This case concerned debtor Craig Piazza's appeal from a bankruptcy court order dismissing his Chapter 7 petition. Creditor Nueterra Healthcare Physical Therapy, LLC had moved to dismiss the petition under 11 U.S.C. § 707(a), arguing that it was filed in bad faith to evade a state court judgment. The district court affirmed the dismissal, holding that a debtor's bad faith constitutes "cause" for dismissal under section 707(a) and that the bankruptcy court properly found bad faith based on the totality of the circumstances, including the timing of the filing to avoid document production, ongoing transfers to the debtor's spouse, and maintenance of luxury expenses despite the judgment. The court reviewed the bankruptcy court's factual findings for clear error and legal conclusions de novo, noting that the record supported the bad faith determination without any single factor being dispositive.
The case arose from the drowning of a boater whose vessel was pulled into a water control structure on Lake Istokpoga after the Army Corps of Engineers and contractors left gates open during high water levels, creating strong currents, and failed to repair a disconnected boat barrier. The decedent's estate sued the United States under the Federal Tort Claims Act, alleging negligence in the operation and maintenance of the structure. The court granted the government's motion to dismiss for lack of subject matter jurisdiction, concluding that the Flood Control Act immunized the United States because the released water constituted flood waters discharged for flood-control purposes.
This case involved a Peruvian seafarer suing Carnival Cruise Lines in Florida state court for workplace injuries on Panamanian-flagged vessels, bringing claims under the Jones Act for negligence, unseaworthiness, maintenance and cure, and failure to treat. The employment agreement contained an arbitration clause requiring ICC arbitration and a choice-of-law provision applying Panamanian law, prompting Carnival to remove the case and move to compel arbitration under the New York Convention while the plaintiff sought remand and challenged the clause's enforceability. The court determined it had authority to assess the arbitration provision's validity because the challenge targeted that clause rather than the entire contract, and it granted the motion to compel arbitration in part after accepting Carnival's stipulation to apply U.S. law if the foreign choice-of-law term would otherwise render the agreement unenforceable.
Joan Lyons sued Miami-Dade County alleging disability discrimination and retaliation under the ADA, FCRA, and Title VII after she was injured on the job in 2005, took medical leave, requested transfers, and was terminated in 2008. The dispute centered on whether Lyons failed to cooperate with a fitness-for-duty examination by not providing five years of medical records and signing releases, which the County viewed as insubordination leading to her dismissal; Lyons disputed the facts and claimed the actions were retaliatory. The district court granted the County's motion for summary judgment, dismissing all claims, because there were no genuine issues of material fact and the County's requests for records and termination decision were justified under its policies and not shown to violate the statutes. The court also dismissed one count without prejudice.
In Lewis v. Liberty Mutual Fire Insurance, an employee injured in a motor vehicle accident sued to determine whether her employer's auto insurance policy provided uninsured motorist coverage equal to the $2,000,000 bodily injury liability limits or only the statutory minimum. The court granted the defendant's motion for summary judgment and denied the plaintiff's, ruling that the employer had validly elected the lower statutory UM limits. The core reasoning was that the Florida UM rejection form, signed by the employer's corporate controller, expressly selected coverage lower than bodily injury limits by writing in "statutory," the policy included an amendatory endorsement specifying $20,000 UM coverage, and no material facts contradicted the proper execution of these documents despite later miscommunications by claims handlers.
This case was a class action lawsuit brought by current and former Broward County employees against the county, alleging that a $20 biweekly surcharge for declining to participate in a voluntary wellness program—which included a confidential health risk assessment questionnaire and biometric screening—violated the Americans with Disabilities Act's prohibitions on medical examinations and inquiries of employees. The court granted the county's motion for summary judgment and denied the plaintiff's motion for partial summary judgment on liability, dismissing all claims with prejudice. The core reasoning was that the wellness program qualified as a term of a bona fide benefit plan under the ADA's insurance safe harbor provision, as it involved risk classification and underwriting principles consistent with state law, was not a subterfuge to evade the ADA's purposes, and allowed the county to administer such terms without violating the medical inquiry rules.