Justia Civil Procedure Opinion Summaries

Tom and Becky Carlson filed a contested case against the Texas Comptroller under the Private Real Property Rights Preservation Act (PRPRPA), alleging that the Comptroller’s approval of a wind turbine project resulted in a taking of their property. The case was referred to the State Office of Administrative Hearings (SOAH), where the Administrative Law Judge (ALJ) dismissed it as untimely filed, stating that neither the Comptroller nor SOAH had jurisdiction. The Carlsons sought clarification from SOAH, which indicated that the case would return to the Comptroller for a final decision. However, the Comptroller later asserted that the ALJ’s order was final and appealable, leading to the Carlsons' mandamus petition.The Carlsons filed a mandamus petition directly in the Supreme Court of Texas, seeking to compel the Comptroller to issue a final order so they could appeal to district court. The State initially defended the Comptroller’s position that the ALJ’s order was final. However, after the Supreme Court requested clarification on the State’s unified position, the Comptroller issued a final decision, rendering the Carlsons' petition moot.The Supreme Court of Texas held that the Comptroller’s issuance of a final decision extinguished the dispute, making the mandamus petition moot. The Court dismissed the petition for lack of jurisdiction, as there was no longer a justiciable controversy between the parties. The Carlsons agreed with this outcome, as they would now receive the judicial review they sought. View "IN RE CARLSON" on Justia Law

Mara Lindsey was involved in a car accident where she was rear-ended by Carlos Pantoja, resulting in personal injuries. Lindsey sought compensation for her medical expenses and, after settling with Pantoja’s insurer for his policy limit of $50,000, she filed a claim with her own insurer, State Farm, under her underinsured motorist (UIM) policy. Dissatisfied with State Farm’s settlement offer of $689.58, Lindsey sued State Farm under the Uniform Declaratory Judgments Act (UDJA) for declarations regarding Pantoja’s liability, her damages, and her entitlement to UIM benefits. She also sued State Farm and its claims adjuster for Insurance Code violations, alleging bad faith in handling her claim.The trial court denied State Farm’s motions to abate the extracontractual claims and to quash the deposition notice of its corporate representative. The court of appeals denied State Farm’s mandamus petitions without substantive explanation. State Farm then petitioned the Supreme Court of Texas for mandamus relief.The Supreme Court of Texas held that the trial court abused its discretion by denying State Farm’s motions. The court ruled that extracontractual claims must be abated until the insured obtains a favorable judgment on the UIM coverage, as these claims are dependent on the right to receive UIM benefits. The court also held that discovery on extracontractual matters is improper before establishing entitlement to UIM benefits. Additionally, the court found that State Farm had demonstrated that the deposition of its corporate representative was not proportional to the needs of the case, given the lack of personal knowledge and the burden of the proposed discovery.The Supreme Court of Texas conditionally granted State Farm’s petition for writ of mandamus, ordering the trial court to vacate its previous orders and grant State Farm’s motions to abate the extracontractual claims and to quash the deposition notice. View "IN RE STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY" on Justia Law

A Colorado real estate investment trust sued a Texas hedge fund and its employees for damages caused by an allegedly defamatory article published under a pseudonym. The claims were dismissed in Colorado federal court for lack of personal jurisdiction. The trust then sued in Texas state court. The defendants moved to dismiss under the Texas Citizens Participation Act (TCPA) and for summary judgment based on collateral estoppel. The trial court granted both motions.The Court of Appeals for the Fifth District of Texas reversed the trial court's decision. It held that the trial court lacked authority to grant the TCPA motion after it was overruled by operation of law and that the defendants failed to conclusively establish that collateral estoppel barred the claims. The appellate court determined that the Colorado court's findings on personal jurisdiction did not preclude the Texas claims and that the addition of new defendants in Texas further demonstrated that the issues were not identical.The Supreme Court of Texas reviewed the case. It agreed with the appellate court that the defendants were not entitled to summary judgment on their collateral estoppel defense. However, it found that the appellate court erred in holding that the order granting the TCPA motion was void. The Supreme Court of Texas concluded that the trial court's error in granting the TCPA motion outside the statutory deadline was harmless because it occurred within the time frame in which the defendants could have appealed the denial by operation of law. The case was remanded to the appellate court to address the TCPA motion on its merits. View "FIRST SABREPOINT CAPITAL MANAGEMENT, L.P. v. FARMLAND PARTNERS INC." on Justia Law

A railroad worker, Phillip Morgan, committed suicide after experiencing months of alleged harassment by his supervisor at Union Pacific Railroad Company. His wife, Kera Morgan, acting as the administrator of his estate, filed a lawsuit under the Federal Employers’ Liability Act (FELA), seeking wrongful death damages. She claimed that the harassment and stress from his job led to Phillip's emotional distress and eventual suicide.The Iowa District Court for Polk County granted summary judgment in favor of Union Pacific, concluding that Phillip's injuries were emotional and not tied to a physical impact or near physical harm, thus falling outside the scope of FELA. The court held that FELA did not cover emotional injuries unless there was a physical impact or the worker was in imminent danger of physical harm.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that under the precedent set by the United States Supreme Court in Consolidated Rail v. Gottshall, FELA incorporates common law limits on compensable injuries. The court concluded that Phillip's emotional injuries, which led to his suicide, did not meet the "zone of danger" test established in Gottshall. This test requires that the worker must have been in immediate risk of physical impact or harm to recover for emotional injuries under FELA. Since Phillip's injuries were purely emotional and not tied to any physical impact or imminent threat of physical harm, the court ruled that FELA did not provide coverage for his case. View "Estate of Morgan v. Union Pacific Railroad Company" on Justia Law

The case involves Leika Joanna García-Gesualdo, who filed an employment discrimination lawsuit against Honeywell Aerospace of Puerto Rico, Inc., and Honeywell International, Inc. García-Gesualdo alleged that Honeywell discriminated against her in violation of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA). The EEOC investigated her claims but decided not to proceed further, issuing a right-to-sue letter on March 29, 2022. García-Gesualdo filed her lawsuit on July 7, 2022, 100 days after the EEOC's decision.The United States District Court for the District of Puerto Rico dismissed García-Gesualdo's claims as time-barred, agreeing with Honeywell that the complaint was filed more than ninety days after the EEOC issued the right-to-sue letter. The court noted that García-Gesualdo's attorney received emails from the EEOC on March 29 and April 6, indicating that a new document was available on the EEOC's portal. The district court concluded that the ninety-day period began on either March 29 or April 6, making the July 7 filing untimely.The United States Court of Appeals for the First Circuit reviewed the case and reversed the district court's dismissal. The appellate court held that neither the March 29 email nor the April 6 email provided sufficient notice of García-Gesualdo's right to sue. The court emphasized that the emails did not unambiguously indicate that the EEOC had terminated its processes or that the ninety-day period to file a lawsuit had begun. Therefore, the appellate court concluded that the facts establishing untimeliness were not clear on the face of the pleadings, and the case was remanded for further proceedings. View "Garcia-Gesualdo v. Honeywell Aerospace of Puerto Rico, Inc." on Justia Law

A firearms dealer in Madison County filed a lawsuit against the Illinois Attorney General, challenging the constitutionality of a state statute known as the Firearms Industry Responsibility Act. The plaintiff argued that the statute was preempted by federal law, void for vagueness, violated the Second Amendment, and violated the Illinois Constitution's three-readings rule. Additionally, the plaintiff contended that the venue provision, which limited venue to Sangamon and Cook Counties for actions seeking declaratory or injunctive relief from a constitutional challenge to a state statute, was unconstitutional as it violated federal due process rights.The circuit court of Madison County denied the Attorney General's motion to transfer the case to Sangamon County and granted the plaintiff's motion for summary judgment on the venue issue. The court found that transferring the case to Sangamon County would be inconvenient for the plaintiff and would deprive it of its ability to effectively challenge the statute. The court concluded that the venue provision was unconstitutional as applied to individuals residing or injured outside of Cook or Sangamon Counties.The Supreme Court of Illinois reviewed the case and reversed the circuit court's decision. The court held that the venue provision did not violate the plaintiff's due process rights. The court emphasized that the inconvenience of traveling to Sangamon County did not rise to the level of a due process violation, especially considering the availability of remote court proceedings. The court also noted that the legislature has the authority to determine venue and that the state's interest in consolidating actions in certain counties was reasonable. The case was remanded for further proceedings. View "Piasa Armory, LLC v. Raoul" on Justia Law

In 2003, Sarah Ramey underwent a urethral dilation performed by Dr. Edward Dunne, which resulted in severe pain and subsequent debilitating medical conditions. Over the next fourteen years, Ramey sought medical advice from numerous doctors to determine the cause of her ailments. In 2017, Drs. Mario Castellanos and Lee Arnold Dellon linked her symptoms to the 2003 procedure. Ramey filed a lawsuit against Dr. Dunne and Foxhall Urology in 2019.The Superior Court of the District of Columbia held a bifurcated trial to determine if Ramey’s claim was barred by the statute of limitations. The jury found that Ramey failed to file her suit within the three-year statute of limitations. Ramey then filed a motion for judgment as a matter of law or, alternatively, for a new trial, arguing that the trial court erred in its rulings and jury instructions. The trial court denied her motion.The District of Columbia Court of Appeals reviewed the case. The court held that the trial court did not err in denying Ramey’s motion for judgment as a matter of law, as there was sufficient evidence for a reasonable jury to find that Ramey had received medical opinions linking her symptoms to the urethral dilation before 2017. The court also found that Ramey waived her claim regarding the jury instructions by affirmatively agreeing to them during the trial.However, the Court of Appeals held that the trial court erred in not granting a new trial based on the improper invocation of inquiry notice by appellees’ counsel during rebuttal closing arguments. The court found that the trial court’s corrective instruction was insufficient to mitigate the prejudicial impact of the improper argument. Consequently, the case was remanded for a new trial. View "Ramey v. Foxhall Urology, Chartered" on Justia Law

Virgin Valley Water District (the District) entered into a lease agreement with Paradise Canyon, LLC (Paradise Canyon) in 2011 to provide water shares for irrigating a golf course. The lease included a right of first refusal for Paradise Canyon to renew the lease, with the District having sole discretion to set rental rates after January 1, 2020. In 2019, the District increased the rental rate, leading Paradise Canyon to sue for declaratory relief and damages, alleging bad faith breach of the lease agreement.The Eighth Judicial District Court in Clark County granted partial summary judgment for Paradise Canyon on certain claims and set others for a jury trial. The jury found that the District had breached the lease in bad faith and awarded damages to Paradise Canyon. The District appealed the decision.The Supreme Court of Nevada reviewed the case and found that the lease agreement unambiguously granted the District sole discretion to set rental rates after January 1, 2020. The court held that the trial court erred in allowing the jury to interpret this unambiguous provision and in finding that the District breached the implied covenant of good faith and fair dealing. The Supreme Court also noted several procedural errors, including the trial court's improper judicial notice of its own factfinding, admission of prejudicial evidence, and unfair trial practices that limited the District's ability to present its case.The Supreme Court of Nevada reversed the portions of the trial court's judgment related to the interpretation of the lease renewal provisions and the jury's verdict on the rental rate and damages. The court affirmed the trial court's rulings on beneficial use and other uncontested matters. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "VIRGIN VALLEY WATER DIST. VS. PARADISE CANYON, LLC" on Justia Law

Barbara McNally sued Debbie-Ann Bromfield and her husband Everald Thompson in the Superior Court for multiple claims related to a property dispute. After Thompson filed for bankruptcy, McNally and Thompson reached a settlement agreement, which included dismissing McNally's pending lawsuit. McNally filed a motion for voluntary dismissal with prejudice under Super. Ct. Civ. R. 41(a)(2), which Bromfield opposed, seeking a decision on the merits through her own summary judgment motion. The trial court granted McNally’s motion to dismiss with prejudice and denied Bromfield’s summary judgment motion as moot, reasoning that Bromfield would not suffer any legal detriment from the dismissal.Bromfield appealed, arguing that the trial court abused its discretion in granting McNally’s motion for voluntary dismissal, claiming it caused her legal prejudice. The District of Columbia Court of Appeals reviewed the case. The court noted that Bromfield was not "aggrieved" by the dismissal with prejudice of the claims against her, as she had effectively prevailed in all relevant respects. The court emphasized that it has an independent obligation to ensure its jurisdiction and that Bromfield did not suffer an infringement or denial of legal rights.The court held that Bromfield’s desire for vindication did not constitute a cognizable legal injury and that her potential future claims, such as a malicious prosecution suit, did not provide grounds for appeal. The court concluded that Bromfield had secured an unmitigated victory in the underlying proceedings and dismissed her appeal for lack of jurisdiction. View "Bromfield-Thompson v. McNally" on Justia Law

The appellants, Robin and Louie Joseph Aquilino, filed for Chapter 7 bankruptcy in April 2020 and retained the law firm Spector Gadon Rosen & Vinci P.C. (Spector Gadon) as their counsel. They agreed to pay a flat fee of $3,500 and a $335 filing fee, which Spector Gadon disclosed to the Bankruptcy Court. However, due to the complexity of the case, Spector Gadon billed the Aquilinos for additional post-petition services, resulting in a fee agreement of $113,000, which was not disclosed to the Bankruptcy Court as required by 11 U.S.C. § 329(a) and Bankruptcy Rule 2016(b).The Bankruptcy Court for the District of New Jersey found that Spector Gadon violated the disclosure requirements and sanctioned the firm by ordering the disgorgement of collected fees and cancellation of the remaining fee agreement. Spector Gadon appealed, and the United States District Court for the District of New Jersey reversed the Bankruptcy Court's decision, concluding that Spector Gadon was entitled to a jury trial under the Seventh Amendment.The United States Court of Appeals for the Third Circuit reviewed the case and determined that the Bankruptcy Court had "core" jurisdiction over the fee disclosure issue under 28 U.S.C. § 157(b)(1). The Third Circuit held that the Seventh Amendment did not entitle Spector Gadon to a jury trial in the § 329(a) proceeding because the sanctions imposed were equitable in nature, designed to restore the status quo, and did not involve legal claims. The Third Circuit also found that the Bankruptcy Court did not abuse its discretion in imposing sanctions, as it considered all relevant factors, including the Debtors' misconduct.The Third Circuit reversed the District Court's judgment and reinstated the Bankruptcy Court's sanctions order. View "In re Aquilino" on Justia Law