This case concerned whether the Moorestown Township Board of Education violated the Individuals with Disabilities Education Act (IDEA) by refusing to evaluate a student with disabilities or develop an Individualized Education Plan (IEP) while he attended a private school, unless his parents first re-enrolled him in the public district. The parents, who had previously removed the child from public school due to concerns over progress, sought an IEP to assess if the district could provide a free appropriate public education (FAPE) before deciding on re-enrollment. The U.S. District Court for the District of New Jersey held that the district had an independent obligation under IDEA to conduct evaluations and offer a FAPE, including preparing an IEP, for any eligible child residing in the district regardless of private enrollment status. The court reasoned that federal regulations require local education agencies to locate, identify, evaluate, and make FAPE available to all children with disabilities in their jurisdiction, including those in private schools whose parents might seek public placement, and that refusal based on enrollment status was inconsistent with these duties. The court granted partial summary judgment to each side on related claims.
This case involved a union representing Conrail maintenance workers challenging arbitration awards by the National Railroad Adjustment Board that dismissed claims over the railroad's use of non-union contractors for track work in several states. The disputes stemmed from an implementing agreement required by the Surface Transportation Board as part of its approval of the Conrail merger, which allowed certain contracting out without union notice. The union argued the Board had jurisdiction under the Railway Labor Act and sought to vacate the awards for merits review, while Conrail contended the STB held exclusive authority. The court denied the union's summary judgment motion and granted Conrail's cross-motion, holding that the claims required interpretation of the STB-mandated agreement and thus fell outside NRAB jurisdiction.
labor & employmentbusiness & regulatoryfederal power
In this civil rights action, plaintiff Larry Peterson alleges that after serving 18 years in prison for a 1989 felony murder and aggravated sexual assault conviction, he was wrongfully convicted based on fabricated witness statements, overstated forensic hair analysis by a state police scientist, and prosecutors' failure to investigate exculpatory leads or act on exonerating evidence. The defendants, including Burlington County prosecutors, investigators, and the forensic expert, moved for summary judgment asserting absolute and qualified immunity. The court partially granted the motion, holding that qualified immunity protected the forensic scientist's testimony and some investigative actions, while absolute prosecutorial immunity shielded certain charging and trial-related conduct but not post-conviction efforts to oppose DNA testing or other exoneration motions; disputed factual issues regarding fabrication and intimidation prevented full dismissal.
This case involves a slip-and-fall negligence claim filed by plaintiff Jo-Anna Lynn Martin against Wal-Mart in New Jersey state court. Wal-Mart removed the action to federal court based on diversity jurisdiction, asserting that the amount in controversy exceeded $75,000 solely because the plaintiff refused to stipulate to damages below that threshold. The court raised the issue of subject-matter jurisdiction sua sponte and determined that the removal notice failed to meet the required burden of establishing federal jurisdiction. The court therefore remanded the case to state court, emphasizing that a plaintiff's refusal to cap damages does not affirmatively demonstrate that the amount in controversy satisfies the statutory requirement under 28 U.S.C. § 1332.
This case concerns a dispute over the assignment of roofing work on a public community center construction project governed by a Project Labor Agreement (PLA) under New Jersey law. Local 27 claimed that Donnelly and Sambe breached the PLA and related agreements by subcontracting the work to Local 623, a non-signatory union, instead of Local 27. The court granted in part and denied in part the parties' summary judgment motions, holding that the PLA remained binding on the contractors despite an NLRB ruling awarding the work to Local 623, because the PLA acts as a master agreement superseding other contracts and creates enforceable obligations under state law. The core reasoning was that Donnelly created conflicting obligations but remains liable for breaching the PLA, with potential damages to be determined.
The case involved European sheet music distributors suing a U.S. distributor for copyright infringement under the U.S. Copyright Act, alleging that the defendant unlawfully exported sheet music to Europe in violation of the plaintiffs' exclusive European distribution licenses. The court granted the defendant's motion to dismiss for lack of subject-matter jurisdiction, concluding that the plaintiffs lacked statutory standing. The core reasoning was that the Copyright Act does not reach the alleged distribution, which occurred abroad, absent any domestic predicate act of infringement within the United States.