Justia Injury Law Opinion Summaries

Charter Oak Production Co., LLC paid to settle a property damage claim after a pipeline installed on its easement ruptured, causing a saltwater spill on the property of Jason and Melissa Mills. Charter Oak sought indemnity from JM Eagle, Inc., the manufacturer, and Rainmaker Sales, Inc., the distributor, alleging the pipe was defective. The district court granted summary judgment in favor of JM Eagle and Rainmaker, finding that Charter Oak lacked the necessary legal relationship to assert an indemnity claim and that the claim was barred by the economic loss rule.The Oklahoma Court of Civil Appeals, Division IV, reversed the district court's decision. It found that Charter Oak's non-delegable duty to the Millses created the legal relationship necessary to support an indemnity claim against JM Eagle and Rainmaker. Additionally, it held that Charter Oak's claim was not barred by the economic loss rule.The Supreme Court of the State of Oklahoma reviewed the case. It held that Charter Oak's non-delegable duty as the dominant tenant of the easement established the legal relationship necessary to seek indemnity from JM Eagle and Rainmaker. The court also held that the economic loss rule did not bar Charter Oak's indemnity claim, as it sought reimbursement for damage to property other than the defective product itself. Consequently, the Supreme Court vacated the Court of Civil Appeals' decision, reversed the district court's order, and remanded the case for further proceedings consistent with its opinion. View "Mills v. J-M Mfg. Co., Inc." on Justia Law

The plaintiff, Sara Roman, filed a complaint in Providence County Superior Court alleging she sustained injuries from slipping on untreated snow and ice at Dr. Martin Luther King Jr. Elementary School in Providence. She claimed negligence against the City of Providence and K. Scott Construction & Disposal, Inc., which had a contract with the city for snow removal.The Superior Court granted summary judgment in favor of both defendants. The first hearing justice ruled in favor of the city, applying the Connecticut Rule, which states that a landlord or business invitor's duty to remove snow and ice arises only after the storm has ceased and a reasonable time has passed. The second hearing justice ruled in favor of K. Scott, determining that K. Scott did not owe a duty to the plaintiff because it was not authorized to begin snow removal until after the plaintiff's fall.The Rhode Island Supreme Court reviewed the case. It vacated the judgment in favor of the city, finding that a question of material fact remained as to whether the plaintiff slipped on preexisting ice or freshly accumulated snow, which would affect the city's duty under the Connecticut Rule. The court affirmed the judgment in favor of K. Scott, holding that K. Scott did not owe a duty to the plaintiff at the time of the incident because it was not authorized to perform snow removal until after the plaintiff's fall. View "Roman v. The City of Providence" on Justia Law

Darnell Hairston was seriously injured while operating machinery at Zeeland Farm Soya, Inc. He sued Zeeland Farm Services, Inc. (ZFS) and an employee, later adding Specialty Industries, Inc. as a defendant for negligence and products liability. ZFS settled, but the case against Specialty Industries proceeded to trial, resulting in a jury awarding Hairston over $13 million. Specialty Industries had insurance policies with Burlington Insurance Company and Evanston Insurance Company, which paid their policy limits, leaving a significant portion of the judgment unpaid.The Ottawa Circuit Court denied Hairston and Specialty Industries' motion for supplemental proceedings to pursue a bad-faith refusal to settle claim against the insurers, suggesting they file a separate lawsuit. Hairston then served writs of garnishment on the insurers, which the trial court quashed, stating there was no judgment of bad faith. The trial court also imposed sanctions on Hairston for filing the writs.The Michigan Court of Appeals reversed the trial court's decision to quash the writs, relying on the precedent set in Rutter v King, which allowed bad-faith refusal to settle claims to be litigated through garnishment. However, the Court of Appeals affirmed the sanctions against Hairston.The Michigan Supreme Court reviewed the case and held that unresolved claims of bad-faith refusal to settle are not subject to garnishment under MCR 3.101(G)(1) because they are not sufficiently liquidated. The Court found that the Court of Appeals erred in relying on Rutter, which was decided before the current court rules were adopted. The Supreme Court reversed the Court of Appeals' decision and remanded the case to the trial court for further proceedings consistent with its opinion. View "Hairston v. Lku" on Justia Law

In the summer of 2023, Sharonda Smith's minor child, K.S., participated in a summer program at a school operated by the Jefferson County Board of Education. On June 5, 2023, K.S. fell asleep on a bus driven by "Mr. Josh" and suffered significant emotional distress, dehydration, and other personal injuries. Smith filed a lawsuit on May 10, 2024, against the Board, "Mr. Josh," and 10 fictitiously named defendants. The Board moved to dismiss the claims against it, citing State immunity.The Jefferson Circuit Court dismissed the claims against the Board on August 1, 2024, but allowed Smith additional time to identify and serve "Mr. Josh." Smith issued subpoenas to the Board for records related to the incident, which the Board moved to quash, arguing the court lacked subject-matter jurisdiction. The court denied the motion and ordered the Board to comply with the subpoenas. Smith later identified "Mr. Josh" as Joshua Dunn and added his estate as a defendant. The Board petitioned the Supreme Court of Alabama for a writ of mandamus to vacate the discovery orders and dismiss the case for lack of jurisdiction.The Supreme Court of Alabama held that the circuit court lacked subject-matter jurisdiction because the only named defendant in the initial complaint, the Board, was entitled to State immunity, and "Mr. Josh" was a fictitiously named defendant. The court granted the Board's petition in part, directing the circuit court to vacate its discovery orders and refrain from issuing further orders against the Board. However, the court denied the Board's request to dismiss the entire action, as the Board, a nonparty, did not demonstrate a clear legal right to such relief. View "Ex parte Jefferson County Board of Education" on Justia Law

An eight-year-old student, J.S., was sexually assaulted by her bus driver, Sergio Sandoval, multiple times over a month. J.S.'s parents filed a lawsuit against the Ocean Springs School District under the Mississippi Tort Claims Act, alleging negligence, negligent hiring, retention, supervision, and training, failure to adopt and follow policies, negligent infliction of emotional distress, and civil assault, battery, and false imprisonment. The Jackson County Circuit Court granted summary judgment in favor of the District, finding it was entitled to discretionary-function immunity and that Sandoval’s actions were not reasonably foreseeable.The plaintiff appealed the decision. The Mississippi Supreme Court reviewed the case and determined that while the District was protected by discretionary-function immunity regarding the failure to adopt sufficient policies and procedures, the claims related to negligent hiring, supervision, and training were not barred by this immunity. The court found that these claims involved simple negligence and did not involve policy decisions.The court also held that the plaintiff had demonstrated a genuine issue of material fact regarding the foreseeability of the injuries. The court noted that the District’s own measures to screen and monitor its bus drivers indicated that a person of ordinary intelligence could anticipate that failure to properly do so could lead to the type of injury sustained by J.S.The Mississippi Supreme Court affirmed the lower court’s decision in part, reversed it in part, and remanded the case for further proceedings consistent with its findings. View "J.S. v. Ocean Springs School District" on Justia Law

Ronald Rubin filed a lawsuit naming Kimberly Grippa as part of a criminal enterprise. His lawyer sent allegedly defamatory letters to state officials, asking them to investigate the alleged criminal enterprise and included copies of the complaint. Grippa sued Rubin for defamation, claiming the letters harmed her reputation and professional standing. Rubin moved for summary judgment, arguing the letters were protected by Florida’s absolute and qualified litigation privileges and that he could not be held vicariously liable for his lawyer’s actions.The United States District Court for the Northern District of Florida denied Rubin’s motion for summary judgment on all grounds. The court found that the letters were not protected by the absolute litigation privilege because they were sent outside the litigation process and included additional statements beyond those in the complaint. The court also determined that there was a genuine dispute of material fact regarding whether the statements were made with express malice, precluding the qualified litigation privilege. Lastly, the court rejected Rubin’s vicarious liability argument, suggesting that Rubin directed his lawyer’s actions.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that the denial of Florida’s absolute litigation privilege is immediately appealable under the collateral order doctrine but lacked jurisdiction to consider the denial of the qualified litigation privilege or the vicarious liability issue. The court affirmed the district court’s denial of the absolute litigation privilege, concluding that the letters were sent outside the judicial process and included additional defamatory statements. The court dismissed the appeal regarding the qualified litigation privilege and vicarious liability for lack of jurisdiction. View "Grippa v. Rubin" on Justia Law

Dennis Christopher Howard sued Spotsylvania County Sheriff Roger L. Harris and Deputy David Setlock for injuries from a self-inflicted gunshot wound while detained in a law enforcement vehicle. Howard claimed Harris was responsible for Setlock’s actions, which he argued constituted gross negligence. The incident began when Howard, a convicted felon, was found with a suicide note and missing shotgun. After being detained and searched, Howard maneuvered his handcuffs, accessed a handgun left in the vehicle, and shot himself.The Circuit Court of Spotsylvania County granted summary judgment for the defendants, ruling that Howard’s gross negligence claim failed as a matter of law and that the defense of illegality barred his claims. The court found that Setlock’s actions did not amount to gross negligence and that Howard’s injuries resulted from his illegal act of possessing a firearm as a convicted felon.The Court of Appeals of Virginia reversed the circuit court’s decision, holding that Howard had stated a viable gross negligence claim and that his claim was not barred by the illegality defense. The appellate court found that there was a genuine dispute of material fact regarding Howard’s mental state and whether it negated the mens rea required for the illegal possession of a firearm.The Supreme Court of Virginia reviewed the case and concluded that Howard’s claim was barred by the defense of illegality. The court held that Howard’s violation of Code § 18.2-308.2, which prohibits convicted felons from possessing firearms, was a proximate cause of his injuries. The court reversed the judgment of the Court of Appeals and entered final judgment for the defendants, finding that Howard’s allegation of an “unsound mind” did not negate the strict liability offense of possessing a firearm as a convicted felon. View "Harris v. Howard" on Justia Law

Fatima Shaw-McDonald filed a medical malpractice lawsuit against Eye Consultants of Northern Virginia, P.C. after suffering vision loss following cataract surgery. While the lawsuit was pending, she filed for Chapter 7 bankruptcy but did not initially disclose the lawsuit in her bankruptcy filings. Eye Consultants moved to dismiss the lawsuit, arguing that Shaw-McDonald no longer had standing to pursue it because her interest in the lawsuit had transferred to the bankruptcy trustee. Shaw-McDonald later amended her bankruptcy filings to include the lawsuit and obtained a discharge from the bankruptcy court.The circuit court dismissed the medical malpractice case, concluding that Shaw-McDonald lost standing when she filed for bankruptcy. The court relied on the precedent set by Kocher v. Campbell, which held that a plaintiff loses standing when a cause of action becomes part of the bankruptcy estate. Shaw-McDonald appealed the decision.The Court of Appeals of Virginia reversed the circuit court's decision, holding that Shaw-McDonald had standing to maintain her medical malpractice action. The court reasoned that once the bankruptcy trustee abandoned the claim, it reverted to Shaw-McDonald as if no bankruptcy petition had been filed.The Supreme Court of Virginia reviewed the case and affirmed the Court of Appeals' decision. The court held that Shaw-McDonald did not lose standing permanently when she filed for bankruptcy; rather, her standing was temporarily suspended. The court concluded that the appropriate remedy was to hold the medical malpractice case in abeyance until the bankruptcy proceedings were resolved, rather than dismissing it. The case was remanded to the Court of Appeals for further proceedings consistent with this opinion. View "Eye Consultants of Northern Virginia P.C. v. Shaw-McDonald" on Justia Law

A personal representative of a deceased resident's estate filed a complaint against a hospital district and its associated rehabilitation center, alleging negligence and vicarious liability for injuries suffered by the resident due to physical abuse by a temporary certified nursing assistant (CNA). The hospital district denied liability, claiming the CNA was an independent contractor. After a six-day trial, the jury found the CNA was an agent of the hospital district, and her negligence was a proximate cause of the resident's damages. The jury apportioned fault between the CNA and the hospital district, awarding $660,000 in damages to the estate.The district court reduced the damages by the percentage of fault attributed to the CNA, leading to an appeal by the personal representative, who argued the reduction was contrary to Wyoming law and inconsistent with the jury's verdict. The hospital district cross-appealed, asserting the district court should not have allowed the jury to consider whether the CNA was an agent and should have granted its motion for judgment as a matter of law.The Wyoming Supreme Court reviewed the case and found the district court did not err in denying the hospital district's motion for judgment as a matter of law. The court held there was sufficient evidence for a reasonable jury to find in favor of the personal representative on both direct and vicarious liability claims. The court also found the jury instructions adequately informed the jury of the applicable law and did not cause confusion.However, the Supreme Court determined the district court erred in reducing the damages. The jury found the CNA's conduct was negligent and that she was an agent of the hospital district, making the hospital district vicariously liable for her actions. The court reversed the judgment and remanded the case with instructions to enter a judgment for the full $660,000 in favor of the estate. View "Campbell County Hospital District v. Elsner" on Justia Law

Ethel Barry Masters filed a petition against Jacob Dawson in 2019, alleging replevin, conversion, and unjust enrichment after Dawson refused to surrender possession of four vehicles that belonged to Masters' deceased long-term companion. Dawson disputed ownership and obstructed the legal process, including failing to respond to requests for admissions and barricading the vehicles to prevent towing. The circuit court granted partial summary judgment in favor of Masters, ordering Dawson to surrender the vehicles, which he did not comply with. Dawson's attorney withdrew due to ethical concerns, and subsequent attorneys also withdrew due to Dawson's failure to pay legal fees.The Circuit Court of St. Louis County scheduled multiple trial dates, which were postponed due to Dawson's actions, including retaining new attorneys and filing motions for continuance. Dawson failed to appear for a pretrial conference, leading the circuit court to cancel the jury trial and enter a default judgment in favor of Masters, awarding her $83,035.41 in actual damages and an equal amount in punitive damages. Dawson's conduct was deemed contemptuous, justifying punitive damages to deter similar behavior.The Supreme Court of Missouri reviewed the case and found that Dawson's constitutional claims regarding the right to a jury trial were unpreserved because he did not adequately raise them in his motion for a new trial. The court held that the circuit court did not abuse its discretion by sanctioning Dawson due to his pattern of obstructive behavior. The Supreme Court of Missouri affirmed the circuit court's judgment, upholding the damages awarded to Masters. View "Masters v. Dawson" on Justia Law