This case involves consolidated antitrust actions by direct and indirect purchaser plaintiffs against polyurethane foam manufacturers, alleging a conspiracy to fix prices, raise prices, and allocate customers in violation of federal and state antitrust laws. The court ruled on multiple motions to dismiss the complaints under Federal Rule of Civil Procedure 8 and the standards from Twombly and Iqbal, finding that the pleadings adequately alleged an express conspiratorial agreement through specific factual details linked to DOJ and Canadian competition investigations, rather than mere parallel conduct or labels. The complaints were held to plausibly suggest a meeting of the minds among defendants, supported by references to price discussions and conduct consistent with the alleged scheme. Motions to dismiss were denied as to the core federal claims, with limited exceptions noted for certain state-law issues and time-barred periods. Additional procedural matters, such as voluntary dismissals and discovery, were addressed separately.
This case involved an appeal by debtor Shannon Sturm from bankruptcy court orders that conditionally dismissed her Chapter 7 filing for presumptive abuse under the means test of 11 U.S.C. § 707(b) and then entered a dismissal order. Sturm had sought discharge of over $51,000 in credit card debt, but the U.S. Trustee challenged her Form B22A calculations, specifically her claimed Local Standards Housing deduction and marital adjustments for her non-filing spouse's mortgage and credit card payments, arguing they inflated her disposable income deficit and avoided a finding of abuse. The district court reversed the bankruptcy court's partial denial of the marital adjustment for the mortgage and its allowance of the housing deduction, holding that these required reconsideration under the statutory definition of current monthly income and the Supreme Court's Ransom decision; it remanded for recalculation of disposable income, including the credit card adjustment, with leave to convert if abuse was still found.
Janet Kleinser sued Bay Park Community Hospital under the FMLA, alleging interference with her rights when the hospital ended her light-duty assignment under its Transitional Work Program and required her to take continuous FMLA leave after a work-related injury limited her lifting ability. The parties cross-moved for partial summary judgment on whether this action violated the FMLA, given that light-duty positions remained available but Kleinser could not perform an essential function of her original bedside nursing role. The court granted the hospital's motion and dismissed the interference claim, holding that the FMLA does not require employers to provide or extend light-duty assignments and that Kleinser received all statutory leave protections before her employment ended upon exhaustion of FMLA and additional hospital leave. The ruling emphasized that reinstatement rights do not extend to temporary light-duty roles when an employee remains unable to perform original job duties.
This case concerns two lawsuits by hourly employees at assisted living and nursing facilities against their employers under the Fair Labor Standards Act, alleging that a company-wide policy of automatically deducting thirty minutes for meal breaks from timecards resulted in unpaid overtime when employees could not take uninterrupted breaks. Plaintiffs sought conditional certification to proceed as a collective action, presenting evidence from corporate discovery rather than individual employee claims, in a procedural posture between the lenient first stage and stricter second stage of FLSA certification review. The court analyzed the appropriate evidentiary burden for this hybrid stage, noting the plaintiffs' top-down approach to showing similarly situated employees through flaws in the policy's implementation, and addressed related issues like opt-in notice language.
This case involved an employer's motion to vacate or modify an arbitration award favoring a former employee in an employment dispute that had previously been sent to binding arbitration under the parties' agreement. The court first addressed its subject matter jurisdiction and determined that the Federal Arbitration Act does not independently confer federal jurisdiction over such motions, requiring instead an independent basis such as a federal question or diversity. Although the underlying dispute referenced the Family and Medical Leave Act, the court found the motion presented a state-law contract issue governed by Ohio arbitration statutes, with no proper federal question appearing on the face of the pleadings and no grounds for vacatur under the exclusive provisions of FAA Section 10. The case was therefore dismissed for lack of subject matter jurisdiction.
In Walters v. Royer, plaintiff Paul Walters sued defendant attorney George Royer for legal malpractice, alleging Royer failed to timely prosecute several patent applications. Royer moved for summary judgment, arguing the claim was barred by Ohio's one-year statute of limitations for legal malpractice. The court explained that under Ohio law, the limitations period begins to run on the later of the date the client discovers or should discover the injury or the date the attorney-client relationship for the matter terminates. Because the parties disputed whether the relationship ended with Walters' May 2009 grievance filing or his July 2009 letters to Royer and the PTO, the court found a genuine issue of material fact on the termination date and denied the motion.
