Justia Injury Law Opinion Summaries

Michael Pryor contracted with a transportation company to deliver cargo in July 2019. After the shipment was rejected by the receiver in Pennsylvania, Pryor returned it to Mississippi at the company’s request. Initially, Pryor was told he would be compensated for the return, but later the company refused to pay. When Pryor asserted a carrier lien on the cargo, the company reported him to local police for theft, leading to criminal charges for felony embezzlement. The charges were eventually “retired to file” in August 2021 and expunged in August 2022. Pryor alleged that the company’s actions caused him emotional distress, humiliation, and economic loss, including heart palpitations diagnosed in November 2021.Pryor first filed suit in the United States District Court for the Northern District of Mississippi in June 2023, seeking damages for malicious prosecution and emotional distress. The federal court dismissed his case for lack of subject-matter jurisdiction. In July 2024, Pryor refiled his claims in the Circuit Court of Pontotoc County. The company moved for summary judgment, arguing that the statute of limitations barred both claims. The Circuit Court granted summary judgment, finding Pryor’s claims untimely.The Supreme Court of Mississippi reviewed the Circuit Court’s decision de novo. It held that the three-year statute of limitations for emotional distress claims began running when Pryor knew of his injuries, which was well before the doctor’s appointment he cited. The one-year statute of limitations for malicious prosecution began when the criminal charges were retired to file, not when they were expunged. As both claims were filed after the relevant limitations periods had expired, the Supreme Court of Mississippi affirmed the grant of summary judgment in favor of the company. View "Pryor v. J. B. Hunt Transport, Inc." on Justia Law

A business owner, who operated an electronics service company, employed a 17-year-old worker whose job included driving duties. One day, during work hours, the employee drove the owner in a personal vehicle owned by the employee’s parents, with their consent. While driving, the employee lost control and crashed, resulting in the owner’s death. The owner had workers’ compensation insurance for employees but opted out of coverage for himself. The owner’s mother, as trustee, sued the employee and the parents in a wrongful death action, alleging negligent driving.The District Court determined that the employee was immune from liability because of the coemployee immunity provision in the Minnesota Workers’ Compensation Act, which protects coemployees from negligence suits for workplace injuries. The court also granted summary judgment to the parents, finding that the owner of a vehicle could not be vicariously liable under the Safety Responsibility Act if the driver was immune. The plaintiff did not appeal the employee’s immunity but challenged the parents’ immunity. The Minnesota Court of Appeals reversed, holding that the parents could still be vicariously liable under the Safety Responsibility Act even if the driver was personally immune.The Supreme Court of Minnesota reviewed the case to resolve whether a motor vehicle owner may be held vicariously liable under the Safety Responsibility Act for the tortious conduct of a permissive driver who is personally immune from liability under the Workers’ Compensation Act. The court held that the Safety Responsibility Act imposes vicarious liability on vehicle owners for a permissive driver’s wrongful conduct even when the driver is personally immune. It further clarified that the coemployee immunity provision is a personal immunity, not a release of liability, and does not extend to protect vehicle owners from vicarious liability. The Supreme Court affirmed the Court of Appeals. View "Niebuhr vs. Sieberg" on Justia Law

A woman was injured in an automobile accident while riding as a passenger in an uninsured vehicle. Because neither she nor anyone in her household had car insurance, she applied for personal injury protection (PIP) benefits through the New Jersey Property-Liability Insurance Guaranty Association under the Unsatisfied Claim and Judgment Fund (UCJF), which approved her for up to $250,000 in medical expense benefits. The cost of her medical care before trial did not exceed this limit. She sued both drivers involved in the accident, and her medical expert estimated her future medical expenses would range from $42,000 to $160,000. At trial, the jury awarded her $250,000 for non-economic damages and $100,000 for future medical expenses, apportioning a portion of these damages against one defendant.After trial in the Superior Court, Law Division, the defendant moved to set aside the verdict, arguing that evidence of the plaintiff’s future medical expenses was inadmissible because those expenses would be paid through PIP coverage. The trial judge denied this motion. The defendant appealed, and the Appellate Division partially reversed, holding that the evidence of future medical expenses was inadmissible since they were “collectible” under the relevant statute. The appellate court modified the judgment to exclude the future medical expenses and related costs.The Supreme Court of New Jersey reviewed the case and affirmed the Appellate Division’s decision. The Court held that, under N.J.S.A. 39:6A-12, future medical expenses that do not exceed the plaintiff’s PIP coverage limits are “collectible” and, therefore, inadmissible in a personal injury trial against a tortfeasor. As a result, such expenses should not be presented to the jury or included in the damages award. The Court also affirmed that additional costs and fees related to the offer of judgment rule should be excluded when based on inadmissible future medical expenses. View "Murray v. Punina" on Justia Law

The case involves a dispute between an individual and two defendants whom he sued for breach of contract, fraud, intentional infliction of emotional distress, and defamation. After a bench trial, the trial court entered judgment in favor of the defendants on all claims. The plaintiff then filed multiple post-trial and post-judgment motions, alleging, among other things, that new evidence showed interference in the case by the Federal Bureau of Investigation. All of these motions were denied. Subsequently, the plaintiff filed several motions seeking to disqualify the presiding judge for alleged bias and misconduct, each of which was also denied.Following these filings, the trial court judge issued an order declaring the plaintiff a vexatious litigant and enjoining him from filing further pleadings without first obtaining the court’s permission. The plaintiff appealed, raising issues about the vexatious litigant order, the denial of his motions to disqualify the judge, and the completeness of the record on appeal.The Supreme Court of the State of Montana reviewed the case. It held that the trial court abused its discretion by declaring the plaintiff a vexatious litigant and issuing a pre-filing order without first providing notice and an opportunity to be heard. The court vacated the vexatious litigant order and remanded for further proceedings, requiring the trial court to allow the plaintiff a chance to be heard and then, if warranted, issue a substantive order with adequate analysis. The Supreme Court affirmed the denial of the plaintiff’s motions for judicial disqualification, finding the motions procedurally deficient, and concluded that the trial court transmitted a sufficient record on appeal. The judgment was affirmed in part, reversed in part, and remanded for further proceedings. View "Heaven v. Weber" on Justia Law

The defendant was convicted of five counts of sexual assault in the first degree and two counts of risk of injury to a child, based on multiple incidents of sexual abuse against two minor victims who attended a day care operated by the defendant’s wife in their home. The abuse occurred over several years, when the victims were between three and eight years old. The state’s case relied on evidence that the defendant committed a variety of sexual acts against each child on separate occasions. Each count of sexual assault was based on multiple, distinct incidents involving a specific sexual act.The Superior Court for the judicial district of New Haven conducted a jury trial. At the conclusion of evidence, the trial court provided the jury with specific unanimity instructions for each count, stating that to find the defendant guilty, all jurors must unanimously agree that the defendant committed at least one specific alleged act described in the count. The jury returned guilty verdicts on all counts, and the court sentenced the defendant to a total effective term of twenty-five years’ imprisonment, execution suspended after twenty-one years, followed by ten years of probation. The defendant appealed directly to the Connecticut Supreme Court, arguing his right to a unanimous jury verdict was violated because the trial court did not require the jury to answer special interrogatories identifying which incident formed the basis for each conviction.The Supreme Court of Connecticut held that the federal constitution does not require special interrogatories on unanimity in addition to a specific unanimity instruction when a single count is based on multiple, separate acts. The Court found the trial court’s unanimity instructions sufficient to protect the defendant’s constitutional rights and affirmed the judgments. View "State v. Carlos G." on Justia Law

A fire at a call center in Davao City, Philippines, resulted in the deaths of twenty-nine individuals who were employees of a Philippine company providing services for a Connecticut-based company. The estates of the deceased and other plaintiffs, most of whom were Philippine citizens or residents, brought a wrongful death and loss of consortium action in Connecticut against the Connecticut company and two of its officers, who were also involved with the Philippine employer.The Superior Court, Complex Litigation Docket, granted the defendants’ motion to dismiss on the ground of forum non conveniens, finding the Philippines to be an adequate alternative forum. The court considered conflicting affidavits from expert witnesses regarding whether Philippine courts would accept the case, given concerns about the statute of limitations. The dismissal was conditioned on allowing the plaintiffs to reinstate the Connecticut action if the Philippine courts declined jurisdiction. The Appellate Court affirmed this decision, concluding that the trial court applied the proper legal standard and meaningfully assessed the adequacy of the Philippine forum.On further appeal, the Connecticut Supreme Court affirmed the Appellate Court’s judgment. It held that the trial court correctly applied the legal standard from Picketts v. International Playtex, Inc., and undertook a meaningful assessment of the adequacy of the Philippines as an alternative forum. The Supreme Court found that the trial court did not rely solely on the defendants’ consent to jurisdiction but weighed competing affidavits and evidence regarding Philippine law and procedure. The conditional nature of the dismissal, allowing reinstatement in Connecticut if the Philippine courts declined jurisdiction, was also deemed appropriate. Thus, the disposition by the Connecticut Supreme Court was to affirm the Appellate Court’s decision. View "DeCicco v. Dynata, LLC" on Justia Law

A garbage truck driver was injured when his vehicle was struck by a train at a railroad crossing in Baldwin, Louisiana. The collision occurred after the left front tire of the garbage truck became stuck in a hole next to the wooden planks of the railroad crossing, which was maintained by the railroad company. The driver was delayed in maneuvering his truck out of the hole and, as he attempted to cross, was hit by an oncoming train. Evidence showed that the crossing was narrower than the adjacent roadway and did not meet industry or the railroad company's own safety standards.A jury in the 16th Judicial District Court found the railroad company negligent and a proximate cause of the accident, and also found the driver negligent but determined his negligence was not a proximate cause, yet assigned him 15% of the fault and the railroad 85%. The trial court entered judgment on this verdict. On appeal, the Louisiana Court of Appeal, First Circuit, found the jury's verdict inconsistent and ordered a new trial. The Louisiana Supreme Court vacated that order, holding that the driver’s acceptance of partial fault resolved the inconsistency, and remanded for review of other issues. On remand, the appellate court found the evidence supported the jury’s findings and damages award.The Supreme Court of Louisiana subsequently granted review to consider the allocation of fault. The court found manifest error in the jury’s allocation of 85% fault to the railroad and 15% to the driver. It held that the lowest reasonable allocation of fault to the driver was 75%, with 25% to the railroad, and amended the judgment accordingly. The amended judgment was affirmed. View "THOMAS VS. BNSF RAILWAY COMPANY" on Justia Law

A blind student attending a university sustained injuries after falling from a balcony on campus. He mistook a guardrail for a bench and climbed over it, leading to a fall of at least ten feet. The student had previously followed set, familiar routes on campus, and although a university representative had shown him some areas, he was not informed about the balcony or its guardrail. The accident occurred during a pandemic-related closure when the student was unfamiliar with the route he took to access the building.The student filed a complaint in the Superior Court of the State of Alaska, Fourth Judicial District, against the university and its Board of Regents, alleging negligence, recklessness, and negligence per se. He claimed that the university owed a duty to maintain a safe environment for all students, including those with disabilities. The university moved for summary judgment, arguing it owed no duty to protect the student from risks created by his own conduct. The superior court granted summary judgment, finding neither statutory nor common law imposed a duty on the university to prevent harm resulting from the student’s own actions. The court determined that neither the Alaska Human Rights Act nor the Americans with Disabilities Act established a relevant duty of care, and Alaska precedent precluded finding a duty under these circumstances.The Supreme Court of the State of Alaska reviewed the case de novo. It affirmed the superior court’s decision, holding that the university had no duty to protect the student from the obvious risks created by his own conduct, specifically his voluntary act of climbing over the guardrail. The court reasoned that statutory protections against discrimination did not translate into a tort duty to prevent physical injury in this context, and existing precedent controlled the outcome. The grant of summary judgment was affirmed. View "Carey-Thomann v. University of Alaska" on Justia Law

The case concerns a dispute between two drivers following a car accident in a parking lot. The plaintiff sought to recover medical expenses for injuries allegedly sustained in the collision. To establish the reasonableness and necessity of her medical costs, the plaintiff submitted affidavits from her medical providers under Section 18.001 of the Texas Civil Practice and Remedies Code. The defendant responded by serving counteraffidavits from qualified experts, challenging only portions of the claimed medical expenses—not the entirety of each provider’s charges. In response, the plaintiff designated the defense experts as her own, intending to rely on their affidavits regarding uncontested medical charges.The trial court, sitting in Collin County, sustained the defendant’s objections and excluded all affidavits from the two contested providers, reasoning that any counteraffidavit required all costs from that provider to be supported by expert testimony at trial. The plaintiff’s attempt to admit the counteraffidavits themselves was also denied on hearsay grounds. The jury awarded only the uncontested medical costs from the third provider. The Court of Appeals for the Fifth District of Texas affirmed, holding that a compliant counteraffidavit rendered the plaintiff’s Section 18.001 affidavits insufficient, thereby requiring expert testimony for all costs from providers whose affidavits were challenged, even in part.The Supreme Court of Texas reversed the court of appeals’ judgment. It held that when a counteraffidavit challenges only part of a medical-cost affidavit, the uncontested portions of the affidavit remain competent evidence under Section 18.001 and may be submitted to the jury. Furthermore, the court held that counteraffidavits can also be admissible for the uncontested claims they affirm. The court remanded the case to the trial court for further proceedings consistent with this holding. View "ORTIZ v. NELAPATLA" on Justia Law

A worker at the Cherry Point oil refinery in Washington was regularly exposed to asbestos-containing insulation during his employment, which began in 1971. The insulation at issue was chosen, supplied, and installed by a subcontractor as part of the refinery’s original construction in the early 1970s. Decades after his exposure, the worker developed mesothelioma and died from the disease. His estate brought claims against numerous defendants, including the subcontractor, based on alleged asbestos exposure at the refinery.The Whatcom County Superior Court first granted summary judgment for the subcontractor, relying on Maxwell v. Atlantic Richfield Co., which held that Washington’s six-year construction statute of repose barred such claims. However, the court reconsidered and denied summary judgment after the Washington Court of Appeals issued Welch v. Brand Insulations, Inc., which found there were factual questions about whether the subcontractor’s activities were covered by the statute of repose. Due to conflicting appellate decisions, the Supreme Court of Washington granted direct review.The Supreme Court of the State of Washington held that claims against the subcontractor arising from its construction activities—specifically, its installation of asbestos insulation as part of constructing an improvement on real property—are barred by the construction statute of repose. However, the court held that claims based on the subcontractor’s independent role as a product seller or supplier, separate from its construction activities, are not barred by the statute of repose. The court affirmed in part, reversed in part, and remanded the case for further proceedings to determine which claims, if any, survive under theories of product seller or supplier liability. The court declined to address the constitutionality of the statute of repose, as that issue was not timely raised. View "Polinder v. Aecom Energy & Constr., Inc." on Justia Law