Justia Civil Procedure Opinion Summaries

A child attended the Ventura Unified School District from 2012 to 2021. During this time, the district performed several psychoeducational assessments, identifying the child as having a specific learning disability but failing to assess for autism. The child’s parents, aware of his persistent academic and behavioral struggles, repeatedly collaborated with the district, sought private assessments, and requested additional services, which were denied. The child was ultimately diagnosed with autism in 2021, after which the parents initiated legal action seeking remedies for allegedly inadequate education dating back to 2012.After the parents filed a due process complaint in 2021, an Administrative Law Judge concluded that claims for services before April 8, 2019, were time-barred under the Individuals with Disabilities Education Act’s (IDEA) two-year statute of limitations, finding the parents knew or should have known of the district’s failure to assess for autism and of the child’s inadequate education before that date. The ALJ awarded relief only for the period after April 8, 2019. The parents then sought further review in the United States District Court for the Central District of California, which reversed the ALJ. The district court held that the statute of limitations did not begin until the autism diagnosis in 2021, reasoning the parents lacked the requisite knowledge to challenge the district’s actions earlier. The court also found both statutory exceptions to the limitations period applied and awarded remedies for the 2012–2019 period.The United States Court of Appeals for the Ninth Circuit reversed the district court. The court held that the IDEA’s two-year statute of limitations begins when parents knew or should have known both of the district’s action or inaction and that their child was being denied a free appropriate public education. It concluded that the parents’ claims for pre-2019 educational services were untimely. The appellate court vacated the district court’s remedial orders and remanded for further proceedings regarding attorneys’ fees. View "J. R. V. VENTURA UNIFIED SCHOOL DISTRICT" on Justia Law

A driver was stopped by a county deputy after allegedly committing traffic violations that led the officer to suspect impaired driving. The officer noted possible signs of intoxication and requested that the driver submit to alcohol testing, which the driver refused. Under Montana’s implied-consent law, the officer seized the driver’s license and issued a notice of automatic six-month suspension. The next day, the driver petitioned for judicial review, arguing that the officer lacked sufficient suspicion for the stop and the test requests.The Eighth Judicial District Court set an evidentiary hearing, but delays resulted from a combination of the petitioner’s request for a continuance due to jury duty and procedural orders requiring both parties to file briefs before a hearing could be held. The petitioner filed a brief, but the State did not, leaving the hearing vacated. Before the court ruled, the six-month suspension expired and the license was reinstated. When the petitioner moved to reset the hearing, the State moved to dismiss the case as moot, arguing that the only relief available was the return of the license, which had already occurred. The District Court agreed and dismissed the petition as moot.The Supreme Court of the State of Montana reviewed whether the expiration of the suspension and reinstatement of the license rendered the case moot. The court held that the case was not moot because the petitioner’s timely challenge could still result in relief, such as removal of the suspension from his driving record and potential reimbursement of reinstatement fees. The court found that the statute contemplates judicial review even after the suspension period if the challenge was timely filed and pursued. The Supreme Court reversed the District Court’s dismissal and remanded the case for further proceedings. View "Kalafat v. State" on Justia Law

A former CEO of a Delaware corporation, who also founded and controlled the company, entered into a series of employment agreements and amendments with the company’s board. These agreements provided him with substantial severance benefits, including a large special payment of restricted stock units and cash, under specific termination conditions—such as his removal from board leadership or a change in board composition. The agreements also included a forum selection clause requiring that disputes “arising out of or relating to” the contract be litigated exclusively in the Superior Court of California. After an activist hedge fund succeeded in electing new directors and the CEO lost control, he resigned and claimed entitlement to the severance and special payment. He initiated litigation in California to enforce his rights under the agreement.Meanwhile, the company’s newly reconstituted board deemed the CEO terminated for cause and filed suit in the Delaware Court of Chancery. The company sought to invalidate the employment agreements, alleging they were the product of the CEO’s breaches of fiduciary duty and that their terms improperly entrenched his control and penalized stockholders. The company argued Delaware was the proper forum based on its bylaws and the nature of the claims.The Delaware Court of Chancery reviewed the case. The court held that, because of the recently enacted Section 122(18) of the Delaware General Corporation Law, the forum selection clause in a governance agreement (such as this employment agreement with a controller/stockholder) is enforceable and can validly require internal affairs and fiduciary duty claims relating to the agreement to be litigated outside Delaware. The court found the agreement was covered by Section 122(18) and that all claims “arose out of or related to” the agreement. The court granted the CEO’s motion to dismiss, holding that venue was proper only in California. View "Masimo Corporation v. Kiani" on Justia Law

Two individuals purchased Florida prepaid college tuition savings plans for their daughters in 2004 and 2006. The plans promised to cover tuition at Florida public colleges or transfer an equivalent amount to non-Florida colleges if the beneficiary chose to attend elsewhere. In 2007, the Florida Legislature authorized a new “tuition differential” fee, exempting holders of existing plans from paying that fee at Florida colleges. The Florida Prepaid College Board amended the plan contracts to specify that this new fee was not covered for out-of-state schools. Over a decade later, when both daughters chose to attend out-of-state colleges, the Board declined to transfer an amount equivalent to the tuition differential fee.The purchasers filed a putative class action in the United States District Court for the Southern District of Florida against members of the Board, alleging that the Board’s refusal violated the Contracts and Takings Clauses of the U.S. Constitution. They sought declaratory and injunctive relief to prevent the Board from applying the statutory exemption and contract amendments to beneficiaries attending non-Florida schools. The Board moved to dismiss, arguing it was protected by sovereign immunity. A magistrate judge recommended denying the motion, reasoning the relief sought was prospective. However, the district court disagreed, ruling that the relief requested was essentially a demand for a refund, thus barred by the Eleventh Amendment, and dismissed the complaint with prejudice.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the suit was barred by sovereign immunity because the relief sought would require specific performance of a contract with the state, which is not permitted under Ex parte Young and related Supreme Court precedent. However, the appellate court vacated the district court’s dismissal with prejudice and remanded with instructions to dismiss without prejudice, as the dismissal was for lack of subject-matter jurisdiction. View "Lavina v. Florida Prepaid College Board" on Justia Law

After his employment as a wet plant foreman was terminated in January 2022, the plaintiff sent a certified letter in April 2022 to his former employer, requesting a service letter as required by Missouri law. He did not receive a response. The plaintiff later filed suit against the company, alleging a violation of section 290.140 for failure to provide the service letter. He also initially included a claim for disability discrimination under the Americans with Disabilities Act, but that claim was dismissed in federal court, and the remaining statutory claim was remanded to state court.The Circuit Court of Cape Girardeau County granted summary judgment to the defendant company. The defendant had argued that the plaintiff’s service letter request and lawsuit were directed at the wrong corporate entity, asserting that another related company had actually employed the plaintiff. The plaintiff failed to properly respond to the summary judgment motion as required by Rule 74.04(c)(2), instead making bulk admissions and denials without specific references to the record. Because of this failure, the court deemed the defendant’s factual statements admitted and found no genuine issue of material fact. The plaintiff appealed, and the Supreme Court of Missouri granted transfer after an opinion by the court of appeals.The Supreme Court of Missouri held that summary judgment is not an “extreme or drastic remedy” and reaffirmed the requirements for summary judgment motions and responses under Missouri law. The Court concluded that, because the plaintiff did not properly preserve or raise any arguments demonstrating error by the circuit court, and failed to comply with procedural rules, there was no basis to overturn the grant of summary judgment. The judgment of the circuit court in favor of the defendant was affirmed. View "Wilkinson vs. Farmers Holding Companies" on Justia Law

The dispute arose after the Fort Sill Apache Tribe opened the Warm Springs Casino near Lawton, Oklahoma, in 2022. The Comanche Nation, which operates casinos in the same region, experienced increased competition and claimed that the Warm Springs Casino was opened in violation of federal law. The Comanche Nation sought injunctive relief to halt the casino’s operations and monetary damages against several officials of the Fort Sill Apache Tribe, both in their individual and official capacities.The United States District Court for the Western District of Oklahoma heard the officials’ motion to dismiss, in which the officials argued that tribal sovereign immunity barred the claims against them. The district court denied the officials' motion to dismiss, finding that the officials were not protected by tribal immunity on the claims at issue and that the Tribe was not a required party for the purposes of the lawsuit. The district court’s order also explicitly denied tribal immunity as a defense to the official-capacity Racketeer Influenced and Corrupt Organizations Act (RICO) claim, and implicitly rejected tribal immunity for the Indian Gaming Regulatory Act (IGRA) claim.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the district court’s denial of tribal immunity under the collateral-order doctrine. The Tenth Circuit held that IGRA abrogates tribal sovereign immunity for claims brought by an Indian tribe to enjoin class III gaming conducted in violation of a tribal-state compact on Indian lands, allowing the Comanche Nation’s official-capacity IGRA claim to proceed. However, the Tenth Circuit concluded that tribal immunity barred the official-capacity RICO claims because the requirements of the Ex Parte Young exception were not met. The court further held that the officials were not entitled to tribal immunity on the individual-capacity RICO claims. The Tenth Circuit affirmed in part and reversed in part. View "Comanche Nation v. Ware" on Justia Law

In 2021, the United States seized over 700,000 barrels of crude oil from two tankers in the Mediterranean Sea. The government alleged that the oil belonged to the National Iranian Oil Company (NIOC), an entity it claimed materially supported the Islamic Revolutionary Guard Corps (IRGC), a designated Foreign Terrorist Organization. The government further asserted that NIOC’s activities included supplying, transporting, and selling oil to benefit the IRGC, which used these resources to fund terrorist activities targeting the United States. A Turkish commodities trading company, Aspan Petrokimya Co., claimed ownership of the seized oil and sought to recover the proceeds from its sale.The United States District Court for the District of Columbia initially dismissed the government’s forfeiture complaints without prejudice, finding that the government had not adequately pled that NIOC’s sale of oil affected foreign commerce. The government then filed an Amended Complaint consolidating the cases and providing additional factual detail. The district court denied Aspan’s renewed motion to dismiss, concluding that the amended allegations sufficiently addressed the jurisdictional element and all other statutory requirements. To expedite appellate review, Aspan admitted the complaint’s factual allegations, consented to judgment on the pleadings, and appealed.The United States Court of Appeals for the District of Columbia Circuit reviewed the district court’s denial of the motion to dismiss de novo. The appellate court held that the government needed only to allege NIOC’s ownership of the property at the time of the offense, not at the time of seizure. The court also found that the Amended Complaint plausibly alleged that NIOC’s material support of the IRGC substantially affected foreign commerce, and that NIOC’s actions were calculated to influence the U.S. government. The court affirmed the district court’s judgment. View "USA v. All Petroleum-Product Cargo Onboard the M/T Arina" on Justia Law

A fifteen-year-old was involved in a physical altercation with a thirteen-year-old after getting off a school bus, during which he struck the younger student and kicked him once. Tragically, the victim died from his injuries. The defendant was subsequently indicted and convicted in the Superior Court of Cherokee County for felony murder, aggravated assault, and aggravated battery. He received a sentence of life imprisonment with the possibility of parole. His convictions were affirmed on direct appeal to the Supreme Court of Georgia, and his federal habeas petition was denied, with the denial affirmed by the United States Court of Appeals for the Eleventh Circuit.Years later, the defendant filed a motion to correct a void sentence, arguing that his sentence constituted cruel and unusual punishment under the Eighth Amendment because a life sentence was grossly disproportionate to an unintentional killing committed by a juvenile during a fistfight. The trial court denied the motion, reasoning that the sentence was within the statutory range and thus not void, and concluded that it lacked jurisdiction to consider the claim. The court also suggested the case did not meet the rare threshold for an Eighth Amendment disproportionality challenge but ultimately dismissed for lack of jurisdiction.The Supreme Court of Georgia reviewed the case and held that a proportionality challenge under the Eighth Amendment is a cognizable void sentence claim that may be raised at any time, not just within the statutory time frame for sentence modification. The Court determined that the trial court erred in dismissing the motion for lack of jurisdiction, vacated the dismissal order, and remanded the case for the trial court to consider the merits of the Eighth Amendment claim. View "MILLER v. THE STATE" on Justia Law

Several individuals alleged that Google collected and misused the private browsing data of Chrome users who utilized Incognito mode, despite Google’s representations about the privacy of this feature. In June 2020, five plaintiffs brought a putative class action on behalf of these users, seeking both injunctive relief and damages. After extensive discovery, the United States District Court for the Northern District of California certified a class for injunctive relief but denied certification for a damages class, finding the plaintiffs had not shown that common issues predominated over individual ones.Following the denial of damages class certification, the named plaintiffs sought review in the United States Court of Appeals for the Ninth Circuit under Rule 23(f), but the petition was denied. The case proceeded, and as trial approached, the parties settled: Google agreed to change its policies, the named plaintiffs would arbitrate their individual damages claims, and they waived their rights to appeal the denial of damages class certification. The settlement explicitly stated that absent class members were not releasing damages claims or appellate rights. Several months after the settlement, a group of 185 Chrome users, referred to as the Salcido plaintiffs, moved to intervene to preserve absent class members’ appellate rights regarding damages.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s denial of the intervention motion. The Ninth Circuit held that the district court did not abuse its discretion in finding the intervention motion untimely. Applying the circuit’s traditional three-part test for intervention—considering the stage of the proceedings, prejudice to other parties, and the reason for and length of delay—the court found that intervention at this late stage would prejudice the existing parties, that the delay was unjustified, and that the timing weighed against intervention. The denial of the motion to intervene was therefore affirmed. View "BROWN V. SALCIDO" on Justia Law

This case involves a dispute over the rights to the name, image, and trademarks associated with the late artist Frida Kahlo. Two Panamanian corporations with principal places of business in Florida, Frida Kahlo Corporation and Frida Kahlo Investments, manage and license numerous Frida Kahlo trademarks. Mara Cristina Teresa Romeo Pinedo, Frida Kahlo’s grandniece and a resident of Mexico, is an owner and former officer of Familia Kahlo S.A. de C.V., a Mexican company. The parties’ relationship became contentious, leading to litigation in several countries over the intellectual property rights. Plaintiffs alleged that, beginning in 2017 and specifically targeting Florida in 2021 and 2022, the defendants sent cease-and-desist letters to plaintiffs’ business partners in Florida, threatening legal action based on what plaintiffs contend were false claims to trademark ownership. Plaintiffs claimed these actions constituted tortious interference under Florida law and the Lanham Act.The United States District Court for the Southern District of Florida dismissed the lawsuit for lack of personal jurisdiction. The court found that Florida’s long-arm statute was satisfied for Familia Kahlo, but the corporate shield doctrine protected Pinedo because she was not acting in her personal capacity. The court further concluded that the minimum contacts required by due process were not established for either defendant, as sending cease-and-desist letters alone was insufficient.On appeal, the United States Court of Appeals for the Eleventh Circuit reversed the district court’s decision. The Eleventh Circuit held that the corporate shield doctrine did not apply to Pinedo because the cease-and-desist letters were sent on her behalf in her personal capacity. The court also held that due process permitted the exercise of personal jurisdiction over both defendants, as the “effects test” was satisfied and a tortious cease-and-desist letter can meet the minimum contacts requirement. The case was remanded for further proceedings. View "Frida Kahlo Corporation v. Pinedo" on Justia Law