This case involved a bankruptcy trustee's attempt to use strong-arm avoidance powers under 11 U.S.C. § 544(a)(1) to recover a condominium that had been sold in a foreclosure sale before the debtors filed for Chapter 7 bankruptcy. The trustee argued that a defective acknowledgment on the original deed of trust rendered it void under Virginia law, allowing him to attach a lien as a hypothetical lien creditor. The district court affirmed the bankruptcy court's ruling that the trustee could not avoid the conveyance, because under Virginia law the acknowledgment defect did not invalidate the deed between the parties, so the foreclosure deed validly transferred title before the bankruptcy filing and left the debtors with no property interest. The court also dismissed the mortgage holder's cross-appeal for lack of standing, as the appellee was not aggrieved by the favorable judgment below.
The case involved a contract dispute between American Exhibitions, Inc. (AEI) and Design & Production, Inc. (D&P), along with Seruto and Company, over the design, fabrication, and installation of a traveling museum exhibit on mummies that AEI hired D&P to create. AEI approved a fixed price and accepted the completed exhibit but did not pay outstanding invoices, leading D&P to sue for breach of contract and declaratory relief while AEI filed counterclaims alleging breach of contract, fraudulent inducement, and negligent misrepresentation based on claims about costs, timing, and services. The court granted D&P's motion for summary judgment on all claims and denied AEI's partial summary judgment motion, awarding D&P $488,677.55 plus interest, because AEI accepted the exhibit without paying, provided no evidence that D&P breached the contract, and the misrepresentation claims either lacked support for fraudulent intent, were waived, or involved duties arising only from the contract rather than tort. The court also dismissed D&P's related motions in limine and to strike as moot.
This case concerns patents for an invisible dip tube component used in perfume fragrance packaging that transports liquid from bottle to sprayer while becoming nearly invisible when immersed. The court resolved eleven summary judgment motions on issues including anticipation, obviousness, inequitable conduct, invalidity, direct/contributory/induced/willful infringement, doctrine of equivalents, and indefiniteness. It granted plaintiffs' motions on anticipation, obviousness, and inequitable conduct defenses due to lack of a single prior art reference, failure to meet all obviousness factors by clear and convincing evidence, and absence of intent to deceive the PTO. It denied or partially granted defendants' motions on infringement and invalidity based on stipulated claim constructions, factual disputes over U.S. sales or offers, and the narrowing effect of the term "quenched" on equivalents.
This case concerns MeadWestvaco's patents on an invisible dip tube for perfume packaging that becomes nearly invisible when immersed in liquid, and alleged infringement by Rexam and Valois through their own similar tubes. The court performed claim construction on seven disputed terms in the patents' claims, adopting definitions such as 'quenched' to mean 'rapidly cooled,' 'transparency' to mean 'allowing visible light through so that objects can be clearly seen through it,' 'about' to mean 'approximately,' and similar constructions for 'dispenser assembly,' 'modified ethylene tetrafluoroethylene,' 'XRD crystallinity,' and 'crystalline content.' The core reasoning followed Federal Circuit precedents like Phillips v. AWH Corp. and Markman v. Westview Instruments, emphasizing the ordinary meaning of claim language to a person skilled in the art while rejecting overly narrow or rigid interpretations not supported by the claims themselves.
This case involves plaintiff Helton's claims against AT&T and its pension plan under ERISA, alleging that the defendants failed to notify her of a change in the plan's early retirement eligibility rules, causing her to lose eight years of monthly benefits. The court addressed four counts: retroactive benefits, noncompliance with ERISA disclosure requirements, breach of fiduciary duty, and failure to provide requested information. It denied summary judgment on the first three counts, finding that the plan administrator abused its discretion by lacking substantial evidence for its denial, that a material factual dispute existed regarding timely notification of plan changes, and that a cognizable fiduciary duty claim was stated without an adequate alternative remedy. The court granted summary judgment on the fourth count because the plaintiff received all information considered or relied upon in the benefits decision.
In Matarese v. ARCHSTONE PENTAGON CITY, the plaintiffs alleged that the defendants violated the Fair Housing Act and Virginia Fair Housing Law by discriminating against them on the basis of Ms. Matarese's handicap, through claims including refusal to renew their lease or allow a transfer, discriminatory rental terms and conditions, discriminatory statements, and retaliation for protected activity. The court held that Ms. Matarese qualified as an individual with a handicap under the FHA because the defendants regarded her as having a condition that substantially limited her breathing. The court found the defendants liable on the refusal-to-rent claims, the terms-and-conditions claims, the discriminatory-statements claims, and the retaliation claim, based on direct evidence of discriminatory intent, statements evaluated under the ordinary-listener standard, and actions taken after the plaintiffs engaged in protected activity.