The case involved Mexican migrant workers employed by Defendants for forestry work who alleged violations of the Trafficking Victims Protection Reauthorization Act (TVPRA) based on the concealment of their H-2B visa extension documents and threats of immigration consequences if they left employment early. Defendants moved to dismiss the TVPRA claim, asserting that the workers held their original passports and visas and faced no actual barrier to departing. The court denied the motion to dismiss, holding that the allegations sufficiently stated a claim because visa extension documents qualify as immigration documents under 18 U.S.C. § 1592(a) and the alleged threats amounted to abuse or threatened abuse of legal process under 18 U.S.C. § 1589(a)(3) and (c).
In Miller v. Meyers, plaintiff Anna Miller sued her ex-husband Darin Meyers after he installed a keylogger on a shared computer to access her password-protected online accounts and used the obtained information during their divorce and subsequent custody proceedings. Miller brought claims under federal statutes including the Computer Fraud and Abuse Act, Stored Communications Act, and Wiretap Act, along with Arkansas state claims for computer trespass, breach of contract, and intentional infliction of emotional distress; Meyers counterclaimed for breach of the parties' divorce settlement agreement. The court granted partial summary judgment to Miller on her Stored Communications Act and computer trespass claims while granting partial summary judgment to Meyers on the Wiretap Act, certain state claims, and the emotional distress claim, and it dismissed the counterclaim with prejudice. It denied summary judgment on the remaining claims under the Computer Fraud and Abuse Act and breach of contract, finding genuine issues of material fact regarding the scope of the settlement agreement and whether Meyers' conduct violated it or other statutes, and set those issues plus damages for trial. The reasoning centered on the terms of the divorce decree and settlement agreement, the specific elements of each federal and state cause of action, and Arkansas precedent narrowly construing claims for intentional infliction of emotional distress.
This bankruptcy appeal arose from a dispute over income generated by a spendthrift trust created under Ronald Reagan's will for the benefit of his widow, Cheryl Reagan, after she filed for Chapter 11 protection. The bankruptcy court had ruled that both present and future trust distributions were payable to Mrs. Reagan personally rather than becoming property of her bankruptcy estate. The district court affirmed, holding that the spendthrift restriction on transfer was enforceable under Arkansas law and thus excluded the beneficial interest from the estate pursuant to 11 U.S.C. § 541(c)(2). It further concluded that the trustee had identified no statutory basis for including the income stream itself in the estate and rejected arguments that Patterson v. Shumate required a different result. The court found no clear error in the bankruptcy court's factual determinations regarding the timing of distributions.
This case involved ERISA claims by participants in an employee stock ownership plan against the FDIC, acting as receiver for a failed bank, alleging breaches of fiduciary duties of prudence and loyalty for allowing the plan to hold the bank's stock amid risky practices. The FDIC moved to dismiss for lack of subject matter jurisdiction due to the plaintiffs' failure to exhaust administrative remedies under FIRREA by filing timely proofs of claim before the claims bar date. The court granted the motion and dismissed the claims against the FDIC with prejudice, holding that FIRREA's exhaustion requirement is a jurisdictional bar, that the plaintiffs' claims accrued before the bar date, and that arguments for equitable tolling or estoppel did not apply based on the facts and Eighth Circuit precedent. The court also rejected the claim that the FDIC was a necessary party under Rule 19.