Robin Eastes sued ACS Human Services under 42 U.S.C. § 1983, alleging that her termination from a call center job violated her First Amendment rights because it was in retaliation for criticizing the privatization of state benefits services. The court granted summary judgment to ACS, dismissing the case. Although Eastes had initially pursued a theory that ACS acted jointly with the state, she abandoned it, and the court rejected her argument that ACS was a state actor under the public function theory. The court reasoned that while operating the call center for benefits inquiries might involve a public function, the specific decision to terminate an employee was not a traditionally public function attributable to the state.
In this case, Annastacia Alalade sued her former employer AWS Assistance Corp. under Title VII for sexual harassment after a single severe incident of assault by her supervisor, along with related retaliation and state-law claims. The court had previously denied AWS summary judgment on the harassment claim, agreeing that AWS met the first prong of the Ellerth/Faragher affirmative defense through its anti-harassment policy and prompt response, but finding a factual issue on the second prong because Alalade's four-day reporting delay did not necessarily show unreasonable failure to mitigate. AWS moved for reconsideration, arguing for the first time that single-instance harassment cases should dispense with the second prong entirely. The court denied reconsideration, holding that the Supreme Court established a mandatory two-prong defense without exception for isolated incidents, that policy reasons for employee reporting still apply, and that lower courts may not modify the framework established by higher authority.
In Maxwell v. South Bend Work Release Center, a disabled work-release inmate sued Imperial Stamping Corporation, a private employer, alleging it refused to hire him due to his disability while participating in a prison work program. The plaintiff brought claims under Title II of the ADA, the Rehabilitation Act, and Section 1983. The court granted Imperial's motion for summary judgment, holding that the company is not a public entity subject to Title II liability, does not receive federal financial assistance required for Rehabilitation Act claims, and that the Section 1983 claim was abandoned due to lack of response. The decision rested on statutory definitions and precedent showing that private contractors with state entities do not become public instrumentalities merely through business relationships.
Jerry Herron applied for Disability Insurance Benefits and Supplemental Security Income claiming disability from bipolar disorder, schizoaffective disorder, and related mental impairments beginning in 2006. An administrative law judge denied the claims after finding Herron not credible and determining that his impairments did not prevent him from performing simple, repetitive work. The district court remanded the matter to the ALJ for further proceedings, holding that the ALJ had improperly ignored or failed to weigh evidence supporting Herron's claim, including reports from examining psychologists and psychiatrists, testimony from his former employer's HR manager, and hearing witnesses, while over-relying on a non-examining state agency psychologist. The court also denied Herron's requests for attorney fees without prejudice as premature or incomplete.
This case is an insurance coverage dispute in which State Farm sought a declaratory judgment that it had no duty to defend or indemnify foster parents Donald and Patricia Nokes, or others, against a state-court lawsuit brought by former foster child Nathan Evans alleging sexual and physical abuse while living in the Nokes' home. The court granted State Farm's motion for summary judgment. The core reasoning was that Evans qualified as an "insured" under the homeowner's policy because he was a resident under age 21 in the care of the Nokes, triggering the policy's explicit exclusion of coverage for bodily injury to any insured.
This case centers on allegations by biotechnology company CoMentis against Purdue University professor Arun Ghosh and the Purdue Research Foundation for mishandling confidential information and intellectual property under consulting and licensing agreements, including claims that Ghosh filed independent patent applications on pyrrolidine compounds developed using CoMentis data. CoMentis asserted ten counts including breach of contract, trade secret misappropriation, fraud, constructive fraud, and unjust enrichment. The court granted Purdue's motion for judgment on the pleadings in part by dismissing the unjust enrichment claim with prejudice due to the existence of valid contracts covering the subject matter, but denied it as to the contract and misappropriation counts; it granted Ghosh's motion to dismiss the fraud and constructive fraud claims without prejudice for failure to plausibly allege intent or unconscionable advantage, while allowing CoMentis leave to amend those counts. The rulings were based on the pleadings, incorporated agreements, and standards requiring plausible factual allegations rather than conclusory statements.