Justia U.S. D.C. Circuit Court of Appeals Opinion Summaries

WMATC filed suit against Paul Rodberg and his company, seeking an injunction to shut down Rodberg's illegal limousine operation. After the district court entered a default judgment, Rodberg ignored the default judgment and continued operating his limousine business under a different name. The district court issued another order enjoining all of Rodberg's companies from transporting passengers without a license. Rodberg appealed the default judgment and order. The court affirmed the default judgment where the district court did not abuse its discretion when it entered default judgment against Rodberg as a sanction for his total discovery lapse. The court concluded that it lacked jurisdiction to consider the subsequent order where the order did not modify the previous injunction because Rodberg's company was already bound by the earlier order as a matter of law. Accordingly, the court affirmed in Case No. 13-7072 and dismissed in Case No. 13-7161. View "Washington Metro. Area Transit Comm'n v. Reliable Limousine Serv." on Justia Law

John Tyler and his wife filed suit seeking damages from various companies that manufacture products containing asbestos that he had been exposed. After Tyler died from a form of lung cancer caused by asbestos, Stephen Wannall became the personal representative of Tyler's estate. Honeywell was named in the suit as the successor-in-interest to the Bendix Corporation, which manufactured brake shoes that Tyler used in helping friends, family, and neighbors perform automobile repairs for over 50 years. Honeywell moved for summary judgment, arguing that plaintiff failed to establish the causal link required under Virginia law between Tyler's exposure to Bendix brakes and his disease. The district court denied the motion. While the parties were preparing for trial, the Supreme Court of Virginia issued Ford Motor Company v. Boomer, which rejected the "substantial" cause standard that the parties had previously understood as controlling, and ruled instead that plaintiffs must demonstrate that "exposure to the defendant's product alone must have been sufficient to have caused the harm." Honeywell moved for reconsideration of its motion for summary judgment in light of Boomer. Plaintiff opposed the motion but did not seek leave to file a new declaration of their expert under Rule 26(e). Nor did plaintiff move under Rule 56(d) for permission to take additional discovery in response to Honeywell's motion. Therefore, the court affirmed the district court's grant of Honeywell's motion to strike the new expert declaration and its renewed motion for summary judgment pursuant to Boomer. View "Wannall v. Honeywell, Inc." on Justia Law

Appellant filed suit against the Republic of Cuba and others in Florida state court, alleging that appellees tortured appellant and that appellant continues to suffer the consequences of the torture. Appellant was incarcerated in Cuba in the 1960s and 1970s, and endured unlawful incarceration and torture committed by the Cuban government and its codefendants. Appellant obtained a default judgment in state court and now seeks to execute that judgment on patents and trademarks held or managed by appellees in this action, who are allegedly agents and instrumentalities of Cuba. The court affirmed the district court's denial of appellant's request because the Florida state court lacked subject matter jurisdiction to grant the default judgment. View "Jerez v. Republic of Cuba" on Justia Law

Plaintiff filed suit against defendants in state court, challenging the foreclosure proceedings that ultimately resulted in the sale of his property. Defendants removed to federal court and moved for judgment on the pleadings. The court affirmed the district court's order denying leave to amend plaintiff's complaint to add additional federal claims; vacated the district court's orders relating to the state-law claims against Chase and Shapiro & Burson because the D.C. statutory and common law claims against the bank and its foreclosing agent should have been decided by the local courts; and remanded to the district court with instructions to remand to Superior Court for determination of plaintiff's state-law claims against those parties. View "Araya v. JPMorgan Chase Bank, N.A." on Justia Law

Plaintiff filed suit alleging that BAE had tortiously interfered with his at-will employment arrangement in violation of District of Columbia law. Plaintiff filed a diversity case in federal district court but would like to have the dispositive question he raises on appeal decided by the District Court of Columbia Court of Appeals: whether District of Columbia law recognizes a cause of action for tortious interference with at will employment against a third party former employer who procured the plaintiff's discharge from his new employer. Because the question on which plaintiff seeks certification is neither genuinely uncertain nor of sufficient public importance to warrant burdening the D.C. Court of Appeals, the court denied the request. The court affirmed the judgment of that court because plaintiff does not ask this court to independently review the district court's resolution of that question. View "Metz v. BAE Sys. Tech." on Justia Law

Plaintiff filed a class action suit against his former employer, Harman, under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., alleging that Harman breached its fiduciary duties by making false and misleading statements to investment firms. On appeal, plaintiff challenged the district court's conversion of defendants' motion to dismiss under Federal Rule of Civil Procedure 12(b)(6)(d) and grant of summary judgment to defendants without giving plaintiff a reasonable opportunity to present evidence. The court did not reach the merits of the appeal, concluding that if the district court violated Rule 12(d), the error would be harmless in this case where discovery would be futile. Accordingly, the court affirmed the judgment. View "Russell v. Harman Int'l Indus." on Justia Law

The County filed suit against the Department, challenging the Secretary's approval of a gaming compact between the Buena Vista Rancheria of Me-Wuk Indians and the State of California. The Tribe sought to intervene after six years of litigation for the purpose of dismissing the amended complaint under Federal Rule of Civil Procedure 19. The court concluded that the district court did not abuse its discretion in denying the motion as untimely where the district court set forth the proper test, analyzed the relevant factors, and concluded that the Tribe's motion did not satisfy Rule 24(a)'s timeliness requirement. Accordingly, the court affirmed the judgment. View "Amador County, CA v. Dept. of the Interior" on Justia Law

Plaintiff filed suit against the Fund, asserting claims for assault, false imprisonment, and intentional infliction of emotional distress. The Fund's motion to dismiss was converted into a discovery dispute when the district court granted plaintiff's request for jurisdictional discovery over the Fund's objections. The court concluded that, because plaintiff's assertions amount to mere conjecture and surmise, they cannot provide sufficient support to justify jurisdictional discovery. Further, the Fund's subsequent voluntary disclosure of the contract at issue conclusively resolved any question of waiver. Accordingly, the court reversed the district court's orders permitting jurisdictional discovery and remanded for further proceedings. View "Nyambal v. International Monetary Fund" on Justia Law

Alaska filed suit challenging the Forest Service's Roadless Rule in 2011. In 2001, the Forest Service adopted the Rule, which prohibited road construction, road reconstruction, and timber harvesting on millions of acres of national forest lands, including national forest land in Alaska. In 2005, the Forest Service repealed the Rule, but, in 2006, the District Court for the Northern District of California ordered reinstatement of the Rule. The court concluded that when the Rule was reinstated in 2006 after its repeal in 2005, a new right of action accrued. Under 28 U.S.C. 2401(a), Alaska had six years from the time of the Rule's reinstatement in 2006 to file a lawsuit challenging the rule. Therefore, Alaska's suit is timely because it filed in 2011. Accordingly, the court reversed the district court's dismissal of Alaska's complaint and remanded for further consideration. View "State of Alaska v. Department of Agriculture" on Justia Law

Appellants filed a wrongful death action against Romarm, a foreign corporation and firearms manufacturer owned by the Romanian government and located in Bucharest. The district court granted Romarm's motion to dismiss based on failure to allege personal jurisdiction over Romarm. Supreme Court Justice Breyer's narrow concurrence in J.McIntyre Machinery, Ltd. v. Nicastro concluded that a foreign corporation's sale to a distributor, without more, is insufficient to establish the minimum contacts necessary for a court to exert personal jurisdiction over the corporation, even if its product ultimately causes injury in the forum state. In light of Nicastro, the court concluded that appellants have failed to allege any conduct by Romarm that was purposely directed toward the District of Columbia; nor could their discovery requests supply the missing element; and the district court appropriately dismissed the case for lack of personal jurisdiction. Accordingly, the court affirmed the judgment of the district court.View "Williams, et al. v. Romarm, SA, et al." on Justia Law