Justia Civil Procedure Opinion Summaries

Robert Carbone, a Connecticut resident, sued two Swiss organizations and several individuals from California, Illinois, and Switzerland for defamation and other tortious conduct. Carbone, a member of the two Swiss organizations, claimed that the defendants used websites to publish defamatory statements about him and facilitate his removal from the organizations. He filed the lawsuit in Ohio, arguing that the defamatory statements passed through servers located in Ohio, which hosted the organizations' websites.The United States District Court for the Southern District of Ohio dismissed Carbone's complaint for lack of personal jurisdiction. The court found that Carbone failed to establish that the defendants had sufficient contacts with Ohio to justify the court's jurisdiction over them. The defendants had not purposefully availed themselves of the privilege of acting in Ohio, as the servers' location in Ohio was chosen by third parties, not the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the defendants did not purposefully avail themselves of the privilege of acting in Ohio, as their only connection to the state was the location of the servers, which was a decision made by third parties. The court also found that Carbone's claims did not arise from the defendants' activities in Ohio, as the allegedly defamatory statements were not directed at Ohio or its residents. Therefore, the exercise of personal jurisdiction over the defendants in Ohio would not comply with the Due Process Clause. View "Carbone v. Kaal" on Justia Law

The Environmental Protection Agency (EPA) approved California regulations under the Clean Air Act that require automakers to produce more electric vehicles and fewer gasoline-powered vehicles to reduce emissions. Several fuel producers, including those of gasoline and ethanol, sued the EPA, arguing that the EPA lacked the authority to approve these regulations as they target global climate change rather than local air quality issues. The fuel producers claimed that the regulations would significantly reduce the demand for liquid fuels, causing them monetary injury.The United States Court of Appeals for the District of Columbia Circuit reviewed the case and held that the fuel producers lacked Article III standing. The court found that the fuel producers failed to demonstrate that automakers would likely respond to the invalidation of the regulations by producing fewer electric vehicles and more gasoline-powered vehicles, thus failing to establish redressability.The Supreme Court of the United States reviewed the case and held that the fuel producers have Article III standing to challenge the EPA’s approval of the California regulations. The Court found that the fuel producers demonstrated injury in fact, causation, and redressability. The Court reasoned that the regulations likely cause monetary injury to the fuel producers by reducing the demand for gasoline and other liquid fuels. The Court also found that invalidating the regulations would likely redress the injury by increasing the sales of gasoline-powered vehicles and, consequently, the demand for liquid fuels. The judgment of the Court of Appeals was reversed and the case was remanded for further proceedings. View "Diamond Alternative Energy, LLC v. Environmental Protection Agency" on Justia Law

McKesson Corporation sent unsolicited fax advertisements to medical practices, including McLaughlin Chiropractic Associates, in 2009 and 2010. McLaughlin sued McKesson in 2014 in the U.S. District Court for the Northern District of California, alleging violations of the Telephone Consumer Protection Act (TCPA) for sending unsolicited faxes without the required opt-out notices. McLaughlin sought damages and an injunction and aimed to represent a class of fax recipients who received the advertisements on traditional fax machines or through online fax services. The District Court certified the class without distinguishing between the two methods of receipt.During the lawsuit, the Federal Communications Commission (FCC) issued the Amerifactors order, which interpreted "telephone facsimile machine" in the TCPA to exclude online fax services. The District Court, following Ninth Circuit precedent, deemed the Amerifactors order binding and granted summary judgment to McKesson for claims involving online fax services. The court then decertified the class, leaving McLaughlin with claims for only 12 faxes received on a traditional machine and damages of $6,000. The Ninth Circuit affirmed the District Court's decision.The Supreme Court of the United States reviewed the case and held that the Hobbs Act does not bind district courts in civil enforcement proceedings to an agency’s interpretation of a statute. District courts must independently determine the law’s meaning under ordinary principles of statutory interpretation while affording appropriate respect to the agency’s interpretation. The Court reversed the Ninth Circuit's decision and remanded the case for further proceedings consistent with this opinion. View "McLaughlin Chiropractic Associates, Inc. v. McKesson Corp." on Justia Law

Carl and Roberta Culp filed a lawsuit alleging federal and state law claims against various defendants, including Fort Wayne and Allen County police officers. The claims included excessive force under 42 U.S.C. § 1983, intentional and negligent infliction of emotional distress, assault and battery, criminal mischief, and violations of the Rehabilitation Act and the Americans with Disabilities Act (ADA). The incident in question occurred on August 20, 2018, when Carl Culp, a double amputee, expressed suicidal intentions during a psychiatric appointment, leading to police intervention.The United States District Court for the Northern District of Indiana granted summary judgment in favor of the defendants on most claims, leaving only Carl Culp’s § 1983 excessive force claim and state law claims against Officers Woods and Schulien for trial. A jury found in favor of the defendants on all claims except for Roberta Culp’s state law battery claim against Officer Woods, awarding her nominal damages of $1. The Culps appealed the summary judgment decision, and Woods and Schulien cross-appealed the denial of costs.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the district court did not err in granting summary judgment to the defendants, as the defendants’ brief complied with the local rules. The court also found that the Culps failed to present evidence of discrimination or failure to accommodate under the ADA and Rehabilitation Act. The court assumed, without deciding, that these laws applied to law enforcement actions but concluded that the evidence did not support the Culps' claims.Regarding the cross-appeal, the Seventh Circuit upheld the district court’s decision to deny costs to both parties, recognizing the mixed outcome of the case. The court affirmed the district court’s judgment in its entirety. View "Culp v. Caudill" on Justia Law

After Hurricane Maria damaged its business, Coco Rico, LLC sued its insurer, Universal Insurance Company, for failing to pay its insurance claim and won. The jury awarded Coco Rico higher damages for its business interruption loss claim than it had requested, plus extra, consequential damages. This appeal centers on the district court's rulings on several post-verdict motions: Universal sought to eliminate or reduce the jury's damages awards, while Coco Rico sought attorneys' fees and prejudgment interest from Universal. After the district court denied the motions, both parties appealed.The United States District Court for the District of Puerto Rico denied Universal's renewed motion for judgment as a matter of law on the consequential damages claim and its motion for a new trial or reduction of the contractual damages award. The court reduced the jury's BI & EE award from $873,000 to $750,000, in line with the insurance policy maximum, but rejected Universal's argument that the award should be further reduced to $686,098. The court also denied Coco Rico's motion to amend the judgment to add attorneys' fees and prejudgment interest.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with Universal that there was no evidentiary basis for the jury to award consequential damages or higher business interruption loss damages than Coco Rico had established at trial. The court reversed the district court's ruling denying Universal's motions regarding the damages awards and affirmed its ruling denying Coco Rico's motion for attorneys' fees and prejudgment interest. The court held that the jury's award of $873,000 for business interruption loss exceeded the evidence presented, which supported only $686,098, and that there was no evidence to support the $250,000 consequential damages award. The court remanded the case for further proceedings consistent with its opinion. View "Coco Rico, LLC v. Universal Insurance Company" on Justia Law

Donald Norman, Patrick Strateman, and Amir Taaki established Intersango, a cryptocurrency exchange. After Intersango ceased operations, Norman filed a derivative complaint on behalf of Intersango against Patrick and Jamie Strateman and Taaki, alleging various claims including breach of fiduciary duty and conversion. The parties later entered into a settlement agreement, but over a year later, Norman sought to set aside the settlement, while the Stratemans moved to enforce it. The trial court granted the motion to enforce the settlement and denied Norman's motion to set it aside, leading to the dismissal of the claims.The trial court, presided over by Judge Rochelle East, found that the settlement agreement was enforceable and dismissed the claims and cross-claims with prejudice. Norman appealed, arguing that the settlement required judicial approval because it involved derivative claims, and that the trial court erred in enforcing the settlement without such approval.The California Court of Appeal, First Appellate District, Division Three, reviewed the case. The court agreed with Norman, holding that the settlement of derivative claims requires judicial approval to ensure it is fair and reasonable and not the product of fraud or collusion. The court found that neither Judge Kahn, who mediated the settlement, nor Judge East, who ruled on the motions, conducted the necessary judicial review and approval of the settlement. Consequently, the appellate court vacated the trial court's order enforcing the settlement and remanded the case for the trial court to conduct the required judicial review of the settlement. View "Norman v. Strateman" on Justia Law

In this case, the plaintiffs, Tsz Keung Wong and Huechi Wong, filed a malicious prosecution action against Yi Dong and his attorneys, alleging that Dong's previous cross-complaint in an earlier lawsuit was filed with malicious intent and lacked probable cause. The Wongs had initially sued Dong over unpaid rent, and Dong responded with a cross-complaint, which he later voluntarily dismissed while an anti-SLAPP motion by the Wongs was pending. The trial court ruled that the Wongs' anti-SLAPP motion would have been granted, entitling them to attorney fees.Dong then filed a motion to strike the Wongs' malicious prosecution action under the anti-SLAPP statute and sought dismissal under Civil Code section 1714.10, which requires pre-filing approval for conspiracy claims against attorneys. The trial court denied both motions, leading Dong to file an interlocutory appeal.The California Court of Appeal, First Appellate District, Division Five, reviewed the case. The court determined that it lacked jurisdiction to review the denial of Dong's anti-SLAPP motion because the Wongs' action qualified as a SLAPPback, which is only reviewable by a peremptory writ petition, not an interlocutory appeal. The court dismissed this portion of Dong's appeal.Regarding the denial of Dong's motion under Civil Code section 1714.10, the court affirmed the trial court's decision. The court held that the Wongs' malicious prosecution action did not require pre-filing approval because it sought to hold the attorneys independently liable for their own actions, not based on a conspiracy with Dong. The court found that the allegation of conspiracy was surplusage and did not affect the applicability of section 1714.10.In conclusion, the court dismissed Dong's appeal concerning the anti-SLAPP motion and affirmed the trial court's denial of the motion under Civil Code section 1714.10. View "Wong v. Dong" on Justia Law

A public benefit corporation, Lawyers for Fair Reciprocal Admissions (LFRA), challenged local rules of federal district courts in the Ninth Circuit. These rules require attorneys seeking general admission to be members in good standing of the bar of the state where the district court is located. LFRA argued that these rules prevent its members, who are barred in states outside the Ninth Circuit and do not wish to join another state bar, from seeking general admission to these federal district courts.The United States District Court for the District of Arizona dismissed LFRA’s amended complaint with prejudice. The court found that LFRA had standing to bring claims on behalf of its members, except for the Sixth Amendment claim, which lacked standing. The court dismissed the remaining claims for failure to state a claim, concluding that the Admission Rules did not violate constitutional, statutory, or procedural grounds as alleged by LFRA.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s dismissal with prejudice. The Ninth Circuit held that the Admission Rules are constitutional and do not violate separation of powers, federalism principles, the Privileges and Immunities Clauses, the Equal Protection Clause, the First Amendment, the Full Faith and Credit Act, the Rules Enabling Act, or procedural due process. The court also found that Rules 1 and 83 of the Federal Rules of Civil Procedure do not create a private right of action. The Ninth Circuit concluded that the district court did not abuse its discretion in dismissing the amended complaint without leave to amend, as the complaint could not be saved by amendment. The court also upheld the denial of LFRA’s motion for judgment on the pleadings as procedurally premature. View "Lawyers for Fair Reciprocal Admissions v. United States" on Justia Law

Jacqueline Sterling failed to pay $500 in gym membership fees to Southlake Nautilus Health and Racquet Club, leading to a default judgment against her in the Superior Court of Lake County, Indiana. Despite a bankruptcy court discharging her debt, Southlake continued to enforce the judgment. Sterling did not notify the Lake County court of her bankruptcy or appear at a hearing, resulting in a bench warrant for her arrest. A year later, she was arrested during a traffic stop and spent a weekend in jail, missing work and suffering emotional distress.The bankruptcy court found Southlake in civil contempt for violating the discharge order and contributing to Sterling's arrest and resulting damages. The court also found Sterling partially at fault for not notifying the Lake County court of her bankruptcy. Applying comparative fault principles, the court allocated half the liability for Sterling's lost wages, emotional distress, and attorney’s fees to each party. Sterling was awarded $9,724.50 in compensatory damages and $99,355 in attorney’s fees.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that while compensatory damages in civil contempt proceedings must be awarded if the complainant proves the defendant's actions caused the injury, the court has broad discretion in awarding attorney’s fees. The bankruptcy court erred by not recognizing this distinction and improperly applied comparative fault principles to reduce the attorney’s fees award. The Seventh Circuit vacated the judgment in part and remanded the case to the bankruptcy court to reassess the attorney’s fees in light of its broad discretion. The court also clarified that costs should be allowed and directed the bankruptcy court to set a deadline for Sterling to file a bill of costs. View "Sterling v Southlake Nautilus Health & Racquett Club, Inc." on Justia Law

Seven District of Columbia citizen-voters filed a complaint challenging the constitutionality of the Local Resident Voting Rights Amendment Act of 2022, which allows noncitizens to vote in municipal elections. The plaintiffs argued that this law dilutes their votes, discriminates against U.S. citizens, and violates the constitutional right to citizen self-government. The District of Columbia Board of Elections, responsible for implementing the law, was named as the defendant.The case was initially brought in D.C. Superior Court, but the Board removed it to the United States District Court for the District of Columbia. The Board then moved to dismiss the case, arguing that the plaintiffs lacked standing and failed to state a claim. The district court agreed with the Board, holding that the plaintiffs did not demonstrate any individual disadvantage and thus lacked standing. The court dismissed the complaint, characterizing the plaintiffs' grievances as generalized and insufficient to confer standing.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the plaintiffs had standing to sue because they alleged a concrete and particularized injury: the dilution of their votes due to the expansion of the electorate to include noncitizens. The court distinguished this case from others where plaintiffs failed to show individualized harm. The court found that the plaintiffs' claims were specific to their voting power in D.C. local elections and not merely a generalized grievance. Consequently, the court reversed the district court's dismissal and remanded the case for further proceedings. The Board's cross-appeal was dismissed as moot. View "Hall v. District of Columbia Board of Elections" on Justia Law