Justia Civil Procedure Opinion Summaries

Edward B. Spencer, an indigent and incarcerated individual, filed multiple lawsuits against various California prison officials. He initially proceeded in forma pauperis (IFP) in each case. Spencer had previously filed numerous lawsuits while incarcerated, and he conceded that two of those actions resulted in strikes under the Prison Litigation Reform Act (PLRA). However, he disputed whether two other actions, which he voluntarily dismissed, should count as strikes.The United States District Court for the Eastern District of California revoked Spencer's IFP status in four cases, finding that he had four strikes, including the two voluntary dismissals. The district court adopted the magistrate judge's findings and recommendations, which concluded that the voluntary dismissals counted as strikes under the PLRA.The United States Court of Appeals for the Ninth Circuit reviewed the district court's revocation of Spencer's IFP status. The Ninth Circuit held that voluntary dismissals under Federal Rule of Civil Procedure 41(a)(1) do not constitute strikes under the PLRA. The court reasoned that the "on the grounds that" clause in 28 U.S.C. § 1915(g) requires grounds to be decided by a court, and voluntary dismissals do not have grounds decided by a court. Therefore, Rule 41(a)(1) voluntary dismissals cannot count as strikes because they are never "on the grounds that" the case was frivolous, malicious, or failed to state a claim.The Ninth Circuit reversed the district court's revocation of Spencer's IFP status in each of the four cases on appeal and remanded for further proceedings. The court did not address any other issues urged by the parties. View "Spencer v. Milan" on Justia Law

In April 2022, six-year-old Emory Sayre was killed by her school bus in Parker County, Texas. The bus was manufactured by Blue Bird Body Company and sold by Rush Truck Centers of Texas to Brock Independent School District. Emory's parents, Sean and Tori Sayre, filed a lawsuit in Dallas County against Rush Truck and Blue Bird, asserting various claims including strict liability and negligence. They argued that venue was proper in Dallas County due to several activities related to the bus sale occurring there.The trial court denied the defendants' motion to transfer venue to Parker or Comal County. Rush Truck and Blue Bird filed an interlocutory appeal, which the Court of Appeals for the Fifth District of Texas affirmed, holding that a substantial part of the events giving rise to the claims occurred in Dallas County.The Supreme Court of Texas reviewed the case and focused on whether the Court of Appeals had jurisdiction to entertain the interlocutory appeal. The Court held that Section 15.003(b) of the Texas Civil Practice and Remedies Code permits interlocutory appeals only in cases where a plaintiff’s independent claim to venue is at issue. Since the Sayres asserted identical claims based on identical facts with identical venue grounds, the trial court did not need to determine whether each plaintiff independently established proper venue. Therefore, the Court of Appeals erred in taking jurisdiction of the interlocutory appeal.The Supreme Court of Texas vacated the judgment of the Court of Appeals and remanded the case to the district court for further proceedings. View "Rush Truck Centers of Texas, L.P. v. Sayre" on Justia Law

Megan E. Hawk and David P. Hawk were involved in a marital dissolution action where the district court ordered David to pay Megan a cash equalization payment of nearly $3 million in eight annual installments, with interest accruing at a rate of 7.264% per annum. Megan filed a motion to alter or amend the decree, which the court partially granted, specifying that each installment would include accrued interest. Megan later filed a motion requesting the court to clarify that payments be made through the court clerk and to attach an amortization schedule.The district court for Douglas County initially modified the decree to specify the payment schedule and interest accrual. After the court's term ended, Megan filed another motion, which the court treated as a request to alter or amend the judgment rather than a nunc pro tunc order. The court held a hearing and clarified that interest would start accruing from the date the first payment was due, not from the date of the decree. The court also directed the court clerk to record the judgment and calculate the balance and interest.The Nebraska Supreme Court reviewed the case de novo and determined that the district court had the inherent power to modify its judgment within the term, as extended by Neb. Rev. Stat. § 25-2001(1). The court held that the rights of a party seeking relief under this statute become fixed at the time the motion is filed, even if the disposition occurs after the term ends. The court found no abuse of discretion in the district court's decision to modify the interest accrual date and affirmed the order. View "Hawk v. Hawk" on Justia Law

A Nebraska county (Hayes) sought reimbursement from a neighboring county (Frontier) for half the cost of replacing a bridge under Neb. Rev. Stat. § 39-827 et seq. Hayes claimed the bridge was on a county line road, thus requiring shared expenses. Frontier's board of commissioners denied the claim, arguing the bridge was not on a county line road and that Frontier was not equally interested in the bridge. Hayes then filed a petition in error in the district court, seeking review of the board's decision.The district court reviewed the case and found that Hayes had not provided sufficient evidence to support its claim. Specifically, the court noted that Hayes did not request an evidentiary hearing before the Frontier Board, resulting in a lack of formal proof regarding the bridge's location. The court concluded that the only evidence in the record was Hayes' claim and its attachments, which were insufficient to establish the bridge's location as required by § 39-827. Consequently, the district court denied and dismissed Hayes' petition in error.On appeal, the Nebraska Supreme Court reviewed whether the Frontier Board acted within its jurisdiction and whether its decision was supported by sufficient relevant evidence. The court found that Hayes failed to meet its burden of proof to demonstrate that the bridge was on a county line road as defined by § 39-1403. The court also noted that the Road Agreement between Hayes and Frontier did not conclusively establish the bridge's location for the purposes of the bridge statutes. The Supreme Court affirmed the district court's judgment but modified the disposition from "denied and dismissed" to "affirmed." View "County of Hayes v. County of Frontier" on Justia Law

Lea and Ann Brent were married in 1953 and divorced in 1983. As part of their divorce, Lea agreed to pay Ann $5,600 per month in permanent periodic alimony until her death or remarriage. Ann died in 2015, never having remarried. Lea began paying less than the required amount in 2002, but Ann never filed a contempt action for the unpaid alimony. Lea died in 2021, and Ann’s Estate filed a probate claim against Lea’s Estate for unpaid alimony totaling $358,700, covering the period from 2002 to 2015.The Washington County Chancery Court found that the claim for unpaid alimony was valid but limited it to the period from July 2014 to November 2015 due to the seven-year statute of limitations. The court awarded Ann’s Estate $139,104, which included the unpaid alimony for that period plus 8 percent interest per annum. However, the court denied Lea’s Estate credit for partial alimony payments totaling $51,000 made between July 2014 and November 2015 and for a $75,143.28 life insurance proceeds payment made to Ann’s Estate in 2019.The Supreme Court of Mississippi reviewed the case and found that the chancery court erred in denying Lea’s Estate credit for the partial alimony payments and the life insurance proceeds payment. The Supreme Court held that the total amount of credit exceeded the total amount owed for the relevant period, leaving no unpaid alimony to award Ann’s Estate. Consequently, the Supreme Court reversed the chancery court’s decision and rendered judgment in favor of Lea’s Estate. View "In re The Estate of Brent v. The Estate of Brent" on Justia Law

Richard Mooney sued his former employer, Roller Bearing Company of America (RBC), alleging violations of the Family and Medical Leave Act (FMLA) and the Washington Family and Medical Leave Act (WFMLA). Mooney claimed his termination was due to his age, depression, and decision to take leave under the FMLA, while RBC argued it was due to a reduction in force in response to the COVID-19 pandemic. Mooney filed the lawsuit in King County Superior Court, and RBC removed the case to federal court under federal question and diversity jurisdiction. The jury found RBC liable and awarded Mooney $160,000 in damages.The United States District Court for the Western District of Washington calculated prejudgment interest based on a fluctuating federal rate. Mooney appealed, arguing that the higher state rate should have applied. The district court concluded it had discretion to select the appropriate rate and chose the federal rate, finding it the most accurate way to compensate Mooney for the lost use of his wages.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that when a judgment is based equally on both state and federal claims, the district court has discretion to select a proper prejudgment interest rate. The Ninth Circuit affirmed the district court's decision, agreeing that the fluctuating federal rate was appropriate given the circumstances, including Mooney's litigation strategy and the combined nature of the state and federal claims. The court found no error in the district court's application of the federal rate and affirmed the judgment. View "Mooney v. Roller Bearing Company of America" on Justia Law

The case involves multiple plaintiffs who sued Khalifa Hifter under the federal Torture Victim Protection Act for his actions as the commander of the Libyan National Army. The plaintiffs sought to hold Hifter liable for alleged torture and extrajudicial killings of their family members in Libya. The lawsuits were filed in the United States District Court for the Eastern District of Virginia over a 15-month period.In the district court, Hifter moved to dismiss the first two cases, and the court granted those motions in part and denied them in part. Hifter later moved to dismiss the third case, and the court again granted the motion in part and denied it in part. The district court eventually consolidated all three cases for discovery and pretrial matters. After cross-motions for summary judgment, the district court dismissed all three suits with prejudice, citing lack of personal jurisdiction over Hifter.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court dismissed Hifter’s cross appeals in Nos. 24-1425, 24-1427, and 24-1429, as they merely sought affirmance of the district court’s judgments on alternative grounds. In Nos. 24-1422 and 24-1426, the court reversed the district court’s judgment, finding that Hifter waived his personal jurisdiction defense by failing to timely assert it in his pre-answer motions. The cases were remanded for further proceedings.In No. 24-1423, the Fourth Circuit concluded that Hifter properly raised a personal jurisdiction defense and that the district court correctly granted summary judgment due to the plaintiffs' failure to make a prima facie showing of personal jurisdiction. However, the court vacated the judgment and remanded with instructions to modify the judgment to state that the dismissal is without prejudice. View "al-Suyid v. Hifter" on Justia Law

Plaintiffs, victims and families of victims of terrorist attacks carried out by Hamas between 2001 and 2003, sued BLOM Bank SAL under the Anti-Terrorism Act, alleging that the bank aided and abetted the attacks by providing financial services to Hamas-affiliated customers. BLOM argued that the complaint failed to state a claim, and plaintiffs affirmed they would not seek to amend their complaint if dismissed. The District Court dismissed the complaint with prejudice, finding that plaintiffs had not adequately alleged BLOM's general awareness for aiding-and-abetting liability and denied leave to amend due to plaintiffs' refusal to amend earlier.The Second Circuit affirmed the dismissal, noting that the District Court applied too stringent a standard for general awareness but concluded that plaintiffs' claims still failed under the correct standard. Plaintiffs then moved under Federal Rule of Civil Procedure 60(b)(6) to vacate the final judgment to file an amended complaint. The District Court denied the motion, ruling that the Second Circuit’s clarification did not constitute "extraordinary circumstances" required for Rule 60(b)(6) relief and that plaintiffs' prior choices not to amend counseled against relief. The Second Circuit reversed, holding that district courts must balance Rule 60(b)’s finality principles with Rule 15(a)’s liberal amendment policy.The Supreme Court of the United States held that relief under Rule 60(b)(6) requires extraordinary circumstances, and this standard does not become less demanding when the movant seeks to reopen a case to amend a complaint. A party must first satisfy Rule 60(b) before Rule 15(a)’s liberal amendment standard can apply. The Court reversed the Second Circuit’s decision, emphasizing that the District Court correctly applied the Rule 60(b)(6) standard and provided substantial justification for its conclusion. The case was remanded for further proceedings consistent with this opinion. View "BLOM Bank SAL v. Honickman" on Justia Law

Amgen Inc., a biotechnology company, holds patents in the U.S. and South Korea for denosumab, a drug used in treating certain bone cancers. Amgen filed patent infringement suits against Celltrion Inc. (Celltrion Korea) in both countries. To support its case, Amgen sought discovery from Celltrion Korea’s subsidiary, Celltrion USA, located in New Jersey. Amgen filed an application under 28 U.S.C. § 1782 in the District of New Jersey to subpoena Celltrion USA for documents and testimony related to Celltrion Korea’s denosumab products.The Magistrate Judge granted Amgen’s § 1782 application, rejecting Celltrion USA’s argument that § 1782 cannot compel it to produce information held by its foreign parent company. The Judge also found the request not unduly burdensome and ordered the parties to meet and confer to agree on a confidentiality agreement. The District Court affirmed the Magistrate Judge’s order, leading Celltrion USA to appeal.The United States Court of Appeals for the Third Circuit reviewed the case to determine if the order under § 1782 was final and thus appealable under 28 U.S.C. § 1291. The Court concluded that the order was not final because the scope of permissible discovery had not been conclusively defined. The Court emphasized that without a definite scope of discovery, it could not properly review whether the District Court had abused its discretion. Consequently, the Third Circuit dismissed the appeal for lack of jurisdiction, holding that an order granting discovery under § 1782 but leaving the scope of discovery unresolved is not a final order under § 1291. View "Amgen Inc v. Celltrion USA Inc" on Justia Law

Matthew Kale sued his employer, Aero Simulation, Inc. (ASI), alleging religious and disability discrimination under Title VII of the Civil Rights Act, the Americans with Disabilities Act (ADA), the Religious Freedom Restoration Act (RFRA), the Constitution, and state law. ASI required all employees to receive the Covid-19 vaccine, with non-compliance resulting in disciplinary action, including termination. Kale requested a religious exemption, citing his belief that his body is a temple of the Holy Spirit and should not be subjected to unwanted intrusions. ASI denied his request, and Kale was terminated. He filed a charge with the EEOC, which issued a right to sue letter.The United States District Court for the District of South Dakota dismissed Kale’s claims, ruling that he failed to plausibly plead religious beliefs conflicting with ASI’s Covid-19 policy, did not allege that ASI regarded him as disabled due to his unvaccinated status, and that his proposed amended complaint was futile. Kale appealed the dismissal of his federal law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court’s dismissal, holding that Kale failed to allege facts showing that ASI’s testing requirement conflicted with his bona fide religious beliefs. The court noted that Kale’s complaint did not adequately connect his objection to testing with specific religious principles. Additionally, the court found that Kale did not exhaust his administrative remedies for his ADA claim, as he only asserted religious discrimination in his EEOC charge. The court also upheld the denial of Kale’s motion to amend his complaint, deeming it futile as it contained the same deficiencies as the original complaint. The judgment was affirmed. View "Kale v. Aero Simulation, Inc." on Justia Law