In Angles v. Flexible Flyer Liquidating Trust, former employees of Flexible Flyer Athletic Company (FFAC) appealed a bankruptcy court ruling that the company did not violate the Worker Adjustment and Retraining Notification (WARN) Act by failing to provide 60 days' notice before a plant closing and mass layoffs. The district court affirmed the bankruptcy court's denial of the employees' motion for summary judgment and its findings after a bench trial. The court held that the unforeseen business circumstances exception and the faltering company exception to the WARN Act applied, as the sudden termination of financing from creditors and the parent company was not reasonably foreseeable, and the company provided notice as soon as practicable upon filing for bankruptcy.
The case involves LaFagus O. Carpenter, a former patrolman at Mississippi Valley State University, who alleged that he faced retaliation, including shift changes and demotion, after indicating his willingness to testify in a co-worker's Title VII lawsuit, leading to his resignation in January 2010. He sued MVSU and two individual supervisors under Title VII for discrimination, retaliation, hostile work environment, and constructive discharge; under 42 U.S.C. § 1983 for First Amendment retaliation and Fourteenth Amendment equal protection violations; and for punitive damages. The court addressed the defendants' motions to dismiss or for summary judgment, focusing on immunity defenses. MVSU was held immune from suit under the Eleventh Amendment as an arm of the State of Mississippi, while the individual defendants' entitlement to qualified immunity was analyzed based on whether the claims implicated clearly established constitutional rights and objective reasonableness of their actions.
In Ivy v. Oxford Municipal Separate School District, an African-American teacher sued the school district alleging racial discrimination in not being hired for administrative positions and in the non-renewal of her teaching contract, claiming violations of Title VII, Sections 1981 and 1983, and the Equal Protection Clause. The court granted the defendant's motion for summary judgment on all claims. The core reasoning was that the plaintiff failed to establish a prima facie case of discrimination under the McDonnell Douglas framework or to show that the district's legitimate nondiscriminatory reasons were pretextual, and her Equal Protection claim similarly lacked evidence of intentional racial discrimination.
The case concerned whether State Farm had a duty to defend or indemnify Billie Ann Mitchell under her homeowners and personal liability umbrella policies in two underlying lawsuits: one alleging breach of a business guaranty, misapplication of trust funds, and related fraud claims arising from a car dealership, and the other seeking corporate dissolution and an accounting. The court granted State Farm’s motion for summary judgment, concluding that the policies provided no coverage because the claims involved excluded business pursuits, intentional or criminal acts, and did not allege an “occurrence” causing covered bodily injury or property damage. The court further held that the insurer had an arguable, good-faith basis for denying the claims after investigation, so no breach of contract or extra-contractual damages could be awarded.
The case involved an African-American middle school teacher terminated by the Lowndes County School District after an incident in which he used physical force to remove a student from his classroom, which administrators determined to be excessive. The teacher sued under Title VII and § 1981 alleging racial discrimination, claimed violations of procedural due process and equal protection under the Fourteenth Amendment, and asserted a state-law breach of contract claim. The court granted the school district’s motion for summary judgment on all claims. It reasoned that the plaintiff failed to produce evidence of pretext or disparate treatment of similarly situated white employees to support the discrimination claims, that he received notice, a hearing, and an opportunity to respond sufficient to satisfy due process, and that Mississippi law permitted termination for use of excessive force against a student, precluding the contract claim.
The case concerned the EPA's veto, under Section 404(c) of the Clean Water Act, of the Yazoo Backwater Project, a federal flood-control effort involving levees and a pump station in Mississippi. The Board of Mississippi Levee Commissioners sued, arguing that the project was exempt from the veto under Section 404(r) because it was a congressionally authorized federal project for which an environmental impact statement had been prepared. The court granted summary judgment to the EPA and intervening environmental groups. It held that the exemption did not apply because the required environmental impact statement had not been submitted to Congress before project authorization or funding, as Section 404(r) demands. The decision therefore upheld the EPA's authority to block the project on environmental grounds.