This case involved plaintiff Baronica Warren's claims against the County Commission of Lawrence County, Alabama, for unpaid overtime under the Fair Labor Standards Act and for retaliation under Title VII of the Civil Rights Act of 1964. A jury found in Warren's favor, awarding $901.28 on the FLSA claim and $400,600 on the retaliation claims for emotional damages and lost pay. On post-trial motions, the court denied a new trial but granted remittitur to reduce the verdict pursuant to the statutory cap in 42 U.S.C. § 1981a(b)(3), and granted the plaintiff's request for front pay as equitable relief after considering factors such as difficulty obtaining comparable employment and the need to make the plaintiff whole. The decision applied Eleventh Circuit standards requiring a verdict to shock the conscience for a new trial and emphasizing case-specific discretion in front pay awards.
This ERISA case involves plaintiff Kevin McCay's challenge to his former employer Drummond's denial of his application for a disability retirement pension under the company's pension plan. After the case was remanded to the plan administrator for further consideration of additional evidence including a favorable Social Security award, the administrator upheld the denial, and McCay sought to reinstate the claim in federal court. The court reviewed the denial under the arbitrary and capricious standard due to the plan's grant of discretion to the administrator and granted Drummond's motion for summary judgment while denying McCay's motion. The core reasoning was that Drummond's decision was reasonable based on the medical evidence available at the time of McCay's termination in 2004, which did not establish total and permanent disability preventing substantially gainful occupation under the plan terms, and the administrator properly distinguished the later SSA award due to differing standards and post-termination evidence like knee surgery.
This case is a Fourth Amendment excessive force claim under 42 U.S.C. § 1983 brought by plaintiff Joi Brown against defendant Officer Gerald Norris and scheduled for jury trial. The court ruled on the defendant's revised motion in limine to exclude multiple categories of evidence under Federal Rules of Evidence 401, 402, and 403. The motion was granted in part as unopposed regarding nine areas, including prior internal affairs complaints, lawsuits, and discipline against the involved officers. It was denied in part as to contested items such as cell phone video clips and related testimony, which the court found relevant and not substantially outweighed by risks of prejudice or confusion under the applicable standards. The court also directed further handling of remaining objections and bifurcated jury deliberation on liability and qualified immunity.
In Harvey v. Standard Insurance, plaintiff Sheryl Harvey, a participant in an employer-sponsored disability benefits plan administered by Standard Insurance Company, sued under ERISA after denial of her long-term disability claim. The case involved Harvey's motion to compel discovery beyond the administrative record that Standard had produced, with Standard objecting on grounds that plan provisions limited review to that record. The court granted the motion to compel, reasoning that Supreme Court precedent in Metropolitan Life Ins. Co. v. Glenn establishes a conflict of interest when an insurer both decides and pays claims, making discovery into the circumstances of that conflict relevant to assessing whether the denial was arbitrary and capricious.
This case involves the United States bringing an enforcement action against Alabama Power Company under the Clean Air Act's New Source Review provisions, alleging that the company made physical or operational changes at its power plants that triggered requirements to install modern pollution controls. The court considered Alabama Power's motion in limine to exclude expert testimony from Robert H. Koppe and Ranajit Sahu under the Daubert reliability standards. The court granted the motion as to these experts, reasoning that their methodology relied on a formula applicable only to baseload units as defined in United States v. Cinergy Corp., but the units at issue (including Barry Unit 2) did not meet that definition and the experts had not conducted sufficient investigation to reliably apply it.
This case involves an Americans with Disabilities Act claim brought by Sanford Lavoy Jones against his former employer, Pilgrim's Pride, Inc. After the company emerged from bankruptcy, it moved for summary judgment, arguing that Jones's claim had been discharged because he failed to file a proof of claim during the bankruptcy proceedings. The court took judicial notice of the relevant bankruptcy records and granted the motion, concluding that the claim was discharged and that no exception applied since the company was self-insured and the insurance threshold had not been met. The court dismissed the case with prejudice.