Justia Injury Law Opinion Summaries

Respondents, North Carolina residents whose sons died in a bus accident outside Paris, France, filed a suit for wrongful death damages in North Carolina state court alleging that the accident was caused by tire failure. At issue was whether foreign subsidiaries of a United States parent corporation were amenable to suit in state court on claims unrelated to any activity of the subsidiaries in the forum state. The Court held that, because the episode-in-suit, the bus accident, occurred in France, and the tire alleged to have caused the accident was manufactured and sold abroad, North Carolina courts lacked specific jurisdiction to adjudicate the controversy. The Court also held that a connection so limited between the forum and the foreign corporation was an inadequate basis for the exercise of general jurisdiction where such a connection did not establish the "continuous and systematic" affiliation necessary to empower North Carolina courts to entertain claims unrelated to the foreign corporation's contacts with the State. Therefore, the Court held that petitioners were not amendable to suit in North Carolina and the judgment of the North Carolina Court of Appeals was reversed.

This case concerned the standard of causation applicable in cases arising under the Federal Employers' Liability Act ("FELA"), 45 U.S.C. 51 et seq., which rendered railroads liable for employees' injuries or deaths "resulting in whole or in part from [carrier] negligence." Respondent, a locomotive engineer with petitioner, an interstate railroad, sustained a debilitating hand injury and subsequently filed suit under the FELA. At issue was whether the causation instruction endorsed by the Seventh Circuit was proper in FELA cases where that instruction did not include the term "proximate cause," but did tell the jury defendant's negligence must "pla[y] a part-no matter how small-in bringing about the [plaintiff's] injury." In accord with the text and purpose of the Act, the Court's decision in Rogers v. Missouri Pacific R. Co., and the uniform view of federal appellate courts, the Court held that the Act did not incorporate "proximate cause" standards developed in nonstatutory common law tort actions. The Court held that the charge proper in FELA cases simply tracked the language Congress employed, informing juries that a defendant railroad caused or contributed to a plaintiff employee's injury if the railroad's negligence played any part in bringing about the injury. Accordingly, the judgment of the Seventh Circuit was affirmed.

This case stemmed from the long-running dispute between Vickie Lynn Marshall and E. Pierce Marshall over the fortune of J. Howard Marshall II, a man believed to have been one of the richest people in Texas. Vickie married J. Howard, Pierce's father, approximately a year before his death. Shortly before J. Howard died, Vickie filed a suit against Pierce in Texas state court asserting that J. Howard meant to provide for Vickie through a trust, and Pierce tortiously interfered with that gift. The litigation worked its way through state and federal courts in Louisiana, Texas, and California, and two of those courts, a Texas state probate court and the Bankruptcy Court for the Central District of California, reached contrary decisions on its merits. The Court of Appeals subsequently held that the Texas state decision controlled after concluding that the Bankruptcy Court lacked the authority to enter final judgment on a counterclaim that Vickie brought against Pierce in her bankruptcy proceeding. At issue was whether the Bankruptcy Court Judge, who did not enjoy tenure and salary protections pursuant to Article III of the Constitution, had the statutory authority under 28 U.S.C. 157(b) to issue a final judgment on Vickie's counterclaims and, if so, whether conferring that authority on the Bankruptcy Court was constitutional. The Court held that the Bankruptcy Court had the statutory authority to enter judgment on Vickie's counterclaim as a core proceeding under section 157(b)(2)(C). The Court held, however, that the Bankruptcy Court lacked the constitutional authority under Article III to enter final judgment on a state law counterclaim that was not resolved in the process of ruling on a creditor's proof claim. Accordingly, the judgment of the Court of Appeals was affirmed.

Plaintiffs, several states, the city of New York, and three private land trusts, sued defendants, four private power companies and the federal Tennessee Valley Authority, alleging that defendants' emissions substantially and unreasonably interfered with public rights in violation of the federal common law of interstate nuisance, or in the alternative, of state tort law. Plaintiffs sought a decree setting carbon-dioxide emissions for each defendant at an initial cap to be further reduced annually. At issue was whether plaintiffs could maintain federal common law public nuisance claims against carbon-dioxide emitters. As a preliminary matter, the Court affirmed, by an equally divided Court, the Second Circuit's exercise of jurisdiction and proceeded to the merits. The Court held that the Clean Air Act, 42 U.S.C. 7401, and the Environmental Protection Act ("Act"), 42 U.S.C. 7411, action the Act authorized displaced any federal common-law right to seek abatement of carbon-dioxide emissions from fossil-fuel fired power plants. The Court also held that the availability vel non of a state lawsuit depended, inter alia, on the preemptive effect of the federal Act. Because none of the parties have briefed preemption or otherwise addressed the availability of a claim under state nuisance law, the matter was left for consideration on remand. Accordingly, the Court reversed and remanded for further proceedings.

Claiming that he was subjected to dirty tricks during his successful campaign to become the police chief of Vinton, La., plaintiff filed a state court suit against the incumbent chief and the town (collectively, "defendant") asserting both state and federal law claims. Defendant removed the case to federal court based on plaintiff's 42 U.S.C. 1983 claims and after discovery, defendant sought summary judgment on the federal claims, which plaintiff conceded were not valid. The District Court accordingly dismissed the federal claims with prejudice and remanded the remaining claims to state court, noting that defendant's attorneys' work could be useful in the state court proceedings. Defendant then asked the federal court for attorney's fees. At issue was whether a court could grant reasonable fees to defendant when plaintiff's suit involved both frivolous and non-frivolous claims. The Court held that, when a plaintiff's suit involved both frivolous and non-frivolous claims, a court could grant reasonable fees to defendant, but only for costs that defendant would not have incurred but for the frivolous claims. The Court concluded that, although the District Court noted the usefulness of the attorneys' work in defending against the state law claims, it failed to take proper account of the overlap between the frivolous and non-frivolous claims; the District Court's reasoning that the close relationship between the federal and state law claims supported the award could not be squared with the congressional policy of sparing defendant from the costs only of frivolous litigation; and the Fifth Circuit did not uphold the award on proper ground where it seemed to think that defendant could receive fees for any work useful to defendant against a frivolous claim, even if his lawyers would have done that work regardless. Accordingly, the court vacated and remanded for further proceedings.