This case is a federal habeas corpus petition by John Sullivan challenging his state murder conviction on the basis that his trial counsel provided ineffective assistance due to a conflict of interest. The same attorneys represented Sullivan and two co-defendants, and the petitioner argued that this joint representation led counsel to forgo certain defenses and strategies to protect the co-defendants. After a de novo review of the full record, including trial transcripts, post-conviction hearings, and evidentiary hearings, the court adopted the magistrate's findings that an actual conflict existed and adversely affected counsel's performance. The court therefore granted the writ, holding that Sullivan was deprived of his Sixth Amendment right to effective assistance of counsel.
In this Fair Labor Standards Act case, the Secretary of Labor sought to enforce a prior consent judgment enjoining overtime violations by filing a petition for civil contempt, while also adding new claims for minimum wage violations under section 6, injunctive relief under section 17, and liquidated damages under section 16(c). The respondent moved to dismiss the new minimum wage and damages claims, arguing they could not be appended to the contempt proceeding after the original action had terminated via final judgment. The court held that the consent decree was final, making joinder of entirely new claims via the contempt petition procedurally improper, but denied the motion to dismiss because the contempt enforcement remained part of the original cause and the issue was one of pleading rather than jurisdiction; the Secretary retained statutory authority to pursue the claims, which could be addressed through flexible federal pleading rules without separate formal filing.
This case involves a property damage claim by plaintiffs against General Electric after a refrigerator they purchased from the defendant allegedly caught fire in 1978, destroying their home and personal belongings without causing personal injuries. The complaint asserted claims for negligence, strict liability in tort, and breach of warranty, with the defendant moving to dismiss the strict liability and warranty counts. The court denied the motion to dismiss the strict liability claim, holding that Pennsylvania law permits such a tort action for physical property damage caused by a defective product, and it is bound by the Third Circuit's decision in Pennsylvania Glass Sand v. Caterpillar Tractor Co. The breach of warranty claim was dismissed as barred by the statute of limitations. The court reasoned that a subsequent state intermediate appellate decision did not override the circuit precedent and lacked precedential force as it was not joined by a majority.
The case involved whether a remaining defendant in a diversity product liability action could introduce evidence of the plaintiff's settlement with a former co-defendant to reduce its potential damages exposure at trial. The court ruled that the evidence was inadmissible. The core reasoning was that Federal Rule of Evidence 408 bars settlement evidence offered to prove or disprove the amount of a claim, and permitting its use here would undermine the rule's policy of encouraging settlements even if framed as avoiding jury prejudice.
In this fire property loss case, plaintiff Robert Lanza sued defendants Vincent and Kathleen Poretti, owners of a beauty salon on the first floor of a building, alleging that their negligence in disposing of smoking materials caused a fire that damaged his fashion design business on the second floor; the complaint was later amended to include an intentional tort claim, and defendants filed a third-party complaint against the prior owners while also arguing the fire was incendiary. After a jury trial, a verdict was returned for the defendants. The court denied the plaintiff's motion for judgment n.o.v. because no motion for a directed verdict had been made at the close of evidence, as required by Fed. R. Civ. P. 50(b). The court also denied the motion for a new trial, finding that an unauthorized jury experiment during deliberations did not create a reasonable possibility of prejudice and that the res ipsa loquitur doctrine was inapplicable due to conflicting expert testimony establishing multiple equally probable causes for the fire.
In this diversity action, settling co-defendant Verson Allsteel Press moved in limine to be excused from trial attendance after executing a joint tortfeasor release with plaintiff Young, while co-defendant Federal Pacific Electric opposed the motion and argued that Pennsylvania's Comparative Negligence Statute required Verson's presence for apportionment of liability. The court examined pre-statute precedent such as Davis v. Miller, which had required settling defendants to remain if their tortfeasor status could benefit a non-settling party, and post-statute developments including Griffin v. United States, which recognized that certain releases could concede tortfeasor status and waive the need for joinder. It concluded that the Comparative Negligence Act altered the prior rule, so that a settling defendant whose liability share is fixed by a Griffin-type release need not attend trial, as its absence does not prevent proper apportionment among remaining parties and avoids potential jury confusion. The motion was therefore granted, relieving Verson of any obligation to participate further.
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