Justia Civil Procedure Opinion Summaries

Nathan Gault was a party to a divorce action in the Medina County Court of Common Pleas. After the case concluded, the clerk charged him various fees, including a “Clerk Computer Operation” fee. Gault believed he had been overcharged, specifically challenging the additional dollar per page fee assessed for making a complete record of the proceedings. He filed a class-action complaint against the clerk, the county treasurer, and the county itself, alleging that the clerk charged him $125 in computer-operation fees, which was over $100 more than statutorily authorized.The Medina County Court of Common Pleas initially granted judgment on the pleadings for the defendants, finding Gault’s claim barred by res judicata. The Ninth District Court of Appeals reversed, holding that res judicata did not apply because the total amount owed and the methodology for determining the fees were not ascertainable from the final judgment in the divorce action, and the defendants were not parties to the prior proceedings. On remand, the trial court again ruled for the defendants, interpreting the statutes to permit the clerk to charge two dollars per page—one dollar under R.C. 2303.20(H) and an additional dollar under former R.C. 2303.201(B)(1). The Ninth District reversed, concluding that only one additional dollar total could be charged for the service, not one dollar per page.The Supreme Court of Ohio reviewed the case, consolidating a discretionary appeal and a certified conflict. The court held that, under the plain text of former R.C. 2303.201(B)(1), the clerk may charge only one additional dollar total for making a complete record under R.C. 2303.20(H), regardless of the number of pages. The Supreme Court of Ohio affirmed the judgment of the Ninth District Court of Appeals. View "State ex rel. Gault v. Medina Cty. Court of Common Pleas Clerk" on Justia Law

A city commissioner in Coffee County, Georgia, who was active in assisting voters, became involved in a heated exchange with the county’s Elections Supervisor at a polling site during early voting for the 2020 general election. After the confrontation, the police were called, and the commissioner left. Later that day, she returned to the polling site to assist another voter, prompting another police response. A City of Douglas police sergeant then issued her a criminal trespass warning, banning her from all county polling places for the remainder of the election period. When she refused to leave, she was arrested.The commissioner filed a lawsuit in the United States District Court for the Southern District of Georgia against the Elections Supervisor and Coffee County, alleging that the trespass warning violated her First Amendment rights and that her arrest violated the Fourth Amendment. The district court granted summary judgment to the defendants, finding that the police sergeant, not the Elections Supervisor or the County, had issued the trespass warning and made the arrest. The court concluded that the plaintiff failed to show that the defendants caused her alleged injuries, as required under 42 U.S.C. § 1983.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The Eleventh Circuit held that the plaintiff did not present sufficient evidence for a reasonable jury to conclude that the Elections Supervisor, rather than the police sergeant, caused her injuries. The court explained that the sergeant acted as a deliberative and autonomous decision-maker, conducting his own investigation and independently deciding to issue the trespass warning and make the arrest. Because causation is a necessary element of a § 1983 claim, and the plaintiff failed to establish it, summary judgment for the defendants was affirmed. View "Coley-Pearson v. Martin" on Justia Law

A group of insurance policyholders, known as subscribers, challenged the actions of a company that manages a reciprocal insurance exchange. The subscribers alleged that the company, acting as attorney-in-fact, breached its fiduciary duty by setting its management fee at the maximum allowed percentage and by failing to implement procedures to address conflicts of interest in 2019 and 2020. These claims arose after the company had previously changed its fee practices, which had already prompted earlier lawsuits by other subscribers over different time periods and types of fees.Prior to the current appeal, the United States District Court for the Western District of Pennsylvania had dismissed earlier lawsuits—Beltz and Ritz—on grounds including the statute of limitations and claim preclusion. In the Ritz case, the court found that the claims were precluded because they could have been brought in the earlier Beltz litigation, and that the parties were in privity. The Stephenson plaintiffs, whose claims were based on later events, filed suit in state court. The company then sought and obtained a preliminary injunction from the District Court to prevent the Stephenson plaintiffs from proceeding, arguing that the prior federal judgments had preclusive effect.The United States Court of Appeals for the Third Circuit reviewed the District Court’s order granting the preliminary injunction. The Third Circuit held that the prior federal judgments did not have claim or issue preclusive effect over the Stephenson plaintiffs’ claims, as those claims were based on events that occurred after the earlier lawsuits were filed. The court concluded that the District Court abused its discretion in granting the preliminary injunction and vacated the order, remanding the case for further proceedings. View "Erie Indemnity Co v. Stephenson" on Justia Law

A woman died after being treated at a hospital and left behind two minor children. Her mother took custody of the children following a juvenile court order that granted her authority over their care. The mother, acting as custodian, sent pre-suit notice to the health care providers she believed responsible for her daughter’s death, identifying herself as the “claimant authorizing the notice” but not mentioning the minor children. She later filed a wrongful death lawsuit, initially on her own behalf and on behalf of the children, but ultimately pursued the claim solely for the children.The Circuit Court for Anderson County first granted, then vacated, the defendants’ motions to dismiss, finding that the mother had substantially complied with the pre-suit notice requirements and that the omission of the children’s names did not prejudice the defendants. The court also found that while the children held the right to the claim, the mother was the claimant on their behalf. The Court of Appeals, however, reversed this decision, holding that the pre-suit notice was deficient because it failed to identify the children as claimants, and that this failure prejudiced the defendants. The appellate court did agree that the mother had standing to bring the suit on behalf of her grandchildren.The Supreme Court of Tennessee reviewed the case and reversed the Court of Appeals. The Court held that under Tennessee Code Annotated section 29-26-121(a)(2)(B), the “claimant authorizing the notice” is the person who asserts the right and formally approves giving pre-suit notice. Since the minor children could not act for themselves, their legal custodian was the proper person to authorize notice and file suit on their behalf. The Court concluded that the mother complied with the statutory pre-suit notice requirements and remanded the case to the circuit court. View "Denson ex rel. Denson v. Methodist Medical Center of Oak Ridge" on Justia Law

An inmate at a Wisconsin correctional institution was attacked by another prisoner, resulting in serious injury. The inmate alleged that prison officials were aware of the risk of such an attack but failed to take preventive action. After the incident, medical staff did not arrange for the inmate to see a specialist within the recommended timeframe. The inmate claimed to have filed a formal complaint about both the lack of protection and inadequate medical care by placing a completed complaint form in his cell door for collection on January 2, 2017. He did not receive an acknowledgment of receipt and, after inquiring with a complaint examiner a month later, was told no complaint had been received. He then filed a new complaint, referencing his earlier attempt and supporting it with a journal entry and correspondence to other inmates.The United States District Court for the Western District of Wisconsin granted summary judgment to the defendants, concluding that the inmate failed to exhaust administrative remedies as required by the Prison Litigation Reform Act. The court relied on the Seventh Circuit’s decision in Lockett v. Bonson, finding that the inmate’s evidence was insufficient to show timely filing and that he should have followed up sooner when he did not receive an acknowledgment.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The appellate court found that, unlike in Lockett, the inmate provided more than a mere assertion of timely filing, including a sworn declaration, a journal entry, and references in subsequent complaints. The court held that this evidence created a genuine dispute of material fact regarding whether a timely complaint was filed. The Seventh Circuit vacated the district court’s judgment and remanded the case for further proceedings, instructing the lower court to determine whether the exhaustion issue is intertwined with the merits, which could entitle the parties to a jury trial under Perttu v. Richards. View "Breyley v. Fuchs" on Justia Law

Ajay Thakore, a resident of La Jolla, California, and owner of Gopher Media LLC, a digital marketing agency, became involved in a dispute with Andrew Melone and American Pizza Manufacturing (APM), a local “take-n-bake” restaurant. The conflict began after the City of San Diego converted parking spaces outside APM to 15-minute zones. Thakore, who frequented nearby businesses and allegedly had a financial stake in a competitor, was accused of parking for extended periods and initiating contentious exchanges. Thakore and Gopher Media sued Melone and APM in the United States District Court for the Southern District of California, alleging harassment, discrimination, and unfair competition. Melone and APM counterclaimed, alleging defamation, trade libel, and unfair business practices, including claims that Thakore and Gopher Media orchestrated negative online reviews and made false statements on social media.In response to the countercomplaint, Thakore and Gopher Media filed a motion to strike under California’s anti-SLAPP statute (Cal. Civ. Proc. Code § 425.16), arguing that the alleged conduct constituted protected speech on a public issue. The United States District Court for the Southern District of California denied the anti-SLAPP motion. Thakore and Gopher Media then sought an interlocutory appeal to the United States Court of Appeals for the Ninth Circuit, challenging the denial.The United States Court of Appeals for the Ninth Circuit, sitting en banc, reviewed whether it had jurisdiction to hear an interlocutory appeal from the denial of an anti-SLAPP motion under the collateral order doctrine. The court held that such denials do not resolve issues completely separate from the merits and are not effectively unreviewable after final judgment. Accordingly, the Ninth Circuit overruled its prior decision in Batzel v. Smith, dismissed the appeal for lack of jurisdiction, and remanded the case. View "GOPHER MEDIA LLC V. MELONE" on Justia Law

In 2006, an individual was civilly committed to the North Dakota State Hospital as a sexually dangerous person. Over the years, he repeatedly sought discharge from commitment, with several applications denied and those denials affirmed on appeal. In July 2024, he again applied for discharge. The State’s expert, a clinical and forensic psychologist, testified at a review hearing, while the individual’s independent examiner did not testify. The individual’s girlfriend, a former hospital employee, also testified. The district court found that the individual’s antisocial personality disorder and history of sexually predatory conduct made him likely to reoffend, and concluded he would have serious difficulty controlling his sexual behavior if released. The court ordered continued commitment in January 2025.The individual appealed the district court’s order to the North Dakota Supreme Court, arguing that the court erred in finding clear and convincing evidence that he has serious difficulty controlling his behavior. He did not challenge the court’s findings on the statutory elements required for civil commitment, but contended that the court’s findings on his ability to control his behavior were conclusory and unsupported by specific evidence. While the appeal was pending, he filed another application for discharge, but the Supreme Court’s review was limited to the January 2025 order.The North Dakota Supreme Court held that the district court failed to make sufficiently specific findings of fact regarding whether the individual has serious difficulty controlling his behavior, as required by substantive due process and precedent. The Supreme Court reversed the district court’s order and remanded the case for further specific findings on this issue, unless the pending application for discharge renders the matter moot. View "Interest of Hoff" on Justia Law

Several pilots were terminated by United Airlines after the company implemented a COVID-19 vaccine mandate. These pilots, represented by their union, the Air Line Pilots Association (ALPA), believed that the union did not do enough to oppose United’s vaccination policies. The pilots had previously filed grievances challenging the mandate, arguing that United’s actions violated the status quo required under the Railway Labor Act because the collective bargaining agreement had expired. ALPA did not support these grievances or file its own, but did file a separate grievance arguing that termination for being unvaccinated was not justified. The pilots’ termination grievances remain pending at their request.After their terminations, the pilots sued ALPA in the United States District Court for the Northern District of Illinois, Eastern Division, alleging that the union breached its duty of fair representation by failing to adequately oppose United’s vaccine mandate. ALPA moved to dismiss the complaint, arguing that the claim was unripe and failed to state a claim. The district court denied the motion to dismiss for lack of ripeness but granted the motion to dismiss for failure to state a claim. The court also denied the pilots’ request to file an amended complaint, finding that amendment would be futile.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s decisions de novo. The Seventh Circuit held that the case was ripe because the pilots’ alleged harm—termination—had already occurred. However, the court affirmed the dismissal, holding that the pilots failed to plausibly allege that ALPA’s actions were arbitrary, discriminatory, or in bad faith, as required to state a claim for breach of the duty of fair representation. The court also affirmed the denial of leave to amend, finding that the proposed amended complaint would not cure the deficiencies. The judgment of the district court was affirmed. View "Wickstrom v Air Line Pilots Association, International" on Justia Law

The case involved two related companies and three individuals who operated a business targeting immigrants detained by U.S. Immigration and Customs Enforcement (ICE) and eligible for release on immigration bonds. The companies marketed their services as an affordable way to secure release, but in reality, they charged high fees for services that were often misrepresented or not provided. The agreements were complex, mostly in English, and required significant upfront and recurring payments. Most consumers did not understand the terms and relied on the companies’ oral representations, which were deceptive. The business was not licensed as a bail bond agent or surety, and the defendants’ practices violated federal and state consumer protection laws.After the plaintiffs—the Consumer Financial Protection Bureau, Massachusetts, New York, and Virginia—filed suit in the United States District Court for the Western District of Virginia, the defendants repeatedly failed to comply with discovery obligations and court orders. They did not produce required documents, ignored deadlines, and failed to appear at hearings. The district court, after multiple warnings and opportunities to comply, imposed default judgment as a sanction for this misconduct. The court also excluded the defendants’ late-disclosed witnesses and exhibits from the remedies hearing, finding the nondisclosures unjustified and prejudicial.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s decisions. The Fourth Circuit held that the default judgment was an appropriate sanction for the defendants’ repeated and willful noncompliance. The exclusion of evidence and witnesses was also upheld, as was the issuance of a permanent injunction and the calculation of monetary relief, including restitution and civil penalties totaling approximately $366.5 million. The court found no abuse of discretion or legal error in the district court’s rulings and affirmed the final judgment in all respects. View "Consumer Financial Protection Bureau v. Nexus Services, Inc." on Justia Law

A group of Black farmers and their association, along with several individual members, sought to file claims with the U.S. Department of Agriculture (USDA) for financial assistance under a program created by the Inflation Reduction Act of 2022. They wished to submit applications on behalf of deceased relatives who had allegedly experienced discrimination in USDA farm lending programs. The USDA, however, had a policy that excluded applications reporting only discrimination against individuals who were deceased at the time of application, making such claims ineligible for the program.The plaintiffs filed suit in the United States District Court for the Western District of Tennessee, seeking an injunction to require the USDA to accept these “legacy claims.” The district court denied their motion for a preliminary injunction and granted the government’s motion to dismiss under Rule 12(b)(6), holding that the relevant statute only authorized financial assistance to living farmers. The plaintiffs appealed this decision to the United States Court of Appeals for the Sixth Circuit and also sought an emergency injunction pending appeal, which was denied.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The appellate court held that the statutory language of § 22007(e) of the Inflation Reduction Act required the USDA to provide “assistance” to farmers who experienced discrimination, and that “assistance” was forward-looking and could not be provided to deceased individuals. The court found that the statute did not authorize compensation for past harm to deceased farmers, distinguishing “assistance” from “compensation.” The court affirmed the district court’s judgment and denied the motion for an injunction pending appeal as moot, holding that the USDA was required to reject applications filed on behalf of deceased farmers. View "Black Farmers & Agriculturalists Ass'n v. Rollins" on Justia Law