Jon Ernest DeGuilio

In Steeno v. Wabash National Trailer Centers, plaintiff Charles Steeno sued his former employer under the Age Discrimination in Employment Act after being terminated at age 72 from his position as Southeast Regional Used Trailer Director. The company, facing significant financial losses in 2008 and 2009, implemented cost-cutting measures including the termination of salaried employees across locations. Supervisors selected Steeno for termination over a 65-year-old colleague with similar duties because Steeno had a higher salary, aiming to maximize savings, and his duties were absorbed by remaining employees. The court granted the defendant's motion for summary judgment, finding that Steeno established a prima facie case of age discrimination but failed to demonstrate that the company's economic rationale was a pretext for discrimination.

labor & employmentcivil rights

In Matthys v. Wabash National, plaintiff Christina Matthys sued her employer for interfering with her rights under the Family and Medical Leave Act by denying leave requests, retaliating against her for seeking FMLA leave, and retaliating for filing a workers' compensation claim after a workplace injury. The court granted the employer's motion for summary judgment on all claims. It reasoned that Matthys was ineligible for FMLA protection because she had not worked the required 1,250 hours in the prior year, that Wabash made no assurances creating estoppel, and that she failed to show causation or pretext linking her termination to protected activity under either federal or state law. The ruling disposed of the case after addressing procedural motions to strike and exercising supplemental jurisdiction over the state claim.

labor & employmenthealthcareprocedure

The case involves a negligence lawsuit brought by Michael Carroll, as guardian for Joshua Carroll, against truck driver Calvin Kamps and several companies after Joshua suffered a severe brain injury in a 2007 accident on an Indiana highway. The claims against High Lean Pork, Inc. centered on vicarious liability, with the plaintiff arguing that Kamps was either High Lean's employee under common-law factors or that federal motor carrier regulations imposed liability due to the parties' trucking agreement. High Lean moved for summary judgment, asserting it was not Kamps' employer and had no regulatory responsibility, while the plaintiff filed a cross-motion. The court examined the contract terms showing High Lean as the lessor of its trailer to T&L Trucking (Kamps' employer), the limited control exercised by High Lean, and precedents applying liability primarily to lessees operating under ICC authority, concluding that the federal regulations did not apply and that genuine issues of fact or legal standards precluded statutory employer status for High Lean.

torts & liabilitybusiness & regulatorylabor & employment

The case involved Medical Assurance seeking a declaratory judgment that it had no duty to defend or indemnify Dr. Miller in a medical malpractice lawsuit filed by the Knights, due to Miller's failure to cooperate with his appointed defense counsel as required by his malpractice insurance policy. The court granted Medical Assurance's motion for summary judgment, holding that Miller breached the policy's cooperation clause by ceasing all communication with counsel starting in spring 2006, ignoring multiple letters and court orders, and remaining unreachable despite the insurer's efforts to locate him. This non-cooperation caused material prejudice to Medical Assurance, including the entry of a default judgment against Miller. The court found no genuine issue of material fact, rejecting arguments that Miller's sinus issues or unproven mental health problems excused his obligations, as there was no admissible evidence of any diagnosed condition affecting his capacity.

proceduretorts & liabilitybusiness & regulatory

In Copeland v. Astrue, Ramona Copeland sought judicial review under 42 U.S.C. § 405(g) of the Social Security Administration's denial of her applications for Disability Insurance Benefits and Supplemental Security Income, alleging disability beginning March 2005 due to chronic back pain, arthritis, and depression. The district court affirmed the ALJ's decision that Copeland was not disabled, concluding she retained the residual functional capacity to perform light work with a sit-stand option and other jobs existing in significant numbers in the national economy. The court reasoned that the ALJ properly discounted the treating physician's opinion of total disability as internally inconsistent and unsupported by objective medical evidence such as x-rays and treatment notes, while crediting other evidence showing only moderate limitations and favorable responses to treatment.

federal powerprocedurehealthcare

In this case, Dr. Charles Bayless sued Ancilla Domini College alleging that his 2007 removal from the Humanities Division Chair position and subsequent non-renewal of his teaching contract violated the Age Discrimination in Employment Act and that the college retaliated against him in violation of Title VII. The district court granted the college's motion for summary judgment on both claims. The court held that Bayless failed to establish a prima facie case of age discrimination because he could not show he was meeting the employer's legitimate expectations or that similarly situated younger employees were treated more favorably, and the college's stated reasons for the decisions—such as unsatisfactory performance reviews, complaints from students and staff, and inadequate leadership—were not shown to be pretextual. On the retaliation claim, the court found no evidence that Bayless had engaged in protected activity or that any such activity was causally linked to the adverse actions.

labor & employmentcivil rights

This case concerns the National Labor Relations Board's request, via its Regional Director, for temporary injunctive relief under Section 10(j) of the National Labor Relations Act against Irving Ready-Mix Inc. while administrative proceedings were pending. The Director alleged that Irving committed unfair labor practices during negotiations with the union representing its ready-mix concrete delivery drivers after their collective bargaining agreement expired in 2010. The district court reviewed the administrative record, including an ALJ's decision finding most violations, along with facts about the company's operations and bargaining sessions, and applied standards for determining whether an impasse existed or rights were waived. The court addressed the legal framework for granting such relief to maintain the status quo pending the Board's final ruling.

labor & employmentprocedure