Justia Injury Law Opinion Summaries

The case involves nearly 75,000 plaintiffs who filed personal injury claims in the Delaware Superior Court, alleging that their ingestion of ranitidine, marketed under the brand name Zantac, caused them to develop various types of cancer. The plaintiffs claim that ranitidine contains or degrades into N-Nitrosodimethylamine (NDMA), a likely carcinogen. The defendants in the case include GlaxoSmithKline LLC, Boehringer Ingelheim Pharmaceuticals, Inc., Sanofi US Services Inc., Pfizer Inc., and Patheon Manufacturing Services, LLC.The Superior Court of Delaware denied the defendants' motions to exclude the plaintiffs' expert testimony, which supported the claim that ranitidine causes cancer. The court concluded that the general causation question could focus on NDMA rather than ranitidine itself and that Delaware law does not require a "threshold dose" for general causation. The court also applied a "liberal thrust" favoring the admissibility of expert testimony, viewing challenges to the experts' methodologies as questions for the jury.The Supreme Court of Delaware reviewed the case and reversed the Superior Court's decision. The Supreme Court held that the Superior Court erred in interpreting Delaware Rule of Evidence 702 by applying a "liberal thrust" favoring admissibility and by concluding that Delaware's standard for admissibility is distinct from the federal standard. The Supreme Court emphasized that the proponent of expert testimony must establish its admissibility by a preponderance of the evidence, and the trial court must act as a gatekeeper to ensure the reliability and sufficiency of the expert's methodology and application.The Supreme Court also found that the Superior Court erred in defining the general causation question as focusing on NDMA rather than the product at issue, ranitidine. The court concluded that the plaintiffs' experts did not reliably link the NDMA studies to the exposure caused by ranitidine, failing to establish the necessary scientific connection between the product and the alleged harm. Consequently, the Supreme Court reversed the Superior Court's decision and remanded the case for further proceedings consistent with its opinion. View "In re Zantac (Ranitidine) Litigation" on Justia Law

A widow, Lori Olson, individually and as the personal representative of her deceased husband Scott Olson's estate, filed a lawsuit against Huron Regional Medical Center (HRMC), Dr. William Miner, and Thomas Miner, a physician’s assistant, alleging negligence, wrongful death, loss of consortium, intentional infliction of emotional distress, civil conspiracy, and fraudulent concealment. Scott Olson died at HRMC in January 2020 under the care of Dr. Miner and Thomas Miner. Lori Olson initiated the lawsuit in September 2021.The Circuit Court of the Third Judicial Circuit in Beadle County, South Dakota, denied Dr. Miner’s motion to dismiss for insufficient service of process but later granted the defendants' motions to dismiss for failure to prosecute. Lori Olson appealed the dismissal, and Dr. Miner filed a notice of review challenging the denial of his motion to dismiss for insufficient service.The Supreme Court of South Dakota reviewed the case and found that there was verifiable record activity within the year prior to the defendants’ motion to dismiss, including efforts to compile medical records and communication between the parties. The court concluded that the Circuit Court erred in dismissing the case under SDCL 15-11-11 for lack of prosecution, as there was sufficient activity to move the case forward. Additionally, the court found that the delays in the case did not rise to the level of egregiousness required for dismissal under Rule 41(b) and that the Circuit Court did not consider less severe sanctions before dismissing the case.The Supreme Court of South Dakota reversed the Circuit Court’s decision to dismiss the case for failure to prosecute and affirmed the denial of Dr. Miner’s motion to dismiss for insufficient service of process, concluding that Dr. Miner was properly served. View "Olson v. Huron Regional Medical Center, Inc." on Justia Law

Sidney and Julian Helvik, who have lived on their family ranch since 1947, sold a portion of their ranch to Wesley and Karen Tuscano in 2018. In 2020, the Helviks agreed to sell the remainder of the ranch to the Tuscanos under an agreement that included a promissory note and provisions for the Tuscanos to assist the elderly Helviks with end-of-life issues. The Helviks signed a quitclaim deed, but the Tuscanos later had them sign a gift deed, which transferred the ranch without consideration. The Tuscanos never made any payments under the agreement and used the gift deed to obtain a mortgage on the ranch.The Helviks filed a complaint in the District Court of the Sixth Judicial District, Sweet Grass County, seeking to void the agreement and the gift deed, alleging undue influence and fraud. The Tuscanos counterclaimed and filed a third-party complaint against Jacqueline Conner, alleging tortious interference and abuse of process. The District Court granted summary judgment in favor of Conner on the tortious interference claim and excluded evidence of an Adult Protective Services investigation and an oral agreement to transfer land.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court's decision to rescind the agreement based on its equitable powers, noting the unique fiduciary duty in grantor-support agreements. The court found no abuse of discretion in excluding evidence of the APS investigation and the oral agreement. The court also held that the Tuscanos waived their argument regarding jury instructions on undue influence by not objecting at trial. The summary judgment in favor of Conner was upheld due to the lack of evidence of damages. The court declined to award attorney fees to Conner under M. R. App. P. 19(5). The District Court's orders and judgments were affirmed. View "Helvik v. Tuscano" on Justia Law

Robert Cox, acting as the personal representative and special administrator of the estate of Greta Cox, sued Total Quality Logistics, Inc. and Total Quality Logistics, LLC (collectively, TQL) for negligence under Ohio law. Cox alleged that TQL, in its role as a freight broker, negligently hired an unsafe motor carrier, Golden Transit, Inc., which resulted in a motor vehicle crash that killed his wife, Greta Cox. The crash occurred when the driver of the motor carrier, Amarjit Singh Khaira, failed to slow down in a construction zone and collided with Greta Cox's vehicle.The United States District Court for the Southern District of Ohio dismissed the case, ruling that Cox’s claims were preempted by the Federal Aviation Administration Authorization Act (FAAAA), specifically 49 U.S.C. § 14501(c). The district court found that the FAAAA preempted the state law claims because they related to the services of a broker with respect to the transportation of property and did not fall within the Act’s safety exception.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred in its interpretation of the FAAAA’s safety exception. The Sixth Circuit concluded that the safety exception, which preserves the safety regulatory authority of a state with respect to motor vehicles, includes common law claims like Cox’s negligent hiring claim. The court reasoned that such claims are genuinely responsive to safety concerns and directly involve motor vehicles and motor vehicle safety. Therefore, the court reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Cox v. Total Quality Logistics, Inc." on Justia Law

Josh Rinaldi, an inmate at the Maine Correctional Center, slipped on an untreated patch of ice on a paved road within the correctional center, referred to as the "Runway," and broke his ankle. Rinaldi filed a twelve-count complaint asserting various tort claims, arguing that the State was not immune under the Maine Tort Claims Act (MTCA) due to an exception for injuries sustained in or on an appurtenance to a public building.The Superior Court (Androscoggin County) granted Rinaldi's motion for partial summary judgment, ruling that the Maine Correctional Center is a public building under the MTCA and that the Runway is an appurtenance to the correctional center's buildings. The State appealed, arguing that it was immune from liability under the MTCA and that the Runway did not fall under any exceptions to the MTCA.The Maine Supreme Judicial Court reviewed the case and concluded that the Runway is not an appurtenance to the correctional center's buildings. The court applied a three-element test to determine whether the Runway was an appurtenance: physical annexation to the realty, adaptation to the realty, and intent to be irremovable from the realty. The court found that the Runway was not physically annexed to the buildings, was not specially adapted to the buildings, and was not intended to be irremovable from the realty. Therefore, the Runway did not meet the criteria for an appurtenance under the MTCA.The Maine Supreme Judicial Court vacated the Superior Court's judgment granting Rinaldi's motion for partial summary judgment and remanded the case for entry of summary judgment in favor of the State, concluding that the State was immune from liability under the MTCA. View "Rinaldi v. Maine Correctional Center" on Justia Law

Jose Cruz-Muniz and Sandra Cruz were injured in a car accident in 2018 and received treatment from C-Spine Orthopedics, PLLC. They assigned their rights to seek personal protection insurance (PIP) benefits from Progressive Michigan Insurance Company to C-Spine. C-Spine then assigned its accounts receivable, including the claims for unpaid benefits, to several factoring companies. Progressive argued that C-Spine lacked standing to seek payment because it had assigned its rights to the factoring companies. C-Spine countered with signed counter-assignments from the factoring companies, purportedly restoring its right to bring suits. The trial court initially denied Progressive's motion but later granted it, concluding that C-Spine lacked standing when the complaints were filed.In a separate case, Parie Wallace was injured in a bus accident and received treatment from several providers, including C-Spine. Wallace assigned her rights to seek PIP benefits to these providers. She later filed a lawsuit against Suburban Mobility Authority for Regional Transportation (SMART) seeking payment of PIP benefits. SMART argued that Wallace could not bring the action because she had assigned her rights to the providers. The trial court allowed Wallace to obtain revocations of the assignments, which she did, and then denied SMART's motion for summary disposition. The Court of Appeals reversed, holding that Wallace was not the real party in interest when she filed her complaint and that her claims were barred by the one-year-back rule.The Michigan Supreme Court held that both C-Spine and Wallace had standing to file their lawsuits but were not the real parties in interest at the time they filed suit because they had assigned their claims. The Court ruled that defects in real party in interest status could be cured after filing a lawsuit. In C-Spine's case, the Court of Appeals' judgment was affirmed on alternate grounds, and the case was remanded to the trial court for further proceedings. In Wallace's case, the Court of Appeals' judgment was affirmed in part, reversed in part, and vacated in part, and the case was remanded for the trial court to consider whether equitable rescission was warranted and whether the real party in interest defect could be cured. View "C-Spine Orthopedics PLLC v. Progressive Michigan Insurance Company" on Justia Law

On July 6, 2013, a train carrying crude oil derailed in Lac-Mégantic, Quebec, causing explosions that killed forty-seven people and destroyed the town center. Joe R. Whatley, Jr., as trustee for the wrongful death claimants, sued Canadian Pacific Railroad Company and related entities, alleging liability for the value of the train’s crude oil cargo.The United States District Court for the District of North Dakota found Canadian Pacific liable under the Carmack Amendment for the value of the crude oil cargo and awarded Whatley $3,950,464 plus prejudgment interest. However, the court declined to address whether the judgment reduction provision from the Montreal Maine & Atlantic Railway (MMA) bankruptcy plan applied, stating that it was a matter for the Bankruptcy Court. Canadian Pacific's motion for reconsideration was denied, leading to this appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court abused its discretion by setting aside part of the joint stipulation between the parties, which required the court to decide whether the judgment reduction provision applied. The Eighth Circuit determined that the judgment reduction provision from the MMA bankruptcy plan should apply, reducing Canadian Pacific’s liability to zero, as MMA was solely responsible for the derailment.The Eighth Circuit reversed the district court’s decision and remanded the case for a complete reduction of the judgment against Canadian Pacific, ensuring that Canadian Pacific would not be held liable for more than its proportionate share of the damages, which in this case was zero due to MMA's sole liability. View "Whatley v. Canadian Pacific Railway Co." on Justia Law

Prisca Fagnon petitioned for a disorderly conduct restraining order against Ndorleh Ngaima, alleging harassment on social media, stalking, threats with a knife, and physical violence resulting in a broken nose. A temporary restraining order was issued, and a hearing was held on February 18, 2025. Both parties testified, with Fagnon presenting evidence of a physical assault by Ngaima on July 24, 2023. Ngaima denied the allegations.The District Court of Stutsman County, Southeast Judicial District, found Fagnon's testimony credible and supported by photographic evidence of her injuries. The court determined that the act of physical violence constituted disorderly conduct and issued a restraining order for two years. Ngaima appealed, arguing that the court abused its discretion by issuing the order without reasonable grounds and that the findings were inadequate.The North Dakota Supreme Court reviewed the case, noting that the standard for issuing a disorderly conduct restraining order requires reasonable grounds to believe the respondent engaged in disorderly conduct. The court found that the district court did not abuse its discretion, as the evidence of physical violence was relevant and sufficient to support the restraining order. The court also addressed the time and distance factors, concluding that the severity of the conduct and the need for controlled contact between the parties justified the order.The Supreme Court affirmed the district court's decision, holding that the findings were adequate and supported by the evidence. The court emphasized that physical violence is generally intended to adversely affect the safety, security, and privacy of another person, and the district court's credibility determinations were upheld. View "Fagnon v. Ngaima" on Justia Law

Kenya Taylor hired Los Angeles Unified School District (LAUSD) employee Tyler Martin-Brand to babysit her six-year-old son, Dayvon, during the winter break in 2019. Tragically, Martin-Brand killed Dayvon. Taylor sued LAUSD, alleging negligent hiring and supervision of Martin-Brand. A jury found in favor of Taylor, awarding her $30 million in damages. LAUSD appealed the trial court's denial of its motion for judgment notwithstanding the verdict (JNOV) and the judgment itself.The Superior Court of Los Angeles County denied LAUSD's motions for JNOV and a new trial, asserting that LAUSD was immune from liability under Education Code section 44808. The jury had found LAUSD negligent in hiring and supervising Martin-Brand, attributing 90% of the fault to LAUSD and 10% to Taylor.The Court of Appeal of the State of California, Second Appellate District, Division Three, reviewed the case. The court concluded that LAUSD was immune from liability for Dayvon’s off-campus death under Education Code section 44808, which limits school district liability for student injuries occurring off school property unless the district has specifically undertaken responsibility for the student. The court found that Dayvon’s death did not occur during any school-sponsored activity or under LAUSD’s supervision. Consequently, the court reversed the trial court's order and judgment, directing the trial court to enter judgment in favor of LAUSD. View "Taylor v. Los Angeles Unified School Dist." on Justia Law

Orlando Miguel Martínez-Ramos pleaded guilty to carjacking resulting in serious bodily injury and aiding and abetting the same, following a home invasion, robbery, and brutal physical attack on a 77-year-old woman who died nine days later. The advisory guideline sentencing range was up to fourteen years, but Martínez-Ramos acknowledged that an upward variance was warranted due to the victim's death. At sentencing, Martínez-Ramos argued for a fifteen-year sentence, while the government requested sixteen years.The United States District Court for the District of Puerto Rico did not accept either recommendation. Instead, it considered a higher advisory guideline range based on the first-degree murder cross-reference, which would have recommended a life sentence, reduced to twenty-five years due to the statutory maximum. However, the court did not apply this cross-reference, citing insufficient causation evidence and the belief that a twenty-five-year sentence was too harsh given Martínez-Ramos's youth. The court imposed an eighteen-year sentence, a substantial upward variance from the guideline range, due to the physical attack contributing to the victim's death.Martínez-Ramos appealed, arguing that the upward variance was substantively unreasonable and that the court applied too lenient a standard of causation. The United States Court of Appeals for the First Circuit reviewed the case. The court found that Martínez-Ramos had acknowledged the victim's death as a factor in his plea agreement and that the autopsy listed facial and bodily trauma as contributory factors to the death. The court concluded that the district court's finding was not clearly erroneous and affirmed the eighteen-year sentence. View "United States v. Martinez-Ramos" on Justia Law