Justia Civil Procedure Opinion Summaries

The Arkansas Board of Corrections filed a complaint against the Governor of Arkansas, the Secretary of the Arkansas Department of Corrections, and the Arkansas Department of Corrections, challenging the constitutionality of Acts 185 and 659 of 2023. The Board argued that these acts unlawfully transferred its power to manage the Department of Corrections to the Governor and the Secretary, in violation of amendment 33 of the Arkansas Constitution. The Board sought a declaratory judgment and a permanent injunction to prevent the enforcement of the challenged legislation.The Pulaski County Circuit Court granted a temporary restraining order (TRO) and later a preliminary injunction, finding that the Board demonstrated irreparable harm and a likelihood of success on the merits. The court also denied motions to dismiss the Board’s complaint and to disqualify the Board’s special counsel. The appellants, including the Governor and the Secretary, appealed the preliminary injunction, arguing that the Board failed to demonstrate irreparable harm.The Supreme Court of Arkansas reviewed the case and denied the appellants' motion to remand with instructions to vacate the preliminary injunction and dismiss as moot. The court found that the dispute was not moot despite the firing of Secretary Profiri, as the Board's complaint concerned the constitutionality of the legislation, not the individual holding the Secretary position. The court also dismissed the appellants' motion to disqualify the Board’s counsel, as it was outside the scope of interlocutory review.The Supreme Court of Arkansas affirmed the circuit court’s decision, holding that the circuit court did not abuse its discretion in determining that the Board demonstrated irreparable harm in the absence of the preliminary injunction. The court emphasized that the dispute over the Board’s authority would continue until the constitutionality of the challenged legislation was resolved. View "Sanders v. Arkansas Board of Corrections" on Justia Law

Dolby Laboratories Licensing Corporation (Dolby) owns U.S. Patent No. 10,237,577, which is directed to a prediction method using an in-loop filter. Unified Patents, LLC (Unified) filed a petition for inter partes review (IPR) challenging claims 1, 7, and 8 of the patent as anticipated and obvious. Unified certified it was the sole real party in interest (RPI). Dolby identified nine other entities it believed should also have been named as RPIs. The Patent Trial and Appeal Board (Board) declined to adjudicate whether these entities were RPIs and instituted the review with Unified as the sole RPI. The Board ultimately held that Unified failed to show any of the challenged claims were unpatentable.The Board's final written decision did not address the RPI dispute, explaining that there was no evidence any of the alleged RPIs were time-barred or estopped from bringing the IPR, or that Unified purposefully omitted any RPIs to gain an advantage. Dolby appealed the Board's decision, arguing that the Board's refusal to adjudicate the RPI dispute caused various harms, including potential breaches of license agreements, conflicts of interest, improper estoppel in future proceedings, and disincentivizing Unified from filing IPRs.The United States Court of Appeals for the Federal Circuit reviewed the case. The court held that Dolby failed to establish an injury in fact sufficient to confer standing to appeal. The court found Dolby's claims of harm to be too speculative, noting that Dolby did not provide evidence of any actual or imminent injury. The court dismissed the appeal for lack of standing and did not reach the merits of Dolby's substantive challenges. View "Dolby Laboratories Licensing Corporation v. Unified Patents, LLC" on Justia Law

Ron Griffin filed a legal malpractice lawsuit against the law firm Snow Christensen & Martineau (SCM). On the last day for timely service, Griffin’s process server attempted to serve SCM’s registered agent but was unsuccessful. Instead, the process server left the complaint with Dawn Chapman, SCM’s administrator. SCM moved to dismiss the complaint, arguing that Chapman was not authorized to receive service under rule 4(d)(1)(E) of the Utah Rules of Civil Procedure, which requires service on an officer, managing or general agent, or other authorized agent. The district court agreed, finding that Chapman did not exercise general power involving judgment and discretion in her role.Griffin appealed to the Utah Court of Appeals, which reversed the district court’s decision. The appellate court, relying on previous cases Beard v. White, Green & Addison Associates, Inc. and In re Schwenke, held that Chapman was a managing or general agent because she was more than a mere employee and had some responsibility for the firm’s affairs. The court also found that it was fair to conclude that service on SCM was proper under the circumstances.SCM petitioned for certiorari review, and the Utah Supreme Court granted the request. The Supreme Court concluded that Chapman was not a managing or general agent under rule 4(d)(1)(E). The court defined a managing or general agent as someone with general power involving the exercise of judgment and discretion, which Chapman did not have in her role as an administrator. Consequently, the Supreme Court reversed the court of appeals’ decision and remanded the case for further proceedings. View "Griffin v. Snow Christensen and Martineau" on Justia Law

Christopher Gum filed a complaint against Muddy Boyz Drywall LLC in May 2024. Muddy Boyz responded with an answer and counterclaims for conversion, breach of contract, fraud, and trespass. Muddy Boyz subsequently moved for summary judgment to dismiss Gum's claims. The district court granted Muddy Boyz's motion and dismissed Gum's claims on the merits.Gum appealed the district court's judgment, arguing that there were genuine issues of material fact that precluded summary judgment. However, the North Dakota Supreme Court reviewed the case and determined that it lacked jurisdiction to hear the appeal. The court noted that the district court had not entered a final judgment resolving all the parties' claims, as Muddy Boyz's counterclaims were still pending and there was no certification under N.D.R.Civ.P. 54(b).The North Dakota Supreme Court held that without a final judgment or proper Rule 54(b) certification, there is no right to appeal. Consequently, the court dismissed the appeal for lack of jurisdiction. View "Gum v. Muddy Boyz Drywall" on Justia Law

Matthew Bare sued his former employer, Rainforest Alliance, Inc., in the Superior Court of the District of Columbia, alleging that the company failed to pay him a redundancy settlement after his position was made redundant due to a reorganization. Bare claimed that he had agreed to resign in exchange for the settlement, which was contingent upon his execution of a release-of-claims agreement. However, after Bare made critical comments about the company, Rainforest Alliance terminated him and refused to pay the settlement, leading to claims of breach of contract and violation of the District of Columbia Wage Payment and Collection Law.The Superior Court dismissed Bare's complaint with prejudice, agreeing with Rainforest Alliance that Bare had failed to allege the occurrence of a condition precedent—specifically, the execution of a release agreement. The court found that without alleging this, Bare could not claim he had earned the redundancy payment under the contract or the wage law. Bare had argued that the issue of the condition precedent was a factual matter for summary judgment or trial and that Rainforest Alliance had waived the condition by not providing a release agreement. He also requested leave to amend his complaint if the motion to dismiss was granted.The District of Columbia Court of Appeals reviewed the case and held that the trial court should have granted Bare's request to amend his complaint. The appellate court found that Bare's request to amend was his first, the case had been pending for a short time, there was no evidence of bad faith or dilatory motives, and there was no prejudice to Rainforest Alliance. The court also determined that Bare's proposed amendment, which would include allegations that Rainforest Alliance waived the condition precedent by not providing a release agreement, was not futile. Consequently, the appellate court reversed the dismissal and remanded the case for further proceedings. View "Bare v. Rainforest Alliance, Inc." on Justia Law

The case involves Ma Shun Bell, who filed a lawsuit against the law firm Friedman, Framme & Thrush (FFT), formerly known as Weinstock, Friedman & Friedman, alleging unfair trade practices and abuse of process. Bell claimed that FFT, representing First Investors Servicing Corporation (FISC), pursued a deficiency debt from her despite knowing it was not lawfully recoverable due to procedural defects in the vehicle repossession process.In the Superior Court of the District of Columbia, Bell's second amended complaint was dismissed. The court ruled that the complaint failed to allege the elements of a Uniform Commercial Code (UCC) violation, that FFT was immune from suit under the Consumer Protection Procedures Act (CPPA) and the D.C. Automobile Financing and Repossession Act (AFRA) due to its role as litigation attorneys, and that the complaint did not articulate how FFT’s conduct violated the Debt Collection Law (DCL). Additionally, the court found that Bell’s claims were barred by res judicata based on a Small Claims Court judgment in favor of FISC, with which FFT was found to be in privity.The District of Columbia Court of Appeals reviewed the case. The court concluded that Bell’s DCL cause of action could proceed, but her other causes of action were properly dismissed. The court held that the Superior Court erred in finding privity between FFT and FISC solely based on their attorney-client relationship and a contingency-fee arrangement. The court determined that the DCL claims were not barred by res judicata or collateral estoppel and that Bell had sufficiently alleged that FFT misrepresented the amount of the debt and charged excessive fees. The court affirmed the dismissal of the UCC, CPPA, and abuse of process claims but reversed the dismissal of the DCL claim, remanding the case for further proceedings. View "Bell v. Weinstock, Friedman & Friedman, PA" on Justia Law

A public interest law firm, TPM, requested certain budget-request documents from the Mayor of the District of Columbia under the D.C. Freedom of Information Act (D.C. FOIA). TPM sought documents related to the budget requests of the D.C. Public Schools (DCPS) and the Office of the State Superintendent of Education (OSSE) for fiscal year 2019, as well as other related documents. The Mayor refused to produce the draft submissions, claiming they were protected by executive privilege. TPM then filed a complaint in the Superior Court of the District of Columbia seeking the documents and their online publication.The Superior Court denied the Mayor's motion to dismiss and granted TPM's motion for summary judgment. The court ordered the Mayor to produce the requested documents and to comply with the publication requirements of D.C. Code § 2-536. The Mayor appealed, arguing that the documents were protected by executive privilege and that TPM lacked standing to enforce the publication provision.The District of Columbia Court of Appeals reviewed the case. The court rejected the Mayor's claim of executive privilege, stating that the budgetary process involves overlapping responsibilities between the Mayor and the Council, and thus does not fall under the exclusive purview of the executive branch. The court also found that TPM had standing to seek enforcement of the publication provision, as the failure to disclose the documents caused a concrete and particularized injury to TPM.The court affirmed the Superior Court's order requiring the production and online publication of the requested budget documents for fiscal years 2019 to the present. However, it vacated and remanded the portion of the order requiring the publication of other documents under D.C. Code § 2-536, instructing the lower court to clarify the scope of the required publication. View "District of Columbia v. Terris, Pravlik & Millian, LLP" on Justia Law

R & J Sheet Metal, Inc. (R&J) appealed an order directing it to pay contribution to W.E. O’Neil Construction Co. of California (WEO), Continental Casualty Company (Continental), and Western Surety Company (Western) (collectively, the WEO defendants). R&J and the WEO defendants were co-debtors on a joint and several judgment in favor of Joseph Karscig, Inc., doing business as Architectural Systems, Inc. (ASI). R&J appealed the judgment, while the WEO defendants satisfied it and sought contribution from R&J. The trial court initially took the motion off calendar due to R&J’s pending appeal. After the appeal was resolved, the WEO defendants filed a second contribution motion, including postjudgment interest, which the trial court granted, ordering R&J to pay one-half of the judgment.The Superior Court of Los Angeles County granted the WEO defendants' motion for contribution, deeming them a single entity for liability purposes and ordering R&J to pay one-half of the judgment. R&J argued the motion was untimely and that the trial court should not have allocated liability pro rata without taking evidence on the judgment debtors’ proportionate liability. R&J also contended that Western should not have been included as a single entity with WEO and Continental.The California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s order. The appellate court held that the original contribution motion was valid despite being filed during the pendency of R&J’s appeal, as taking the motion off calendar did not affect the appeal’s status quo. The court also found that the second motion was a permissible update of the original motion to include postjudgment interest. The court rejected R&J’s argument that the trial court should have determined the judgment debtors’ proportionate liability through an evidentiary hearing, holding that pro rata contribution was proper in the absence of a judgment or underlying instrument allocating liability. The court also found that R&J had forfeited its argument regarding Western’s inclusion in a single entity with WEO and Continental by failing to raise it below. View "R & J Sheet Metal v. W.E. O'Neil Construction" on Justia Law

Plaintiffs, 640 Octavia LLC and Edward Kountze, owned an apartment building in San Francisco and hired Walston Law Group to represent them in a federal unlawful detainer action against a tenant. During the trial, it was discovered that Walston's attorney had created a document with new house rules during the trial, which led to the federal judge excluding the document and giving a curative instruction to the jury. The jury found in favor of the tenant, and plaintiffs subsequently sued Walston for legal malpractice, alleging various breaches and negligence.The San Francisco Superior Court dismissed plaintiffs' complaint with prejudice due to their failure to comply with discovery orders, and the case proceeded to trial on Walston's cross-complaint for unpaid attorney fees. The jury awarded Walston $78,905.43 in damages plus $29,826.25 in prejudgment interest. Plaintiffs appealed, arguing that the trial court's pretrial order excluding evidence of their malpractice allegations was erroneous and prejudicial.The California Court of Appeal, First Appellate District, Division Five, reviewed the case and concluded that the trial court erred in applying the doctrine of claim or issue preclusion to exclude evidence supporting plaintiffs' malpractice allegations. The appellate court held that the dismissal of plaintiffs' complaint was interlocutory and not a final judgment, thus preclusion doctrines did not apply. The court found that the exclusion of evidence was prejudicial, as it prevented the jury from properly considering plaintiffs' defense that Walston's alleged malpractice excused them from paying the fees.The appellate court reversed the judgment and remanded the case for a new trial, allowing plaintiffs to present evidence of Walston's alleged malpractice. View "640 Octavia LLC v. Walston" on Justia Law

T.M. has a medical condition that causes psychosis when she ingests gluten. After an episode in 2023, she was involuntarily committed to Baltimore Washington Medical Center. Despite her and her father's request for voluntary admission, an administrative hearing led to her involuntary commitment. A clinical review panel approved forcibly injecting T.M. with antipsychotic medication, a decision affirmed by a Maryland administrative law judge. T.M. and the medical center later reached an oral agreement for her release, which was formalized in a consent order by a state court. The consent order required T.M. to follow certain conditions, including taking prescribed medications and dismissing other lawsuits.The United States District Court for the District of Maryland dismissed T.M.'s claims, citing the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court found it lacked subject matter jurisdiction over T.M.'s claims and dismissed the parents' claims for failure to state a claim. T.M.'s claims were dismissed with prejudice, while the parents' claims were dismissed without prejudice.The United States Court of Appeals for the Fourth Circuit affirmed the district court's dismissal of T.M.'s claims for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. The court held that T.M. was a state court loser seeking to overturn a state court judgment, which is barred by the doctrine. The court vacated the dismissal with prejudice and remanded with instructions to modify the judgment to dismiss T.M.'s claims without prejudice. The court also affirmed the dismissal of the parents' claims for failure to state a claim, noting that the complaint did not allege a violation of their First Amendment rights. View "T.M. v. University of Maryland Medical System Corporation" on Justia Law