Sue Lewis Robinson

Charles T. Monroe, a Delaware inmate, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254 challenging his state convictions for weapons possession and related offenses arising from a 2004 traffic stop that led to a pat-down search and discovery of a concealed weapon and ammunition. The District Court dismissed the application after determining that multiple claims were procedurally defaulted because they had not been fairly presented to the state courts or exhausted, while the remaining claims failed to satisfy the deferential standards of § 2254(d) as the state-court decisions were neither contrary to nor unreasonable applications of clearly established federal law. The court also declined to issue a certificate of appealability.

criminal lawprocedure

In Daughtry v. Family Dollar Stores, Inc., plaintiff Darlene Daughtry, an African-American former employee, sued her employer alleging race-based hostile work environment and retaliation under Title VII and 42 U.S.C. § 1981 after her 2006 demotion from district manager to store manager. The claims stemmed from alleged discriminatory comments by supervisors, inadequate training upon promotion, and her participation in a discrimination investigation involving another employee. The court granted defendant's motion for summary judgment, finding insufficient evidence to support the claims under the applicable legal standards for hostile work environment and retaliation.

labor & employmentcivil rights

The case involved the sentencing of defendant Paul E. Pavulak after his conviction on multiple federal charges related to sex offenses against minors, including failure to register as a sex offender, possession of child pornography, attempted production of child pornography, and attempting to entice a minor. The court determined that a mandatory life imprisonment sentence applied under 18 U.S.C. § 3559(e) due to the defendant's prior state convictions for unlawful sexual contact with minors. The court reasoned that the prior convictions, which involved minor victims and were stipulated to at trial, satisfied the requirements for the enhancement without needing jury proof under Apprendi v. New Jersey. It also noted that the enhancement under § 2251(e) would likely apply as well, and the sentence aligned with other statutory factors.

criminal lawprocedure

This case is a patent infringement action in which SRI International sued Symantec and Internet Security Systems for infringing four patents related to network security monitoring systems. Following a jury trial that found infringement and validity on certain claims of the '203, '615, and '338 patents, along with appeals and concurrent PTO reexamination proceedings, Symantec moved to amend its answer and counterclaims to add inequitable conduct allegations based on positions taken by SRI during reexamination. The court denied the motion, holding that granting leave to amend at this late stage—between liability and damages phases—would require an extensive review of the reexamination record to compare advocacy across proceedings, which is not an efficient use of judicial resources. The decision rested on the timing, the nature of the proposed amendment, and the court's discretion under Rule 15(a).

procedurebusiness & regulatory

This case is a patent infringement action in which Asahi Glass Co. and its affiliate sued Guardian Industries for allegedly infringing two related patents on sputtering targets made of substoichiometric metal oxides for depositing high-refractive-index films on glass via DC sputtering. Guardian asserted counterclaims of noninfringement and invalidity and sought to add inequitable-conduct defenses, but the court denied that amendment motion. The opinion addresses pending claim-construction disputes and cross-motions for summary judgment on infringement of specified claims and on invalidity under §§ 102, 103, and 112. The court’s analysis centers on the patents’ disclosure of oxygen-deficient targets, prior-art processes such as sintering and plasma spraying, and whether the accused products and references anticipate or render obvious the claimed inventions.

business & regulatoryprocedure

This case involves a patent infringement dispute in which Intermec sued Palm for infringing five patents related to data capture systems and bar code readers, while Palm asserted counterclaims for infringement of two of its patents concerning portable computers and rechargeable battery systems. The court addressed pending cross-motions for summary judgment on noninfringement and invalidity of Palm's '803 and '049 patents after lifting a prior stay and closing discovery. It construed disputed claim terms, determined that certain prior art references did not anticipate the independent claims of the '049 patent, and declined to reach additional arguments on dependent claims or obviousness.

business & regulatoryprocedure

In Johnson v. Phelps, a Delaware inmate convicted of delivering cocaine to a minor and within 300 feet of a park sought federal habeas corpus relief under 28 U.S.C. § 2254, challenging aspects of the prosecutor's closing arguments, inconsistent verdicts, and the reliability of police testimony. The district court dismissed the petition, finding that the claims had been procedurally defaulted in state post-conviction proceedings under Delaware Superior Court Criminal Rule 61(i)(3) because they were not raised on direct appeal. The court held that the petitioner failed to establish cause and prejudice for the default or that a fundamental miscarriage of justice would result from declining review, and it therefore could not reach the merits of the constitutional claims.

criminal lawprocedure

In Crist v. Phelps, an inmate at the James T. Vaughn Correctional Center sued prison officials under 42 U.S.C. § 1983, alleging that his transfer to administrative segregation was in retaliation for letters complaining about prison conditions, that officials ignored DOC rules and procedures, and that they conspired to punish him. The court granted summary judgment to the defendants and denied the plaintiff's motion, concluding there was no evidence of retaliation or conspiracy. The core reasoning was that the letters contained threatening language, staff assaults occurred shortly after one letter, and officials reasonably viewed the inmate as a security threat based on the timing and content of the communications plus his prior disciplinary history.

criminal lawcivil rights

This case involves a patent dispute in which Solvay, S.A. sued Honeywell Specialty Materials LLC and Honeywell International Inc. for infringing U.S. Patent No. 6,730,817, which covers a process for producing HFC-245fa. Following a Federal Circuit remand on invalidity issues under 35 U.S.C. § 102(g), the district court addressed multiple summary judgment motions concerning the patent's validity, infringement, and willful infringement. The court denied Honeywell's renewed motion for summary judgment of invalidity under § 102(g), concluding that the Russian research partner's work did not qualify Honeywell as a prior inventor in the United States. It granted Honeywell's motion for summary judgment of no willful infringement, finding insufficient evidence to support a willfulness claim, and denied the remaining procedural motions as moot or outside the scheduling order.

business & regulatoryprocedure

In Faines v. United States, a federal inmate convicted in 2005 of armed bank robbery and related charges filed a 28 U.S.C. § 2255 motion in 2009 seeking to vacate his sentence on grounds of ineffective assistance of counsel and actual innocence. The court denied the motion as time-barred under AEDPA's one-year limitations period, which began running when the conviction became final in October 2007 upon denial of certiorari. The inmate argued that a 2007 FDIC letter constituted newly discovered evidence restarting the clock under § 2255(f)(4) or supporting equitable tolling via actual innocence, but the court found the letter did not qualify as new evidence and that no other exceptions applied.

criminal lawprocedure

In Thorpe v. Little, a pretrial detainee at a Delaware correctional center proceeding pro se and in forma pauperis brought a § 1983 action alleging violations of his constitutional rights along with claims under the ADA, Rehabilitation Act, and other federal and state laws, seeking damages and injunctive relief including transfer to another facility. The court screened the complaint under 28 U.S.C. §§ 1915 and 1915A and permitted the plaintiff to proceed on Fourth Amendment claims, an excessive force claim, and claims related to deliberate indifference to his serious medical needs involving sarcoidosis, while dismissing the remaining claims as frivolous. The decision rested on the standards for frivolousness, failure to state a claim under Iqbal and Twombly, and the requirement that well-pleaded facts show a plausible entitlement to relief, with the court also denying the plaintiff's motions to show cause and for transfer. The opinion applied liberal construction to the pro se pleading but found many allegations lacked an arguable basis in law or fact or failed to plausibly allege violations.

criminal lawcivil rightsprocedure

This case involved Belden Technologies suing Superior Essex Communications for infringing multiple patents on high-performance data cables that use twisted-pair technology to control signal attenuation and crosstalk. Following stipulations on infringement and a prior summary judgment ruling that invalidated some claims, a jury trial addressed remaining validity issues and found certain claims invalid as anticipated or obvious while upholding others. The court then considered post-trial renewed motions for judgment as a matter of law on anticipation and obviousness, as well as Belden's request for a permanent injunction. In denying some motions as moot and evaluating the injunction, the court relied on evidence of substantial competition in the copper cable market, including multiple suppliers with varying market shares, to assess the equitable factors for relief.

business & regulatoryproperty

This case involved antitrust claims by ZF Meritor LLC and Meritor Transmission Corporation against Eaton Corporation, their rival in the Class 8 commercial truck transmissions market, alleging violations of Sections 1 and 2 of the Sherman Act and Section 3 of the Clayton Act through exclusive dealing arrangements. A jury found Eaton liable after a trial on liability, but the court had previously excluded the plaintiffs' expert damages testimony under Daubert because it relied on unreliable data from a single page of a strategic business plan. On reconsideration, the court denied the motion, finding no change in law, new evidence, or clear error to justify admitting or modifying the expert report, and awarded plaintiffs zero damages. The court also enjoined Eaton from linking discounts or benefits to market penetration targets, citing the public interest in competition.

business & regulatory

In Lane v. Phelps, an inmate at the James T. Vaughn Correctional Center sued prison officials Perry Phelps and Carl Danberg under 42 U.S.C. § 1983, claiming that from June 2008 to December 2009 the defendants failed to provide adequate treatment for his hernias and chronic pain despite being notified of his condition, in alleged violation of the Eighth Amendment. The defendants moved to dismiss for failure to state a claim, arguing insufficient facts to show personal involvement and reliance on a respondeat superior theory of liability. The plaintiff filed motions to amend the complaint with additional details about his medical history and the officials' awareness. The court granted the motion to dismiss and denied the motions to amend, holding that the allegations did not plausibly establish the defendants' personal involvement or deliberate indifference and that further amendment would be futile.

civil rightscriminal law

The case involved plaintiffs, who managed a now-liquidated Guernsey investment fund under a Delaware-governed Investment Management Agreement containing a forum selection clause, seeking an anti-suit injunction to halt parallel litigation filed by the fund's liquidators in New York, the District of Columbia, and Guernsey, and to confine all disputes to Delaware Chancery Court. After the liquidators removed the Delaware Chancery action to federal district court, the plaintiffs moved to remand and for injunctive relief, while the liquidators moved to dismiss. The court granted remand, determining that the action belonged back in Chancery Court to allow prompt resolution there and denying without prejudice the request for fees and costs associated with the removal.

procedurebusiness & regulatory

Plaintiff ULCS sued defendants HOTI (formerly Highlines) and Diversified for fraud, fraudulent misrepresentation, breach of contract, and enforcement of a guaranty tied to an asset purchase agreement for Highlines' material assets. The claims centered on defendants' alleged failure to disclose liabilities associated with certain subcontracts and business relationships. Defendants moved to dismiss or, alternatively, to transfer or stay the case in favor of a parallel Louisiana state lawsuit involving overlapping parties and events. The court denied the motion, holding that the contracts' Delaware choice-of-law and venue provisions applied given the amount in controversy, that diversity jurisdiction existed, and that abstention under Colorado River was not warranted after weighing the relevant factors such as the adequacy of the state forum and the presence of federal-law issues.

business & regulatoryproceduretorts & liability

The case involves John C. Dolbow appealing the Social Security Commissioner's denial of disability insurance benefits after injuries from a 2005 car accident that caused spinal fractures and ongoing pain. The ALJ had found a closed period of disability ending November 2007 but determined that Dolbow could perform other work thereafter. The district court granted the plaintiff's motion for summary judgment and remanded the matter, concluding that the ALJ had not adequately assessed medical improvement after the closed period. Challenges to the ALJ's handling of lay witness testimony and the finding that anxiety was not severe were rejected as harmless errors.

federal powerprocedurehealthcare

Plaintiff, a former inmate, filed a § 1983 action against Correctional Medical Services and Dr. Wallace alleging that he contracted MRSA in prison due to unsanitary conditions and received inadequate medical treatment for the infection. The court granted the defendants' motions to deem matters admitted, to dismiss, and for summary judgment. It found that the plaintiff had not responded to the motions or requests for admissions and that the medical records showed he received appropriate antibiotic treatment without evidence of deliberate indifference under the Eighth Amendment. Because no underlying constitutional violation occurred, the corporate defendant could not be held liable on a policy or custom theory.

civil rightscriminal law

This case involved a trademark dispute between Maya Argentina, the designer and manufacturer of Maya brand bikinis, and Maya USA, a former distributor that continued selling prior-year Maya products online after the parties' business relationship ended in 2010. Plaintiffs alleged violations of Sections 32 and 43(a) of the Lanham Act through unauthorized use of the Maya mark and false designation of origin, plus a state-law claim for tortious interference with a contractual relationship involving a former employee. The court granted in part and denied in part the motion for a preliminary injunction, allowing defendants to sell genuine Maya bikinis but requiring them to change their website URL, avoid prominent use of the stylized mark, adopt a different business name, and include clear disclaimers; it also denied the motion to dismiss the Lanham Act claims but granted dismissal of the tortious interference count. The core reasoning focused on the potential for consumer confusion from defendants' website presentation without disclaimers and the insufficient pleading of the tort claim.

business & regulatorytorts & liability

The case concerns plaintiff George McMahon's appeal of the Social Security Commissioner's denial of his application for disability insurance benefits under Title II, alleging disability since 2003 due to seizures, degenerative disc disease, carpal tunnel syndrome, and cirrhosis of the liver. The district court had jurisdiction under 42 U.S.C. § 405(g) to review the ALJ's determination, following cross-motions for summary judgment, that the plaintiff was not disabled because he retained the residual functional capacity to perform other work existing in the national economy. The court reviewed the plaintiff's work history, medical records including MRI results and examinations by treating and consulting physicians, state agency RFC assessments, and testimony from a vocational expert to assess whether the ALJ's findings were supported by substantial evidence.

federal powerprocedurelabor & employmenthealthcare