Justia Class Action Opinion Summaries

Defendant was charged with violating Ohio Rev. Code 4301.69(A), which prohibits the sale of beer to an underage person. At Defendant's trial, the State had difficulty proving what Defendant sold to an informant was beer as defined by statute. The court then took judicial notice that Bud Light was, in fact, beer. Defendant was convicted as charged. The court of appeals reversed and ordered a new trial, concluding that the trial court erred in taking judicial notice of a fact - the alcohol content by volume of Bud Light - that was not something that was "generally known." The Supreme Court reversed and vacated Defendant's conviction, holding that because there was no evidence admitted on the statutory element of the alcohol content of the substance sold by Defendant to the informant, there was insufficient evidence for a conviction, and double jeopardy barred a retrial. View "State v. Kareski" on Justia Law

After a jury trial, Defendant was convicted of rape and first-degree sexual abuse and sentenced to life imprisonment and ten years' imprisonment, respectively. Defendant subsequently filed a petition for postconviction relief, alleging several claims of ineffective assistance of counsel. The circuit court granted Defendant a new trial based on one ground of ineffective assistance as to the rape conviction and two grounds of ineffective assistance as to the sexual-abuse conviction. The State appealed. The Supreme Court affirmed the circuit court's grant of a new trial based on ineffective assistance of counsel, holding that, based on the standard of review under Strickland v. Washington, the circuit court was not clearly erroneous in its rulings on both of Defendant's convictions.View "State v. Estrada" on Justia Law

After his vehicle was stopped by a police officer, Defendant was arrested for driving while intoxicated, and a breathalyzer test computed his blood alcohol content at close to twice the legal limit. Defendant was subsequently indicted for felony DWI. During the jury trial, the People offered into evidence documents pertaining to the routine calibration and maintenance of the breathalyzer machine used in Defendant's breath test to demonstrate it was in proper working order at the time Defendant was tested. Defendant raised a Confrontation Clause challenge to the documents, contending that he was entitled to cross-examine the authors of the records. The county court allowed the documents to be received in evidence, and Defendant was convicted of felony DWI. The appellate division affirmed. The Court of Appeals affirmed, holding that documents pertaining to the routine inspection, maintenance, and calibration of breathalyzer machines are nontestimonial, and consequently, the Confrontation Clause was not implicated in this case, and the trial judge did not err in declining Defendant's request to cross-examine the authors of the testing records before the court ruled on their admissibility.View "People v. Pealer" on Justia Law

This case involved the appeal of Petitioner of her sentence of life without mercy imposed in the circuit court by order, as recommended by the jury which found Petitioner guilty of first degree murder. Petitioner assigned four errors committed by the trial court, including the admission of the decedent's statements, failure to give a Harden instruction, failure to give a good character instruction, and the failure to suppress one of Petitioner's statements to the police. The Supreme Court reversed the judgment of the circuit court and remanded the case for a new trial, holding (1) the court did not err in admitting the statements of the decedent; (2) the court's decision to admit the statement was not an abuse of discretion; but (3) under the limited circumstances of this case, the court erred in failing to give a proper good character instruction.View "State v. Surbaugh" on Justia Law

After a jury trial, Appellant was convicted of rape and sentenced to seventy years' imprisonment. For his only point on appeal, Appellant argued that the circuit court erred in not allowing testimony concerning the victim's prior sexual conduct. Under the state's rape-shield law, evidence of a victim's prior sexual conduct is not admissible by the defendant for any purpose unless the circuit court makes a written determination that such evidence is relevant to a fact in issue and that its probative value outweighs its inflammatory or prejudicial nature. The Supreme Court affirmed, holding that Appellant's arguments were not preserved for appeal. View "Stewart v. State" on Justia Law

The State appealed a three-judge district court order directing California to remedy two ongoing violations of the Cruel and Unusual Punishments Clause, a guarantee binding on the States by the Due Process Clause of the Fourteenth Amendment, by reducing the prison system population where the violations were the subject of two class actions involving a class of prisoners with serious mental disorders and a class of prisoners with serious medical conditions. At issue was whether the remedial order issued by the three-judge court was consistent with requirements and procedures set forth in a congressional statute, the Prison Litigation Reform Act of 1995 ("PLRA"), 18 U.S.C. 3626. The Court held that the court-mandated population limit was necessary to remedy the violation of prisoners' constitutional rights and was authorized by the PLRA.View "Brown, et al. v. Plata, et al." on Justia Law

Plaintiff sued Sentinel for criminal contempt of court for resisting the Superior Court's order granting him a writ of habeas corpus and "using its position as a probation company to attempt to collect a debt that is not owed or due by threatening to have [plaintiff] jailed without bond." Plaintiff also alleged that Sentinel engaged in a pattern of racketeering activity under O.C.G.A. 16-14-1 et seq. Sentinel removed the suit to the district court pursuant to the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d)(2). The court rejected plaintiff's arguments under CAFA; concluded that the district court did not err in shifting the burden of production to plaintiff in response to Sentinel's testimonial evidence; and concluded that plaintiff offered no citation to support the theory of corporate liability. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Sentinel. View "McGee v. Sentinel Offender Services, LLC" on Justia Law

In 2008, plaintiffs were inmates at the Indianapolis jail, which was operated by CCA under contract with the Marion County Sheriff’s Department. They claimed that the jail provided inadequate medical care and exposed inmates to inhumane living conditions so egregious that they amounted to cruel and unusual punishment in violation of the Eighth Amendment. The district court certified a class, but dismissed claims that the jail failed to provide adequate medical care, that the conditions of confinement inside the jail were inhumane, and that the procedures in the jail violated inmates’ rights under the Health Insurance Portability and Accountability Act and later entered summary judgment for CCA on the remaining issues. The Seventh Circuit affirmed, noting that CCA had produced an affidavit indicating that complained-of problems had been resolved. View "Kress v. CCA of TN, LLC" on Justia Law

The district court presided over four class action cases. Two insurance companies (collectively, Defendants) were the defendants in the two underlying cases. Allianz Life Insurance Company (Allianz) was a defendant in the other cases. Defendants filed motions for summary judgment. Plaintiffs opposed and attached a declaration by Dr. Craig McCann to support their theories. When Defendants moved to exclude the opinion, the court appointed an expert witness, Dr. Zvi Bodie, to evaluate Dr. McCann's opinion. The district court ordered Dr. Bodie's report sealed until it determined whether the report was admissible. In its case, Allianz filed a motion for summary judgment and a Daubert motion to exclude Dr. McCann. Defendants settled with the plaintiffs before the district court ruled on the Daubert or summary judgment motions. Allianz subsequently intervened in the underlying cases and requested the unsealing of Dr. Bodie's report. The district court denied its motion, ruling that the presumption in favor of public access to judicial records did not apply to the records at issue because they were attached to a non-dispositive Daubert motion. The Ninth Circuit Court of Appeals reversed and remanded with directions to grant the motion, because the records at issue were filed in connection with pending summary judgment motions. View "Midland Nat'l Life Ins. Co. v. Allianz Life Ins. Co. of N.A." on Justia Law

A suit seeking to represent a class of inmates at the “supermax” Tamms Correctional Center, alleging due process violations, was dismissed. The Seventh Circuit reversed. While remand was pending, the Illinois Department of Corrections developed a “Ten-Point Plan,” revising procedures for transferring inmates to Tamms, with a detailed transfer-review process. Although it had not been implemented, IDOC submitted the Plan at trial. The court held that conditions at Tamms impose atypical and significant hardship, establishing a due-process liberty interest in avoiding transfer to Tamms, and that procedures for transfer decisions were unconstitutional. The court entered an injunction incorporating the Ten-Point Plan. The Seventh Circuit vacated. The scope and specificity of the injunction exceed what is required to remedy the due process violation, contrary to the Prison Litigation Reform Act, 18 U.S.C. 3626(a)(1)(A), and to Supreme Court statements about remedial flexibility and deference to prison administrators in this type of litigation. Injunctive relief to remedy unconstitutional prison conditions must be “narrowly drawn,” extend “no further than necessary” to remedy the violation, and use the “least intrusive means” to correct the violation of the federal right. Making the Plan a constitutional baseline eliminated operational discretion and flexibility, exceeding what due process requires and violating the PLRA. View "Westefer v. Neal" on Justia Law