Justia Injury Law Opinion Summaries

Mike Dennis developed mycosis fungoides, a subtype of non-Hodgkin’s lymphoma, after regularly applying Roundup, a glyphosate-based herbicide manufactured by Monsanto, for approximately 20 years. Dennis claimed his cancer resulted from exposure to Roundup, which he alleged was sold and marketed without adequate warnings about its carcinogenic risks, despite Monsanto’s knowledge of the potential danger. He brought claims for design defect, failure to warn (under both negligence and strict liability), and negligence. At trial, the jury found that Monsanto was liable for failing to warn about the cancer risk, determining Monsanto knew or should have known of the risk, failed to provide adequate warnings, and acted with malice or oppression. The jury awarded Dennis $7 million in economic damages and $325 million in punitive damages.Following the verdict, Monsanto moved for a new trial and for judgment notwithstanding the verdict (JNOV). The Superior Court of San Diego County denied Monsanto’s requests to overturn the liability findings but reduced the punitive damages award from $325 million to $21 million, finding the original award disproportionate to the compensatory damages. Monsanto timely appealed, arguing that Dennis’s failure to warn claims were preempted by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and that the punitive damages were excessive and unconstitutional.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that FIFRA does not preempt state law failure to warn claims that parallel federal misbranding requirements, in line with United States Supreme Court precedent and California decisions. The court also found that the punitive damages award, as reduced by the trial court, did not violate due process, as it was based on highly reprehensible conduct directly related to Dennis’s harm. The Court of Appeal affirmed the judgment in full. View "Dennis v. Monsanto Co." on Justia Law

In April 2020, a store manager working for a retail employer contracted COVID-19, followed by a stroke one week later. He alleged that both the infection and the subsequent stroke were caused by exposure to COVID-19 while working in a high-traffic store environment during the early months of the pandemic. The claimant described frequent, close interactions with the public and stated that employer-provided protective measures, such as masks and sneeze guards, were not implemented until mid-April. The claimant also testified that he had minimal contact with others outside of work. Medical evidence linked the stroke to the COVID-19 infection, and it was noted that the claimant lacked typical stroke risk factors.The Workers’ Compensation Law Judge initially established the claim as an occupational disease with a consequential stroke. On review, the New York State Workers’ Compensation Board modified the determination, finding instead that the claimant suffered an accidental injury, not an occupational disease, but otherwise affirmed the compensability of both injuries. The Board applied its “prevalence” framework, which looks to whether the workplace presented an extraordinarily high risk of exposure to COVID-19 due to conditions such as significant public contact in an area where the virus was prevalent. The Appellate Division, Third Department, affirmed the Board’s decision.The New York Court of Appeals affirmed the Appellate Division’s order. The Court held that the Board’s “prevalence” framework is consistent with New York Workers’ Compensation Law as interpreted by prior case law. The Court found that substantial evidence supported the Board’s findings that the claimant’s COVID-19 infection and consequential stroke arose out of and in the course of employment, given the extraordinary risk presented by the claimant’s work environment and the credible medical evidence linking the injuries. The Court rejected the employer’s argument that a specific exposure event must be identified. View "Matter of Aungst v Family Dollar" on Justia Law

Four individuals—three transit workers and one teacher—filed claims for Workers' Compensation benefits in 2020, alleging psychological injuries such as PTSD that resulted from workplace exposure to COVID-19. The Workers' Compensation Board determined that the claimants experienced stress comparable to that faced by other employees in similar roles during the pandemic. Therefore, the Board denied the claims, finding that the stress encountered did not meet the threshold for a compensable "accident" under the Workers' Compensation Law.The Appellate Division, Third Department, reversed the Board’s decisions. It held that the Board erred by not considering each claimant’s individual vulnerabilities and by applying different burdens for psychological injury claims compared to claims for contracting COVID-19 itself. The Appellate Division cited Matter of Wolfe v Sibley, Lindsay & Curr Co., stating that psychological injuries precipitated by psychic trauma should be compensable to the same extent as physical injuries. It further concluded that the Board should apply its “prevalence rule”—which allows proof of an elevated risk via workplace prevalence of COVID-19—to psychological injury claims as well as physical injury claims.Upon review, the New York Court of Appeals reversed the Appellate Division’s orders and reinstated the Board’s decisions. The Court of Appeals held that the Board is not required to consider a claimant’s particular vulnerabilities when evaluating psychological injury claims. It clarified that, at the relevant time, claimants needed to show that their workplace stress was greater than that ordinarily experienced by similarly situated workers in the normal work environment for the injury to be deemed accidental. The Court found substantial evidence supporting the Board’s conclusion that the claimants’ stress was not exceptional, and ruled that the prevalence of COVID-19 in the workplace does not alter the legal standard for compensable psychological injury. View "Matter of McLaurin v New York City Tr. Auth." on Justia Law

A police officer employed by a city suffered injuries during a traffic stop in May 2019. The city, acting as a self-insured employer through a third-party administrator, initially accepted liability for a right hip injury, providing compensation and full salary. Subsequently, the officer developed left hip symptoms, and medical opinions varied on whether these were related to the workplace accident. The employer questioned the connection, declined to authorize further treatment for the left hip, and requested access to medical records and an independent medical examination (IME). After the officer did not cooperate with these requests, the employer sent a letter stating that compensation benefits would be suspended, although the Idaho Industrial Commission later found that no actual suspension occurred.The officer later filed a petition with the Idaho Industrial Commission seeking a declaratory ruling on whether a recent Idaho Supreme Court decision (Arreola v. Scentsy, Inc.) applied retroactively to her situation, which would have affected the employer’s ability to suspend benefits unilaterally. While this petition was pending, the employer filed a complaint with the Commission to resolve disputes about the officer’s entitlement to benefits and failure to attend IMEs. The officer responded with a second petition, challenging the employer’s ability to file such a complaint. The Commission declined to address the first petition on procedural grounds and denied the second on the merits, concluding that it had jurisdiction to adjudicate an employer’s complaint.On appeal, the Supreme Court of the State of Idaho affirmed the Commission’s denial of the first petition, finding the issue moot because the officer’s benefits had not been suspended and thus there was no live controversy. However, the Court set aside the denial of the second petition, holding that under Idaho’s worker’s compensation law, only employees—not employers—may file a complaint (application for hearing) with the Commission to adjudicate claims regarding unpaid or discontinued compensation or income benefits. View "Coronado v. City of Boise" on Justia Law

Plaintiffs, a couple and their two minor children, brought suit against their neighbor after a long history of escalating neighborhood disputes. The neighbor’s husband exhibited a pattern of threatening and violent behavior, including verbal threats, physical assault, gun-related incidents, and other menacing acts. The central incident occurred when the husband violently attacked one plaintiff with a baseball bat, after which he barricaded himself and ultimately died by suicide with a firearm. Plaintiffs alleged that the neighbor was negligent in failing to control her husband, failing to warn others, and providing false assurances about the absence of firearms and the husband’s dangerousness.The Contra Costa County Superior Court, treating the defendant’s demurrer as a motion for judgment on the pleadings, granted it and dismissed the action as to the neighbor. The court found that the complaint failed to establish that she had a special relationship with her husband or the plaintiffs that would give rise to a duty to protect the plaintiffs from his conduct. It also ruled there was no viable claim for intentional infliction of emotional distress, and denied leave to amend, finding no reasonable possibility of amendment. Plaintiffs’ motion for a new trial was denied.On appeal, the California Court of Appeal, First Appellate District, Division Three, held that the trial court correctly found no duty for the neighbor to protect plaintiffs from her husband under negligence principles, as the plaintiffs failed to allege facts showing her ability to control him or a special relationship that would give rise to such a duty. The court also determined that, although the existing complaint did not adequately allege negligent misrepresentation due to insufficient allegations of reasonable reliance, plaintiffs should have been granted leave to amend their complaint to attempt to state such a claim. The judgment was reversed and remanded for further proceedings. View "Sproul v. Vallee" on Justia Law

Two plaintiffs, identified as Jane Roe and John Doe, brought a defamation lawsuit against Jenna Smith and her mother, alleging that Jenna had falsely accused John of sexual assault and Jane of being a non-consensual partner while all were students at a Los Angeles County high school. These accusations, made both to other students and school officials, led to an investigation by the school, which ultimately found John not responsible for the alleged misconduct. The plaintiffs claimed significant reputational and emotional harm from the spread of these accusations and sought damages, injunctive relief, and an order preventing future defamatory statements.After the complaint was filed under pseudonyms, the First Amendment Coalition moved to unseal the plaintiffs’ names. The Superior Court of Los Angeles County, however, deemed the motion premature and directed the plaintiffs to file a formal motion to maintain anonymity. Both plaintiffs and defendants filed such motions without supporting evidence. The court granted both motions, allowing all parties to proceed pseudonymously. The Coalition then appealed the order granting anonymity to the plaintiffs, while no party appealed the order regarding defendants.The California Court of Appeal, Second Appellate District, reviewed the matter and applied independent judgment on the constitutional issue. It held that, absent statutory authorization, litigating under pseudonyms should only occur in rare circumstances and requires an evidentiary showing of an overriding interest that outweighs the public’s right of access to court records. The court found that the plaintiffs’ generalized fears of reputational harm and potential future impact on employment were insufficient and unsupported by evidence. It reversed the Superior Court’s order granting plaintiffs anonymity, emphasizing that defamation plaintiffs are generally not entitled to proceed pseudonymously without robust factual support. View "Roe v. Smith" on Justia Law

A wealthy bond trader from New York, through a network of assistants, recruited women from across the United States to travel to his New York penthouse for what was represented as consensual sadomasochistic sexual encounters in exchange for money. The women were enticed with promises of cash, luxury experiences, and travel. However, once there, while some anticipated rough consensual sex, they were subjected to violent, nonconsensual acts, including severe physical abuse, sexual assault, and use of force far beyond what had been described or agreed to. The trader required the women to sign non-disclosure and purported consent agreements, often after they had used alcohol or drugs, and none received copies. The plaintiffs, six women, alleged lasting physical and psychological harm.The United States District Court for the Eastern District of New York conducted a jury trial on claims under the Trafficking Victims Protection Act (TVPA) and state tort law. After deliberation, the jury found the defendant liable under the TVPA and awarded each plaintiff $500,000 in compensatory damages. Five plaintiffs received $120,000 in punitive damages each, and one plaintiff received $250,000. The jury did not find the defendant’s assistants liable, except for one minor battery claim. The defendant’s post-trial motions for judgment as a matter of law or a new trial were denied.On appeal, the United States Court of Appeals for the Second Circuit reviewed challenges to the sufficiency of the evidence, the district court’s jury instructions, and the availability of punitive damages under the TVPA. The court held that sufficient evidence supported the jury’s verdict, the instructions properly conveyed the applicable law, and punitive damages are available under the TVPA. The Second Circuit affirmed the district court’s judgment in all respects. View "Moore v. Rubin" on Justia Law

A high-speed police pursuit in Iowa ended with a motorcycle crash that left the rider, Augustin G. Mormann, paralyzed and ultimately led to his death after life support was withdrawn. The chase began when an Iowa State Trooper attempted to stop Mormann for speeding, but he fled, weaving through traffic and entering residential neighborhoods. The trooper disengaged due to safety concerns, but Manchester police officer James Wessels continued the pursuit at speeds exceeding 100 miles per hour. During the chase on a county road, Wessels’s police cruiser struck Mormann's motorcycle, leading to a crash that caused catastrophic injuries. Mormann was hospitalized, tested positive for methamphetamine, and died after choosing to discontinue life support. His family subsequently filed a civil suit against Wessels and the City of Manchester.In the Iowa District Court for Delaware County, the plaintiffs asserted claims including constitutional violations and, ultimately, common law assault and battery. The district court dismissed the constitutional claims after a change in Iowa law but allowed the assault and battery claims to proceed to trial. The jury found Wessels liable for both torts, awarding $4.25 million in compensatory damages and $10,000 in punitive damages. The court denied post-trial motions for judgment notwithstanding the verdict and for a new trial.The Iowa Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that emergency response immunity under Iowa law does not shield a municipality or its officer from liability when the officer acts with reckless disregard for safety, as found by the jury. The court also concluded that the assault and battery claims were sufficiently pleaded under Iowa’s notice pleading standard, that there was substantial evidence to support the jury’s verdicts, and that the admission of the decedent’s dying declaration and evidence regarding police recording policies was proper. The punitive damages award was also upheld. View "Mormann v. City of Manchester, Iowa" on Justia Law

A patient received treatment for diabetes at VA facilities from 2016 to 2022. In early 2020, he reported worsening symptoms and expressed dissatisfaction with his medical care, believing negligence contributed to his condition. Two years later, he filed a complaint with the Office of the Inspector General, alleging improper diagnosis and treatment at VA facilities. He also submitted a Standard Form-95 (SF-95) to the Office of the General Counsel, naming himself as claimant and his wife as a witness and property owner. The agency denied his claim, and he was informed of his right to sue. The couple then filed a pro se lawsuit under the Federal Tort Claims Act (FTCA), alleging negligent medical care caused kidney disease. Subsequently, the wife filed her own SF-95, asserting power of attorney, but the agency denied this claim as duplicative and because the couple had already sought judicial remedy.The United States District Court for the Eastern District of Texas, following a magistrate judge’s recommendation, dismissed the wife’s claims for failure to exhaust administrative remedies, dismissed both plaintiffs’ claims as time-barred, and denied leave to amend as futile. The plaintiffs objected, but the district court adopted the recommendations and dismissed the case with prejudice. The plaintiffs appealed.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the district court erred in finding the wife failed to exhaust administrative remedies for her property damage claim, because the administrative filing gave sufficient notice for that claim. However, the Fifth Circuit affirmed the district court’s dismissal on the alternative ground that all claims were barred by the FTCA’s statute of limitations, as the plaintiffs’ injuries and property damages were or should have been known more than two years before the administrative claims were filed. The denial of leave to amend was also affirmed. View "Ellsworth v. Dallas Texas Department of Veteran Affairs" on Justia Law

OneTaste, Inc., a company founded in 2004 that promoted “orgasmic meditation,” sued Netflix for defamation in 2023. The lawsuit was based on a Netflix documentary that featured allegations from former employee Ayries Blanck, who claimed she was sexually assaulted and abused in connection with her employment and participation in OneTaste’s activities. The documentary included statements from Blanck’s sister and other former associates, as well as references to earlier media investigations and reports about alleged exploitative and abusive practices at OneTaste. OneTaste asserted that Netflix published false statements with actual malice, despite being provided with information it claimed disproved the allegations.The Superior Court of Los Angeles County reviewed Netflix’s special motion to strike under California’s anti-SLAPP statute (Code of Civil Procedure section 425.16). Netflix argued its conduct was protected activity and that OneTaste could not demonstrate a probability of prevailing, especially on the element of actual malice. After considering the pleadings and both parties’ evidence, the trial court concluded that OneTaste failed to present sufficient evidence that Netflix published the challenged statements with actual malice. The court also found OneTaste’s additional evidence did not establish that Netflix was aware of probable falsity or recklessly disregarded the truth. As a result, the court granted Netflix’s motion to strike the complaint.On appeal, the California Court of Appeal, Second Appellate District, Division Three, affirmed the trial court’s order. The appellate court held that OneTaste did not meet its burden to show a probability of prevailing on the defamation claim because it failed to produce evidence of actual malice by Netflix. The court also rejected OneTaste’s constitutional and public policy challenges to the anti-SLAPP statute and denied its requests for judicial notice of materials not considered by the trial court. View "Onetaste Incorporated v. Netflix, Inc." on Justia Law