Justia Civil Procedure Opinion Summaries

A same-sex married couple, one a U.S. citizen residing in California and the other a Saudi citizen, spent part of each year living together in Saudi Arabia, where homosexuality is punishable by death. In 2021, after U.S. travel restrictions eased, they booked tickets with a German airline to fly from Saudi Arabia to San Francisco. The airline, which operates extensively in California, required them to confirm their marital status for entry into the U.S. During check-in in Riyadh, a senior airline employee publicly disclosed and questioned their relationship, and copies of their marriage certificate and passports were sent electronically to airline headquarters despite their concerns about Saudi government surveillance. After the trip, the Saudi government updated one plaintiff’s official status to “married,” and he feared returning to Saudi Arabia due to potential severe penalties. The couple alleged that the airline’s actions led to significant personal, financial, and health consequences.The couple filed suit in California state court against the airline and its U.S. subsidiary, alleging breach of contract and several torts. The defendants removed the case to the United States District Court for the Northern District of California, asserting diversity and federal question jurisdiction. The district court dismissed the case for lack of personal jurisdiction. On appeal, the United States Court of Appeals for the Ninth Circuit initially remanded for clarification of the subsidiary’s citizenship, after which the district court allowed amendment of the removal notice to reflect the correct citizenship.Upon renewed review, the Ninth Circuit held that the district court had both specific personal jurisdiction over the defendants and subject matter jurisdiction based on diversity. The court found that the airline purposefully availed itself of California’s market, the claims arose from the airline’s California-related activities, and exercising jurisdiction was reasonable. The court reversed the district court’s dismissal and remanded for further proceedings. View "DOE V. DEUTSCHE LUFTHANSA AKTIENGESELLSCHAFT" on Justia Law

An employee began working at a foundry in Minnesota and, after developing back problems, was placed on a lifting restriction by her doctor. She informed her employer of this restriction, but the employer terminated her employment without attempting to provide accommodations. The employee then applied for unemployment benefits, prompting the employer to complete a questionnaire for the Department of Employment and Economic Development (DEED) regarding her termination and disability. In the questionnaire, the employer indicated it had not tried to accommodate her condition.The employee subsequently filed a lawsuit under the Minnesota Human Rights Act, alleging disability discrimination and failure to accommodate. During discovery, the employer sought to exclude the DEED questionnaire from evidence at trial, arguing it was absolutely privileged under Minnesota Statutes section 268.19, subdivision 2(c). The District Court agreed and excluded the document, reasoning that information created solely for unemployment insurance purposes was inadmissible in other civil proceedings. After a bench trial, the District Court ruled in favor of the employer and dismissed the employee’s claims. The Minnesota Court of Appeals affirmed, holding that the questionnaire was absolutely privileged and inadmissible.The Supreme Court of Minnesota reviewed the case to determine whether section 268.19, subdivision 2(c), bars admission of such documents in civil cases. The court held that the phrase “absolutely privileged” in the statute provides immunity from liability for information submitted to DEED, but does not create a general rule of inadmissibility for such evidence in unrelated civil proceedings. Because the employee’s discrimination claim was not based on the content of the DEED questionnaire, its exclusion was erroneous. However, the court found the error was not prejudicial, as the excluded evidence was cumulative of other admitted evidence. The Supreme Court affirmed the decision of the Court of Appeals, but on different grounds. View "McBee vs. Team Industries, Inc." on Justia Law

Rocky Freeman was involved in a Brooklyn drug ring and was hired to kill a rival dealer, Freddie Gonzalez, in 1993. He was later arrested and charged in the United States District Court for the Eastern District of New York with drug conspiracy, the Gonzalez murder, and the unrelated murder of Augustin Sosa. At trial, Freeman was convicted of the drug and Gonzalez murder counts but acquitted of the Sosa murder. However, his presentence report (PSR) incorrectly stated that he had committed both murders. Although a judge ordered the error corrected, the PSR was not amended, and the inaccurate report was transmitted to the Bureau of Prisons (BOP). Freeman subsequently endured heightened security conditions in prison, including solitary confinement and severe restrictions, which he later attributed to the erroneous PSR.Freeman discovered the error in 2015 and pursued administrative remedies, including filing an SF-95 form alleging a Federal Tort Claims Act (FTCA) violation. He then filed a civil complaint in the United States District Court for the Middle District of Pennsylvania against the BOP, the U.S. Probation Office (USPO), his unit manager, and probation officers, alleging FTCA and Bivens claims. The District Court dismissed his FTCA claim for lack of jurisdiction and on the merits, and dismissed his Bivens claim for failure to serve the probation officers. Freeman appealed.The United States Court of Appeals for the Third Circuit reviewed the case de novo. The court held that the District Court erred in dismissing Freeman’s FTCA claim for lack of jurisdiction, finding that he had properly presented his claim to the appropriate agency. The court also held that the District Court improperly applied the Prison Litigation Reform Act’s physical injury requirement to the FTCA presentment phase. The Third Circuit reversed the dismissal of the FTCA claim and remanded for further proceedings. However, the court affirmed the dismissal of Freeman’s Bivens claim, concluding that his claim was not cognizable under current Supreme Court precedent. View "Freeman v. Lincalis" on Justia Law

The case centers on a long-standing dispute involving three churches over ownership and sale of real property in Los Angeles. Attorney Steven C. Kim represented one of the churches, Central Korean Evangelical Church, which granted him a deed of trust on the property to secure payment of attorney fees. Central Korean had contracted to sell the property to New Life Oasis Church but later reneged, leading to litigation. The trial court ordered Central Korean to honor the sale and expunged Kim’s deed of trust, which was obstructing the transaction. Kim’s client appealed, but the appeal was dismissed for lack of standing, and Kim did not pursue his own appeal. The judgment became final in 2018.Following the final judgment, Kim filed a new lawsuit against New Life Oasis Church and Bank of Hope, seeking a declaration that his deed of trust was still valid and challenging the prior expungement order. New Life and Bank of Hope moved for judgment on the pleadings, arguing that issue preclusion barred Kim from relitigating the validity of his lien. The Superior Court of Los Angeles County agreed and entered judgment against Kim. Additionally, New Life filed a cross-complaint alleging that Kim’s recording of a lis pendens constituted slander of title and abuse of process. After a bench trial, the court ruled in favor of New Life, awarding damages and not addressing Kim’s defense based on the litigation privilege.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. It affirmed the trial court’s application of issue preclusion, holding that Kim could not relitigate the validity of his deed of trust. However, it reversed the judgment on the cross-complaint, holding that the litigation privilege protected Kim’s recording of the lis pendens from claims of slander of title and abuse of process. The case was remanded for entry of judgment consistent with these holdings. View "Kim v. New Life Oasis Church" on Justia Law

North Mountain Foothills Apartments (NMFA), a company managing a large apartment complex in Phoenix, Arizona, hired Jasper Press as a maintenance technician during a period of increased workload due to a heatwave. Press discussed his compensation and the poor conditions at the complex with several coworkers. Management became aware that other employees knew about Press’s pay and housing benefits, leading to a meeting where Press was reprimanded for these discussions and told not to talk about pest issues with residents. The day after this meeting, Press was terminated, allegedly for failing to complete work orders. Press filed a complaint with the National Labor Relations Board (NLRB), alleging unfair labor practices.An administrative law judge held an evidentiary hearing and found that NMFA violated Section 8(a)(1) of the National Labor Relations Act by interrogating Press about his wage discussions, issuing overly broad directives restricting such discussions, threatening reprisals, and discharging Press for engaging in protected activities. The NLRB adopted these findings and ordered remedies including reinstatement and back pay for Press. NMFA appealed, raising for the first time constitutional challenges to the NLRB’s structure and process, and also contested the Board’s factual findings.The United States Court of Appeals for the Ninth Circuit held that it had jurisdiction to consider NMFA’s unexhausted constitutional claims because such structural challenges are not suited to agency resolution. The court rejected NMFA’s Article II removal protection challenge for lack of demonstrated harm, found no Seventh Amendment right to a jury trial in NLRB proceedings, and held that the combination of investigatory and adjudicatory functions within the NLRB does not violate due process. On the merits, the court found substantial evidence supported the NLRB’s finding that Press was discharged for protected activity and granted enforcement of the NLRB’s order. View "NATIONAL LABOR RELATIONS BOARD V. NORTH MOUNTAIN FOOTHILLS APARTMENTS, LLC" on Justia Law

Giovanni Irizarry Sierra worked as an Attorney Advisor for the Social Security Administration (SSA) in Puerto Rico and was terminated in March 2019 for unsatisfactory performance. He subsequently filed a complaint with the SSA’s Office of Civil Rights and Equal Opportunity (OCREO), alleging that his termination was the result of discrimination and retaliation. The OCREO reorganized his allegations, dismissing one as untimely and bifurcating the remainder into pre-termination and termination discrimination claims. The termination claim was treated as a “mixed case” because it involved both discrimination and an adverse personnel action.After receiving a report of investigation, Irizarry requested a hearing before an Equal Employment Opportunity Commission (EEOC) Administrative Judge (AJ). The AJ dismissed the termination claim for lack of jurisdiction, explaining that mixed cases must proceed through the Merit Systems Protection Board (MSPB), not the EEOC. Irizarry then appealed his termination claim to the MSPB, which sustained his removal and notified him that he had thirty days from the final decision to seek judicial review in federal district court. Irizarry did not file within that period. Later, the OCREO erroneously issued a Final Agency Decision (FAD) on the termination claim, which was subsequently rescinded.Irizarry filed suit in the United States District Court for the District of Puerto Rico, relying on the rescinded FAD. The SSA moved to dismiss, arguing the complaint was untimely and the FAD was issued in error. The district court granted the motion, finding the claims time-barred and rejecting Irizarry’s arguments for equitable tolling and estoppel.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The court held that Irizarry’s claim was untimely because he failed to file within thirty days of the MSPB’s final decision, and equitable relief was not warranted. View "Irizarry Sierra v. Bisignano" on Justia Law

Edward T. Saadi, a licensed attorney proceeding pro se, obtained a $90,000 judgment against Pierre Maroun and Maroun’s International, LLC (MILLC) following a jury verdict in a federal defamation suit. Despite the judgment, Saadi was unable to collect payment for nine years. In 2018, Saadi discovered information suggesting Maroun had transferred $250,000 from his personal account to MILLC, allegedly to evade the judgment. Saadi claimed these funds were used to purchase a condominium titled to MILLC but used as Maroun’s residence, and to pay Maroun’s personal expenses. Saadi initiated proceedings supplementary under Florida law, seeking to void the transfer and recover assets.The United States District Court for the Middle District of Florida allowed Saadi to file an impleader complaint against Maroun and MILLC, asserting claims for fraudulent transfer and actual and constructive fraud under Florida statutes. Saadi also sought sanctions when MILLC failed to produce a representative for deposition, but the district court denied the motion, finding the individual was not a managing agent of MILLC. Ultimately, the district court granted summary judgment for Maroun and MILLC, ruling that Saadi’s claims were time-barred under Florida’s statutes of repose and limitations, and that tolling provisions did not apply. The court also found that the remedies Saadi sought were unavailable under the relevant statutes.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s rulings. Finding that several dispositive questions of Florida law lacked controlling precedent and were subject to conflicting interpretations by Florida’s intermediate appellate courts, the Eleventh Circuit certified five questions to the Florida Supreme Court. The court deferred its decision pending the Florida Supreme Court’s response to the certified questions. View "Saadi v. Maroun" on Justia Law

After the death of Marjorie Johnson in 2020, her daughter, Rita Johnson, was appointed as executrix of her estate by the Wayne County, Michigan probate court. Rita initiated probate proceedings to determine whether certain assets belonged to the estate or to the Johnson Family Trust, which had a provision requiring arbitration of disputes. Amos C. Johnson, Marjorie’s son and trustee of the Trust, sought to compel arbitration in state court, but the request was denied. Subsequently, Amos and the Trust filed suit in the United States District Court for the Eastern District of Michigan, seeking to compel arbitration of the probate dispute under § 4 of the Federal Arbitration Act (FAA).The district court ordered the plaintiffs to show cause why the case should not be dismissed for lack of subject matter jurisdiction, citing the probate exception, the prior-exclusive-jurisdiction doctrine, and potential lack of diversity. The court ultimately dismissed the case, finding that the FAA does not provide an independent basis for federal question jurisdiction and that the probate proceedings were in rem, meaning the federal court would improperly interfere with property under the state probate court’s control.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit held that federal courts may only compel arbitration under § 4 of the FAA if they would have jurisdiction over the underlying dispute. Because the probate proceedings were purely matters of state law and involved property already under the state court’s jurisdiction, the federal court lacked both federal question and diversity jurisdiction. The Sixth Circuit affirmed the district court’s dismissal, holding that the federal court did not have subject matter jurisdiction to compel arbitration of the state probate proceedings. View "Johnson v. Johnson" on Justia Law

In 2024, Minnesota enacted a law that revised the criteria for classifying independent contractors in the construction industry, expanding a previous nine-part test to a fourteen-part test. Several construction industry organizations and a general contractor challenged the law, arguing that certain provisions were unconstitutionally vague and that the civil penalties authorized by the statute violated the Excessive Fines Clause of the Eighth Amendment. The plaintiffs specifically objected to requirements regarding written contracts, invoicing, expense responsibility, and profit or loss realization, as well as the potential for significant civil penalties for noncompliance.The United States District Court for the District of Minnesota denied the plaintiffs’ request for a preliminary injunction to prevent enforcement of the law. The court found that the plaintiffs had not demonstrated a likelihood of success on the merits of their constitutional claims. The plaintiffs then appealed this decision to the United States Court of Appeals for the Eighth Circuit.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that the plaintiffs had standing to challenge the law, as they alleged specific conduct targeted by the statute and faced a credible threat of enforcement. However, the court concluded that the challenged statutory terms were sufficiently clear for people of ordinary intelligence and did not encourage arbitrary or discriminatory enforcement. The court also determined that the plaintiffs’ excessive fines claim was premature, as no penalties had yet been imposed and Minnesota law requires a proportionality analysis before penalties are assessed. Because the plaintiffs failed to show a likelihood of success on the merits, the court found no basis for a preliminary injunction and affirmed the lower court’s judgment. View "MN Chapter of Assoc. Builders v. Blissenbach" on Justia Law

A creditor obtained a judgment against an individual debtor and later sought to collect on that judgment by garnishing the debtor’s alleged employer, a company. The creditor, as successor in interest to the original plaintiff, filed a petition for garnishment against the company, asserting it employed or was otherwise indebted to the debtor. The company was served with the petition and interrogatories but did not timely file answers in court. However, before a hearing on the creditor’s motion for judgment pro confesso, the company provided sworn answers directly to the creditor, stating it never employed or owed anything to the debtor and identifying the debtor’s actual employer. The company did not file these answers into the court record. At the hearing, the court was not informed of the company’s responses and, based on the lack of record answers, rendered a judgment against the company for the full amount owed by the debtor.Subsequently, the company moved to reopen the garnishment proceedings and set aside the judgment, arguing it had provided the necessary information to the creditor before the hearing. The city court granted the motion and vacated its prior judgment, finding it had not been made aware of the company’s responses. On appeal, the Louisiana Court of Appeal, First Circuit, reversed and reinstated the original judgment against the company, holding that the relevant statute did not permit reopening a judgment pro confesso under these circumstances.The Supreme Court of Louisiana reviewed the case to determine whether La.R.S. 13:3923, as amended, allows a trial court discretion to reopen and reconsider a judgment pro confesso against a garnishee. The court held that, although the statute is clear and unambiguous, its application in this case would lead to absurd results because the trial court’s original judgment was based on an omission of material information. The Supreme Court reversed the court of appeal and reinstated the city court’s judgment vacating the original garnishment judgment, allowing the company an opportunity to prove it was not the debtor’s employer. View "FIRST PAY, INC. VS. DUKES" on Justia Law