Alleged Shoving Match Between Counsel at a Deposition Leads to Sanctions and an Appeal to the Seventh Circuit

In Vega v. Chicago Bd. of Ed., No. 23-1183 (7th Cir. July 29, 2024), the Seventh Circuit affirms in part and reverses in part sanctions awarded by the district court under 28 U.S.C. § 1927 and the court’s inherent authority after an acrimonious deposition that allegedly led to a physical confrontation. “On July 13, 2017,Continue reading “Alleged Shoving Match Between Counsel at a Deposition Leads to Sanctions and an Appeal to the Seventh Circuit”

Eleventh Circuit Judge, in Concurring Opinion, Challenges Expansion of Younger Abstention as Chilling First Amendment Rights

In a case involving Stacey Abrams’ New Georgia Project, the Eleventh Circuit holds in New Georgia Project, Inc., et al v. Attorney General, State of Georgia, No. 22-14302 (11th Cir. July 8, 2024), that federal litigation of a challenge to Georgia’s campaign laws must await the conclusion of a state administrative enforcement action against theContinue reading “Eleventh Circuit Judge, in Concurring Opinion, Challenges Expansion of Younger Abstention as Chilling First Amendment Rights”

Split Ninth Circuit Panel Applies Prior Exclusive Jurisdiction Rule to Affirm Dismissal of Federal Action Against State Insurance Commission

In Applied Underwriters v. Laras,  No. 21-15679 (9th Cir. June 10, 2022), a split panel affirms the dismissal of a federal civil-rights action in favor of a pending state conservatorship action, but disagrees on the grounds. The panel majority would affirm under the prior exclusive jurisdiction rule, while the concurring judge would rely (as didContinue reading “Split Ninth Circuit Panel Applies Prior Exclusive Jurisdiction Rule to Affirm Dismissal of Federal Action Against State Insurance Commission”

Second Circuit Holds That Younger Abstention Does Not Apply to State Probate Court Order Concerning the Validity of a Lien

In Cavanaugh v. Geballe, No.21-571 (2d Cir. Mar. 17, 2022), the Second Circuit holds that the district court erred by abstaining under the doctrine established in Younger v. Harris, 401 U.S. 37 (1971), from hearing a due process challenge to a statutory lien on plaintiff’s inheritance and grandmother’s estate. The panel holds that a stateContinue reading “Second Circuit Holds That Younger Abstention Does Not Apply to State Probate Court Order Concerning the Validity of a Lien”