Comments on Recent Cases: August 2025
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Part of my work involves reading court decisions to keep abreast of how judges decide the types of cases I handle. Below, I share some thoughts on recent decisions.
Court Holds Plaintiff Failed to Allege Facts Connecting Defendant to Local Jurisdiction
One of the first things a plaintiff needs to do at the start of litigation is select which court to file her complaint. Often plaintiffs choose a court that is convenient for them, but unless the defendant resides in the same place as the court, the court may dismiss for lack of personal jurisdiction. Exceptions exist for times where a defendant who resides elsewhere causes harm in the same place as the court, but merely alleging such an incident may not be enough.
For example, in a recent case in the federal district court in Manhattan, a plaintiff claimed that a famous musician’s entourage beat him up in New York City. The musician, however, lives in Pennsylvania. The court dismissed the case for lack of personal jurisdiction because the plaintiff failed to allege enough details to connect the musician to the New York City attack.
Cases like this illustrate the burden plaintiffs need to meet to connect an incident in one jurisdiction to a claim that case belongs in that jurisdiction’s court.
Court Vacates Arbitration Decision on Appeal
Courts typically defer to the decisions of arbitrators, even when they believe that the arbitrators made a mistake. This is because federal law implements a policy where people can rely on arbitration being quick and final and not just the first step towards a lengthy litigation process. Still, people still attempt to appeal in court and, sometimes, they win.
For example, in a recent case before the federal appeals court in St. Louis, the losing party in an arbitration sought to vacate the decision against him. The lower court had criticized the decision, but held that it was powerless to disturb it. But the appeals court reversed, holding that the arbitrators had exceeded their authority by reading the contract incorrectly. Many commentators have noted that it is a subjective and often inconsistent doctrine that lets some courts find that arbitrators’ decisions deserve deference while others must be reversed.
Cases like this illustrate one of the instances in which a court may disturb the result of arbitration.
Court Dismisses Discrimination Claim on Summary Judgment
It is difficult to dismiss an employment discrimination claim before trial without settlement. This is because the minimum sufficient evidence a plaintiff must submit to survive dismissal is relatively low. Still, however, courts sometimes dismiss discrimination claims on summary judgment.
For example, in a recent case before the state appeals court in Brooklyn, a court affirmed the dismissal of a gender discrimination claim brought by university employees who lost their stipends. The court held that the plaintiffs met their burden of establishing a claim, but that the university met its burden by providing a non-discriminatory explanation for the termination of the stipends. The court then held that the plaintiffs failed to produce any evidence that the non-discriminatory explanation was false, and so it upheld dismissal of the case before trial.
Cases like this illustrate how courts may rule in favor of discrimination defendants before trial.
Court Affirms Dismissal of Claims As Duplicative of Malpractice Claim
Plaintiffs in litigation often articulate different legal theories to explain why the defendant’s conduct entitles them to relief. For example, a plaintiff who buys a defective product that injures her may allege that the defendant was negligent in designing the product, and also negligent in assembling it, and also lied about it being safe. But courts may dismiss claims as duplicative if they do not allege different harms.
One situation where courts do this involves malpractice claims. In a recent case before the state appeals court in Brooklyn, a former client sued her attorney, alleging malpractice, but also fraud, breach of contract, breach of fiduciary duty, and intentional and negligent infliction of emotional distress. The appeals court affirmed the dismissal of these claims as duplicative of the malpractice clam because “they arose from the same facts and did not allege distinct damages.” This suggests the result may have been different if the plaintiff alleged the fraud or emotional distress caused her a different amount of harm as the malpractice.
Cases like this illustrate situations where courts dismiss alternate legal theories as duplicative.