Justia Civil Procedure Opinion Summaries

In April 2011, JJJTB, Inc. initiated a foreclosure action against Stephen Schmidt and Schmidt Farms, Inc. in Hillsborough County. In 2015, the Thirteenth Judicial Circuit denied the foreclosure judgment, and the Second District Court of Appeal affirmed this decision. Over two years later, JJJTB amended its complaint to include new defaults. Schmidt moved to dismiss the amended complaint but did not argue lack of case jurisdiction. The trial court denied the motion, and Schmidt filed an answer with affirmative defenses and a counterclaim but again did not raise the issue of case jurisdiction. In 2021, the court entered a foreclosure judgment against Schmidt, who then unsuccessfully moved for rehearing, asserting lack of subject matter jurisdiction.Schmidt appealed to the Second District Court of Appeal, arguing the trial court lacked jurisdiction. The Second District reversed the foreclosure judgment, holding that the trial court lacked case jurisdiction and that such objections cannot be waived. The court certified conflict with the Fourth District Court of Appeal's decision in MCR Funding v. CMG Funding Corp., which held that case jurisdiction is waivable.The Supreme Court of Florida reviewed the case to resolve the conflict. The court held that case jurisdiction is waivable and that objections must be timely raised, or they are waived. The court quashed the Second District's decision and approved the Fourth District's decision in MCR Funding. The Supreme Court concluded that Schmidt waived the objection to the trial court's lack of case jurisdiction by not raising it timely and by seeking affirmative relief. The Second District erred in reversing the foreclosure judgment based on untimely objections to case jurisdiction. View "JJJTB, Inc. v. Schmidt" on Justia Law

ELG Utica Alloys, Inc. ("ELG") sued a group of its former customers in the United States District Court for the Northern District of New York, asserting claims under the Comprehensive Environmental Response, Compensation, and Liability Act ("CERCLA"). ELG had remediated contamination at one portion of a 23-acre facility in 2007 and continued to remediate contamination at a different portion of the facility pursuant to a 2015 consent order with the New York State government. ELG sought contribution for the costs of the 2015 cleanup from the defendants, alleging they were also responsible for the contamination.The defendants moved for summary judgment, arguing that the six-year statute of limitations for certain CERCLA claims had elapsed. The District Court granted the motion, reasoning that the remediation began in 2007, and the 2015 work was a subsequent step in the work that commenced in 2007. Therefore, the statute of limitations started to run in 2007 and elapsed in 2013, before ELG sued. The District Court also imposed spoliation sanctions on ELG for shredding over 23,000 pounds of potentially relevant documents.The United States Court of Appeals for the Second Circuit reviewed the case and agreed with the District Court that the statute of limitations on ELG’s claims commenced once on-site physical remediation began in 2007. The court also found no error in the District Court’s imposition of spoliation sanctions. Consequently, the Second Circuit affirmed the judgment of the District Court and remanded to the District Court to order the agreed-upon spoliation sanction. View "ELG Utica Alloys, Inc. v. Niagara Mohawk Power Corp." on Justia Law

In this case, Michael Patrick Murray and other plaintiffs, who either suffer from brain tumors or represent estates of decedents who died from brain cancer, sued Motorola, Inc. and other telecommunications companies. They alleged that long-term exposure to cell phone radiation caused their health issues. The litigation began in 2001 and has been through multiple appeals. In a previous decision, the court allowed the litigation to proceed, and in another, it changed the evidentiary standard for admitting expert testimony from the "general acceptance" test to the "reliability" test.The Superior Court of the District of Columbia, post-remand, denied the plaintiffs' motions for additional discovery and to add new experts, struck portions of their supplemental expert reports, excluded all of their expert testimony under Rule 702, and granted summary judgment in favor of the defendants. The trial judges ruled that the plaintiffs failed to provide admissible expert testimony on general causation, which was necessary to proceed with the case.The District of Columbia Court of Appeals reviewed the case and affirmed the trial court's decisions. The appellate court found no abuse of discretion in the trial judges' rulings on discovery and expert testimony. The court held that the trial judges correctly applied the legal principles and managed the discovery process appropriately. The appellate court also agreed that the plaintiffs failed to meet the standards set out in Rule 702 for their expert testimony, and thus, summary judgment for the defendants was appropriate. View "Murray v. Motorola, Inc." on Justia Law

John and Stacy Bang own several parcels of real property in Dunn County, including the subject property in this dispute. They own both the surface and mineral estates. In May 2004, John Bang executed an oil and gas lease agreement with Diamond Resources, Inc., whose successor, Continental Resources, Inc., is the operator and holds the mineral lease. Continental notified the Bangs of its intent to install oil and gas facilities on the property, which the Bangs objected to. Continental subsequently constructed various facilities on the property.The Bangs filed a lawsuit against Continental in 2022, alleging trespass, seeking an injunction, and claiming damages under North Dakota law. The district court denied the Bangs' motions for a temporary restraining order and preliminary injunction. Continental filed a separate action seeking a declaratory judgment and an injunction against John Bang, which was consolidated with the Bangs' case. In January 2024, the district court granted Continental partial summary judgment, declaring Continental had the right to install a pipeline corridor and denied the Bangs' claims for trespass and permanent injunction. The court also denied Continental summary judgment on damages. A jury trial in February 2024 awarded the Bangs $97,621.90 for their compensation claims. The Bangs' motions for a new trial and other relief were denied.The North Dakota Supreme Court reviewed the case and affirmed the district court's amended judgment and order denying a new trial. The court held that the lease was unambiguous and provided Continental the authority to install pipeline facilities on the subject property. The court also upheld the district court's evidentiary rulings, including the exclusion of certain expert testimony and evidence of settlement agreements, and the exclusion of speculative evidence of future agricultural damages. The court found no error in the jury instructions and concluded that the district court did not abuse its discretion in denying the Bangs' motions under N.D.R.Civ.P. 59 and 60. View "Bang v. Continental Resources" on Justia Law

Workforce Safety and Insurance (WSI) initiated a civil action against Boechler PC and Jeanette Boechler for unpaid workers' compensation premiums, penalties, and interest for periods ending in mid-August 2019. WSI was awarded a judgment of $11,661.99, mostly penalties, against the corporation, and the claim against Boechler personally was dismissed without prejudice. In May 2022, WSI filed a second action against the corporation and Boechler personally for additional amounts not included in the previous judgment. The district court granted summary judgment in favor of WSI against the corporation for $10,854.53 but identified issues regarding Boechler’s personal liability.The district court found that Boechler, as president of the corporation, was personally liable for unpaid premiums but not for penalties related to the failure to file payroll reports. The court awarded WSI $5,802, holding that Boechler’s personal liability did not extend to penalties for failing to file payroll reports and that personal liability only applied to amounts determined as of the date of WSI’s decision.The North Dakota Supreme Court reviewed the case and held that the district court correctly interpreted N.D.C.C. § 65-04-26.1 to mean that Boechler’s personal liability does not include penalties for failing to file payroll reports. However, the Supreme Court found that the district court erred in determining that personal liability only applied to amounts existing as of the date of the decision. The Supreme Court concluded that Boechler’s personal liability should include amounts accruing after the WSI determination of her liability. The court affirmed in part, reversed in part, and remanded the case for entry of a judgment consistent with its opinion. View "WSI v. Boechler" on Justia Law

Louisville Metro Police Department officers conducted a search of Jennie and Saul Wright’s home, where they lived with their great-nephews, Jawand Lyle and Brendon Burnett. The Wrights claimed the search violated their constitutional rights and filed a lawsuit against Louisville Metro Government and unknown police officers under 42 U.S.C. § 1983. The district court dismissed the claims of both the Wrights and their great-nephews.The United States District Court for the Western District of Kentucky dismissed the Wrights' claims, and the Wrights appealed. The Sixth Circuit Court of Appeals dismissed the appeal for lack of jurisdiction. The Wrights' counsel withdrew, and the Wrights, proceeding pro se, filed an amended complaint naming the previously unknown officers. The district court dismissed the claims against the individual officers as untimely and dismissed the Monell claim against Louisville Metro Government for failure to state a claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that it lacked appellate jurisdiction over the claims of Jawand and Brendon because they were not included in the notice of appeal. The court affirmed the district court’s dismissal of Jennie and Saul Wright’s claims against the individual officers as untimely, as the amended complaint did not relate back to the original complaint under Rule 15(c)(1). The court also affirmed the dismissal of the Monell claim against Louisville Metro Government, finding that the Wrights failed to provide sufficient factual allegations to support their claims of inadequate training and unconstitutional policies or customs. The court declined to take judicial notice of a 2023 Department of Justice report and denied the request to remand the case for consideration of the report. View "Wright v. Louisville Metro Government" on Justia Law

The case involves a class action lawsuit against Matt Martorello for violating civil provisions of the Racketeering Influenced and Corrupt Organizations Act (RICO). The plaintiffs, a group of Virginia citizens, alleged that Martorello orchestrated a "Rent-A-Tribe" scheme with the Lac Vieux Desert Band of Chippewa Indians to issue high-interest loans that circumvented state usury laws by claiming tribal immunity. The loans were made through tribal entities, Red Rock Tribal Lending, LLC, Big Picture Loans, LLC, and Ascension Technologies. The plaintiffs sought damages under federal civil RICO law.The U.S. District Court for the Eastern District of Virginia dismissed the tribal entities from the case due to sovereign immunity but allowed the claims against Martorello to proceed. The court found that Martorello had made material misrepresentations about the lending operations and granted class certification. Martorello's subsequent interlocutory appeals were denied, and the district court eventually granted summary judgment in favor of the plaintiffs, awarding them over $43 million in damages.The United States Court of Appeals for the Fourth Circuit reviewed the case. Martorello challenged three district court rulings: the denial of his motion to dismiss for failure to join necessary and indispensable parties, the application of Virginia law instead of tribal law, and the rejection of his "mistake of law" defense. The Fourth Circuit affirmed the district court's judgment. It held that the tribal entities were not indispensable parties due to their settlement agreement, Virginia law applied to the off-reservation lending activities, and a mistake-of-law defense was irrelevant to the civil RICO claims, which did not require proof of specific mens rea beyond the predicate acts. The court concluded that the district court did not abuse its discretion in any of its rulings. View "Williams v. Martorello" on Justia Law

Jordan Watkins, while in federal custody, underwent hernia repair surgery and subsequently experienced severe pain and swelling in his groin. Medical staff at the correctional facility dismissed his symptoms as routine side effects and refused to schedule a follow-up appointment before his transfer to another facility. Watkins filed Bivens claims against the medical and correctional staff for deliberate indifference to his serious medical needs and a Federal Tort Claims Act (FTCA) claim against the United States for negligent medical treatment.The United States District Court for the Northern District of Illinois dismissed all of Watkins' claims under Rule 12(b)(6). The court held that the Supreme Court's framework for evaluating Bivens claims barred Watkins' claims and that his FTCA claim was filed too late.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that Watkins' Bivens claims could proceed under the precedent set by Carlson v. Green, which allows federal prisoners to sue for damages resulting from deliberate indifference to their serious medical needs. The court found that Watkins' claims fit within the context recognized by Carlson and were not meaningfully different. The court also held that the district court's dismissal of Watkins' FTCA claim was premature. Watkins may be able to establish the requirements for equitable tolling due to extraordinary circumstances, such as disruptions caused by COVID-19, which prevented him from filing his suit on time. The Seventh Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Watkins v. Mohan" on Justia Law

In this case, the families of Michael Jackson, Carl Wiley, Jr., and Rashad Henderson, who were killed during high-speed police chases in Houston, Texas, sued the City of Houston. They alleged that the Houston Police Department (HPD) has a policy of racial profiling that leads to more high-speed chases in predominantly black neighborhoods, resulting in the deaths of their loved ones. The plaintiffs brought several federal municipal liability claims, including violations of equal protection, Title VI, 42 U.S.C. § 1982, and substantive due process, as well as state tort claims.The United States District Court for the Southern District of Texas granted in part and denied in part Houston's motions to dismiss for lack of subject matter jurisdiction and for judgment on the pleadings. The court dismissed all claims except the equal protection claims and Jackson’s state law claims. Houston then filed an interlocutory appeal, raising issues regarding standing, failure to state federal claims, capacity to sue, and governmental immunity for Jackson’s state law claims.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court determined that it lacked jurisdiction to review non-final district court orders except under 28 U.S.C. § 1292(b). The court found that it could only review whether the plaintiffs had standing to assert their equal protection claims. The court held that the plaintiffs lacked standing because their injuries did not stem from unequal treatment based on race. Consequently, the court reversed the district court’s order regarding standing for the equal protection claims and vacated the district court’s decision on governmental immunity for Jackson’s negligence claim, remanding the case for further proceedings. View "Jackson v. City of Houston" on Justia Law

In November 2023, Media Matters for America, a nonprofit organization, published articles critical of X Corp. and its CEO, Elon Musk, alleging that advertisements from popular brands were placed next to harmful content on the X platform. This led to significant losses for X as advertisers withdrew. X sued Media Matters and its employees in the federal district court for the Eastern District of Texas, alleging interference with contract, business disparagement, and interference with prospective economic advantage. Media Matters moved to dismiss the complaint for lack of personal jurisdiction, improper venue, and failure to state a claim, but the district court denied the motion. Media Matters then sought to certify the personal jurisdiction question for immediate appeal, which was also denied.The district court denied Media Matters' subsequent motion to transfer venue to the Northern District of California, citing untimeliness and a pattern of gamesmanship. Media Matters then filed a petition for writ of mandamus with the United States Court of Appeals for the Fifth Circuit, seeking a venue transfer based on 28 U.S.C. §§ 1404 and 1406.The United States Court of Appeals for the Fifth Circuit reviewed the petition and found that the district court had not properly considered the eight public- and private-interest factors required for a venue transfer analysis. The appellate court granted Media Matters' petition in part, vacated the district court's order denying the transfer, and remanded the case for a proper venue analysis. The court also held Media Matters' interlocutory appeal in abeyance pending the resolution of the remand. View "In Re: Media Matters for America" on Justia Law