The case involved Michael Hedlund seeking discharge of his government-insured student loans in bankruptcy under the undue hardship exception of 11 U.S.C. § 523(a)(8). The bankruptcy court partially discharged amounts exceeding roughly $32,000 after applying the Brunner test and finding that full repayment would cause undue hardship given Hedlund's employment history, family obligations, and failed bar exam attempts. PHEAA appealed, and the district court reversed the bankruptcy court's ruling. The district court concluded that Hedlund had not met the Brunner factors, including evidence that he could increase household income through additional work by himself or his spouse and that he had not made sufficient efforts to repay the loans despite available repayment options.
The case involved plaintiff Craig Shaw suing his former employer, Restaurants Unlimited, Inc., for wrongful discharge under Oregon common law, alleging he was fired in retaliation for filing an age discrimination complaint with the Oregon Bureau of Labor and Industry. The court granted the defendant's motion for summary judgment and dismissed the case. The core reasoning was that the decision to terminate the plaintiff had been made prior to the filing of the complaint, so there was no causal link between the protected activity and the discharge, and any statutory claim would similarly fail on the merits.
The case involved a plaintiff suing Breg, Inc., the manufacturer of a medical pain pump device, for products liability and negligence after the device was used following her shoulder surgeries and allegedly caused glenohumeral chondrolysis, a condition destroying cartilage in the joint. Breg moved for summary judgment, arguing the claims were barred by the statute of limitations, that it lacked knowledge of any dangers associated with intra-articular use, that any failure to warn did not cause the injury, and that punitive damages were unavailable. The court denied the motion, finding genuine issues of material fact on each point, including when the plaintiff reasonably could have discovered the link to the device, the extent of Breg's knowledge and marketing practices regarding FDA-cleared uses, and the impact on causation and punitive claims.
In Schoenborn v. Stryker Corp., plaintiffs sued the manufacturer and distributor of a medical pain pump device for products liability and negligence after the device was used to deliver anesthetics directly into plaintiff Eric Schoenborn's shoulder joint following surgery, allegedly causing glenohumeral chondrolysis. Stryker moved for summary judgment, arguing it had no duty to warn of risks because it did not know and could not have known of them at the time of the 2004 surgery, that plaintiffs could not prove causation, and that punitive damages were unavailable. The court denied the motion, finding material issues of fact regarding whether Stryker knew or should have known of toxicity risks associated with intra-articular use, whether its alleged failure to warn caused the injury in light of the surgeon's testimony, and whether the facts supported punitive damages. The opinion discusses FDA 510(k) clearance processes for the Class II device and evidence of Stryker's marketing practices for unapproved uses.
In Caldwell v. Astrue, the plaintiff sought judicial review under the Social Security Act of the Commissioner's denial of his applications for Title II disability insurance benefits and Title XVI supplemental security income, claiming disability beginning in 2002 due to memory loss, headaches, arthritis, back pain, and depression. The district court reversed the Commissioner's decision and remanded for further administrative proceedings. The ALJ had found at step four that the plaintiff could perform past relevant work as a motel cleaner and cannery worker based on a residual functional capacity for light work limited to simple tasks with minimal public interaction, but the court held that the ALJ erred by failing to give germane reasons specific to each lay witness when discounting third-party statements from the plaintiff's acquaintances about his impairments and by omitting the limitations described in that testimony from the hypothetical questions to the vocational expert. The court concluded that the error was not harmless because including the lay testimony could have altered the vocational expert's responses and the step-four finding.
In Longmore v. Astrue, the plaintiff sought judicial review under the Social Security Act of the Commissioner's denial of Disability Insurance Benefits and Supplemental Security Income, claiming disability since 1997 due to physical ailments and severe mental illness including schizophrenia. The Administrative Law Judge had granted benefits only from January 2006 onward, finding the plaintiff could perform other work prior to that date. The court reversed the decision, holding that the ALJ's findings were not supported by substantial evidence, particularly regarding the plaintiff's credibility and the onset of his psychiatric condition as indicated by treating psychiatrists, and remanded for payment of benefits starting earlier.
