Harry Sandlin Mattice jr

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.

federal powerhealthcare

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.

criminal law

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.

business & regulatoryprocedure

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.

labor & employmentcivil rights

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.

labor & employmenthealthcareprocedure

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.

procedurefederal power

This case involves a plaintiff's claims against multiple defendants, including Vertrue, Inc., My Choice Medical, Inc. (doing business as DoctorsSayYes.net), and various medical providers such as Dr. Jeffrey Marvel and associated clinics, arising from medical services and related contracts. The court addressed motions to dismiss under Federal Rules of Civil Procedure 12(b)(2) for lack of personal jurisdiction, 12(b)(6) for failure to state a claim, and improper venue based on a forum selection clause. It granted the motions filed by Vertrue and My Choice Medical, dismissing them from the case, while denying the motion filed by the medical provider defendants. The core reasoning centered on the enforceability of a forum selection clause in the contract with My Choice, the plaintiff's failure to meet pleading standards under Twombly and Iqbal for some claims, and the absence of grounds for dismissal as to the local medical defendants who had not invoked the same jurisdictional or venue defenses.

procedurehealthcare

In this case, Pennsylvania National Mutual Casualty Insurance Company filed a declaratory judgment action in federal court seeking a ruling on its obligations under commercial general liability and umbrella policies issued to HVAC, Inc., specifically whether the policies required it to defend and indemnify HVAC in a pending state-court personal injury lawsuit alleging negligent mold and asbestos removal at a school that caused bodily injury to minor plaintiffs. The court exercised its discretionary jurisdiction under the Declaratory Judgment Act after weighing the relevant factors and granted Penn National's motion for summary judgment. The reasoning centered on the policies' explicit fungi or bacteria exclusions (covering mold) and asbestos exclusions, which the court found unambiguously barred coverage for the bodily injury and personal injury claims alleged in the state complaint, including any duty to defend.

business & regulatoryproceduretorts & liability

In Doe v. University of the South, pseudonymous plaintiffs James Doe and Mary Doe brought claims against the university under Title IX of the Education Amendments of 1972, the Clery Act, and various contractual and quasi-contractual theories arising from the university's handling of campus matters. The district court granted the university's motion to dismiss the Title IX and Clery Act claims (Counts III and IV) for lack of subject matter jurisdiction and failure to state a claim, and likewise dismissed the contract and unjust enrichment claims (Counts I, II, and XII) after determining that no enforceable contractual or quasi-contractual relationship had been adequately alleged. The court applied the standards under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), requiring plausible factual allegations rather than conclusory assertions, and overruled the university's objection to the magistrate judge's order allowing the plaintiffs to proceed under pseudonyms. All dismissed claims were terminated with prejudice.

civil rightsprocedure

This case involved the administrators of an ERISA group health plan suing plan beneficiaries to recover medical benefits paid after the beneficiary was injured in a car accident and received a $100,000 third-party insurance settlement. The court granted summary judgment to the plaintiffs and denied the defendants' motion, ordering reimbursement of $73,811.46 to the plan. The decision rested on the plan's explicit terms, which established a right to full reimbursement from the first dollars recovered and disavowed the default federal make-whole rule that would otherwise have barred recovery when the insured was not fully compensated. The court found the plan language unambiguous in prioritizing the plan's subrogation and reimbursement rights regardless of whether the beneficiary was made whole.

healthcarebusiness & regulatoryprocedure

This case involved Chapter 13 debtors who objected to an IRS proof of claim for over $60,000 in unpaid 2005 income taxes arising from a reported discharge of indebtedness after a foreclosure on their Georgia property. The IRS had treated a Form 1099 from the mortgage lender showing $93,739 in forgiven debt as taxable income under federal law, even though the lender had not obtained judicial confirmation of the foreclosure sale under Georgia Code § 44-14-161. The bankruptcy court overruled the objection and dismissed the debtors' motion to alter or amend, finding that the lack of confirmation barred a deficiency judgment but did not extinguish the debt for tax purposes and that the debtors had not rebutted the prima facie validity of the IRS claim with reliable evidence. On appeal, the district court reviewed the bankruptcy court's factual findings for clear error and legal conclusions de novo, affirmed the orders, and held that the debtors failed to meet their evidentiary burden to shift the presumption of validity from the IRS proof of claim.

taxesproperty

The Equal Employment Opportunity Commission sued Texas Hydraulics, Inc. on behalf of employee Keith Vogeler, claiming that the company violated Title VII by failing to accommodate Vogeler's religious belief against working on Saturdays and terminating him for accumulating attendance points due to Saturday absences. The court denied the defendant's motion for summary judgment. It reasoned that while the plaintiff established a prima facie case of religious discrimination, the defendant did not sufficiently demonstrate that it had considered reasonable accommodations or that any such accommodations would impose an undue hardship, as required under Title VII.

labor & employmentcivil rightsreligious liberty

The case involved defendant Pete Resa's motion to suppress evidence seized during a 2006 traffic stop on I-75 in Tennessee, where he argued the stop lacked probable cause and that officers exceeded any consent by disassembling parts of the rental vehicle's interior. The court denied the motion after an evidentiary hearing. The stop was justified because the gold SUV matched an AMBER Alert description and was operating without headlights in the rain, violating state law. The officer's extended questioning was supported by inconsistencies in the occupants' stories about the rental car, mismatched names on documents, and travel through known drug corridors, leading to valid consent for the search.

criminal lawprocedure

In McKee Foods Kingman v. Kellogg Co., Tennessee and Arizona-based plaintiffs who sell LITTLE DEBBIE MARSHMALLOW TREATS sued for declaratory judgment after Kellogg sent a cease-and-desist letter accusing them of infringing Kellogg’s RICE KRISPIES TREATS trademark and trade dress and of false advertising. Kellogg moved to dismiss for lack of subject-matter jurisdiction, discretionary abstention under the Declaratory Judgment Act, personal jurisdiction, and alternatively to transfer venue to Michigan under 28 U.S.C. § 1404(a). The court held that the letter created a justiciable controversy sufficient for federal jurisdiction and that the factors for discretionary jurisdiction did not warrant abstention. It denied transfer because moving the case would merely shift inconvenience from one party to the other rather than serve overall convenience and justice. The court denied the motion on those grounds but reserved ruling on personal jurisdiction pending limited discovery.

business & regulatoryprocedure

In Boles v. Polyloom Corp. of America, a former employee sued his employer after termination, alleging violations of the ADA for disability discrimination related to his Crohn's disease and need for bathroom breaks, the FMLA for interference with medical leave, and ERISA for potential retaliation tied to rising health insurance costs from his treatments. The court granted the defendant's motion for summary judgment on the FMLA claims, finding insufficient evidence of interference or retaliation, but denied summary judgment on the ADA and ERISA claims because genuine issues of material fact existed regarding whether the employer's disciplinary actions and termination were pretextual. The court also denied summary judgment on issues related to the plaintiff's bankruptcy and the after-acquired evidence doctrine, determining that the employer had not shown it would have terminated the employee solely based on a prior concealed conviction. The decision rested on viewing facts in the light most favorable to the plaintiff and applying the standard that summary judgment is inappropriate where a reasonable jury could find for the nonmoving party.

labor & employmentcivil rightshealthcare

Jason Person, an African-American man formerly employed by Progressive Logistics Services LLC (PLS) as a freight lumper and supervisor, sued PLS for racial discrimination under 42 U.S.C. § 1981 and the Tennessee Human Rights Act (THRA), retaliation under the THRA, and related state-law claims, while also suing Kroger Limited Partnership I (KLPI) and related entities for racial discrimination under § 1981 and interference with contractual relations after being denied access to work as an independent contractor. The district court denied KLPI's motion to dismiss or for summary judgment. The court granted PLS's motion for judgment on the pleadings in part by dismissing the THRA retaliation claim with prejudice, finding that the complaint failed to allege protected activity before termination or a causal link to the adverse action, but denied the motion as to the remaining claims against PLS.

civil rightslabor & employmentprocedure