Justia Injury Law Opinion Summaries

The appellant in this case was a member of two limited liability companies, holding approximately a 33% interest. After disputes arose concerning the operation of the LLCs, the appellant initiated litigation seeking dissolution and other relief. Subsequently, he was expelled as a member. The LLCs’ operating agreement required immediate compensation for expelled members’ interests, but the appellant was not paid. While the case was ongoing, the district court enjoined the LLCs from harming the appellant’s interests and appointed a special master to value those interests. Despite the injunction, the appellant’s membership interests were assigned and sold to a third party without his knowledge. The appellant amended his complaint to assert conversion and defamation claims.A jury in the District Court of Park County found for the appellant, awarding $1,784,640 for conversion and $75,000 for defamation per se. Defendants moved post-judgment under Wyoming Rules of Civil Procedure 50(b), 59, and 60, arguing the conversion damages should not exceed the special master’s valuation and that defamation damages lacked evidentiary support. The district court initially denied the Rule 50(b) motion, affirming the jury’s findings. Later, under Rule 60(b), the court reduced conversion damages to $293,017 (the special master’s value) and defamation damages to $500, citing the appellant’s rightful expulsion and lack of proof of reputational harm or economic loss.The Supreme Court of Wyoming reviewed the district court’s reductions. It held that the appellant retained a property interest in the LLCs after expulsion until compensated, and the jury’s conversion award was proper based on fair market value at the time of conversion. For defamation per se, the Court clarified that Wyoming law allows presumed damages above nominal amounts, and sufficient evidence supported the jury’s $75,000 award. The Supreme Court reversed the district court’s reductions and reinstated the original jury awards. View "Mccall v. Best of the West Productions, LLC" on Justia Law

A serious car accident occurred when a teenager, driving at excessive speeds while racing another vehicle, lost control and crashed, leaving the plaintiff, a sixteen-year-old passenger, with catastrophic injuries resulting in paraplegia. The plaintiffs, the injured teen and her mother, filed suit against a wide array of parties, including the two teenage drivers, various family members, city officials, law enforcement, fire department personnel, paramedics, two cities, a railroad company, and county prosecutors. The claims included negligence, allegations of discrimination and violations of civil rights under 42 U.S.C. § 1983, and claims related to the handling of the accident’s aftermath and investigation.In the United States District Court for the Eastern District of Texas, the court adopted a magistrate judge’s recommendation and dismissed all claims with prejudice against all defendants except one, whose claims were dismissed without prejudice. The district court found the complaint to be vague, conclusory, and “riddled with pleading deficiencies.” It determined that claims against certain defendants were time-barred, that some defendants were not state actors for purposes of § 1983, that the plaintiffs failed to state claims upon which relief could be granted, and that certain claims were duplicative or failed as a matter of law. The plaintiffs sought the opportunity to replead, which the district court denied, finding amendment would be futile.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s dismissals de novo. The appellate court affirmed the district court’s judgment, holding that all claims were properly dismissed with prejudice except for those against the county prosecutors, which were modified to be dismissed without prejudice due to Eleventh Amendment immunity and lack of standing. The Fifth Circuit found no error or abuse of discretion in the lower court’s rulings and declined to remand for further amendment. View "Quiroz v. Hernandez" on Justia Law

The case involves a civil lawsuit in which the respondent alleges that the appellant sexually assaulted her in a Las Vegas hotel room in the late 1980s or early 1990s. The respondent claims that after being drugged, her hand was covered in lotion and she was forced to masturbate the appellant. She and other plaintiffs seek damages for various torts, including battery and assault, arguing that their claims are timely due to a Nevada statute that eliminates limitations periods for civil actions arising from sexual assault as defined under state law.The United States District Court for the District of Nevada reviewed the case and was faced with the question of whether the alleged conduct—specifically, forced masturbation without genital or anal intrusion—constitutes sexual assault under Nevada’s criminal statutes. The appellant moved to dismiss, asserting that the conduct in question does not meet the statutory definition of sexual assault and, therefore, the limitations period had expired. The federal district court certified this question to the Supreme Court of Nevada for resolution.The Supreme Court of Nevada addressed the certified question by interpreting the relevant statutes, NRS 200.364(9) and NRS 200.366. The court held that, under the plain language of these statutes, "sexual penetration" requires an intrusion into a genital or anal opening, whether by a body part or an object. The court concluded that forced masturbation, in the absence of such intrusion, does not fall within the statutory definition of sexual assault. Accordingly, the Supreme Court of Nevada answered the certified question in the negative, clarifying that this specific conduct is not considered sexual assault under the relevant state law. View "Cosby v. Leslie" on Justia Law

Susan Cox, a resident of Albion, Washington, died from an overdose of medications prescribed by her primary care physician, Dr. Patricia Marciano. Dr. Marciano, along with Gritman Medical Center, both based in Idaho near the Washington border, had treated Susan for several years. Although Susan lived in Washington, her medical treatment occurred in Idaho. At Susan’s request, her prescriptions were regularly transmitted to pharmacies in Washington. Susan’s husband, Mark Cox, and her estate brought a wrongful death and survivor action in the Eastern District of Washington, alleging that Susan’s death resulted from negligent over-prescription of pharmaceuticals.The United States District Court for the Eastern District of Washington denied the plaintiffs’ request for jurisdictional discovery regarding general personal jurisdiction over Gritman and dismissed the case for lack of personal jurisdiction. The district court found that Washington’s long-arm statute did not confer jurisdiction and that exercising specific jurisdiction would violate due process, as the defendants had not purposefully availed themselves of the Washington forum. The district court did not reach the question of venue.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal. The court of appeals held that the district court’s exercise of personal jurisdiction over the Idaho defendants was proper under Washington’s long-arm statute and consistent with the Due Process Clause because the defendants maintained ongoing, deliberate relationships with Washington residents and regularly sent prescriptions to Washington pharmacies in compliance with state law. The court also held that venue was proper in the Eastern District of Washington since a substantial part of the events underlying the claims occurred there. The case was remanded for further proceedings, with dismissal affirmed only for one defendant whom the plaintiffs conceded was properly dismissed. View "COX V. GRITMAN MEDICAL CENTER" on Justia Law

The petitioner received a Prevnar 13 pneumococcal conjugate vaccine and soon after began experiencing symptoms that ultimately led to a diagnosis of Guillain-Barré Syndrome (GBS). He sought compensation under the National Vaccine Injury Compensation Program, alleging that the vaccine caused his condition. To support his claim, he presented expert testimony advancing a molecular mimicry theory, arguing that components of the vaccine could trigger an autoimmune response resulting in GBS. The government countered with its own expert, disputing this causation theory.A special master in the United States Court of Federal Claims evaluated the evidence and found that the petitioner failed to prove, by a preponderance of the evidence, that the vaccine can cause GBS. The special master determined that key elements of the petitioner’s expert’s theory lacked support from reliable scientific literature and that the evidence did not sufficiently establish a causal connection. As a result, the special master denied compensation. The United States Court of Federal Claims reviewed and affirmed the special master’s decision.The United States Court of Appeals for the Federal Circuit reviewed the case. It held that the special master did not require the petitioner to provide direct medical literature establishing causation, which would have been contrary to the standard set forth in Althen v. Secretary of Health & Human Services, 418 F.3d 1274 (Fed. Cir. 2005). Instead, the special master properly considered the absence of supporting literature as one factor in evaluating the reliability of the causation theory, consistent with governing law. The Federal Circuit affirmed the Claims Court’s decision, noting concern about inconsistent outcomes among special masters on similar facts but finding no legal error in this case’s resolution. View "GAMBOA-AVILA v. HHS " on Justia Law

A Montana public housing authority employed an executive director for many years, during which she received positive performance evaluations. In 2022, a tenant grievance triggered an independent investigation into her conduct, but the investigation did not substantiate any policy violations. Shortly afterward, the executive director resigned, citing lack of support from the board. She was briefly rehired on a contract basis until an interim director took over in early 2023. Later that year, a local newspaper published an article quoting the interim director as criticizing the previous administration’s actions as unethical and damaging to the housing authority, statements that were widely republished. A board member admitted at trial that these statements about the former executive director were at least partially untrue. Despite requests for a retraction, the housing authority declined.The former executive director sued for defamation in the Eleventh Judicial District Court, Flathead County. The housing authority counterclaimed, alleging negligent performance and inadequate notice of resignation, but the court granted summary judgment against the counterclaim and denied the plaintiff’s request for attorney fees, finding the counterclaim was not frivolous. At trial, the housing authority objected to the admission of the newspaper article on hearsay grounds, but the court overruled the objection, and a jury awarded significant damages to the plaintiff. The housing authority’s post-trial motions for a new trial, judgment notwithstanding the verdict, and to apply a statutory damages cap were denied.The Supreme Court of the State of Montana reviewed the case. It held that the housing authority had, through the pretrial order and its litigation conduct, waived its hearsay objection to the article. The court affirmed the district court’s evidentiary rulings, denial of post-trial motions, and denial of attorney fees, ruling that the counterclaim was not made in bad faith. The judgment was affirmed. View "Collins v. Whitefish Housing Authority" on Justia Law

The dispute centers on an injury suffered by Catherine Dudley at a property owned by Michel Kanyambo and Speciose Mahirwe, which was insured under a general liability policy issued by Hudson Specialty Insurance Company. The policy, procured through intermediaries, was in effect from September 14, 2017, to September 14, 2018. Before the expiration, a renewal quote was relayed from Hudson’s intermediary to Kanyambo via their insurance agent, but Kanyambo and Mahirwe never received a written quote nor communicated directly with Hudson or its intermediary. They took no steps to renew, and no written notice of nonrenewal was sent to them. Dudley was injured on the property nine days after the policy’s expiration and, after settling her claims against the owners, she initiated a statutory “reach-and-apply” action against Hudson.In the Androscoggin County Superior Court, both Dudley and Hudson sought summary judgment on whether the policy was effective at the time of the injury. The Superior Court granted summary judgment to Hudson, reasoning that the owners’ receipt of the renewal quote via their agent meant Hudson was not required to provide written notice of nonrenewal. The court found there was no material fact in dispute and held the policy was not in effect, barring Dudley’s claims against Hudson.The Maine Supreme Judicial Court reviewed the case de novo. It concluded that under the plain language of Maine’s statutes, an insurer must send a written notice of nonrenewal before a policy terminates at its expiration, regardless of whether the insurer offered to renew. The statutory definition of “nonrenewal” encompasses any termination at the expiration date, and failure to provide the required notice means the policy does not terminate. The Court vacated the summary judgment in favor of Hudson and remanded for further proceedings, holding that Hudson was obligated to send notice and its failure to do so meant coverage remained in effect. View "Dudley v. Hudson Specialty Insurance Company" on Justia Law

A healthcare provider and several of its employees became involved in a dispute after the Idaho Department of Health and Welfare took protective custody of a child suffering from severe malnutrition. Following the hospital’s treatment of the child, a relative of the child, using media platforms and political organizations, publicly accused the hospital and its staff of participating in a conspiracy to kidnap, traffic, and harm children. These accusations led to public protests, threats, and disruptions at the hospital. The healthcare provider and its employees then sued the relative, his associates, and affiliated entities, alleging defamation, invasion of privacy, intentional infliction of emotional distress, trespass, and civil conspiracy, among other claims. They sought compensatory and punitive damages, injunctive relief, and removal of false statements.During proceedings in the District Court of the Fourth Judicial District, the defendant repeatedly failed to comply with discovery orders, missed depositions, and did not attend court hearings, despite multiple warnings and opportunities to comply. The court imposed escalating sanctions, culminating in striking the defendant’s pleadings and entering default as to liability. The court held a jury trial solely on damages, at which the defendant did not appear in person despite being given the opportunity. The jury awarded $52.5 million in compensatory and punitive damages, and the court issued a permanent injunction preventing further defamatory statements or harassment.The Supreme Court of the State of Idaho reviewed the case. It held that the district court did not abuse its discretion in imposing sanctions, entering default, and excluding evidence not properly disclosed. The court found that the defendant’s due process rights were not violated given repeated, willful noncompliance with court orders. The Supreme Court affirmed the district court’s judgment, including the damages award and the injunction, and awarded attorney fees and costs on appeal to the respondents. View "St. Luke's Health System, LTD v. Rodriguez" on Justia Law

A laser-cutting system operator died after being trapped between components of an industrial laser-cutting system when a steel beam descended into a gap, resulting in fatal injuries. The system, designed, sold, installed, and maintained by one company, consisted of several components, including a material handler, load frame, and main frame. On the day of the incident, the operator entered a narrow gap between the material handler and the load frame; when the system was activated, a steel beam pinned him, leading to his death. There were multiple possible routes into the gap, and prior incidents indicated the operator had previously entered the area. The estate of the deceased operator sued the designer and installer for negligent design, negligent installation, breach of warranty of merchantability (based on design and manufacturing defects), and negligent failure to maintain and warn of dangerous conditions.The case was initially filed in state court, then removed to the United States District Court for the District of Massachusetts. After discovery, the district court granted summary judgment to the defendant on all claims. The district court found that the system included a barrier fence at installation, making the system adequately protected and negating breach of warranty or negligent design claims. For the claims related to maintenance and failure to warn, the court found no triable issue on causation, as there was insufficient evidence that the operator had entered the gap through the unguarded wall-side opening.On appeal, the United States Court of Appeals for the First Circuit vacated the district court’s summary judgment on the design-related claims, finding a genuine factual dispute as to whether a reasonable alternative design—such as additional safety devices—could have mitigated the system’s risks. However, the appellate court affirmed summary judgment on the installation, maintenance, and failure to warn claims, concluding there was insufficient evidence to establish causation for those theories. The case was remanded for further proceedings on the design claims. View "Alicea v. Cincinnati Incorporated" on Justia Law

A woman died after a rapid health decline while receiving emergency and critical care at a West Des Moines hospital. Her husband, who was appointed as the administrator of her estate, filed a wrongful-death medical malpractice lawsuit against various medical providers. He brought the suit both on behalf of the estate and in his individual capacity, alleging multiple claims including negligence and seeking damages for emotional and financial loss. The husband, a nonlawyer, filed the petition without legal counsel and argued that, as the sole beneficiary, he should be allowed to proceed pro se or, alternatively, be given time to retain an attorney if one was required.The Iowa District Court for Polk County dismissed the lawsuit, ruling that the petition was a legal nullity because a nonlawyer cannot represent an estate or other parties in court, and denied the husband’s request for more time to secure counsel. The court also denied his motion to amend the petition. On appeal, the Iowa Court of Appeals affirmed the dismissal, agreeing that the wrongful-death action could not proceed without a lawyer and finding that the request for additional time had not been properly preserved for appeal. Two appellate judges dissented, concluding the husband was entitled to a warning and additional time to obtain counsel.The Supreme Court of Iowa granted further review. The court held that a nonlawyer cannot represent an estate or other persons in a wrongful-death action in district court. However, it found that the district court abused its discretion by not granting the husband reasonable time to retain counsel before dismissing the case. The Supreme Court vacated the court of appeals’ decision, reversed the district court’s judgment, and remanded the case with instructions to allow at least thirty days for the husband to secure trial counsel. View "Estate of Tornell v. Trinity Health Corporation" on Justia Law