Justia Injury Law Opinion Summaries

A man seeking treatment for mental health issues voluntarily admitted himself to a hospital in Chattanooga, Tennessee. Medical staff determined he needed emergency medication and began to physically restrain him when he refused a shot. An off-duty police officer, working as a hospital security guard and wearing his police uniform, intervened. He twisted the patient's arm behind his back, and when the patient pulled away to relieve pain, the officer punched the patient’s head into a cinderblock wall, causing head trauma. The patient remained nonviolent throughout and was smaller in stature than those restraining him.Following the incident, the Chattanooga Police Department conducted an internal investigation. Opinions within the review process were divided, but the interim chief ultimately found no policy violation. The patient filed suit in the United States District Court for the Eastern District of Tennessee, alleging excessive force under 42 U.S.C. § 1983, multiple state-law torts, and municipal liability against the City for failing to train or supervise the officer. The district court granted summary judgment for the officer on all but the assault and battery claim, finding qualified immunity on the excessive force claim, and granted summary judgment for the City on all claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that, although a reasonable juror could find the officer’s use of force excessive under the circumstances, the law was not clearly established that an officer in this situation could not use such force. Therefore, the officer was entitled to qualified immunity. The court also found that the City was not liable under Monell since the plaintiff failed to demonstrate that a final policymaker’s actions were the moving force behind his injury. The district court’s judgment was affirmed. View "Guptill v. City of Chattanooga" on Justia Law

A member of the Kuwaiti royal family was defrauded by a Baltimore restaurateur, who convinced her to send nearly $7.8 million under the guise of investing in real estate and restaurant ventures in the United States. The restaurateur used the funds to acquire multiple properties, including a condominium in New York City and a home in Pikesville, Maryland, but secretly held ownership in his own name and for his personal use. After the fraud was uncovered, the investor sued the restaurateur for fraud and sought to impose a constructive trust over the properties purchased with her funds. Around the same time, she attempted to file a notice of lis pendens to protect her interest in the Pikesville property, but the notice was recorded against the wrong property and was thus ineffective.During discovery, the investor learned that World Business Lenders, LLC (WBL) had issued three loans to the restaurateur, each secured by properties acquired with her funds. She then filed suit against WBL in the United States District Court for the District of Maryland, alleging that WBL aided and abetted the restaurateur’s fraud by encumbering the properties with liens, thereby hindering her ability to recover on any judgment. Following a bench trial, the district court found for WBL on two of the loans, but found WBL liable for aiding and abetting fraud in relation to the loan secured by the Pikesville home, awarding compensatory and punitive damages.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s factual findings for clear error and legal conclusions de novo. The appellate court affirmed the district court’s judgment for WBL on the first two loans but reversed as to the Pikesville loan. The Fourth Circuit held that WBL was not willfully blind to the restaurateur’s fraud in any of the loans as a matter of law and remanded with instructions to enter final judgment for WBL on all claims. View "Al-Sabah v. World Business Lenders, LLC" on Justia Law

The plaintiff, an experienced bus rider, was injured when she fell while standing on a public bus operated by a transit district. She had stood up and moved toward the rear door in anticipation of her stop, holding a bag in one hand and a phone in the other. Security camera footage showed she was not holding onto a railing at the time the bus made a routine turn, lost her balance, and fell. The driver was not alleged to have made any unusual maneuver, nor did other passengers appear affected. The plaintiff claimed the driver operated the bus negligently and failed to warn her to hold on or sit down.After the incident, the plaintiff filed a lawsuit in the Superior Court of Kern County, asserting causes of action for motor vehicle negligence against both the driver and the transit district (the latter on a vicarious liability theory). The defendants moved for summary judgment, relying heavily on the bus’s video recording to argue that the bus’s movement was ordinary and that the plaintiff’s own actions were the proximate cause of her injury. The plaintiff argued that factual disputes remained, that the heightened duty of care for common carriers was not met, and that expert opinion and the doctrine of res ipsa loquitur created triable issues for the jury. The Superior Court granted summary judgment for the defendants, concluding there was no evidence of negligence by the driver and that the plaintiff’s own conduct was the sole proximate cause of her injury.On appeal, the Court of Appeal of the State of California, Fifth Appellate District, reviewed the case de novo. The court affirmed the lower court’s judgment, holding that, while common carriers owe a heightened duty of care, that duty does not make them insurers of passenger safety for ordinary vehicle movements. The court further held that evidence, including the video, established the driver did not breach the applicable duty, and the plaintiff’s own negligence was the sole proximate cause of her injury. The court also ruled that neither comparative negligence nor res ipsa loquitur doctrines applied under these facts. Judgment for the defendants was affirmed. View "Agustin v. Golden Empire Transit Dist." on Justia Law

The case involves a woman who, as a minor, engaged in a sexual relationship with an adult more than twice her age. After the relationship ended, she experienced significant psychological distress, including anxiety and difficulty with personal relationships, and was later diagnosed with PTSD by a psychologist. Years after the relationship, she reported the events to the police, resulting in criminal charges against the adult, who was ultimately acquitted. Over a decade after the relationship ended, she brought civil claims for negligence per se, battery, and intentional infliction of emotional distress.The Circuit Court of Fairfax County sustained the defendant’s plea in bar, finding that the statute of limitations had run. The court determined that the version of the Virginia accrual statute in effect when the plaintiff reached the age of majority governed the action. The court found no legislative intent to apply later, more favorable statutes retroactively and ruled that the limitations period began when the plaintiff turned 18. The Court of Appeals of Virginia affirmed, concluding that the relevant accrual statute did not apply retroactively and that the plaintiff’s own complaint demonstrated awareness of her injuries and their connection to the relationship before reaching adulthood.On appeal, the Supreme Court of Virginia reviewed whether the lower courts erred in refusing to apply the more recent accrual statute retroactively and in finding that the plaintiff was aware of her injuries and their causal connection before the age of majority. The Supreme Court held that arguments for retroactive application of the statute were waived because they were not properly raised below, and that the record supported the finding that the plaintiff knew of her injury and its connection to the relationship as a minor. The Supreme Court of Virginia affirmed the judgment of the Court of Appeals, holding that the claims were time barred. View "Doe v. Green" on Justia Law

Mike Dennis developed mycosis fungoides, a subtype of non-Hodgkin’s lymphoma, after regularly applying Roundup, a glyphosate-based herbicide manufactured by Monsanto, for approximately 20 years. Dennis claimed his cancer resulted from exposure to Roundup, which he alleged was sold and marketed without adequate warnings about its carcinogenic risks, despite Monsanto’s knowledge of the potential danger. He brought claims for design defect, failure to warn (under both negligence and strict liability), and negligence. At trial, the jury found that Monsanto was liable for failing to warn about the cancer risk, determining Monsanto knew or should have known of the risk, failed to provide adequate warnings, and acted with malice or oppression. The jury awarded Dennis $7 million in economic damages and $325 million in punitive damages.Following the verdict, Monsanto moved for a new trial and for judgment notwithstanding the verdict (JNOV). The Superior Court of San Diego County denied Monsanto’s requests to overturn the liability findings but reduced the punitive damages award from $325 million to $21 million, finding the original award disproportionate to the compensatory damages. Monsanto timely appealed, arguing that Dennis’s failure to warn claims were preempted by the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and that the punitive damages were excessive and unconstitutional.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. It held that FIFRA does not preempt state law failure to warn claims that parallel federal misbranding requirements, in line with United States Supreme Court precedent and California decisions. The court also found that the punitive damages award, as reduced by the trial court, did not violate due process, as it was based on highly reprehensible conduct directly related to Dennis’s harm. The Court of Appeal affirmed the judgment in full. View "Dennis v. Monsanto Co." on Justia Law

In April 2020, a store manager working for a retail employer contracted COVID-19, followed by a stroke one week later. He alleged that both the infection and the subsequent stroke were caused by exposure to COVID-19 while working in a high-traffic store environment during the early months of the pandemic. The claimant described frequent, close interactions with the public and stated that employer-provided protective measures, such as masks and sneeze guards, were not implemented until mid-April. The claimant also testified that he had minimal contact with others outside of work. Medical evidence linked the stroke to the COVID-19 infection, and it was noted that the claimant lacked typical stroke risk factors.The Workers’ Compensation Law Judge initially established the claim as an occupational disease with a consequential stroke. On review, the New York State Workers’ Compensation Board modified the determination, finding instead that the claimant suffered an accidental injury, not an occupational disease, but otherwise affirmed the compensability of both injuries. The Board applied its “prevalence” framework, which looks to whether the workplace presented an extraordinarily high risk of exposure to COVID-19 due to conditions such as significant public contact in an area where the virus was prevalent. The Appellate Division, Third Department, affirmed the Board’s decision.The New York Court of Appeals affirmed the Appellate Division’s order. The Court held that the Board’s “prevalence” framework is consistent with New York Workers’ Compensation Law as interpreted by prior case law. The Court found that substantial evidence supported the Board’s findings that the claimant’s COVID-19 infection and consequential stroke arose out of and in the course of employment, given the extraordinary risk presented by the claimant’s work environment and the credible medical evidence linking the injuries. The Court rejected the employer’s argument that a specific exposure event must be identified. View "Matter of Aungst v Family Dollar" on Justia Law

Four individuals—three transit workers and one teacher—filed claims for Workers' Compensation benefits in 2020, alleging psychological injuries such as PTSD that resulted from workplace exposure to COVID-19. The Workers' Compensation Board determined that the claimants experienced stress comparable to that faced by other employees in similar roles during the pandemic. Therefore, the Board denied the claims, finding that the stress encountered did not meet the threshold for a compensable "accident" under the Workers' Compensation Law.The Appellate Division, Third Department, reversed the Board’s decisions. It held that the Board erred by not considering each claimant’s individual vulnerabilities and by applying different burdens for psychological injury claims compared to claims for contracting COVID-19 itself. The Appellate Division cited Matter of Wolfe v Sibley, Lindsay & Curr Co., stating that psychological injuries precipitated by psychic trauma should be compensable to the same extent as physical injuries. It further concluded that the Board should apply its “prevalence rule”—which allows proof of an elevated risk via workplace prevalence of COVID-19—to psychological injury claims as well as physical injury claims.Upon review, the New York Court of Appeals reversed the Appellate Division’s orders and reinstated the Board’s decisions. The Court of Appeals held that the Board is not required to consider a claimant’s particular vulnerabilities when evaluating psychological injury claims. It clarified that, at the relevant time, claimants needed to show that their workplace stress was greater than that ordinarily experienced by similarly situated workers in the normal work environment for the injury to be deemed accidental. The Court found substantial evidence supporting the Board’s conclusion that the claimants’ stress was not exceptional, and ruled that the prevalence of COVID-19 in the workplace does not alter the legal standard for compensable psychological injury. View "Matter of McLaurin v New York City Tr. Auth." on Justia Law

A police officer employed by a city suffered injuries during a traffic stop in May 2019. The city, acting as a self-insured employer through a third-party administrator, initially accepted liability for a right hip injury, providing compensation and full salary. Subsequently, the officer developed left hip symptoms, and medical opinions varied on whether these were related to the workplace accident. The employer questioned the connection, declined to authorize further treatment for the left hip, and requested access to medical records and an independent medical examination (IME). After the officer did not cooperate with these requests, the employer sent a letter stating that compensation benefits would be suspended, although the Idaho Industrial Commission later found that no actual suspension occurred.The officer later filed a petition with the Idaho Industrial Commission seeking a declaratory ruling on whether a recent Idaho Supreme Court decision (Arreola v. Scentsy, Inc.) applied retroactively to her situation, which would have affected the employer’s ability to suspend benefits unilaterally. While this petition was pending, the employer filed a complaint with the Commission to resolve disputes about the officer’s entitlement to benefits and failure to attend IMEs. The officer responded with a second petition, challenging the employer’s ability to file such a complaint. The Commission declined to address the first petition on procedural grounds and denied the second on the merits, concluding that it had jurisdiction to adjudicate an employer’s complaint.On appeal, the Supreme Court of the State of Idaho affirmed the Commission’s denial of the first petition, finding the issue moot because the officer’s benefits had not been suspended and thus there was no live controversy. However, the Court set aside the denial of the second petition, holding that under Idaho’s worker’s compensation law, only employees—not employers—may file a complaint (application for hearing) with the Commission to adjudicate claims regarding unpaid or discontinued compensation or income benefits. View "Coronado v. City of Boise" on Justia Law

Plaintiffs, a couple and their two minor children, brought suit against their neighbor after a long history of escalating neighborhood disputes. The neighbor’s husband exhibited a pattern of threatening and violent behavior, including verbal threats, physical assault, gun-related incidents, and other menacing acts. The central incident occurred when the husband violently attacked one plaintiff with a baseball bat, after which he barricaded himself and ultimately died by suicide with a firearm. Plaintiffs alleged that the neighbor was negligent in failing to control her husband, failing to warn others, and providing false assurances about the absence of firearms and the husband’s dangerousness.The Contra Costa County Superior Court, treating the defendant’s demurrer as a motion for judgment on the pleadings, granted it and dismissed the action as to the neighbor. The court found that the complaint failed to establish that she had a special relationship with her husband or the plaintiffs that would give rise to a duty to protect the plaintiffs from his conduct. It also ruled there was no viable claim for intentional infliction of emotional distress, and denied leave to amend, finding no reasonable possibility of amendment. Plaintiffs’ motion for a new trial was denied.On appeal, the California Court of Appeal, First Appellate District, Division Three, held that the trial court correctly found no duty for the neighbor to protect plaintiffs from her husband under negligence principles, as the plaintiffs failed to allege facts showing her ability to control him or a special relationship that would give rise to such a duty. The court also determined that, although the existing complaint did not adequately allege negligent misrepresentation due to insufficient allegations of reasonable reliance, plaintiffs should have been granted leave to amend their complaint to attempt to state such a claim. The judgment was reversed and remanded for further proceedings. View "Sproul v. Vallee" on Justia Law

Two plaintiffs, identified as Jane Roe and John Doe, brought a defamation lawsuit against Jenna Smith and her mother, alleging that Jenna had falsely accused John of sexual assault and Jane of being a non-consensual partner while all were students at a Los Angeles County high school. These accusations, made both to other students and school officials, led to an investigation by the school, which ultimately found John not responsible for the alleged misconduct. The plaintiffs claimed significant reputational and emotional harm from the spread of these accusations and sought damages, injunctive relief, and an order preventing future defamatory statements.After the complaint was filed under pseudonyms, the First Amendment Coalition moved to unseal the plaintiffs’ names. The Superior Court of Los Angeles County, however, deemed the motion premature and directed the plaintiffs to file a formal motion to maintain anonymity. Both plaintiffs and defendants filed such motions without supporting evidence. The court granted both motions, allowing all parties to proceed pseudonymously. The Coalition then appealed the order granting anonymity to the plaintiffs, while no party appealed the order regarding defendants.The California Court of Appeal, Second Appellate District, reviewed the matter and applied independent judgment on the constitutional issue. It held that, absent statutory authorization, litigating under pseudonyms should only occur in rare circumstances and requires an evidentiary showing of an overriding interest that outweighs the public’s right of access to court records. The court found that the plaintiffs’ generalized fears of reputational harm and potential future impact on employment were insufficient and unsupported by evidence. It reversed the Superior Court’s order granting plaintiffs anonymity, emphasizing that defamation plaintiffs are generally not entitled to proceed pseudonymously without robust factual support. View "Roe v. Smith" on Justia Law