Justia Injury Law Opinion Summaries

In January 2020, Salve Chipola attended a high school basketball game where Sean Flannery made statements to a school official accusing Chipola of being a drug dealer and providing drugs and alcohol to students. As a result, Chipola was later banned from school grounds and questioned by a police officer about these allegations, which he denied. Flannery admitted to making the statements. Nearly two years after the incident, Chipola filed a lawsuit against Flannery for false light invasion of privacy, alleging that the false statements harmed his reputation and caused emotional distress.The Superior Court of New Jersey, Law Division, granted Flannery’s motion to dismiss, finding that Chipola’s claim was time-barred under the one-year statute of limitations for defamation, as established in Swan v. Boardwalk Regency Corp. The Appellate Division affirmed this decision, reasoning that false light claims are essentially akin to defamation and thus subject to the same one-year limitations period. The court relied on prior case law, including Rumbauskas v. Cantor, which recognized the similarities between false light and defamation claims.The Supreme Court of New Jersey reviewed the case to resolve whether the statute of limitations for false light invasion of privacy should be one year, as for defamation, or two years, as for personal injury. The Court held that the one-year statute of limitations for defamation claims also applies to false light claims. The Court reasoned that the conduct and injuries underlying both torts are closely aligned, and applying a longer limitations period to false light would undermine legislative intent and free speech protections. The judgment of the Appellate Division was affirmed. View "Chipola v. Flannery" on Justia Law

After experiencing shortness of breath and chest pain, Jorge Armenta lost consciousness and his wife called 911. Emergency medical technicians from Unified Fire Authority (UFA) responded, evaluated Armenta, and told him that everything appeared normal, suggesting he had an anxiety attack and did not need to go to the emergency room. A week later, Armenta was hospitalized for a massive heart attack, which resulted in significant and potentially life-shortening heart damage. Armenta filed a negligence suit against UFA, alleging that their failure to properly diagnose and treat him caused his injuries.The Third District Court, Salt Lake County, reviewed UFA’s motion to dismiss, which argued that the Utah Governmental Immunity Act (UGIA) shielded UFA from liability. The district court applied a three-part test, found that UFA’s actions were a governmental function, that immunity was generally waived for such activities, but that an exception for “providing emergency medical assistance” restored immunity. The court dismissed Armenta’s claims against UFA and entered judgment under rule 54(b) of the Utah Rules of Civil Procedure.On direct appeal, the Supreme Court of the State of Utah reviewed the district court’s statutory interpretation and dismissal. The Supreme Court held that the district court erred in its interpretation of the “providing emergency medical assistance” exception under the UGIA. The Court determined that, when read in context with related statutory provisions, the exception applies only to medical assistance provided in response to certain types of emergencies, such as disasters or catastrophic events, not to routine emergency medical responses like the one at issue. Therefore, the UGIA does not immunize UFA from Armenta’s suit. The Supreme Court reversed the district court’s dismissal and remanded the case for further proceedings. View "ARMENTA v. UNIFIED FIRE AUTHORITY" on Justia Law

Several individuals from five different states purchased ovens with front-mounted burner knobs manufactured by a major appliance company. They allege that these ovens have a defect causing the stovetop burners to turn on unintentionally, sometimes resulting in gas leaks. The plaintiffs claim they were unaware of this defect at the time of purchase, but that the manufacturer had prior knowledge of the issue through consumer complaints sent to the U.S. Consumer Product Safety Commission (CPSC) and reviews posted on the company’s website. The plaintiffs assert that, had they known about the defect, they would have paid less for the ovens or not purchased them at all.The plaintiffs filed a class action in the United States District Court for the Western District of Michigan, alleging violations of federal warranty law, fraud by omission, breach of express and implied warranties, unjust enrichment, and violations of state consumer protection statutes. The district court found that the plaintiffs had Article III standing, as they alleged a concrete injury, but dismissed all claims for failure to state a plausible claim for relief. The plaintiffs appealed the dismissal of their state common law fraud and statutory consumer protection claims, while the manufacturer argued that the plaintiffs lacked standing.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the plaintiffs had Article III standing because they plausibly alleged economic injury from overpaying for a defective product. The court further held that the plaintiffs plausibly alleged the manufacturer’s knowledge of the defect and its safety risks, particularly because the CPSC had sent incident reports directly to the manufacturer. The court reversed the district court’s dismissal of most state law fraud and consumer protection claims, except for the Illinois common law fraud claim, which failed for lack of a duty to disclose under Illinois law. The case was remanded for further proceedings consistent with these holdings. View "Tapply v. Whirlpool Corp." on Justia Law

A four-year-old child drowned after wandering unattended from the home where she had been placed under temporary custody by order of the Probate Court. The child’s parents had previously lost guardianship, and the court had vested temporary custody in maternal relatives. To determine whether to grant a full transfer of guardianship, the Probate Court ordered the Department of Children and Families (DCF) to investigate the home and report its findings. DCF submitted its report, recommending the placement, but before the court could hold a hearing on permanent guardianship, the child died. The child’s estate, through her father as administrator, alleged that DCF’s negligence in investigating the placement and in making recommendations to the Probate Court was a proximate cause of the child’s death, and also claimed DCF failed to fulfill independent duties to protect the child from abuse and neglect.After the estate received permission from the Claims Commissioner to sue the state, DCF moved to dismiss the action in the Superior Court, arguing that it was entitled to absolute quasi-judicial immunity for actions integral to the judicial process, such as conducting court-ordered investigations and making recommendations. The Superior Court agreed, holding that DCF was protected by absolute quasi-judicial immunity when acting as an arm of the Probate Court, and that the Claims Commissioner could not waive this immunity. The court dismissed the action, finding the complaint’s allegations insufficient to overcome DCF’s immunity.On appeal, the Connecticut Supreme Court held that the Claims Commissioner’s waiver of sovereign immunity under the relevant statute does not preclude the state from asserting absolute quasi-judicial immunity. However, the Court reversed in part, concluding that some of the estate’s allegations may fall outside the scope of quasi-judicial immunity, particularly those involving DCF’s independent statutory duties. The case was remanded for further proceedings to determine which claims, if any, are not barred by quasi-judicial immunity. View "Jamie G. v. Dept. of Children & Families" on Justia Law

A woman brought suit against the United States under the Federal Tort Claims Act (FTCA) after her child suffered severe and permanent nerve damage during childbirth at a Texas hospital. She alleged that the resident physician who delivered her baby used excessive force in responding to a complication known as shoulder dystocia, and that the attending physician failed to properly supervise. The plaintiff sought compensatory damages for medical care and related expenses.The United States District Court for the Western District of Texas dismissed the case for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1). The district court, adopting a magistrate judge’s recommendation, determined that shoulder dystocia is always an obstetrical emergency under Texas law. It concluded that, in such emergencies, Texas law requires proof of “willful and wanton negligence” (a heightened standard akin to gross negligence). The court further reasoned that because the FTCA does not waive sovereign immunity for punitive damages, and because damages for willful and wanton negligence are punitive, it lacked jurisdiction to hear the case.On appeal, the United States Court of Appeals for the Fifth Circuit reversed and remanded. The Fifth Circuit held that the district court erred in two respects: first, by presuming as a matter of law that the physician provided emergency medical care in every instance of shoulder dystocia, rather than treating it as a factual question; and second, by conflating the heightened standard of liability (willful and wanton negligence) with the nature of damages recoverable. The Fifth Circuit clarified that compensatory damages for gross negligence are available under Texas law and are not barred by the FTCA, which only precludes punitive damages. The case was remanded for further proceedings. View "Robledo v. USA" on Justia Law

Burke McCarthy died in October 2018 after receiving medical treatment from Dr. Wesley Hiser at Wyoming Medical Center. Dianna Ellis, McCarthy’s daughter and wrongful death representative, filed a wrongful death lawsuit against Dr. Hiser and the hospital in February 2021, within the two-year statute of limitations. However, Dr. Hiser was never served with the original complaint. Nearly two years later, Ellis voluntarily dismissed her suit against Dr. Hiser. In December 2023, she refiled her complaint, relying on Wyoming’s savings statute to argue she had an additional year to commence a new action. Dr. Hiser was served for the first time in February 2024, more than five years after McCarthy’s death.The District Court of Natrona County granted Dr. Hiser’s motion to dismiss the refiled complaint. The court found that it had never obtained jurisdiction over Dr. Hiser in the original action because he was not served, and therefore the savings statute could not apply to extend the time for refiling. Ellis appealed this decision.The Supreme Court of Wyoming reviewed the case de novo. The court held that Wyoming’s savings statute, Wyo. Stat. Ann. § 1-3-118, does not apply to actions that are voluntarily dismissed by the plaintiff. The court overruled its prior decision in Hugus v. Reeder, 2022 WY 13, which had held that a voluntary dismissal qualified as a “failure otherwise than upon the merits” under the savings statute. The court reasoned that a voluntary dismissal is not a “failure” within the meaning of the statute, as it is a matter of choice rather than an unsuccessful attempt to proceed. Accordingly, the Supreme Court of Wyoming affirmed the district court’s dismissal of Ellis’s refiled complaint. View "Ellis v. Hiser" on Justia Law

Stanley Watson, a former county commissioner, accused Sheneeka Bradsher and Zarinah Ali of stealing his wallet at a bar. Despite no evidence, he repeatedly demanded their arrest and threatened police officers who did not comply. Bradsher was arrested for disorderly conduct, but later released when Watson's wallet was found in his car. Bradsher and Ali sued Watson for slander, battery, and false imprisonment, winning a $150,500 judgment.Watson filed for bankruptcy, and Bradsher and Ali sought to except their judgment from discharge. The bankruptcy court found Watson genuinely believed the women stole his wallet, discharging the slander and battery debts but ruling the false imprisonment debts nondischargeable. The district court affirmed the nondischargeability of the false imprisonment debts but remanded for further clarification on the slander claim. On remand, the bankruptcy court found the slander debt dischargeable, attributing two-thirds of the damages to false imprisonment and one-third to slander.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the bankruptcy court did not clearly err in finding Watson willfully and maliciously caused the women’s confinement, making the false imprisonment debts nondischargeable under 11 U.S.C. § 523(a)(6). The court also upheld the bankruptcy court’s allocation of damages, finding it supported by the evidence. The Eleventh Circuit affirmed the judgments in favor of Bradsher and Ali. View "Watson v. Bradsher" on Justia Law

In May 2020, a fire started in the engine of a recreational power boat on the Lake of the Ozarks, causing an explosion that injured Lauren Wilken and killed Shawn Carroll. The Carroll family and Wilken sued the boat's designer, manufacturer, and seller (collectively "Brunswick") for defective design, failure to warn, negligence, and wrongful death. The jury returned a verdict in favor of Brunswick.The plaintiffs appealed, asserting four errors by the United States District Court for the Western District of Missouri. They claimed the district court erred in denying their Batson challenge, excluding evidence of other similar incidents, striking expert testimony, and not allowing them to introduce evidence of other explosions during closing arguments.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found no clear error in the district court's denial of the Batson challenge, as Brunswick's reason for striking Juror No. 13 was deemed reasonable and based on accepted trial strategy. The court also upheld the exclusion of evidence related to the Schroeder explosion, as the plaintiffs failed to show that the conditions of the boats were sufficiently similar. The court found no abuse of discretion in the district court's decision to strike the expert's testimony about the Schroeder explosion as a sanction for violating its order. Lastly, the court determined that the district court's curative instruction to the jury regarding Brunswick's counsel's comment during closing arguments was sufficient to mitigate any potential prejudice.The Eighth Circuit affirmed the district court's judgment in favor of Brunswick. View "Carroll v. Brunswick Corporation" on Justia Law

In a suburban shopping center parking lot on July 1, 2016, Michael Cokes, Isaiah Stevenson, and Ronald Arrington waited in a car while Jimmie Malone robbed a restaurant manager. After the robbery, the men drove away with Malone, who later took over as the driver. When Illinois state troopers stopped the car, the men refused to exit, and Malone sped off, leading to a high-speed chase. During the chase, Chicago Police Officer Dean Ewing, driving an unmarked car, collided with the Pontiac, resulting in serious injuries to Cokes, Stevenson, and the officers in Ewing’s car, and the deaths of Malone and Arrington.The plaintiffs, including Arrington’s estate, sued the City of Chicago and Officer Ewing, alleging various torts related to the collision. After a nine-day trial, a jury found in favor of the defendants on all claims. The plaintiffs then moved for a new trial, challenging the district court’s decisions on affirmative defenses, jury instructions, and the admissibility of evidence. The district court denied these motions, leading to the current appeal.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decisions. The appellate court found no legal error or abuse of discretion in the district court’s handling of the affirmative defenses, jury instructions, and evidentiary rulings. Specifically, the court upheld the district court’s decisions to allow the defendants to plead a joint enterprise theory of contributory negligence, to admit testimony about Arrington’s conduct under Federal Rule of Evidence 601 rather than the Illinois Dead Man’s Act, and to exclude the COPA report under Rule 403. The appellate court concluded that any potential errors did not substantially affect the jury’s verdict. View "Arrington v. City of Chicago" on Justia Law

Georgia-Pacific LLC, a large corporation in the pulp and paper industry, acquired Bestwall Gypsum Co. in 1965, inheriting significant asbestos-related liabilities. By 2017, Bestwall faced around 64,000 pending asbestos claims, prompting Georgia-Pacific to implement a divisional merger known as the Texas two-step. This maneuver split Georgia-Pacific into two entities: Georgia-Pacific retained most assets, while Bestwall assumed the asbestos liabilities and filed for Chapter 11 bankruptcy to manage these claims through a § 524(g) trust.The United States Bankruptcy Court for the Western District of North Carolina granted Bestwall's motion for an injunction to prevent asbestos claimants from pursuing claims outside the bankruptcy process. The Official Committee of Asbestos Claimants opposed this and moved to dismiss the bankruptcy case, arguing it was filed in bad faith since Bestwall was solvent. The bankruptcy court denied the motion, stating that filing for Chapter 11 to resolve asbestos claims is a valid purpose, even for solvent debtors.The Committee later moved to dismiss the case for lack of subject-matter jurisdiction, arguing that the Constitution does not grant jurisdiction over bankruptcy cases involving solvent debtors. The bankruptcy court rejected this argument, holding that Congress has the authority to define bankruptcy jurisdiction, which includes cases filed by solvent debtors.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the bankruptcy court's decision. The Fourth Circuit held that federal courts have subject-matter jurisdiction over bankruptcy cases involving solvent debtors because the Bankruptcy Code is a federal law, and petitions for relief under it arise under the laws of the United States. The court clarified that challenges to a debtor's eligibility for bankruptcy protection are not jurisdictional issues. View "Bestwall LLC v. Official Committee of Asbestos Claimants" on Justia Law