The case involved Ella D. McClellan seeking judicial review of the Social Security Commissioner's final decision denying her application for disability benefits under the Social Security Act. The district court adopted the magistrate judge's report and recommendation, overruling the Commissioner's objections, denying the Commissioner's summary judgment motion, granting the plaintiff's, and remanding the case for further evaluation. The core reasoning was that the ALJ had failed to consider whether the plaintiff met the requirements of Listing 12.05C for mental retardation despite her qualifying IQ score of 63 and a separate physical impairment imposing work-related limitations, and that the record raised unresolved questions about deficits in adaptive functioning before age 22 that required proper analysis rather than being dismissed as harmless error.
This case concerned whether the reduced mandatory minimum penalties for crack cocaine offenses under the Fair Sentencing Act of 2010 applied to defendant Jackie Campbell, who committed his offense in January 2010 but was sentenced after the Act's August 2010 enactment. The court held that the new penalties were inapplicable and that Campbell remained subject to the pre-FSA statutory minimums. The decision rested on the federal savings statute, 1 U.S.C. § 109, which preserves prior penalties absent an express contrary provision in the repealing statute, combined with Sixth Circuit precedent in United States v. Carradine holding that the FSA lacks such an express retroactivity clause. The court rejected arguments for implied retroactivity based on congressional intent or the Act's partial implementation through amended sentencing guidelines.
This case involves a patent dispute between Manuli Stretch USA, Inc. and Pinnacle Films, Inc. regarding U.S. Patent No. 6,265,055 for a multilayer stretch cling film, including claims of infringement, invalidity, and inequitable conduct, along with a counterclaim for attorney's fees against the named inventors and related parties. The court denied Pinnacle's motion for summary judgment on invalidity, finding genuine issues of material fact; denied Manuli's motion for summary judgment on inequitable conduct for the same reason; and granted summary judgment dismissing the counterclaim for attorney's fees because the counterclaim defendants lacked standing after transferring patent rights and had no ongoing legal relationship with Pinnacle. The court reserved ruling on Pinnacle's motion for summary judgment on non-infringement and ordered additional briefing. The decisions were based on the summary judgment standard under Fed. R. Civ. P. 56, requiring no genuine disputes of material fact for judgment as a matter of law, and the requirements under 35 U.S.C. § 285 for exceptional cases involving prevailing parties.
In this employment dispute, plaintiff Connie Payne sued her former employer Goodman Manufacturing after 17 years of service, alleging interference and retaliation under the FMLA related to her pregnancy and maternity leave request, violations of the Tennessee maternity leave statute and other THRA provisions for pregnancy discrimination and retaliation, and an Equal Pay Act claim based on pay differences. The court granted the employer's motion for summary judgment in part, dismissing the THRA pregnancy discrimination, maternity leave, and retaliation claims along with the EPA claim, while denying summary judgment on the FMLA interference and retaliation claims so they could proceed to trial. The dismissals rested on findings that the plaintiff failed to establish a prima facie case, including that her pay complaint did not qualify as protected activity under the THRA because it was not tied to sex discrimination, and that there was insufficient evidence for the other dismissed claims; the FMLA claims survived due to genuine issues of material fact regarding the timing and handling of her leave and termination.
In this ERISA case, plaintiff Penny Richards sued Johnson & Johnson and related entities under 29 U.S.C. § 1132(a)(1)(B) seeking judicial review of the termination of her long-term disability benefits under the company's plan, which took effect in January 2007. The court conducted a de novo review of the magistrate judge's report and recommendation and adopted it in full, applying the arbitrary and capricious standard of review because the plan granted the administrator discretionary authority. The court reversed the denial of benefits, finding that the administrator had not provided a reasoned explanation supported by substantial evidence in the administrative record, and remanded the matter for further proceedings; it also denied the defendant's counterclaim for reimbursement of an alleged overpayment and rejected motions to strike portions of the record. The ruling rested on the quantity and quality of medical evidence, procedural notice deficiencies under ERISA regulations, and the limited scope of review to the administrative record.
In this case, Chapter 13 debtors Michael and Sheila Messick appealed a bankruptcy court order denying their motion to hold Ascend Federal Credit Union and its employee in contempt for allegedly violating the automatic stay under 11 U.S.C. § 362. The debtors had listed accounts with Ascend and an unsecured debt to the credit union in their bankruptcy petition; after filing, Ascend sent letters notifying them of a policy to restrict services for members who caused losses and discussed options during phone calls initiated by the debtors. The bankruptcy court found no violation after a hearing, and the district court affirmed, concluding that the communications merely explained account policies without coercive collection efforts and that any discussion of voluntary repayment was not an attempt to collect the debt outside the plan. The court reviewed factual findings for clear error and legal conclusions de novo, determining that Ascend did not willfully violate the stay.