Justia Injury Law Opinion Summaries

Sean Hart and Tiffany Guzman filed a lawsuit against the City of Grand Rapids and three police officers, alleging excessive force during a 2020 Black Lives Matter demonstration. Hart and Guzman claimed that the officers used excessive force and that the City ratified this conduct. The officers sought summary judgment based on qualified immunity, and the City argued that the plaintiffs failed to establish municipal liability.The United States District Court for the Western District of Michigan granted summary judgment in favor of the City and the officers, dismissing the federal claims with prejudice and declining jurisdiction over the state claims. The plaintiffs appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's grant of summary judgment based on qualified immunity for Officer Johnson and Sergeant Bush, finding that the plaintiffs did not show that the officers violated clearly established rights. However, the court reversed the grant of summary judgment for Officer Reinink, determining that a reasonable jury could find that he used excessive force when he fired a Spede-Heat canister at Hart at close range, which could be considered deadly force. The court remanded the case for further proceedings on this claim.The court also affirmed the grant of summary judgment in favor of the City, concluding that the plaintiffs did not provide sufficient evidence to support their claim of municipal liability based on ratification of unconstitutional conduct. The plaintiffs' evidence, a spreadsheet of excessive force complaints, lacked qualitative specifics to show a pattern of inadequate investigations by the City. View "Hart v. City of Grand Rapids, Mich." on Justia Law

James Ethridge, a Texas resident, purchased a Samsung 18650 lithium-ion battery from a Wyoming-based seller on Amazon in October 2018. The battery exploded in his pocket in November 2019, causing severe burns and other injuries. Ethridge filed a personal injury lawsuit in Texas state court in 2021 against Samsung SDI Company, Firehouse Vapors LLC, and two Amazon entities. He later added Macromall LLC as a defendant. After dismissing Firehouse Vapors, the remaining defendants removed the case to federal court. Ethridge then dismissed Macromall, leaving Samsung and the Amazon entities as defendants.The United States District Court for the Southern District of Texas granted summary judgment in favor of the Amazon defendants and dismissed Samsung for lack of personal jurisdiction. Ethridge appealed the dismissal of Samsung to the United States Court of Appeals for the Fifth Circuit, voluntarily dismissing his appeal against Amazon.The Fifth Circuit reviewed the district court's decision de novo and reversed the dismissal. The court held that Samsung had purposefully availed itself of the Texas market by shipping 18650 batteries to companies like Black & Decker, HP, and Dell in Texas. The court found that Ethridge's claims were related to Samsung's contacts with Texas, as the same type of battery that injured Ethridge was sold in Texas. The court concluded that exercising personal jurisdiction over Samsung in Texas was fair and reasonable, given the state's interest in providing a forum for its injured residents and Samsung's ability to litigate in Texas. The case was remanded for further proceedings. View "Ethridge v. Samsung SDI" on Justia Law

Marietta Area Healthcare, Inc., Marietta Memorial Hospital, and Marietta Healthcare Physicians, Inc. (collectively "Marietta") filed a lawsuit against Camden-Clark Memorial Hospital Corporation, Camden-Clark Health Services, Inc., West Virginia University Hospitals, Inc., and West Virginia United Health System, Inc. (collectively "Camden-Clark"). Marietta alleged that Camden-Clark attempted to economically disadvantage them by causing its agents and employees to initiate and pursue a spurious qui tam action against Marietta. The claims included malicious prosecution, tortious interference, abuse of process, fraudulent legal process, civil conspiracy, negligent supervision, aiding and abetting tortious conduct, and vicarious liability.The United States District Court for the Northern District of West Virginia reviewed the case and denied Camden-Clark's motion to dismiss seven of the eight claims. However, the court deferred ruling on the negligent supervision claim, noting that the law regarding negligent supervision in West Virginia was unsettled. The district court then certified three questions to the Supreme Court of Appeals of West Virginia regarding the viability and elements of a negligent supervision claim and whether intentional or reckless torts by an employee could form the basis for such a claim.The Supreme Court of Appeals of West Virginia held that a claim for negligent supervision is viable under West Virginia common law. The court clarified that the elements of a negligent supervision claim include the traditional elements of negligence—duty, breach, causation, and damages—along with the necessity of demonstrating a tortious act or omission by the employee. The court further held that an employer could be liable for negligent supervision regardless of whether the employee's conduct was negligent, reckless, or intentional, provided the elements of the claim are met. View "Camden-Clark Memorial Hospital, Inc. v. Marietta Area Healthcare, Inc." on Justia Law

Kiril Lozanov and Capital City Renewables, Inc. (CCR) appealed a Superior Court decision granting summary judgment in favor of Lily B. Piel. Lozanov and CCR alleged that Piel, a former employee, accessed and disclosed Lozanov’s personal emails without authorization, which included confidential information about a wind project unrelated to CCR. Lozanov claimed that Piel’s actions led to increased child support obligations and health issues due to stress from related litigation.The Superior Court dismissed CCR’s claim for intrusion upon seclusion, as the company did not have a right to privacy in Lozanov’s emails. Lozanov’s claim for intentional infliction of emotional distress was also dismissed, as the court found Piel’s conduct was not outrageous enough to warrant such a claim. The court allowed Lozanov’s intrusion upon seclusion claim to proceed but ultimately granted summary judgment for Piel on all counts, finding no evidence that Piel’s actions caused the alleged damages.The Maine Supreme Judicial Court reviewed the case de novo and affirmed the Superior Court’s decision. The court found no evidence that Piel breached any duty owed to CCR or that her actions caused the damages claimed by Lozanov and CCR. The court also concluded that CCR's and Lozanov’s damages were too remote and speculative to support their claims. Additionally, the court noted that public policy considerations barred recovery, as Lozanov’s attempt to hide assets in a child support proceeding was contrary to the best interests of the child and public policy. View "Capital City Renewables, Inc. v. Piel" on Justia Law

Late one afternoon, Eugene Jennings was driving a tractor-trailer truck for his employer, All State Enterprise, Inc., in Custer County. As he negotiated a curve on Highway 69, his truck flipped over and crushed the vehicle in the oncoming lane driven by Timothy Trenshaw, killing him instantly. Jennings reported injuries and was transported to Parkview Hospital, where he discussed how he was injured with an emergency department physician. The physician documented these statements in Jennings's medical records.The district attorney's office for the Eleventh Judicial District charged Jennings with vehicular homicide and careless driving resulting in injury. Trenshaw's sister and son sued Jennings and All State in a wrongful death action. Plaintiffs obtained a police report containing a screenshot of Jennings's medical records, which included his description of the collision. Jennings filed a motion for a protective order, which the district court granted, prohibiting Plaintiffs from possessing or further disclosing Jennings's medical records. However, the district court later reviewed the screenshot in camera and ruled that five sentences describing the collision were not privileged, dissolving the protective order and requiring Jennings to disclose those sentences.The Supreme Court of Colorado reviewed the case and held that medical records containing information provided by a patient to a physician during treatment are protected by the physician-patient privilege. The court concluded that the district court erred in reviewing the screenshot and conducting a sentence-by-sentence analysis. The Supreme Court made absolute the order to show cause, emphasizing that the proper method for Plaintiffs to learn about the facts of the collision is through discovery directed at Jennings, not by accessing his privileged medical records. View "Gardne v. Jennings" on Justia Law

Plaintiff Jacqueline Statham suffered injuries during a hysterectomy performed by Dr. David S. Quang, assisted by Dr. Tan-Loc Nguyen and a medical student. The medical student, under the supervision of the defendant physicians, improperly inserted a sponge stick into Statham's rectum instead of her vagina, leading to a rectovaginal fistula. Statham sued the physicians and their medical practice, alleging professional negligence, negligent supervision, and vicarious liability for the medical student's actions.The trial court granted partial summary judgment to the defendants, ruling they could not be held vicariously liable for the medical student's negligence. The Court of Appeals affirmed, with the lead opinion concluding that OCGA § 51-1-38 did not impose vicarious liability on the physicians and that the evidence did not support vicarious liability under general agency principles or the borrowed servant doctrine.The Supreme Court of Georgia reviewed the case and agreed with the Court of Appeals that OCGA § 51-1-38 did not provide a basis for vicarious liability. The court also agreed that the borrowed servant doctrine did not apply as an independent basis for imposing vicarious liability. However, the court disagreed with the conclusion that the defendant physicians could not be held vicariously liable under general agency principles. The court held that under the doctrine of respondeat superior, a physician can be vicariously liable for a medical student's negligence if the student was acting as the physician's servant in furtherance of the physician's goals and within the scope of the physician's business.The Supreme Court found that genuine issues of material fact remained regarding whether the defendant physicians were vicariously liable under the doctrine of respondeat superior. Therefore, the court reversed the Court of Appeals' judgment affirming the trial court's grant of partial summary judgment to the defendants on the issue of vicarious liability. View "STATHAM v. QUANG" on Justia Law

The plaintiffs, a group of individuals and entities associated with the Daughtry family, sued Silver Fern Chemical, Inc. and its employee, Gilda Franco. Silver Fern supplied the plaintiffs with a chemical called 1,4 butanediol (BDO), which can be used as a date-rape drug. The Drug Enforcement Administration (DEA) investigated the distribution of BDO for illicit use and subpoenaed Silver Fern for emails related to BDO purchases. Franco altered these emails to include a Safety Data Sheet (SDS) that was not originally attached, and the plaintiffs allege this was done to aid the government in prosecuting them.The United States District Court for the Eastern District of Texas dismissed the claims against Franco for lack of personal jurisdiction and against Silver Fern for failure to state a claim. The court found that the plaintiffs did not adequately allege that Silver Fern intended for them to rely on the altered emails, nor did they show reliance on these emails to their detriment. The court also dismissed the products-liability claims, stating that the plaintiffs were not the end users of the chemical and did not suffer physical harm.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal of the fraud claims, agreeing that the plaintiffs failed to show that Silver Fern intended for them to rely on the altered emails. The court also upheld the dismissal of the civil conspiracy to commit fraud claim, as it was dependent on the underlying fraud claim. Additionally, the court affirmed the dismissal of the products-liability claims, noting that the plaintiffs did not suffer physical harm and were not the end users of the chemical.The Fifth Circuit concluded that the district court's judgment of dismissal was correct and affirmed the decision. View "Daughtry v. Silver Fern Chemical" on Justia Law

Floyd Ruffin, a shoreline clean-up worker in Louisiana following the 2010 Deepwater Horizon oil spill, was diagnosed with prostate cancer five years later. Ruffin sued BP, alleging that his exposure to crude oil during the clean-up caused his cancer. He designated Dr. Benjamin Rybicki, a genetic and molecular epidemiologist, as his expert to establish causation. Rybicki claimed that Ruffin was exposed to polycyclic aromatic hydrocarbons (PAHs) in crude oil, specifically pointing to benzo(a)pyrene as a carcinogen.The United States District Court for the Eastern District of Louisiana excluded Rybicki’s testimony, finding it inadmissible under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharmaceuticals, Inc. The court concluded that Rybicki failed to identify a harmful level of exposure to PAHs necessary to cause prostate cancer and noted several methodological flaws in his analysis. Consequently, the court granted BP’s motion for summary judgment, determining that Ruffin lacked the necessary evidence to prove causation.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s exclusion of Rybicki’s testimony and the grant of summary judgment de novo. The Fifth Circuit affirmed the district court’s decision, agreeing that Rybicki’s testimony was inadmissible due to significant analytical gaps. The court noted that Rybicki’s testimony did not establish a link between PAHs and prostate cancer, as his analysis focused on benzo(a)pyrene, which Ruffin did not specifically claim to have been exposed to. Additionally, the court emphasized that general causation requires showing that a substance is capable of causing the specific injury in the general population, which Rybicki’s testimony failed to do. Consequently, the Fifth Circuit upheld the exclusion of the expert testimony and the summary judgment in favor of BP. View "Ruffin v. BP Exploration & Production, Incorporated" on Justia Law

The case involves a former principal of a charter school, Emily Roseberry, who alleged that the school district superintendent, Pauline Harvey, overstepped her authority in violation of Alaska statutes and the governing charter school contract and bylaws. Roseberry was fired after making complaints about Harvey’s conduct to the superintendent, the board of education, and an independent commission. Roseberry initially filed suit in federal court, raising federal civil rights claims and a state whistleblower claim. The federal court dismissed her federal claims with prejudice and declined to exercise supplemental jurisdiction over her state whistleblower claim.Roseberry then filed suit in state court, bringing the whistleblower claim and three additional state-law claims: intentional interference with contractual relations, negligent supervision, and defamation. The defendants moved to dismiss, arguing that the claims were barred by issue and claim preclusion. The superior court agreed and dismissed the complaint. Roseberry appealed the decision.The Supreme Court of the State of Alaska reviewed the case and concluded that Roseberry’s state claims were not barred by issue and claim preclusion. The court held that the federal court’s dismissal of Roseberry’s First Amendment claim did not preclude her whistleblower claim because the definitions of “matter of public concern” under the First Amendment and the Alaska Whistleblower Act are different. The court also held that Roseberry’s additional state-law claims were not barred by claim preclusion because the federal court would likely have declined to exercise supplemental jurisdiction over them, given that it had already declined to exercise jurisdiction over the whistleblower claim.The Supreme Court of the State of Alaska reversed the superior court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Roseberry v. North Slope Borough School District" on Justia Law

This case involves a motor vehicle accident that occurred on March 31, 2017, in Calcasieu Parish. Elvis Dean Thompson, driving an 18-wheeler for Terry Graham Trucking, rear-ended Tracey Day's vehicle, which then struck another vehicle driven by Teresa Jeffries. Thompson's truck also collided with a vehicle driven by Daniel Guidry. Tracey Day and her husband, Bradley Day, sued Thompson, Terry Graham Trucking, and their insurer, Prime Insurance Company, for damages. Bradley Day also claimed loss of consortium. The Days' case was consolidated with Jeffries' case but was later severed.The district court set the trial for September 20, 2021, but it was postponed to January 3, 2022, due to Hurricane Ida. The court ruled that no further discovery would be allowed. On the first day of the trial, the Days requested that Tracey Day be excused from attending the trial except for her testimony, citing her inability to sit for long periods. The defense objected but the court granted the request. During the trial, the defense obtained surveillance video of Tracey Day, which they argued was necessary to impeach her testimony. The district court excluded the video and the testimony of the private investigator who recorded it, citing the late production and the closed discovery period. The jury awarded the Days $3,926,849.17, and the defendants appealed.The Louisiana Supreme Court reviewed whether the district court erred in excluding the surveillance evidence. The court found that the district court abused its discretion by not conducting an in camera review of the evidence. However, after conducting its own review, the Supreme Court determined that the surveillance did not contradict Tracey Day's testimony and was not impeachment material. Therefore, the exclusion of the evidence was proper, and the judgment was affirmed. View "DAY VS. THOMPSON" on Justia Law