Justia Injury Law Opinion Summaries

Trenton Johnson, an employee of Concorp, Inc., was injured while performing maintenance work at Exide Technologies, Inc.'s plant in Kansas City, Missouri. Johnson fell into a vat of molten lead while replacing a belt on a conveyor, resulting in severe burns. He subsequently sued Exide for negligence in Missouri state court.The case was removed to the United States District Court for the Western District of Missouri, where the parties engaged in discovery and briefed the issue of whether Johnson's exclusive remedy was under Missouri's workers' compensation system. The district court granted summary judgment in favor of Exide, concluding that Johnson's claim was indeed limited to workers' compensation benefits.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision de novo. The appellate court examined whether an employer-employee relationship existed between Exide and Johnson under Missouri's workers' compensation statute. The court applied the means/control test and the statutory-employee status test. It found that Concorp, not Exide, had the means/control relationship with Johnson. However, the court determined that Johnson was a statutory employee of Exide because his work was performed under a contract and in the usual course of Exide's business.The Eighth Circuit held that Johnson's exclusive remedy for his injuries was through Missouri's workers' compensation system, and Exide was immune from the negligence claim. The court affirmed the district court's summary judgment in favor of Exide. View "Johnson v. Exide Technologies, Inc." on Justia Law

M.R., a high school student and basketball player, was sexually abused by Cody Butler, a women's basketball coach at Yakima Valley Community College (YVCC), starting when she was 17 years old. The abuse continued into her adulthood, including inappropriate touching, sexual comments, and physical advances. Butler's actions had a significant negative impact on M.R.'s life, leading to substance abuse, abusive relationships, and other personal issues. In 2018, M.R. connected her experiences of abuse to her injuries while in therapy.In 2019, M.R. sued the State of Washington, YVCC, and Butler for various claims, including negligence and assault. The trial court denied the State's motion for summary judgment, which argued that M.R.'s claims were time-barred by the three-year statute of limitations in RCW 4.16.080(2). The court found that the abuse was a continuous series of events that could not be segregated. The Court of Appeals reversed, concluding that RCW 4.16.340 only applies to claims based on acts of childhood sexual abuse occurring before the plaintiff turns 18 years old.The Supreme Court of the State of Washington reviewed the case and reversed the Court of Appeals. The court held that RCW 4.16.340 does not preclude complainants from bringing claims of sexual abuse that originate from childhood sexual abuse and extend into the victim’s adulthood. The court found that the statute's plain language and legislative intent support the inclusion of claims for continuing sexual abuse that are based on intentional acts of childhood sexual abuse. The court also noted that the statute accounts for the continuing tort doctrine, allowing for claims involving a common scheme of abuse by the same perpetrator. View "M.R. v. State" on Justia Law

Z.M., a non-verbal autistic child, attends the Center for Autism at Kiln Creek Elementary School. Through his father, he filed a lawsuit alleging that while being transported on a school bus, Newport News Public Schools employees struck him with a wet sock, verbally abused him, and allowed him to leave the bus partially unclothed. The complaint also mentioned previous verbal insults by school employees. Z.M. sought $15 million in compensatory and punitive damages, alleging negligence and gross negligence by the School Board and its employees.The Newport News School Board filed a plea in bar, claiming sovereign immunity. The Circuit Court of Newport News denied the plea regarding claims of simple and gross negligence but granted it concerning punitive damages, citing sovereign immunity. The School Board then filed an interlocutory appeal under Code §§ 8.01-626 and 8.01-670.2, which allow appeals from decisions on sovereign immunity pleas.The Supreme Court of Virginia reviewed the case de novo. The court concluded that Code § 22.1-194, which waives sovereign immunity when a vehicle is "involved in an accident," did not apply because the bus was not involved in an accident. The court held that the alleged acts did not relate to the operation of the bus as a vehicle. Consequently, the court reversed the circuit court's judgment and remanded the case for further proceedings. The court also noted that while the School Board is protected by sovereign immunity, the employees accused of gross negligence are not, allowing the lawsuit to proceed against them. View "Newport News School Board v. Z.M." on Justia Law

In 2009, John Roe DZ 20, John Roe DZ 21, and John Roe DZ 22 (Plaintiffs) sued an employee of Doe 3, Family Services Organization (Family Services) for alleged childhood sexual assault. The trial court dismissed the claims against the employee with prejudice due to the statute of limitations. In 2022, Plaintiffs filed a new complaint against Family Services based on the same allegations, relying on the revival provision of Code of Civil Procedure section 340.1.The trial court overruled Family Services' demurrer, which argued that Plaintiffs' claims could not be revived under section 340.1, subdivision (q), because they were derivative of the claims litigated to finality in the 2009 action. Family Services then petitioned for a writ of mandate to direct the trial court to vacate its order and sustain the demurrer without leave to amend.The California Court of Appeal, Sixth Appellate District, reviewed the case. The court held that a claim for derivative liability against a principal (Family Services) was "litigated to finality" under section 340.1, subdivision (q), where a previous suit against an agent (Dowell) for the same damages based on the same operative facts was dismissed with prejudice. The court directed the trial court to vacate its order overruling the demurrer and to sustain the demurrer with leave to amend, allowing Plaintiffs the opportunity to amend their complaint to allege facts supporting liability based on conduct other than that of Dowell. View "Doe 3, Family Services Organization v. Superior Court" on Justia Law

Several hundred children in Benton Harbor, Michigan, suffered from elevated lead levels in their blood after drinking lead-contaminated water from the city’s public water system for three years. Plaintiffs, represented by their guardians, filed a lawsuit against various state and city officials, as well as two engineering firms, alleging that these parties failed to mitigate the lead-water crisis and misled the public about the dangers of the drinking water. The claims included substantive-due-process and state-created-danger claims under 42 U.S.C. § 1983, as well as state-law negligence claims.The U.S. District Court for the Western District of Michigan dismissed the complaint in full. The court found that the plaintiffs did not plausibly allege a violation of their constitutional rights and declined to exercise supplemental jurisdiction over the state-law claims. Plaintiffs appealed the dismissal of their federal claims against the city and state officials and the state-law claims against one of the engineering firms.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the dismissal of the claims against the state officials, finding that the plaintiffs did not plausibly allege that these officials acted with deliberate indifference. However, the court reversed the dismissal of the claims against the city officials and the City of Benton Harbor, finding that the plaintiffs plausibly alleged that these officials misled the public about the safety of the water, thereby causing the plaintiffs to drink contaminated water. The court also reversed the district court’s declination of supplemental jurisdiction over the state-law claims against the engineering firm and remanded the case for further proceedings. The court affirmed the district court’s denial of leave to amend the complaint. View "Mitchell v. City of Benton Harbor" on Justia Law

Maxwell Tillinghast, a 13-year-old student, collapsed from sudden cardiac arrest while jogging during a physical education class at Palms Middle School. Although the school had a defibrillator in the main office, the teachers were unaware of its presence. Despite being trained to use a defibrillator, the teachers could not utilize it, leading to Tillinghast's death. His father sued the Los Angeles Unified School District (LAUSD) and several employees, alleging negligence for failing to inform the teachers about the defibrillator.The Superior Court of Los Angeles County heard the case, where the jury focused on whether Tillinghast's latent heart defect would have been fatal even if the teachers had known about the defibrillator. The jury found the school district negligent and awarded Tillinghast's father $15 million in damages. The jury exonerated the school principal, Dr. Derek Moriuchi, from negligence.The LAUSD appealed to the Court of Appeal of the State of California, Second Appellate District, Division Eight, arguing that the trial court erred in giving a specific jury instruction (CACI No. 423) related to public entity liability for failure to perform a mandatory duty. The appellate court found that the school district had forfeited its objections to this instruction by not raising the issue during the trial. Additionally, the court noted that the school district had conceded mistakes were made regarding the defibrillator's availability and training.The Court of Appeal affirmed the judgment, holding that the evidence supported the jury's verdict and that the school district's failure to inform the teachers about the defibrillator constituted negligence. The court awarded costs to the respondent, Tillinghast's father. View "Tillinghast v. L.A. Unified School District" on Justia Law

Rodney Dean Bjornson, the relator, suffered two injuries while employed by McNeilus Companies, Inc. He received treatment at Mayo Clinic, with expenses paid by United Healthcare Services. Bjornson's attorney, David C. Wulff, sought Roraff fees for recovering medical benefits. The compensation judge awarded Wulff $49,000 in Roraff fees, finding that United paid $327,257.37 in medical benefits based on itemized medical bills from Mayo Clinic attached to Bjornson's Employee’s Claim Petition.The Workers’ Compensation Court of Appeals (WCCA) reviewed the case and concluded that the itemized bills from Mayo Clinic were not in the appellate record. The WCCA reversed the compensation judge’s award of Roraff fees due to insufficient evidence regarding the bills and modified the Roraff fees to $500, as per the statutory formula for unascertainable benefits amounts.The Minnesota Supreme Court reviewed the case to determine if Wulff presented sufficient evidence of the ascertainable dollar value of medical benefits. The court found that the WCCA did not assess whether the remaining evidence, including Wulff’s testimony and exhibits, was adequate to support the compensation judge’s conclusion. The Supreme Court reversed the WCCA's decision and remanded the case for further proceedings. The WCCA was directed to clarify whether the itemized medical bills were actual bills or a summary document and to determine if the evidence in the record was adequate to support the compensation judge’s conclusion. View "Bjornson v. McNeilus Companies, Inc." on Justia Law

A man was injured in an accident outside city limits and sued a city and an emergency-responder employee for negligently providing assistance and aggravating his injuries. The city and employee offered the man $7,500 to settle the lawsuit, which he did not accept. They also moved for summary judgment, arguing that they could not be sued because AS 09.65.070(d)(4) does not allow lawsuits based on the “gratuitous extension of municipal services” beyond city limits. The superior court granted summary judgment in their favor, ruling that their actions were gratuitous because they were under no legal obligation to take them. The court also granted attorney’s fees to the city and employee based on a court rule that requires a party to pay the other side’s legal fees if the party rejected an offer of judgment to settle the case that was more favorable than the judgment the party ultimately received.The man appealed, arguing that the city’s emergency response was not gratuitous because he was billed a mileage fee for the ambulance service. He also argued that the city and employee were not entitled to attorney’s fees because their pretrial offer of judgment was invalid.The Supreme Court of the State of Alaska reviewed the case. The court held that AS 09.65.070(d)(4) bars the lawsuit because the city and employee’s actions were gratuitous, meaning they were performed without legal obligation and without charging more than the standard fee. The court also held that the offer of judgment was valid and that the superior court did not err in awarding attorney’s fees to the city and employee. The court affirmed the superior court’s grant of summary judgment and the award of attorney’s fees. View "Rochon v. City of Nome" on Justia Law

PorterCare Adventist Health Systems had inadequate surgical-sterilization procedures for about two years, leading to over $40 million in liability from thousands of patients' claims. PorterCare sought coverage from AdHealth, its excess-liability insurer, for the full $40 million policy limit, arguing that the claims arose from one medical incident. AdHealth refused coverage, asserting that a medical incident covers injuries to a single person, not multiple people, and filed a complaint seeking a declaratory judgment. PorterCare counterclaimed for declaratory judgment and breach of contract.The United States District Court for the District of Colorado granted summary judgment to AdHealth, agreeing with its interpretation that a medical incident is limited to the acts or omissions causing injury to one person. The court found that AdHealth owed coverage only for the claims of a single patient that trigger the excess policy’s liability threshold, not for multiple patients' claims grouped together.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the policy’s definition of “medical incident” unambiguously applies to the injuries of a single person. Therefore, AdHealth is liable only for individual claims exceeding PorterCare’s $2 million self-insurance retention, not for the aggregated claims of multiple patients. View "Adhealth, Limited v. PorterCare Adventist Health Systems" on Justia Law

The case involves Raymond Dugan, who was convicted and sentenced in the Southern District of West Virginia for accessing child pornography. Dugan raised three main issues on appeal: the denial of his motion to compel discovery related to a foreign law enforcement agency's investigation, the denial of his motion to suppress evidence obtained from a search warrant, and the restitution order requiring him to pay $22,000 to five child victims.In the lower court, Dugan was convicted by a jury of accessing child pornography. He was sentenced to 54 months in prison, followed by five years of supervised release, and ordered to pay $22,000 in restitution. Dugan filed pretrial motions to compel discovery and suppress evidence, both of which were denied by the district court. The court found that the foreign agency's tip was reliable and that the search warrant was supported by probable cause. The court also ruled that the officers acted in good faith when executing the warrant.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's decisions, holding that the denial of the motion to compel discovery was appropriate because Dugan's request was speculative and unsupported by evidence. The court also upheld the denial of the motion to suppress, finding that the search warrant was based on probable cause, given the deliberate steps required to access the child pornography website. Finally, the court found no abuse of discretion in the restitution order, as the district court had carefully considered the relevant factors and evidence in determining the amounts.The Fourth Circuit affirmed Dugan's conviction and sentence, including the restitution order. View "US v. Dugan" on Justia Law