This case involves claims by Lynn M. Johnson against BAE Systems, Inc. and Thomas Schiller arising from alleged sexual harassment and misconduct while working together on an intelligence team in Iraq. Johnson asserted tort claims including negligent supervision, sexual battery, intentional infliction of emotional distress, and defamation, alleging that Schiller's actions caused her health problems and led to retaliation. The court granted summary judgment to the defendants on the claims for negligence, battery, and defamation, finding no reasonable jury could rule in her favor, but allowed the intentional infliction of emotional distress claim to proceed. Additionally, due to Johnson's destruction of potentially relevant evidence on her computer, the court imposed sanctions including an adverse inference instruction but declined to dismiss the case entirely.
torts & liabilityprocedurelabor & employmentcivil rights
In this patent infringement dispute, Bell Helicopter Textron sued Airbus Helicopters over helicopter gear technology, leading to rulings on infringement, damages, and injunctive relief, followed by Airbus's bill of costs for an injunction hearing. The district court denied the request, holding that Airbus was not the prevailing party under Federal Circuit precedent because Bell obtained greater relief on the merits by securing a declaratory judgment of noninfringement for the currently used modified gear and avoiding any damages obligation, while Airbus's injunction applied only to a discontinued original gear. Even if Airbus qualified as prevailing, the highly mixed outcome—with each side succeeding on some contested issues—provided grounds to exercise discretion under Rule 54(d) and require the parties to bear their own costs rather than award them to one side.
The case involved a D.C. prisoner who sued the U.S. Parole Commission, claiming that its use of 2000 parole guidelines at his 2011 hearing violated the Constitution's ex post facto clause and seeking application of the 1987 guidelines or immediate release. The court granted the defendants' motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. It reasoned that the Commission had in fact applied the 1987 guidelines to the plaintiff's hearing, eliminating any ex post facto issue, and that immediate release was not an available remedy in the action. The court declined to address other asserted grounds for dismissal such as lack of personal jurisdiction or improper venue.
The case involved TriZetto seeking judicial review under 15 U.S.C. § 1071(b)(4) of a Trademark Trial and Appeals Board order denying cancellation of Farmaco-Logica's trademark for non-use, with the action initially filed in the District of Columbia. TriZetto moved to transfer the case to the Eastern District of Virginia under 28 U.S.C. § 1406(a) after realizing the filing relied on an outdated version of the statute that had been amended in 2011 to designate the Eastern District of Virginia as the proper venue. The defendant opposed transfer, arguing lack of jurisdiction and that transfer would not serve the interests of justice. The court granted the motion, holding that it could resolve the transfer request without first addressing jurisdictional questions and that transfer was warranted because the initial filing was an inadvertent mistake and dismissal would likely bar review on limitations grounds.
Larry Hodge sued the Invisible Empire (associated with the Ku Klux Klan) and other defendants in the U.S. District Court for the District of Columbia. After the court dismissed his amended complaint for failing to meet the minimal pleading standards under Federal Rule of Civil Procedure 8(a), Hodge moved for reconsideration under Rule 60(b)(1), citing mistake or excusable neglect due to personal obligations that prevented him from submitting supporting documents. The court denied the motion, explaining that Hodge had already received two opportunities to correct the deficiencies and that a litigant's failure to present all known facts does not provide grounds for relief under the rule. The court further noted that Hodge had still not offered any relevant evidence to support the basis of his claim, rendering any relief futile.
In this case, plaintiff Patricia Thyer sued the Department of Justice under FOIA seeking records about herself from the Executive Office for United States Attorneys, the Office of Information Policy, and the Department of Homeland Security. The underlying facts involved Thyer's 2005 guilty plea to murder-for-hire and related firearm charges, which included a broad waiver of her rights to obtain federal records about the investigation and prosecution via FOIA or the Privacy Act. The district court granted the government's motion to dismiss or for summary judgment. The court held that the plea agreement's explicit waiver barred her FOIA claims and, alternatively, that she had failed to exhaust administrative remedies because she did not properly appeal the agencies' responses to her requests.