In Bantom v. DTE Energy Co., the plaintiff sued his former employer in Michigan state court for retaliatory discharge against public policy, negligent discharge, defamation, and intentional infliction of emotional distress after being fired for alleged theft and unauthorized reconnection of electrical service. The defendant removed the case to federal court, arguing that the claims were completely preempted by the Labor Management Relations Act because they arose under a collective bargaining agreement and involved union activity. The court ordered the defendant to show cause why the case should not be remanded and, after review, concluded it lacked subject matter jurisdiction under the well-pleaded complaint rule. The court reasoned that the complaint made no reference to the CBA, union activity, or any federal claim, and the plaintiff as master of his complaint could avoid federal jurisdiction by pleading only state-law causes of action. Accordingly, the case was remanded to Wayne County Circuit Court.
This case concerns competing claims to a 'Held Payment' fund of about $280,000 that the plaintiffs (administrators of a laborers' multiemployer benefit plan) and defendants (construction companies) created under a temporary agreement to secure a 2008 ERISA judgment for unpaid fringe benefits and fees while the defendants appealed. An intervenor (PUDF) held its own separate judgment against the defendants and sought the fund via writs of garnishment. The court held that the plaintiffs hold the superior interest in the fund as security for their affirmed judgment, PUDF holds the next priority as a lien creditor, and defense counsel is entitled to a reasonable attorney's fee from any refunded portion generated by his successful appeal work under Michigan equitable principles on charging liens. The ruling applies the fund first to the plaintiffs, then allows counsel's fee claim from any remainder before satisfying PUDF and any residual lien.
The case involved First American Title Insurance Company seeking to have debts owed by debtor Bryan Pazdzierz declared nondischargeable in bankruptcy under 11 U.S.C. § 523(a)(2), based on alleged fraudulent misrepresentations in loan documents for carwash purchases as part of a larger fraud scheme. The bankruptcy court granted summary judgment to Pazdzierz, finding that the assigned fraud claims were not assignable under Michigan law, First American could not show its own reliance, and subrogation did not apply. The district court reversed, holding that enforcing the promissory notes did not violate the non-assignability rule for fraud claims, First American could rely on the original lender's reliance for the nondischargeability elements, and subrogation was not available but not needed.
In Murphy v. Lockhart, a Michigan prisoner sued Department of Corrections officials under 42 U.S.C. § 1983 and state law, claiming retaliation for comments to a reporter about a prior escape attempt, interference with religious mail, retaliation for an earlier lawsuit, and due process violations from extended administrative segregation without review. The district court performed de novo review of objections to two magistrate judges' reports and recommendations on the defendants' summary judgment motions. It adopted in part and rejected in part the first magistrate's report, adopted the second, overruled the defendants' objections and the plaintiff's objections in part, granted the first motion in part and denied it in part, and denied defendant Werner's second motion. The core reasoning addressed waiver of arguments not raised before the magistrate, the defendants' failure to prove exhaustion of remedies, and correction of the docket for previously dismissed defendants.
In this copyright sampling dispute, after the federal court dismissed the plaintiffs' claims on the merits and sanctioned them for evidence manipulation, the plaintiffs filed a new state court lawsuit against the defendants' attorneys alleging various state-law claims including abuse of process, negligence, fraud, and intentional infliction of emotional distress. The defendants moved in federal court to enjoin that state action, arguing it sought to relitigate issues already decided against the plaintiffs. The court denied the injunction, holding that the Anti-Injunction Act limits federal authority to enjoin state proceedings to narrow circumstances and that the specific state-law claims had not been adjudicated in the federal case, even if related factual findings might support preclusion defenses. The court concluded that traditional issue and claim preclusion doctrines should be applied by the state court judge.
The case involved a dispute over life insurance proceeds from an ERISA-governed employee benefit plan, where the decedent's estate sought to recover funds paid by the insurer to the ex-wife (the named beneficiary) based on a divorce judgment that included a waiver of such benefits under Michigan law. The defendant removed the case from state court to federal court, asserting complete preemption by ERISA. The court granted the motion to remand, determining that the complaint asserted a state-law equitable claim to enforce the divorce judgment rather than a claim for benefits under the plan itself, so it was not completely preempted and the federal court lacked subject matter jurisdiction. The court denied attorney fees, finding the removal attempt was objectively reasonable though ultimately unsuccessful.
