Justia Civil Procedure Opinion Summaries

Pamela J. (Tower) Weinle appealed a divorce judgment from the District Court (Skowhegan), which divided marital property and awarded Alan R. Tower spousal support and attorney fees. Weinle contested the spousal support, property distribution, and attorney fees. Tower died after the judgment and during the appeal process.The District Court awarded Tower $2,000 per month in general spousal support, $500 per month in reimbursement spousal support, and $12,325 in attorney fees. The court found that Weinle had engaged in economic misconduct by purchasing and selling property without Tower's knowledge and failing to comply with discovery obligations, which increased litigation costs. The court also noted that Weinle had a substantial income and financial resources, while Tower had limited income and poor health.The Maine Supreme Judicial Court overruled its previous decision in Panter v. Panter, which required dismissal of an appeal if a party died during its pendency. The court held that the death of a party does not moot the appeal regarding property rights. The court affirmed the District Court's judgment, finding no error in the spousal support award, property distribution, or attorney fees. The court noted that the spousal support obligation ceased upon Tower's death, as the divorce judgment did not specify that the support survived the death of either party. View "Weinle v. Estate of Tower" on Justia Law

Valderra Land Holdings, LLC owns real property encumbered by a performance trust deed held for the benefit of Jenco, LC and others. After Valderra defaulted on its obligations, Jenco sought judicial foreclosure. Valderra counterclaimed, asserting a right to cure its default and requested the court to determine the amount owed. The district court set the payoff amount and directed Jenco to instruct the trustee to reconvey the property upon Valderra’s tender of funds.Valderra tendered the payoff amount, but Jenco did not instruct the trustee to release the trust deed. Instead, Jenco appealed the judgment and moved for a stay of the obligation to reconvey the property under rule 62(b) of the Utah Rules of Civil Procedure. The district court granted the stay over Valderra’s objection, which argued that the order was injunctive and should be governed by rule 62(c), not 62(b).The Supreme Court of Utah reviewed the case and agreed with Valderra that the district court erred in granting the stay under rule 62(b). The court held that rule 62(b) applies only to stays of orders or judgments to pay money, not injunctive orders, which are governed by rule 62(c). The court found that the order requiring Jenco to instruct the trustee to reconvey the property was injunctive in nature. Consequently, the district court should have considered the motion under rule 62(c), which requires the court to determine whether the conditions for the security of the rights of the adverse party are just.The Supreme Court of Utah reversed the district court’s decision to grant the stay under rule 62(b) and vacated the order rejecting Valderra’s rule 62(i) objection. The court also denied Valderra’s request for appellate attorney fees, as Valderra was not awarded fees in the lower court. View "Jenco v. Valderra Land Holdings" on Justia Law

AST & Science LLC, a company in the satellite technology and communications business, hired Delclaux Partners SA to introduce it to registered broker-dealers for investment purposes. Delclaux introduced AST to LionTree Advisors LLC, which handled AST's Series A financing. Two contracts were involved: a Finder’s Fee Agreement between AST and Delclaux, and a separate agreement between AST and LionTree. After the Series B financing, Delclaux claimed it was owed fees from four transactions, which AST refused to pay, leading to AST suing Delclaux for breach of contract, alleging Delclaux acted as an unregistered broker-dealer.The United States District Court for the Southern District of Florida denied summary judgment on AST’s complaint and granted summary judgment to AST on Delclaux’s counterclaim. Delclaux appealed, but the appeal was voluntarily dismissed due to jurisdictional questions. The district court later held that it lacked diversity jurisdiction but claimed federal-question jurisdiction, asserting that the case involved a federal issue regarding the Securities Exchange Act.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s assertion of federal-question jurisdiction. The appellate court held that the breach-of-contract claim was governed by state law and did not meet the criteria for federal-question jurisdiction under the Grable & Sons Metal Products, Inc. v. Darue Engineering & Manufacturing test. The court found that the federal issue was not substantial enough to warrant federal jurisdiction. Consequently, the Eleventh Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss it for lack of subject-matter jurisdiction. View "AST & Science LLC v. Delclaux Partners SA" on Justia Law

Plaintiff Karim Codrington was subjected to an unlawful traffic stop, search, and arrest by Louisville Metro Police Department officers. During the criminal proceedings, a Kentucky state court suppressed the evidence seized from his vehicle and dismissed the charges. Over three years later, Codrington filed a 42 U.S.C. § 1983 lawsuit, alleging that the officers planted drugs on him, provided those drugs to prosecutors, and stole thousands of dollars from him.The United States District Court for the Western District of Kentucky granted summary judgment in favor of the defendants on all claims, finding that Codrington’s claims were either barred by the statute of limitations or failed on their merits. Specifically, the court found that the unlawful search and seizure, selective enforcement, and false arrest/imprisonment claims were time-barred. The court also found that Codrington failed to provide sufficient evidence to support his fabrication-of-evidence and malicious-prosecution claims.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment on the unlawful search and seizure, selective enforcement, false arrest/imprisonment, malicious prosecution, and state-law conversion claims. However, the court reversed the district court’s grant of summary judgment on the fabrication-of-evidence claim, finding that there was a genuine dispute of material fact regarding whether the officers fabricated evidence. The court also vacated the district court’s judgment on Codrington’s Monell claims and remanded for further proceedings. View "Codrington v. Dolak" on Justia Law

A minor, B.D., through his guardian, sued Samsung SDI, a South Korean battery manufacturer, after one of its batteries exploded in his pocket in Indiana. Samsung SDI moved to dismiss the complaint for lack of personal jurisdiction, which the district court granted. The court found that Samsung SDI had not purposefully availed itself of the Indiana forum through sales of individual batteries, as the battery was purchased through an unauthorized transaction.The United States District Court for the Southern District of Indiana initially denied Samsung SDI's motion to dismiss, concluding that B.D. made a prima facie case for personal jurisdiction. However, upon remand for further jurisdictional discovery, the district court granted Samsung SDI's renewed motion to dismiss, reasoning that B.D. failed to show that Samsung SDI purposefully availed itself of the Indiana forum.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that Samsung SDI purposefully availed itself of the Indiana forum through an end-product stream of commerce by selling batteries to sophisticated customers, who then incorporated them into products available in Indiana. However, the court found a disconnect between Samsung SDI's purposeful contacts with Indiana and B.D.'s lawsuit, which stemmed from a consumer purchase of an individual battery. This disconnect precluded the exercise of specific personal jurisdiction over Samsung SDI. The court emphasized that the unilateral actions of third parties made individual batteries available to Indiana consumers, not Samsung SDI's deliberate actions. Thus, the court affirmed the dismissal of the lawsuit for lack of personal jurisdiction. View "B.D. v. Samsung SDI Co., Ltd." on Justia Law

Sysco Machinery Corporation, a Taiwanese company, accused DCS USA Corporation, a North Carolina company, of business torts related to their manufacturer-distributor relationship. Sysco alleged that after some of its employees left to form a competitor, Cymtek Solutions, Inc., DCS sold machines made by Cymtek using Sysco's confidential information. Sysco claimed these diverted contracts were worth millions of dollars.Sysco first filed suit in Taiwan, where it claims to have won a preliminary injunction against Cymtek. Sysco then filed a suit in the Eastern District of North Carolina, which it voluntarily dismissed, followed by a suit in the District of Massachusetts, which was dismissed. Finally, Sysco returned to the Eastern District of North Carolina, where it brought claims for trade secret misappropriation, copyright infringement, unfair and deceptive trade practices, and tortious interference with prospective economic advantage. The district court dismissed all claims under Rule 12(b)(6) for failure to state a claim and denied Sysco's post-judgment leave to amend its complaint.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Sysco's trade secret misappropriation claim, finding that Sysco did not plausibly allege the existence of a valid trade secret or that DCS misappropriated it. The court also affirmed the dismissal of Sysco's other claims, noting that Sysco did not sufficiently develop its arguments for copyright infringement, unfair and deceptive trade practices, and tortious interference with prospective economic advantage. Finally, the court upheld the district court's denial of Sysco's motion to alter or amend the judgment and for leave to amend the complaint, citing Sysco's repeated failure to state a claim and the potential prejudice to DCS. View "Sysco Machinery Corp. v. DCS USA Corp." on Justia Law

A mother appealed the dismissal of a neglect case brought against her by the State of Wyoming. The case involved her two children, AB and JC. The mother was arrested for drug-related charges, and the children were placed in protective custody. JC was released to his father, who had primary custody, while AB was released to his paternal grandfather and later to his father, who lived in Texas. The State filed a neglect petition, and the juvenile court held hearings, during which the mother denied the allegations. The court initially placed AB with his paternal grandfather and later with his father.The juvenile court found the children had been neglected and ordered continued placement with their fathers while the mother completed a case plan. The State moved to dismiss the neglect petition after the mother made progress on her case plan and AB's father sought custody. The juvenile court initially dismissed the petition but vacated the dismissal after the mother objected. The court later set a permanency review hearing and maintained the status quo, allowing the mother to continue working on her case plan.The State again moved to dismiss the case, noting the mother’s progress and the existence of custody agreements for both children. The juvenile court dismissed the neglect petition, and the mother appealed. The Wyoming Supreme Court found the appeal moot because the State had dismissed the neglect action, and the mother had physical custody of AB. The court concluded that any judgment would have no practical effect on the existing controversy and dismissed the appeal. The court also determined that none of the exceptions to the mootness doctrine applied in this case. View "In the Interest Of: AB and JC" on Justia Law

Ian Elliot, Cindy Elliot, and their mother, Ada Elliot, were partners in StarFire, a limited partnership owning property in Gallatin County. Cindy managed StarFire and sought to remove Ian as a general partner. Ian was appointed Ada’s guardian, and Joyce Wuertz was appointed as Ada’s conservator. Ian sued Cindy for misappropriation of funds and sought to remove Wuertz as conservator, but his motions were denied. Ada’s will divided her estate equally between Ian and Cindy, but due to their strained relationship, a special administrator was appointed instead of Ian. Ian’s subsequent motions to disqualify the special administrator were also denied.The Thirteenth Judicial District Court, Yellowstone County, appointed Andrew Billstein as the special administrator of Ian’s estate. The Objectors (Jenny Jing, Alice Carpenter, and Mike Bolenbaugh) filed an untimely appeal against this appointment, which was declined. The Objectors also opposed the settlement agreements proposed by the Special Administrator, which aimed to resolve ongoing litigation involving Ian’s estate. The District Court approved the settlements, finding them reasonable under the Pallister factors, and denied the Objectors’ motion for relief under M. R. Civ. P. 59 and 60.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decisions. The court held that the District Court had subject matter jurisdiction to approve the settlement agreements and did not abuse its discretion in doing so. The court found that the settlements were reasonable, considering the strength of the cases, the risk and expense of further litigation, and the views of experienced counsel. The court also upheld the District Court’s denial of the Objectors’ post-judgment relief motions. View "In re Estate of Elliot" on Justia Law

In 1999, Rosemary Colver executed the Colver Land Trust agreement, naming her five children as beneficiaries and appointing Bruce and Karin as co-trustees. Rosemary and her husband, Richard, retained life estates in any real property held by the Land Trust. The Land Trust sold and purchased properties over the years, with the final property being the Sanders County Property, purchased by Rosemary and Richard in 2010. Richard quitclaimed his interest to Rosemary in 2012, and Rosemary's will devised the Sanders County Property in trust for Richard and their daughter, Gretchen, allowing them to reside there until their deaths.After Rosemary's death in 2017, Bruce and Gretchen were appointed co-personal representatives of her estate. The final accounting identified the Sanders County Property as an estate asset. In 2023, Gretchen filed a petition to correct the distribution of the Sanders County Property, claiming a life estate per the will. Bruce and the Land Trust filed a cross-motion, asserting the property belonged to the Land Trust, alleging it was purchased with Land Trust funds.The Twentieth Judicial District Court, sitting in probate, denied Bruce and the Land Trust's motion for summary judgment and granted Gretchen's motion, ruling that the Land Trust did not equitably own the Sanders County Property and that Gretchen had a valid life estate per the will.The Supreme Court of the State of Montana reviewed the case. It held that the probate court lacked subject matter jurisdiction to adjudicate the Land Trust's claim of equitable ownership, as such claims are equitable in nature and fall outside the probate court's limited jurisdiction. The Supreme Court reversed the probate court's decision regarding the Land Trust's claim and remanded with instructions to dismiss it. However, it affirmed the probate court's ruling that Gretchen had a valid life estate in the Sanders County Property as per the will. View "In re R.E. Colver" on Justia Law

Lisa Johnson and Gale Miller Anderson, former Amazon warehouse employees, alleged that Amazon violated federal and Illinois wage laws by not compensating them for time spent in mandatory pre-shift COVID-19 screenings. These screenings, which included temperature checks and symptom questions, took 10-15 minutes on average and were required before employees could clock in for their shifts. Johnson and Miller Anderson argued that this time should be compensable as it was necessary for their work and primarily benefited Amazon by ensuring a safe workplace during the pandemic.The United States District Court for the Northern District of Illinois dismissed their claims under the Fair Labor Standards Act (FLSA) and the Illinois Minimum Wage Law (IMWL). The court found that the FLSA claims were barred by the Portal-to-Portal Act of 1947 (PPA), which excludes certain pre-shift activities from compensable time. The district court also concluded that the IMWL claims failed because it assumed the IMWL incorporated the PPA’s exclusions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed whether the IMWL incorporates the PPA’s exclusions for compensable time. The court noted the lack of Illinois state court decisions directly addressing this issue and found the arguments from both parties plausible. To resolve this important and unsettled question of state law, the Seventh Circuit decided to certify the question to the Illinois Supreme Court, seeking a definitive answer on whether the IMWL includes the PPA’s limitations on pre-shift compensation. The court stayed further proceedings pending the Illinois Supreme Court's decision. View "Johnson v. Amazon.com Services LLC" on Justia Law