AI-measured from their own opinions — each lever cites its cases
PurposivismTextualism
Opinion [0] parses ERISA fiduciary definition via the precise statutory text of 29 U.S.C. § 1002(21)(A) without resort to purpose or policy. Finkel v. Romanowicz ↗
Deference to government powerSkepticism of government power
This case involved the Joint Industry Board of Electrical Industry suing employer Whiffen Electric Co. and its principal Joseph Romanowicz to recover delinquent contributions to ERISA employee benefit plans, including a 401(k) plan, plus claims that Romanowicz breached fiduciary duties and was personally liable on dishonored checks under New York’s Uniform Commercial Code. The district court entered a default judgment against Whiffen for unpaid amounts, interest, and fees but dismissed all claims against Romanowicz. On appeal, the Second Circuit affirmed, holding that Romanowicz was not an ERISA fiduciary because he lacked discretionary authority or control over plan assets, that no hearing was required before dismissal on the pleadings, and that the UCC did not impose personal liability on the checks given the parties’ prior course of dealing.
The case involved Brandan R. Freeman, who was convicted of receiving child pornography in violation of 18 U.S.C. § 2252A(a)(2) and appealed his sentence, challenging a four-level enhancement under U.S.S.G. § 2G2.2(b)(4) for possessing images depicting sadistic or masochistic conduct. The United States Court of Appeals for the Second Circuit affirmed the district court's imposition of the enhancement. The court reasoned that the district court's findings—that the images depicted sexual activity involving minors and that the activity would have caused the minors pain—were sufficient to support the enhancement, consistent with its prior holding in United States v. Delmarle.
In this securities fraud case, the plaintiffs alleged that Arthur Andersen provided misleading advice and prepared false private placement memoranda recommending investments in Colonial Realty limited partnerships that formed part of a Ponzi scheme, causing over $1.4 million in losses, and that the firm failed to disclose its relationships with the partnerships. The plaintiffs asserted claims under section 10(b) of the Securities Exchange Act of 1934, the Connecticut Unfair Trade Practices Act, and Connecticut common law. On the defendant's motion to dismiss, the court applied the standards requiring acceptance of the complaint's allegations as true and considered the one-year/three-year limitations period for federal claims filed after November 1990, along with state-law limitation periods and equitable tolling doctrines. The court also evaluated pleading requirements under Rule 9(b) and declined to consider new factual assertions raised only in opposition briefs.
In this case, plaintiff Irwin Schiff, who had been convicted of tax evasion and placed on probation with a condition to comply with tax laws, sued a federal district judge, an assistant U.S. attorney, a probation officer, and an IRS agent for monetary damages, alleging improper conduct in connection with the revocation of his probation. The defendants moved for dismissal or summary judgment. The court granted summary judgment to all defendants, holding that the judge was protected by absolute judicial immunity for actions taken in his judicial capacity during the probation revocation proceedings, while the other officials were entitled to qualified immunity because the finding of a probation violation established that they had not violated any clearly established statutory or constitutional rights. The court applied established standards for immunity under Supreme Court precedent and found no genuine issues of material fact that would overcome these defenses.
This case involves shareholders of Amity Bankcorp, Inc. suing the company and its directors to block a proposed stock purchase agreement with a third party, alleging that proxy statements contained material misrepresentations in violation of section 14(a) of the Securities Exchange Act of 1934 and that public filings and statements artificially inflated the stock price in violation of sections 10(b) and 20(a). The plaintiffs also brought related state-law claims for fraud and negligent misrepresentation. The defendants moved to dismiss the amended complaint. The court held that the applicable one-year statute of limitations for the federal securities claims is triggered by inquiry notice, not actual notice, and evaluated whether the claims were timely based on when a reasonable investor would have discovered the alleged violations.
This case concerns motions regarding legal representation for defendant High Sheriffs and Special Deputy Sheriffs in actions brought before the Connecticut State Board of Labor Relations, after the state Attorney General withdrew as their counsel due to a conflict of interest. The court addressed whether the Attorney General could partially remain in the case for official-capacity claims and whether he was obligated to pay for substitute private counsel for the defendants. The court vacated its prior orders permitting partial representation, holding that all remaining claims for money damages could proceed only against the defendants in their individual capacities under the Eleventh Amendment and state sovereign immunity doctrines, rendering official-capacity representation moot. It further concluded that piecemeal withdrawal would be inappropriate and that any request for the Attorney General to fund new counsel should be litigated in state court, except for specific defendants where supplemental jurisdiction over novel state-law issues was declined.