Justia Commercial Law Opinion Summaries

Lavonne S. Mottern died after receiving a contaminated intravenous injection at Princeton Medical Center, operated by Baptist Health System, Inc. (BHS). Donald J. Mottern, as administrator of Lavonne's estate, filed claims against BHS, Meds I.V., LLC (the manufacturer of the injection), and three individuals associated with Meds I.V. The claims against Meds I.V. and the individuals were settled, leaving only the claims against BHS, which included negligence, wantonness, a claim under the Alabama Extended Manufacturer's Liability Doctrine (AEMLD), and a breach of implied warranty under the Uniform Commercial Code (UCC).The Jefferson Circuit Court dismissed all of Mottern's claims against BHS, including the negligence and wantonness claims, which BHS conceded should not have been dismissed. BHS argued that the AEMLD and UCC claims were subject to the Alabama Medical Liability Act (AMLA) and required proof of a breach of the standard of care. The trial court agreed and dismissed these claims, leading to Mottern's appeal.The Supreme Court of Alabama reviewed the case and agreed with BHS that all of Mottern's claims, including those under the AEMLD and UCC, are subject to the AMLA's standard-of-care provisions. The court held that the AMLA applies to all actions for medical injury, regardless of the theory of liability, and requires proof of a breach of the standard of care. The court reversed the trial court's dismissal of the negligence and wantonness claims and remanded the case for further proceedings consistent with its opinion. The main holding is that the AMLA's standard-of-care provisions apply to all claims alleging medical injury, including those under the AEMLD and UCC. View "Mottern v. Baptist Health System, Inc." on Justia Law

United Parcel Service, Inc. (UPS) challenged the Postal Regulatory Commission's (Commission) handling of the United States Postal Service's (Postal Service) pricing of competitive products, arguing that the Postal Service underprices these products by not accounting for "peak-season" costs incurred during the holiday season. UPS claimed that these costs, driven by increased demand for package deliveries, should be attributed to competitive products rather than being treated as institutional costs.The Commission denied UPS's petition to initiate rulemaking proceedings and its subsequent motion for reconsideration. The Commission found that UPS's methodology for calculating peak-season costs was flawed and did not produce reliable estimates. It also concluded that the existing cost-attribution framework already accounted for the costs caused by competitive products during the peak season. The Commission explained that the Postal Service's costing models, which use an incremental-cost approach, appropriately attribute costs to competitive products and that the remaining costs are correctly treated as institutional costs.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court upheld the Commission's decision, finding that the Commission's rejection of UPS's methodology was reasonable and well-explained. The court noted that the Commission had addressed UPS's concerns about the Postal Service's costing models and had initiated further proceedings to explore potential updates to the models. The court also rejected UPS's argument that the Commission failed to consider whether peak-season costs are institutional costs uniquely associated with competitive products, noting that this issue was not properly presented in this case.The court denied UPS's petition for review, affirming the Commission's orders. View "United Parcel Service, Inc. v. PRC" on Justia Law

Michael R. Rattagan, an Argentinian lawyer, was retained by Uber Technologies, Inc. through its Dutch subsidiaries to assist with launching Uber's ridesharing platform in Argentina. Rattagan also agreed to act as the Dutch subsidiaries' legal representative in Argentina, a role that exposed him to personal liability under Argentinian law. Despite warnings about potential personal exposure, Uber allegedly concealed its plans to launch the platform in Buenos Aires, which led to significant legal and reputational harm to Rattagan when the launch was deemed illegal by local authorities.The United States District Court for the Northern District of California dismissed Rattagan’s third amended complaint without leave to amend, ruling that his fraudulent concealment claims were barred by the economic loss rule as interpreted in Robinson Helicopter v. Dana Corp. The court concluded that Robinson provided only a narrow exception to the economic loss rule, which did not apply to Rattagan’s claims of fraudulent concealment. The court also found that Rattagan’s negligence and implied covenant claims were time-barred.The Supreme Court of California, upon request from the Ninth Circuit, addressed whether a plaintiff may assert a tort claim for fraudulent concealment arising from or related to the performance of a contract under California law. The court held that a plaintiff may assert such a claim if the elements of the claim can be established independently of the parties’ contractual rights and obligations, and if the tortious conduct exposes the plaintiff to a risk of harm beyond the reasonable contemplation of the parties when they entered into the contract. The court clarified that the economic loss rule does not bar tort recovery for fraudulent concealment in these circumstances. View "Rattagan v. Uber Technologies, Inc." on Justia Law

The City of Los Angeles contracted with PricewaterhouseCoopers (PwC) to modernize the billing system for the Department of Water and Power (LADWP). The rollout in 2013 resulted in billing errors, leading the City to sue PwC in 2015, alleging fraudulent misrepresentation. Concurrently, a class action was filed against the City by Antwon Jones, represented by attorney Jack Landskroner, for overbilling. Discovery revealed that the City’s special counsel had orchestrated the class action to settle claims favorably for the City while planning to recover costs from PwC.The Los Angeles County Superior Court found the City engaged in extensive discovery abuse to conceal its misconduct, including withholding documents and providing false testimony. The court imposed $2.5 million in monetary sanctions against the City under the Civil Discovery Act, specifically sections 2023.010 and 2023.030, which allow sanctions for discovery misuse.The California Court of Appeal reversed the sanctions, interpreting the Civil Discovery Act as not granting general authority to impose sanctions for discovery misconduct beyond specific discovery methods. The appellate court held that sections 2023.010 and 2023.030 do not independently authorize sanctions but must be read in conjunction with other provisions of the Act.The Supreme Court of California reversed the Court of Appeal’s decision, holding that the trial court did have the authority to impose monetary sanctions under sections 2023.010 and 2023.030 for the City’s pattern of discovery abuse. The Supreme Court clarified that these sections provide general authority to sanction discovery misuse, including systemic abuses not covered by specific discovery method provisions. View "City of Los Angeles v. Pricewaterhousecoopers, LLP" on Justia Law

Taxinet Corporation sued Santiago Leon, alleging various claims stemming from a joint effort to secure a government concession for a taxi-hailing app in Mexico City. The district court granted summary judgment for Leon on all claims except for a Florida-law unjust enrichment claim, which went to trial along with Leon’s counterclaims for fraudulent and negligent misrepresentation. The jury awarded Taxinet $300 million for unjust enrichment and Leon $15,000 for negligent misrepresentation. However, the district court granted Leon’s Rule 50(b) motion for judgment as a matter of law, ruling that the damages award was based on inadmissible hearsay and was speculative.The United States District Court for the Southern District of Florida initially allowed testimony regarding a $2.4 billion valuation by Goldman Sachs, which was later deemed inadmissible hearsay. The court concluded that without this evidence, there was insufficient support for the jury’s $300 million award. The court also noted that the valuation was speculative and not directly tied to the benefit conferred by Taxinet in 2015.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s Rule 50(b) order, agreeing that the valuation evidence was inadmissible hearsay and that the remaining evidence was insufficient to support the $300 million award. However, the appellate court exercised its discretion to remand for a new trial on the unjust enrichment claim. The court found that Taxinet had presented enough evidence to show that it conferred a benefit on Leon, which he accepted, and that it would be inequitable for him to retain the benefit without payment. The court also noted that Taxinet could potentially present other evidence of damages in a new trial.The appellate court affirmed the district court’s summary judgment on Taxinet’s other claims, ruling that the alleged joint venture agreement was subject to Florida’s statute of frauds, as it could not be completed within a year. Thus, any claims based on the existence of the joint venture agreement were barred. View "Taxinet Corp. v. Leon" on Justia Law

Ryan Cox filed a class action lawsuit alleging that the defendants manipulated the price of a cryptocurrency called HEX by artificially lowering its ranking on CoinMarketCap.com. The defendants include two domestic companies, a foreign company, and three individual officers of the foreign company. Cox claimed that the manipulation caused HEX to trade at lower prices, benefiting the defendants financially.The United States District Court for the District of Arizona dismissed the case for lack of personal jurisdiction, concluding that Cox needed to show the defendants had sufficient contacts with Arizona before invoking the Commodity Exchange Act's nationwide service of process provision. The court found that none of the defendants had sufficient contacts with Arizona.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the Commodity Exchange Act authorizes nationwide service of process independent of its venue requirement. The court concluded that the district court had personal jurisdiction over the U.S. defendants, CoinMarketCap and Binance.US, because they had sufficient contacts with the United States. The court also found that Cox's claims against these defendants were colorable under the Commodity Exchange Act. Therefore, the court reversed the district court's dismissal of the claims against the U.S. defendants and remanded for further proceedings.However, the Ninth Circuit affirmed the district court's dismissal of the claims against the foreign defendants, Binance Capital and its officers, due to their lack of sufficient contacts with the United States. The court vacated the dismissal "with prejudice" and remanded with instructions to dismiss the complaint against the foreign defendants without prejudice. View "COX V. COINMARKETCAP OPCO, LLC" on Justia Law

Children’s Health Defense (CHD), a nonprofit organization, alleged that Meta Platforms, Inc. (Meta) censored its Facebook posts about vaccine safety and efficacy. CHD claimed that Meta’s actions were directed by the federal government, violating the First and Fifth Amendments. CHD also asserted violations of the Lanham Act and the Racketeer Influenced and Corrupt Organizations Act (RICO). Meta, Mark Zuckerberg, the Poynter Institute, and Science Feedback were named as defendants.The United States District Court for the Northern District of California dismissed CHD’s complaint. The court found that CHD failed to establish that Meta’s actions constituted state action, a necessary element for First Amendment claims. The court also dismissed the Lanham Act claim, ruling that Meta’s fact-checking labels did not constitute commercial advertising. Additionally, the court rejected the RICO claim, stating that CHD did not adequately allege a fraudulent scheme to obtain money or property.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that CHD did not meet the requirements to treat Meta as a state actor. The court found that Meta’s content moderation policies were independently developed and not compelled by federal law. CHD’s allegations of government coercion and joint action were deemed insufficient. The court also upheld the dismissal of the Lanham Act claim, concluding that Meta’s fact-checking labels were not commercial speech. The RICO claim was dismissed due to a lack of proximate cause between the alleged fraud and CHD’s injury.Judge Collins partially dissented, arguing that CHD could plausibly allege a First Amendment claim for injunctive relief against Meta. However, he agreed with the dismissal of the other claims. The Ninth Circuit’s decision affirmed the district court’s judgment in favor of Meta. View "Children's Health Defense v. Meta Platforms, Inc." on Justia Law

The case involves BioPoint, Inc., a life sciences consulting firm, which accused Catapult Staffing, LLC, and Andrew Dickhaut of misappropriating trade secrets, confidential business information, and engaging in unfair trade practices. BioPoint alleged that Catapult, with the help of Dickhaut and Leah Attis (a former BioPoint employee and Dickhaut's fiancée), used BioPoint's proprietary information to recruit candidates and secure business from BioPoint's clients, including Vedanta and Shire/Takeda.The U.S. District Court for the District of Massachusetts handled the initial proceedings. The jury found Catapult liable for misappropriating BioPoint's trade secrets concerning three candidates and two clients, and for tortious interference with BioPoint's business relationship with one candidate. The jury awarded BioPoint $312,000 in lost profits. The judge, in a subsequent bench trial, found Catapult liable for unjust enrichment and violations of the Massachusetts Consumer Protection Law (chapter 93A), awarding BioPoint $5,061,444 in damages, which included treble damages for willful and knowing conduct, as well as costs and attorneys' fees.The United States Court of Appeals for the First Circuit reviewed the case. The court largely affirmed the lower court's findings but reduced the judge's award by $157,068, as it found that BioPoint could not recover both lost profits and unjust enrichment for the same placement. The court also reversed the district court's imposition of joint-and-several liability on Andrew Dickhaut, ruling that he could not be held liable for profits he did not receive. The case was remanded for further proceedings to determine Dickhaut's individual liability. View "BioPoint, Inc. v. Dickhaut" on Justia Law

The case involves a pass-through billing scheme orchestrated by Beau Gertz, Mark Blake, SeroDynamics, and LabMed Services (collectively, the Sero Defendants). They made it appear that blood tests conducted at their Colorado lab were performed at a small hospital in Unionville, Missouri, resulting in a $26.3 million profit. The scheme involved billing Blue Cross using the hospital's provider numbers, despite the tests not being conducted there. Blue Cross paid the hospital $18,053,015 for these tests. The Sero Defendants were found liable for fraud, tortious interference with contract, civil conspiracy, and money had and received.The United States District Court for the Western District of Missouri oversaw the trial. After five days of evidence, the jury found the Sero Defendants liable and awarded Blue Cross $18,053,015 in compensatory damages and $1.9 million in punitive damages against each of the four Sero Defendants. The Sero Defendants appealed, raising multiple claims of error, including the exclusion of their lead counsel from delivering closing arguments and the admission of certain evidence.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's judgments, finding no abuse of discretion in the exclusion of lead counsel from closing arguments due to repeated misconduct. The court also upheld the admission of a portion of an audit report, finding it relevant and not unfairly prejudicial. The court found sufficient evidence to support the jury's findings of fraud and tortious interference, noting that the Sero Defendants had actual knowledge of the contract between Putnam and Blue Cross and intentionally interfered with it. The court also upheld the jury's award of damages and punitive damages, finding no miscarriage of justice.In conclusion, the Eighth Circuit affirmed the district court's judgments, rejecting all of the Sero Defendants' claims of error. View "RightCHOICE Managed Care v. Labmed Services, LLC" on Justia Law

F.C. Bloxom Company, a Seattle-based distributor of fresh produce, entered into an agreement with Seven Seas Fruit to deliver three loads of onions to Honduras. The onions required phytosanitary certificates from the U.S. Department of Agriculture to clear Honduran customs, but the parties did not explicitly discuss who would procure these certificates. Bloxom believed Seven Seas would handle it, based on past practices and vague assurances. However, the onions were shipped without the necessary certificates, leading to their rejection in Honduras and eventual spoilage upon return to the U.S.Seven Seas initiated administrative proceedings under the Perishable Agricultural Commodities Act (PACA) when Bloxom refused to pay for the onions. The Secretary of Agriculture ruled in favor of Seven Seas, finding no evidence that Seven Seas had agreed to procure the certificates. Bloxom appealed to the U.S. District Court for the Central District of Illinois, which granted summary judgment for Seven Seas. The court found that Bloxom had accepted the onions at the Port of Long Beach and did not revoke that acceptance, thus obligating Bloxom to pay for the onions.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Bloxom had accepted the onions by shipping them to Honduras and did not revoke this acceptance even after learning the certificates were missing. The court also found no abuse of discretion in the district court's denial of Bloxom's request for additional discovery time, as further discovery would not have changed the outcome. The court concluded that Bloxom was liable for the payment under PACA. View "F.C. Bloxom Company v. Tom Lange Company International, Inc." on Justia Law