The case involved a plaintiff suing healthcare providers for medical negligence and manufacturers/distributors for product liability after two failed hip replacement surgeries using a Pinnacle Cup System device. Diverse defendants removed the action to federal court under diversity jurisdiction, contending that non-diverse defendants were fraudulently misjoined because the medical and product claims did not arise from the same transaction or occurrence. The court granted remand to state court, ruling that joinder was proper under Rule 20 because the claims shared common questions of fact and law regarding the device's failure and the resulting injuries, so complete diversity was lacking and federal jurisdiction did not exist.
In Walters v. McMahen, legal hourly employees of Perdue Farms filed a class action lawsuit against twenty-nine current and former Perdue employees, alleging a single count of civil RICO conspiracy under 18 U.S.C. § 1961 et seq. The plaintiffs claimed that the defendants conspired to hire large numbers of illegal immigrants by falsely attesting to their work authorization, which allegedly depressed wages for authorized workers. The U.S. District Court for the District of Maryland granted the defendants' motion to dismiss with prejudice. The court held that the claim failed to state a plausible cause of action under Twombly and Iqbal because the alleged scheme lacked factual support and logical coherence. Additionally, the intracorporate conspiracy doctrine barred the claim, as employees acting within the scope of employment cannot conspire with their corporation or each other, and no exception applied.
This case is a class action lawsuit brought by purchasers of titanium dioxide against several manufacturers, including Cristal, alleging a conspiracy to fix prices in violation of Section 1 of the Sherman Act. Defendant Cristal, a Saudi Arabian corporation, moved to dismiss the claims against it for insufficient service of process and lack of personal jurisdiction. The court granted the motion, finding that Cristal and its subsidiary Millennium are separate corporate entities and that Millennium's contacts with the United States could not be imputed to Cristal under an agency or alter ego theory. Plaintiffs failed to allege sufficient facts showing Cristal's direct minimum contacts with Maryland or the United States, and jurisdictional discovery was deemed unwarranted.
This case is a class action antitrust suit brought by direct purchasers of titanium dioxide against major producers including DuPont, Huntsman, Kronos, and Millennium, alleging a conspiracy to fix, raise, and stabilize prices in violation of Section 1 of the Sherman Act from 2002 onward. The defendants moved to dismiss the complaint, arguing that it failed to meet the plausibility pleading requirements established in Twombly and Iqbal. The court denied the motion to dismiss, holding that the complaint adequately alleged a conspiracy through parallel price increases that followed industry meetings and conferences, together with additional plus factors such as the use of consultants and third parties to signal pricing intentions and private discussions among the defendants to monitor compliance.
This case involved former employees of two Baltimore taverns suing the owner Jason Zink and his companies under the Fair Labor Standards Act and related Maryland wage laws, alleging that Zink's participation in a shared tip pool while taking a tip credit unlawfully reduced their wages. The court addressed multiple motions, including for summary judgment and decertification of the collective action. It held that an owner-employer may not participate in employee tip pools under the FLSA, granting partial summary judgment to plaintiffs on that issue while denying other claims and decertifying the collective action except for three similarly situated bartender plaintiffs, whose claims would proceed separately from the sous chef's. The decision followed the weight of authority from other courts on this question of first impression in the district and circuit, with further proceedings ordered on damages.
The case involved the EEOC's application to enforce an administrative subpoena against Randstad, a staffing agency, in connection with an individual charge alleging national origin discrimination (later amended to include disability discrimination) after the agency declined to place a worker who could not read on light industrial assignments. The court denied the application to enforce the subpoena. The court reasoned that the EEOC lacked jurisdiction over untimely aspects of the amended charge, that the broad requests for information on all job placements and policies since 2006 were not relevant to the specific charge, and that compliance would impose an undue burden by requiring Randstad to create new records for over 100,000 placements at significant cost. The decision turned on the scope of the EEOC's investigative authority under Title VII and the ADA relative to the charge filed.
