This case involved motions by defendants in adversary proceedings stemming from the liquidation of British Virgin Islands investment funds that had placed assets with Bernard Madoff's firm. The funds' foreign representatives filed state-law claims in New York state courts, then removed them to federal bankruptcy court after obtaining Chapter 15 recognition of the BVI proceedings, prompting defendants to seek remand or abstention on grounds of lacking subject-matter jurisdiction. The district court granted leave to appeal and reversed the bankruptcy court's denial of the motions. It held that the claims, which rest on state or BVI law rather than arising under title 11, did not qualify for core bankruptcy jurisdiction under 28 U.S.C. § 1334 and that mandatory abstention was required because the actions could be timely resolved in state court. The court further rejected related-to jurisdiction as insufficient to override abstention rules in these circumstances.
The case involved the Equal Employment Opportunity Commission suing Bloomberg L.P. on behalf of a class of female employees, alleging a pattern or practice of sex and pregnancy discrimination under Title VII through reduced pay, demotions, fewer responsibilities, and exclusion from meetings for pregnant workers or those returning from maternity leave. The court granted Bloomberg's motion for summary judgment on the pattern-or-practice claim. The court reasoned that accusations alone were insufficient and the evidence did not show discrimination as Bloomberg's standard operating procedure, noting instead that the company increased compensation for women returning from maternity leave more than for employees taking comparable leaves and did not disproportionately reduce their responsibilities, with only isolated anecdotal incidents rather than statistical proof of systemic bias.
This case involves a class action by purchasers of digital music alleging that major record labels violated federal and state antitrust laws by conspiring to fix wholesale prices, licensing terms, and usage restrictions for Internet Music through joint ventures like MusicNet and pressplay, along with most-favored-nation clauses and digital rights management. The court addressed defendants' renewed motion to dismiss the Third Consolidated Amended Complaint following remand from the Second Circuit. It analyzed the Sherman Act claims under Twombly's plausibility standard, finding the allegations of collusion sufficient to proceed, while evaluating state-law claims under varying rules for indirect purchasers, dismissing some (such as certain Illinois claims) and allowing others from states with Illinois Brick repealers to continue based on the pleaded facts and applicable statutes.
This case involves claims and counterclaims between USI Insurance Services and its former employee Jeffrey Miner, who left USI in 2010 to join a competitor, centering on alleged breaches of an employment agreement and an asset purchase agreement that included restrictive covenants, notice requirements, and non-solicitation provisions. The court addressed multiple cross-motions for partial summary judgment, granting USI's motion that Miner failed to provide required written notice under Section 4.2 before alleging compensation breaches, while also ruling on issues such as the enforceability of covenants not to solicit clients and whether Miner had improperly contacted former USI clients. The court applied New York law on contract interpretation, substantial compliance with notice clauses, and the protection of goodwill sold in the APA, finding that strict adherence to notice procedures was enforceable and that certain client contacts constituted solicitation. It denied or deferred other requests, including those on trade secret misappropriation and injunctive relief, due to factual disputes or insufficient evidence on confidentiality. The rulings were based on the agreements' explicit terms, precedents like Bessemer v. Lake Champlain, and the absence of genuine issues of material fact on the resolved issues.
The case involved former members of the 1970s band the Bay City Rollers suing Arista Records for tens of millions in unpaid royalties allegedly due under a 1981 agreement. Arista raised an affirmative defense that the statute of limitations barred recovery for royalties accruing before 2001, while the plaintiffs argued that Arista had acknowledged the debt in writing under New York General Obligations Law Section 17-101, restarting the limitations period. The court granted the plaintiffs' motion for partial summary judgment on the limitations defense and denied Arista's cross-motion, after first addressing motions to strike certain unauthenticated or hearsay exhibits from Arista's summary judgment papers. The core reasoning centered on whether Arista's writings sufficiently acknowledged the debt to revive the claim and on the admissibility of evidence under the Federal Rules for summary judgment purposes.
This case was a civil rights action under the Individuals with Disabilities Education Act (IDEA) in which the plaintiffs, after obtaining a judgment against the Katonah-Lewisboro School District, moved for an award of attorneys' fees and expenses incurred during the litigation. The court granted the motion in part and awarded $153,870.40 in attorneys' fees, $2,088.75 in paralegal fees, and $1,017.69 in expenses. The court first confirmed that the plaintiffs qualified as prevailing parties under the IDEA fee-shifting provision, then evaluated the reasonableness of the requested rates and hours by comparing them to prevailing market standards for similar work and experience levels, and reduced the hours claimed by certain attorneys to account for administrative tasks, vague entries, and inefficient time spent on routine matters.
