Justia Civil Procedure Opinion Summaries

Chris Kelly was pulled over in August 2020 for minor traffic infractions, leading to the suspension of his driver's license. Despite efforts by a prosecutor to correct the record, Kelly was pulled over again in January 2021 for driving on a suspended license. He continued to face issues with his suspended license, which he claimed caused him to lose a job opportunity and incur over $1,000 in expenses. Kelly alleged that despite acknowledging the error, the Bureau of Motor Vehicles (BMV) failed to correct his driving record.Kelly sued the BMV in January 2023 for negligently failing to correct his driving record, seeking costs, damages, and interest. The BMV moved to dismiss the claim, arguing that the statutes did not create a private right of action. The Marion Superior Court granted the BMV's motion and dismissed the complaint without prejudice. The Indiana Court of Appeals reversed, finding that Kelly had sufficiently alleged a common-law negligence claim and that the relevant statute conferred a private right of action. The BMV petitioned for transfer to the Indiana Supreme Court.The Indiana Supreme Court reviewed the case and affirmed the trial court's dismissal. The court held that the Legislature did not intend to create a private right of action under the relevant statutes, as the material error review process and the Administrative Orders and Procedures Act (AOPA) provided independent enforcement mechanisms. Additionally, the court found that the BMV's duty to maintain driving records primarily served public safety rather than individual drivers. The court also concluded that Kelly failed to establish a common-law duty for the BMV to maintain accurate records. View "Kelly v. Indiana Bureau of Motor Vehicles" on Justia Law

Lisa Sánchez, a member of the Boise City Council, moved her residence outside of the district she represented. She was informed by the mayor and city council that she had automatically vacated her seat due to this move. The mayor subsequently appointed a new council member to fill her seat. Sánchez sued the City of Boise, claiming improper removal and seeking reinstatement, along with damages for lost salary and benefits. The City moved for judgment on the pleadings, which the district court granted, dismissing her case with prejudice. Sánchez appealed, questioning whether a city council member automatically vacates their seat under Idaho Code section 59-901(1)(e) when they unintentionally move out of their district.The district court concluded that Idaho Code section 59-901(1)(e) applies to city council members and that Sánchez's intent to remain a resident of her district was irrelevant. The court held that the statute's plain language indicated an automatic vacancy upon moving out of the district, regardless of intent. The court also found that Sánchez received all due process required under the statute.The Supreme Court of Idaho affirmed the district court's decision. The court held that Idaho Code section 59-901(1)(e) applies to city council members and that the statute's plain language does not require an inquiry into the official's intent. The court also concluded that no additional due process was required because any potential property interest in Sánchez’s elected position was forfeited when she moved out of her district. Thus, the district court's judgment on the pleadings in favor of the City was affirmed. View "Sanchez v. City of Boise" on Justia Law

CoStar Group, Inc. and CoStar Realty Information, Inc. (collectively, “CoStar”) and Commercial Real Estate Exchange, Inc. (“CREXi”) are online platforms competing in the commercial real estate listing, information, and auction markets. CoStar sued CREXi for copyright infringement, alleging that CREXi listed images and information hosted by CoStar without permission. CREXi counterclaimed on antitrust grounds, asserting that CoStar engaged in monopolistic practices to exclude competition.The United States District Court for the Central District of California dismissed CREXi’s antitrust counterclaims and directed entry of final judgment on those claims under Fed. R. Civ. P. 54(b). The district court held that CREXi failed to show CoStar had monopoly power and that the agreements at issue were not exclusive. CREXi appealed the dismissal of its antitrust counterclaims.The United States Court of Appeals for the Ninth Circuit reviewed the case and reversed the district court’s dismissal of the antitrust counterclaims. The Ninth Circuit held that CREXi successfully stated claims under §§ 1 and 2 of the Sherman Act, California’s Cartwright Act, and the Unfair Competition Law. The court found that CREXi plausibly alleged CoStar had monopoly power in the relevant markets and engaged in anticompetitive conduct by entering into de facto exclusive deals with brokers and imposing technological barriers to entry. The court concluded that a monopolist using its power to exclude competitors and maintain monopoly power violates § 2 of the Sherman Act, and using exclusive deals to do so violates § 1 of the Sherman Act and the Cartwright Act. The court also held that CREXi stated claims under the “unfair” and “unlawful” prongs of the Unfair Competition Law. The Ninth Circuit affirmed the district court’s dismissal of CREXi’s tortious interference claims as they were improperly raised. The case was remanded for further proceedings. View "COSTAR GROUP, INC. V. COMMERCIAL REAL ESTATE EXCHANGE, INC." on Justia Law

A group of plaintiffs, including individuals and community organizations, challenged the constitutionality of Louisiana’s Infrastructure Trespass Statute, arguing that amendments to the statute rendered it unconstitutionally vague and overbroad, violating the Due Process Clause and the First Amendment. The statute criminalizes unauthorized entry into critical infrastructure, including pipelines, and imposes significant penalties for violations.The United States District Court for the Western District of Louisiana granted summary judgment in favor of the defendants, including the Louisiana Attorney General, the District Attorney of the 16th Judicial District, and the Sheriff of St. Martin Parish. The district court dismissed claims against the Attorney General on sovereign immunity grounds and found that the Advocacy and Landowner Plaintiffs lacked standing. The court also dismissed the Arrested Plaintiffs' as-applied claims as moot due to the expiration of the statute of limitations for their alleged violations.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s dismissal of claims against the Attorney General, agreeing that the Ex Parte Young exception to sovereign immunity did not apply. The court also upheld the dismissal of the Advocacy and Landowner Plaintiffs for lack of standing, finding that their alleged injuries were not traceable to or redressable by the remaining defendants. The court agreed that the Arrested Plaintiffs had standing for their facial challenges but affirmed the dismissal of their as-applied claims as moot.On the merits, the Fifth Circuit concluded that the Infrastructure Trespass Statute was neither impermissibly vague nor violative of the First Amendment. The court found that the statute provided sufficient notice of prohibited conduct and did not authorize arbitrary enforcement. The court also determined that the statute was not overbroad, as it served a substantial governmental interest in protecting critical infrastructure and did not substantially burden protected speech. The court affirmed the district court’s grant of summary judgment in favor of the defendants. View "White Hat v. Murrill" on Justia Law

Eric Holmes, an Indiana state prisoner, filed a lawsuit against the Marion County Sheriff’s Office under 42 U.S.C. § 1983, alleging unlawful imprisonment in violation of the Fourteenth Amendment. Holmes sought to proceed in forma pauperis, but the Prison Litigation Reform Act (PLRA) restricts this ability for prisoners who have had three prior civil actions or appeals dismissed as frivolous, malicious, or for failing to state a claim.The United States District Court for the Southern District of Indiana found that Holmes had incurred three strikes under the PLRA. The court determined that a previous case dismissed for failure to state a claim because it was barred by Heck v. Humphrey counted as Holmes’s third strike. Holmes did not contest the validity of his first two strikes. He filed a notice of appeal and moved to proceed in forma pauperis on appeal, but a motions panel of the Seventh Circuit denied his motion, identifying a different case dismissed due to judicial immunity as his third strike.The United States Court of Appeals for the Seventh Circuit reviewed whether dismissals based on affirmative defenses, such as those barred by Heck or due to judicial immunity, count as strikes under the PLRA. The court held that a case dismissed for failure to state a claim because it was barred by Heck counts as a strike if the Heck bar is clear from the face of the complaint. Similarly, a case dismissed on judicial immunity grounds incurs a strike if the immunity defense is clear from the face of the complaint. The court affirmed the district court’s dismissal of Holmes’s current suit, concluding that both the Heck dismissal and the judicial immunity dismissal counted as strikes. View "Holmes v Marion County Sheriff's Office" on Justia Law

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