The case concerned whether two senior executives at a mutual fund distributor could be held primarily liable under SEC Rule 10b-5(b) for using and disseminating prospectuses that allegedly contained false statements about market-timing practices, even though the executives did not author those statements. The en banc First Circuit affirmed the district court's dismissal of the SEC's Rule 10b-5(b) claim. The court held that the defendants did not "make" any untrue statement within the meaning of the rule, rejecting the SEC's arguments that merely using or disseminating a prospectus, or impliedly vouching for its accuracy as an underwriter, constitutes making a statement. The core reasoning was that the SEC's expansive reading of "make" is inconsistent with the rule's text and ordinary meaning, the structure of the securities laws, and Supreme Court precedent.
The case concerned whether a bankruptcy court has authority under the Bankruptcy Code to review the statutory fees of a standing Chapter 13 trustee appointed under the U.S. Trustee Pilot Program in 28 U.S.C. §§ 581-589. The district court held that bankruptcy courts lack such authority in pilot districts, reversing the bankruptcy court's decision to reduce the trustee's fee from approximately $6000 to $3000. The core reasoning was that Congress created the Pilot Program specifically to transfer administrative responsibilities, including oversight of standing trustees' compensation, from the courts to the U.S. Trustee and Attorney General, as evidenced by the statutory scheme in 28 U.S.C. § 586(e) and the legislative history distinguishing pilot from non-pilot districts.
The case involves a nursing student at a religiously affiliated college who was expelled from the program due to her chronic obesity and inability to lose weight despite repeated discussions and requirements from faculty, leading her to sue the college and officials for damages under diversity jurisdiction. The claims included multiple theories such as breach of contract and invasion of privacy under Rhode Island law, arising from incidents like fitting uniforms, modeling procedures for obese patients, and discussions of her weight. The defendants moved for summary judgment on all counts, and the court applied the standard requiring no genuine issues of material fact and entitlement to judgment as a matter of law, viewing evidence in the light most favorable to the plaintiff. The court denied summary judgment on the privacy claim, finding potential jury questions about whether actions amounted to unreasonable intrusion or publicity of private facts, while construing any ambiguities in school documents against the college.
This case arose from a Chapter 7 bankruptcy in which the trustee sought to sell the debtor's Rhode Island Class B-V liquor license to a third party free and clear of liens under 11 U.S.C. § 363(b). The Rhode Island Division of Taxation objected, citing R.I. Gen. Laws § 3-7-24, which conditions any transfer or renewal of a liquor license on proof that all state taxes owed by the licensee have been paid. The bankruptcy court overruled the objection and authorized the sale, and the district court affirmed. The court held that the debtor's liquor license constitutes property of the bankruptcy estate under 11 U.S.C. § 541(a)(1) and that the state statute is preempted by the Bankruptcy Code's provisions on estate property, the automatic stay, and the discharge, pursuant to the Supremacy Clause.
The case concerned whether a Rhode Island statute requiring health insurance plans to reimburse for optometric services performed by licensed optometrists applied to General Dynamics Corporation's self-funded plans and collective bargaining agreement, which limited such coverage to examinations by ophthalmologists. Plaintiffs, consisting of Rhode Island optometrists, their trade association, and an affected employee, filed suit in state court seeking injunctive relief to enforce the statute, after which the defendant removed the action to federal court asserting both federal question and diversity jurisdiction. The court analyzed whether the state-law claims arose under federal law and whether the amount in controversy requirement was satisfied for the proposed plaintiff classes under diversity jurisdiction. It concluded that neither basis for federal jurisdiction existed, resulting in remand to state superior court.
The case arose from the 1984 sinking of the Tall Ship S/V Marques during a race, in which the plaintiffs' parents perished while participating in a sail training program. The plaintiffs sued the American Sail Training Association (ASTA), its officers and directors, and the vessel's owners under Ohio wrongful death law, contract theories, the Death on the High Seas Act, and the Jones Act. The court addressed summary judgment motions by the ASTA defendants on the Jones Act claims. It ruled that those claims failed because the decedents were not employees of ASTA, as they paid fees to participate rather than working in exchange for passage, and ASTA exercised no operational control over the vessel during the voyage.