Justia Civil Procedure Opinion Summaries

Delanor L. Macksyn, an inmate at the Richland Correctional Institution, filed an original action against Department of Rehabilitation and Correction employees Kenneth Spencer, LeAnn Walker-Williams, and Kelly Rose. Macksyn sought a writ of mandamus to compel the production of records in response to multiple public-records requests and an award of statutory damages. His requests included emails, kites, grievances, and video footage.The lower court proceedings involved Spencer assuming responsibility for answering public-records requests and responding to Macksyn’s various requests. Spencer provided some of the requested records, including kites and grievances, and allowed Macksyn to view the requested video footage. However, there was a dispute over whether all requested records, particularly emails, had been produced.The Supreme Court of Ohio reviewed the case and found that while Spencer had provided some records, there was insufficient evidence to confirm that all requested emails had been produced. The court issued a limited writ of mandamus ordering the respondents to, within 21 days, either produce the requested emails and certify the date of production or certify that no responsive emails exist. The court deferred ruling on Macksyn’s request for statutory damages until the respondents complied with the limited writ. The court also denied several motions filed by Macksyn, including motions to strike respondents’ brief and for judicial notice. View "State ex rel. Macksyn v. Spencer" on Justia Law

The case involves Pavan V. Parikh, the Hamilton County clerk of courts, who implemented a policy in May 2022 that eliminated remote online access to court records in residential-eviction cases older than three years from the date of judgment satisfaction. Parikh argued that this policy was to prevent misuse of court documents by the public, such as employers and landlords. The judges of the Hamilton County Municipal Court objected to this policy and issued Administrative Order No. 23-45 in October 2023, directing Parikh to rescind the policy and restore online access to the records. Parikh did not comply, leading to the judges threatening contempt proceedings.Parikh filed a complaint for a writ of prohibition in the First District Court of Appeals to prevent the judges from enforcing the administrative order and holding him in contempt. The judges counterclaimed, requesting a writ of mandamus to compel Parikh to comply with their order. The court of appeals, with visiting judges from the Twelfth District, ruled in favor of the judges, granting their motion for judgment on the pleadings on the prohibition claim and issuing a writ of mandamus ordering Parikh to rescind his policy and comply with the administrative order.The Supreme Court of Ohio reviewed the case and affirmed the court of appeals' judgment. The court held that Parikh had a clear legal duty under R.C. 1901.31(E) to comply with the judges' administrative order. The court also determined that Parikh had an adequate remedy through appeal if held in contempt, and the judges did not patently and unambiguously lack jurisdiction to hold him in contempt for noncompliance. Therefore, the court affirmed the denial of Parikh's request for a writ of prohibition and the granting of the judges' request for a writ of mandamus. View "State ex rel. Parikh v. Berkowitz" on Justia Law

Ronald Ayers, an inmate at the Lake Erie Correctional Institution, petitioned for a writ of mandamus to compel Laura Sackett, the prison's records custodian, to produce public records. Ayers requested a copy of the Department of Administrative Services’ general retention schedule and video footage from a security search of his cell on August 31, 2023. Sackett denied the requests, claiming the retention schedule was not specific to the Department of Rehabilitation and Correction and that the video footage was not preserved as it did not document a "qualifying event."The Supreme Court of Ohio reviewed the case after Ayers filed his petition. The court found that Ayers did not need to exhaust administrative remedies before filing for mandamus. The court determined that the requested video footage did not exist at the time of Ayers' request, as it had been recorded over, and thus Sackett correctly denied this request. However, the court found that the general retention schedule was a public record received and used by the prison, and Sackett's denial of this request was not justified.The Supreme Court of Ohio granted Ayers' writ of mandamus in part, ordering Sackett to produce the retention schedule. The court awarded Ayers $1,000 in statutory damages for the improper denial of the retention schedule but denied his request for court costs due to his affidavit of indigency. The court denied Ayers' motions for discovery as moot. View "State ex rel. Ayers v. Sackett" on Justia Law

Michael Reilly approached William G. Harris III, a developmentally disabled individual, to purchase his home for $30,000, significantly below its appraised value. Harris, unable to understand the value of money, signed the contract. Reilly attempted to finalize the sale but was informed by the Sheltered Workshop, where Harris was a client, of Harris's disability and was denied further contact with him. Harris passed away in December 2021, and Reilly sued Harris's Estate for specific performance of the contract. The Estate counterclaimed, alleging negligence, violations of the Montana Consumer Protection Act (CPA), and sought punitive damages.The Second Judicial District Court, Butte-Silver Bow County, dismissed Reilly's complaint without imposing sanctions and denied the Estate's request for treble damages and attorney fees. The jury awarded the Estate $28,900 in compensatory damages and $45,000 in punitive damages. Reilly moved to dismiss his complaint just before the trial, which the District Court granted, but the Estate objected, seeking sanctions for the late dismissal. The District Court did not rule on the objection. The jury found Reilly exploited Harris and violated the CPA, awarding damages accordingly. The District Court later denied the Estate's request for treble damages and attorney fees, citing the substantial jury award as sufficient.The Supreme Court of the State of Montana reviewed the case. It held that the District Court abused its discretion by dismissing Reilly's complaint without imposing sanctions, given the late timing and the Estate's incurred costs. However, it affirmed the District Court's denial of treble damages and attorney fees under the CPA, agreeing that the jury's award was substantial. The Supreme Court affirmed the compensatory and punitive damages awarded to the Estate and remanded the case to the District Court to award the Estate its full costs and attorney fees incurred before Reilly's motion to dismiss. View "Harris Estate v. Reilly" on Justia Law

A fifty-nine-year-old General Manager (GM) at a Chili’s restaurant in Nashville, Tennessee, was terminated and replaced by a thirty-three-year-old with no managerial experience. The employer, Brinker International, Inc., claimed the termination was due to the GM creating a toxic "culture" and not "living the Chili’s way," despite the restaurant being one of the top performers in the market. The GM alleged that the termination was due to age discrimination, as he was the oldest manager in the region and believed Brinker was systematically replacing older employees with younger ones.The United States District Court for the Middle District of Tennessee granted summary judgment in favor of Brinker, accepting the company's explanation of "culture" as a legitimate, non-discriminatory reason for the termination. The court found that the GM could not sufficiently rebut this explanation to show it was pretext for age discrimination. The court also granted in part and denied in part the GM's motion for sanctions due to Brinker’s spoliation of evidence, awarding fees and costs but not excluding the TMR Report, which documented the termination decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the TMR Report could not be authenticated under Federal Rule of Evidence 901 and was therefore inadmissible. The court vacated the district court’s order on sanctions and instructed it to consider whether additional sanctions beyond fees and costs were appropriate. The appellate court also reversed the district court’s grant of summary judgment for Brinker, finding that the GM had provided sufficient evidence to rebut Brinker’s explanation and create a genuine issue of material fact regarding age discrimination. The court affirmed the district court’s denial of the GM’s motion for summary judgment. View "Kean v. Brinker Int'l, Inc." on Justia Law

A group of staffing companies in Texas challenged a memorandum issued by the former General Counsel of the National Labor Relations Board (NLRB), Jennifer Abruzzo. The memorandum outlined a plan to urge the NLRB to reverse its holding in a previous case, Babcock, which allowed employers to compel employees to attend meetings where they were urged to reject union representation. The staffing companies argued that the memorandum violated their First Amendment rights by restricting their speech about unionization and sought an injunction and declaratory judgment against its enforcement.The United States District Court for the Eastern District of Texas dismissed the case for lack of jurisdiction, stating that the plaintiffs were challenging unreviewable prosecutorial decisions by the NLRB General Counsel, that the NLRA's scheme precluded jurisdiction, and that the plaintiffs lacked standing. The staffing companies appealed, arguing that the district court erred in its dismissal and that they had standing because the memorandum applied to them and was a final agency action reviewable under the Administrative Procedure Act (APA).The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the staffing companies lacked standing. The court noted that the plaintiffs had not provided evidence of a credible threat of enforcement of the memorandum causing them direct injury. The court also found that the plaintiffs did not demonstrate an intent to engage in conduct regulated by the memorandum, as there was no known unionization attempt at their businesses. The court concluded that the plaintiffs failed to establish a credible threat of enforcement or a substantial risk of future injury.The Fifth Circuit affirmed the district court's dismissal of the case for lack of standing. View "Burnett Specialists v. Cowen" on Justia Law

Ammar al-Baluchi, a Pakistani national, has been detained at the U.S. naval base in Guantánamo Bay since 2006. He is accused of supporting the September 11, 2001, attacks as a senior member of al-Qaeda. In 2008, al-Baluchi filed a habeas corpus petition in federal district court. In 2022, he moved to compel the government to convene a Mixed Medical Commission to assess his eligibility for repatriation due to alleged torture and resulting serious health issues. The district court denied his request, ruling that detainees captured during non-international armed conflicts are not entitled to such examinations under the Third Geneva Convention or Army Regulation 190-8.The United States District Court for the District of Columbia initially stayed al-Baluchi’s habeas case pending the outcome of his military commission trial. After temporarily lifting the stay to consider his motion for a Mixed Medical Commission, the court denied the motion, leading al-Baluchi to appeal the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court determined that it lacked jurisdiction to review the district court’s nonfinal order. The court found that al-Baluchi did not demonstrate that the denial of his motion had the practical effect of denying injunctive relief or that it caused serious or irreparable harm requiring immediate review. The court noted that even if a Mixed Medical Commission found al-Baluchi eligible for repatriation, the government retained discretion to delay repatriation until the completion of his military commission proceedings. Consequently, the appeal was dismissed for lack of jurisdiction. View "Al-Baluchi v. Hegseth" on Justia Law

This case involves a dispute over the sale of real property. Patricia Ann Scott, the seller, previously sued real estate agent Kaylee Schnelle for professional negligence, alleging mishandling of the sale. Schnelle's motions for summary judgment and directed verdict were denied, and the jury found in her favor. Subsequently, Schnelle filed a malicious prosecution claim against Scott and her attorneys, arguing they lacked probable cause and conspired against her. The defendants moved to dismiss, citing the prior denials as evidence of probable cause.The district court denied the motion to dismiss, stating that the previous denials were factors to consider but did not conclusively establish probable cause. The court found Schnelle's allegations sufficient to support her claim. The Colorado Court of Appeals affirmed this decision, agreeing that the denials did not create a rebuttable presumption of probable cause.The Supreme Court of Colorado reviewed the case to determine if such denials should create a rebuttable presumption of probable cause. The court concluded that while the denials are factors in the probable cause analysis, they do not create a rebuttable presumption. The court emphasized the need for a careful, case-by-case analysis rather than a bright-line rule. Consequently, the court affirmed the judgment of the court of appeals, holding that the denials of summary judgment and directed verdict motions do not establish probable cause as a matter of law. View "Cantafio v. Schnelle" on Justia Law

In this case, the appellant, Brendan Linton, was riding his bicycle on a heavily trafficked state highway in Butler Township, Pennsylvania. The highway had one lane of travel in each direction, with a speed limit varying from 45 to 55 mph. Pennsylvania State Trooper Joshua Osche observed Linton riding his bicycle at speeds significantly lower than the posted speed limits, causing a buildup of traffic behind him. Despite multiple vehicles successfully passing Linton, Trooper Osche eventually initiated a traffic stop, citing Linton for impeding the normal and reasonable movement of traffic under Section 3364(b)(2) of the Vehicle Code.The Court of Common Pleas of Butler County found Linton guilty of violating Section 3364(b)(2), concluding that he should have moved to the berm area to allow faster-moving traffic to pass. The court imposed a $25 fine. The Superior Court of Pennsylvania affirmed the judgment, agreeing that Linton's failure to use the berm constituted a violation of the statute.The Supreme Court of Pennsylvania reviewed the case to determine whether Section 3364(b)(2) requires pedalcyclists to leave the roadway whenever faster-moving traffic approaches. The Court concluded that the statute calls for a fact-bound assessment of reasonableness, taking all relevant considerations into account. The Court held that there may be circumstances under which a factfinder could determine that the "reasonable efforts" a pedalcycle operator must exert include temporarily leaving the roadway. However, the Court rejected the rigid interpretations of both the appellant and the lower courts, emphasizing that the statute does not mandate pedalcyclists to always vacate the roadway for faster-moving traffic.The Supreme Court reversed the Superior Court's order and remanded the case for further proceedings consistent with its opinion, instructing the lower court to reconsider the sufficiency of the evidence using the proper legal standard. View "Commonwealth v. Linton" on Justia Law

Duke Energy Ohio, Inc. applied to the Public Utilities Commission of Ohio (PUCO) for an increase in natural gas distribution rates and approval of an alternative-rate plan. The Office of the Ohio Consumers’ Counsel (OCC) filed an application for rehearing, which PUCO initially extended through a tolling order. However, following a decision in a related case, In re Application of Moraine Wind, L.L.C., it was determined that PUCO lacked the authority to issue such tolling orders, meaning the OCC’s application for rehearing was denied by operation of law after 30 days.The OCC did not appeal the denial by operation of law but instead filed a second application for rehearing challenging PUCO’s tolling order practice. After the Moraine Wind decision, PUCO journalized an entry on September 4, 2024, acknowledging the denial by operation of law and closing the case. The OCC then filed a third application for rehearing, which PUCO denied on October 2, 2024. The OCC subsequently filed a notice of appeal on October 25, 2024.The Supreme Court of Ohio reviewed the case and denied Duke Energy’s motion to dismiss the appeal for lack of jurisdiction. The court held that under R.C. 4903.11, the OCC’s appeal was timely because it was filed within 60 days of PUCO’s journalized entry on September 4, 2024, which constituted an “entry upon the journal of the commission of the order denying an application for rehearing.” Thus, the OCC properly invoked the court’s jurisdiction, and the appeal was allowed to proceed. View "In re Application of Duke Energy Ohio, Inc." on Justia Law