This case is a bankruptcy appeal concerning a Chapter 7 debtor who entered an agreement to assume a car lease after the trustee rejected it under section 365(d)(1), but without court approval, and later surrendered the vehicle before discharge. The Bankruptcy Court held that the assumption eliminated discharge protection, allowing the lessor to obtain a post-discharge default judgment for remaining lease obligations including early termination penalties. The District Court reversed, holding that an unapproved assumption under section 365(p) does not remove the discharge that follows from the trustee's rejection. The core reasoning is that to revive personal liability, the lessor must obtain both the debtor's assumption and Bankruptcy Court approval under the reaffirmation rules of section 524(c) or equivalent provisions, consistent with the statutory text, the discharge form, and bankruptcy policies protecting the fresh start.
The case involved a credit card issuer appealing a bankruptcy court's ruling that a debtor's credit card charges were dischargeable in bankruptcy rather than excepted under 11 U.S.C. § 523(a)(2)(A) for alleged fraud. The bankruptcy court credited the debtor's testimony that he intended to repay the debt despite medical problems preventing work and an economic downturn, and it awarded the debtor costs and attorney fees under § 523(d) after finding the creditor's position not substantially justified; the court rejected arguments that the debtor needed a formal counterclaim for fees or that the fee award was untimely. The district court affirmed, holding that the bankruptcy court's credibility findings were supported and that the debtor's answer sufficiently requested fees while fee awards are collateral to the merits judgment.
The case involved Joseph Casias, an at-will Walmart employee in Michigan who was fired after testing positive for marijuana following a workplace injury, despite holding a registry card under the Michigan Medical Marihuana Act (MMMA) authorizing his medical use. Casias sued Walmart and his store manager in state court for wrongful discharge in violation of public policy and the MMMA, after which the defendants removed the case to federal court on diversity grounds, arguing the manager was fraudulently joined. The court analyzed whether the MMMA altered Michigan's at-will employment doctrine to create a protected class for qualifying medical marijuana users or imposed any duty on private employers to accommodate such use. It concluded that the MMMA's text, structure, and purpose did not regulate private employment relationships, did not create a private right of action against employers, and could not override federal law or the default at-will rule, leading to dismissal of the claims. The court also addressed jurisdictional issues by determining that the manager's joinder did not defeat diversity once the claims against him were found meritless.
This case involves a petition by the National Labor Relations Board under Section 10(j) of the National Labor Relations Act seeking temporary injunctive relief against Douglas Autotech Corporation. The dispute arose after a union representing employees at the company's Bronson, Michigan facility called an economic strike without having filed the required 30-day notice with the Federal Mediation and Conciliation Service, rendering the strike unlawful; the union promptly offered to return to work unconditionally upon discovering the error, but the company locked out the workers and later terminated the entire bargaining unit. The court granted the petition, ordering the company to reinstate the workers to a lockout position and to bargain in good faith with the union pending a final Board decision. The reasoning centered on preserving the status quo and the possibility of meaningful collective bargaining, as the company had exceeded the narrow window during which it could lawfully respond to the illegal strike by eliminating the bargaining unit entirely, and interim relief would prevent irreparable harm to the bargaining process without prejudging the merits.
This case involves Muslim prisoners at Lakeland Correctional Facility who filed a civil rights action under 42 U.S.C. § 1983, RLUIPA, and § 1986, alleging that prison officials violated their rights by failing to provide Halal food consistent with Shari’ah, prohibiting prayer oil and certain religious clothing, and interfering with Ramadan observances and Eid celebrations; they sought a preliminary injunction requiring a partial Halal kitchen and specific Halal meals during Ramadan 2010. The district court approved the magistrate judge’s report and denied the motion for preliminary injunction. The court found the requested relief moot because Ramadan 2010 had ended by the time of decision. Even if not moot, the court concluded plaintiffs were unlikely to succeed on the merits due to procedural hurdles like exhaustion of remedies, the availability of a vegetarian menu as an alternative, and the need for deference to prison officials in managing food services, with no showing of irreparable harm.