the defendant’s document search and later discovered evidence indicating the defendant had produced such documents to a government agency in another matter. The trial court denied the plaintiff’s motions to compel and for terminating sanctions, accepted the defendant’s responses, and excluded key evidence at trial, which left the plaintiff unable to prove fraud.At trial, the jury found that a defect existed but concluded the defendant remedied it, resulting in a defense verdict. The trial court denied the plaintiff’s motions for a new trial and judgment notwithstanding the verdict, focusing on the plaintiff’s delay in discovering withheld documents and awarding costs to the defendant.On appeal, the California Court of Appeal, Fourth Appellate District, Division One, reversed and remanded. The court held that the defendant’s discovery misuse denied the plaintiff a fair trial, requiring a new trial and monetary sanctions to compensate for costs and attorney fees. It also directed that the plaintiff be given leave to amend the CLRA claim and vacated the award of prevailing-party costs to the defendant. View "Higginson v. Kia Motors America" on Justia Law

Empower Oversight Whistleblowers & Research, a nonprofit organization, filed a motion to intervene in a closed grand jury proceeding and sought to unseal Department of Justice applications for non-disclosure orders related to a 2017 grand jury subpoena for Google account records. At the time of the subpoena, Jason Foster, Empower’s founder, was the Chief Investigative Counsel for the Senate Judiciary Committee, investigating alleged misconduct at the Department. Google notified Foster in 2023 that a subpoena and non-disclosure order had been issued and extended multiple times. Empower argued that the applications should be unsealed, claiming they were judicial records subject to public access under common law and the First Amendment, and that grand jury secrecy had been waived due to public disclosures.The United States District Court for the District of Columbia permitted Empower to intervene but granted only partial unsealing. It held that the applications were ancillary grand jury records protected by Federal Rule of Criminal Procedure 6(e)(6), limiting unsealing to jurisdictional and legal standard sections. The court found no waiver of secrecy, as disclosures were not sufficiently public to meet the threshold established by precedent. Most of the documents remained sealed, and Empower appealed.The United States Court of Appeals for the District of Columbia Circuit reviewed for abuse of discretion and affirmed the district court’s decision. The appellate court held that the applications were covered by Rule 6(e)(6), which displaces any common law or First Amendment right of access, and that grand jury secrecy had not been waived by the disclosures identified by Empower. The court also declined to review new evidence (the December 2024 OIG report) not presented to the district court but remanded the case for the lower court to consider whether to allow Empower to amend its motion and supplement the record with the OIG report. View "In re: Application of the United States for an Order Pursuant to 18 U.S.C. 2705(b)" on Justia Law

Premium Healthcare Solutions, LLC, an Illinois company, had two competing judgment creditors: Vivek Bedi and MedLegal Solutions, Inc. Bedi obtained a state court judgment against “Premier Healthcare Solutions, LLC” in 2022, which was a misnomer for Premium. His lien on Premium’s assets was thus not discoverable to other creditors. MedLegal, a medical billing company, later secured an arbitration award and a federal court judgment against Premium in 2024 after discovering Premium had breached their contract. Both Bedi and MedLegal initiated collection efforts targeting Premium’s assets, particularly its accounts receivable managed by third parties.After Bedi discovered the misnomer in his judgment, he obtained a corrective order in Illinois state court in September 2024, amending his judgment nunc pro tunc to name Premium as the debtor and making the correction effective as of the original judgment date. Concerned that Bedi’s corrected judgment might threaten its priority, MedLegal sought a federal court order establishing its claim as superior. In the United States District Court for the Northern District of Illinois, Bedi intervened but focused his opposition on jurisdictional grounds, invoking the Rooker-Feldman doctrine. The district court rejected this argument and granted MedLegal’s motion for partial summary judgment, ruling MedLegal’s interest as superior. The court subsequently issued a turnover order requiring certain third parties to transfer Premium’s assets to MedLegal.On appeal, the United States Court of Appeals for the Seventh Circuit held that appellate jurisdiction was proper because the February 11, 2025, turnover order was a final decision. The Seventh Circuit also found that Rooker-Feldman did not bar the district court’s jurisdiction, as MedLegal was not a party to the prior state court action. Finally, because Bedi failed to raise any substantive arguments on priority in the district court, the Seventh Circuit affirmed the district court’s turnover order in favor of MedLegal. View "Bedi v Premium Healthcare Solutions LLC" on Justia Law

An employee of a New York City tour company was terminated in 2012, allegedly for attempting to unionize. The National Labor Relations Board (NLRB) began investigating the termination, and in 2013, its adjudicative body found the discharge violated the National Labor Relations Act (NLRA), ordering the company to reinstate the employee and compensate him for lost earnings. After a brief reinstatement and a second termination, further proceedings led to a backpay judgment against the company and several affiliates, including some of the current appellants. When the judgment debtors failed to pay, the NLRB issued administrative subpoenas seeking documents to determine whether the appellants could be held liable for the judgment. The appellants did not comply with these subpoenas.The United States District Court for the Southern District of New York reviewed the NLRB’s application to enforce the subpoenas. The court rejected the appellants’ arguments concerning lack of subject-matter jurisdiction, personal jurisdiction, and improper venue, holding that the NLRA authorized nationwide service of process and that the inquiry was conducted in the Southern District of New York. The court denied the appellants’ motion to transfer the case to the Southern District of Texas and awarded attorneys’ fees and costs to the NLRB, later specifying the amount.The United States Court of Appeals for the Second Circuit found that the district court had subject-matter and personal jurisdiction to enforce the subpoenas, and that venue was proper. It held that the district court did not abuse its discretion by refusing to transfer the case or by awarding fees and costs based on the appellants’ repeated evasion of service and failure to comply. However, the appellate court lacked jurisdiction to review the district court’s subsequent order fixing the amount of fees and costs, as no timely notice of appeal was filed for that order. The judgment was thus affirmed in part and dismissed in part. View "Nat'l Lab. Rels. Bd. v. Universal Smart Conts., LLC" on Justia Law

The case centers on Orlando González Tomasini, who filed civil rights and tort claims against the United States Postal Service, his former employer, alleging that psychological and medical conditions prevented him from working. His then-wife, Juliette Irizarry-Miranda, was initially a co-plaintiff but eventually became a defense witness after a contentious divorce and ongoing custody dispute over their son. On the eve of trial, the Postal Service accused González of witness tampering, specifically of seeking to dissuade Irizarry from testifying by conditioning custody concessions on her refusal to take the stand. Irizarry recorded part of a phone call between them, and the Postal Service submitted this as evidence.Prior to the current appeal, the case was heard in the United States District Court for the District of Puerto Rico, where a magistrate judge presided by consent of the parties. The magistrate judge held a three-day evidentiary hearing to address the witness tampering allegations. After hearing testimony from González, Irizarry, and a social worker, the court found by clear and convincing evidence that González had engaged in witness tampering. As a sanction for this fraud on the court, the magistrate judge dismissed González’s case.The United States Court of Appeals for the First Circuit reviewed the district court's decisions. The First Circuit affirmed the district court in all respects, holding that the evidentiary hearing was appropriately ordered, the finding of witness tampering was not clearly erroneous, and the sanction of dismissal was within the court’s discretion. The appellate court found that González’s conduct constituted a fraud on the court, justifying dismissal, especially given the egregiousness of the witness tampering and its potential impact on the integrity of judicial proceedings. Judgment was affirmed for the Postal Service. View "Gonzalez Tomasini v. Steiner" on Justia Law

Plaintiffs, who provided subadvisory investment services and loaned $1.5 million to FolioMetrix (personally guaranteed by two individuals), later engaged with defendants involved in a proposed merger of investment firms. Plaintiffs alleged that during merger negotiations, defendant Putnam promised to relieve the original borrowers of their obligations and personally assume the debt. Subsequent communications referenced intentions to transfer the loan liability to the new entity, but when plaintiffs sought a formal promissory note, defendants refused. Ultimately, defendants did not repay any portion of the loan.Plaintiffs filed suit in the Superior Court of the City and County of San Francisco in March 2019, alleging breach of contract, fraud, negligent misrepresentation, and breach of the covenant of good faith and fair dealing. At trial, the central dispute was whether defendants had agreed to assume the loan obligations under the promissory note. Plaintiffs argued that the agreement was formed through emails and conduct, while defendants denied any assumption of liability. The jury found in favor of defendants, determining no contract was formed and no promise was made to repay the loans. Following trial, the court awarded defendants attorney fees under Civil Code section 1717, based on a fee provision in the original promissory note, after reducing the requested amount.On appeal, the California Court of Appeal, First Appellate District, Division Five, addressed several issues. It ruled that the automatic bankruptcy stay did not preclude resolution of the appeal because the debtor (NAI) was the plaintiff rather than a defendant. The court rejected plaintiffs’ claims of error regarding jury instructions on contract formation, finding insufficient argument and no prejudice. It affirmed the attorney fee award, concluding the action was “on the contract” containing the fee provision, and held the fee amount was within the trial court’s discretion. The judgment and fee order were affirmed. View "Navellier v. Putnam" on Justia Law