This case was a proposed class action brought by several West Virginia policyholders against State Farm Mutual Automobile Insurance Company and one of its agents, alleging that State Farm failed to make commercially reasonable offers of underinsured motorist coverage as required by state law when issuing their auto policies. The plaintiffs sought declaratory relief to reform their policies to include such coverage, plus claims for breach of contract, bad faith, and violations of the Unfair Trade Practices Act stemming from denied claims after accidents where damages exceeded the at-fault drivers' liability limits. The court granted in part and denied in part the defendants' motion for summary judgment and denied the plaintiffs' motion for class certification. Class certification was rejected because resolving the claims would require individualized inquiries into each policyholder's specific facts, such as the validity of coverage selection forms and signatures, failing to satisfy the commonality requirement of Federal Rule of Civil Procedure 23.
The case involves the sentencing of defendant Harold Thompson, who pleaded guilty to theft of firearms from a licensed dealer under 18 U.S.C. § 922(u) and later to being a felon in possession of a firearm and making counterfeit currency. At the sentencing hearing, Thompson raised objections to the presentence report, including whether his prior § 922(u) conviction qualified for the career offender enhancement under U.S. Sentencing Guidelines § 2K2.1 based on the definition of "crime of violence" in § 4B1.2(a). The court granted the first objection, holding that a § 922(u) violation is not a crime of violence because it does not have as an element the use of physical force against a person and does not categorically involve conduct presenting a serious potential risk of physical injury to another, as analyzed under the categorical approach from cases like Begay and James. The court denied the second objection to the presentence report.
This case involves an environmental group's citizen suit against a coal mining company under the Clean Water Act and the Surface Mining Control and Reclamation Act, seeking enforcement of effluent limits on selenium discharges from mine operations into state waters. The West Virginia Department of Environmental Protection had issued NPDES permits with selenium standards, but the defendant sought modifications and state court stays that raised questions about federal court jurisdiction. The court denied the plaintiffs' initial partial summary judgment motion as moot, granted in part and denied in part their supplemental motion along with the defendant's motions to dismiss, abstain, and for summary judgment. Core reasoning focused on the federal statutes' requirements for permit compliance, EPA oversight of state programs, the absence of ongoing conflicting state proceedings warranting abstention, and the ineffectiveness of certain state stays on federal claims.
This case involved the civil forfeiture of $13,963 seized from claimant Donald Jamal Wilson during a 2006 drug trafficking investigation that led to his federal conviction. After the DEA referred the matter, the government filed its forfeiture complaint 20 days past the 90-day statutory deadline under 18 U.S.C. § 983(a)(3), but Wilson did not raise the timeliness issue in his answer or earlier motions; the district court granted summary judgment for the government, which was affirmed on appeal. Wilson later moved to set aside the judgment as void, arguing the deadline was jurisdictional and deprived the court of authority. The court denied the motion, holding that the deadline is a nonjurisdictional statute of limitations that functions as an affirmative defense, which Wilson had forfeited by failing to assert it timely. The ruling relied on Supreme Court precedents distinguishing jurisdictional rules from claim-processing requirements and on the absence of explicit jurisdictional language in the statute.
This case is a putative shareholder class action challenging a proposed two-step acquisition of International Coal Group (ICG), a Delaware corporation, in which Arch Coal would acquire ICG through a tender offer at $14.60 per share followed by a back-end merger. Plaintiffs sought to enjoin the deal, alleging breaches of fiduciary duties under Delaware law and violations of the federal Securities Exchange Act. The court granted in part the defendants' motion by staying the Delaware-law claims to allow parallel proceedings in the Delaware Court of Chancery to resolve those state-law issues first, while retaining jurisdiction over the federal claims; it denied as moot the plaintiffs' expedited discovery motions and held the preliminary injunction motion in abeyance pending developments in Delaware. The decision rested on the similarity of the state-law claims to those in the Delaware actions, the need to avoid duplicative litigation, and the ease of transferring relevant documents.
The case involves citizen suits by environmental groups against coal mining companies under the Clean Water Act and Surface Mining Control and Reclamation Act to enforce selenium discharge limits in state-issued WV/NPDES permits. The court granted the plaintiffs' motions for partial summary judgment and denied the defendants' cross-motions, holding that stays issued by the state Environmental Quality Board did not postpone the effective dates of the selenium effluent limitations. The core reasoning was that the EQB's state-law authority could not alter the federally approved permit requirements or compliance schedules, and the defendants had not exhausted available federal review processes with the EPA. The court also granted a motion to stay proceedings in one case pending EPA negotiations.
