In United States v. Malloy, the defendant, a 33-year-old man, was convicted under 18 U.S.C. § 2251(a) for producing a videotape depicting himself and another adult engaging in sexual activity with a 14-year-old girl, with the visual depiction using materials transported in interstate commerce. Malloy appealed, arguing that the statute exceeds Congress's Commerce Clause authority, that it should be interpreted to include a reasonable mistake-of-age defense, and that his 15-year mandatory minimum sentence violates the Eighth Amendment. The Fourth Circuit affirmed the conviction and sentence, holding that the production of child pornography is part of an economic class of activities with a substantial effect on interstate commerce, that the statute does not require a mistake-of-age defense given its purpose to protect minors, and that Eighth Amendment proportionality review does not apply to sentences less than life without parole.
This case involves the conviction of defendant Moose for trafficking in cocaine based on evidence obtained from a search of his business premises. The police obtained a search warrant relying on information from a first-time informant whose details were verified, and during the search, the defendant directed officers to the location of nearly a kilogram of cocaine. On appeal, the defendant challenged the nondisclosure of the informant's identity, certain jury instructions, and other procedural aspects of the trial. The court found no violations of his constitutional rights or errors in the proceedings, reasoning that the informant was merely a tipster not entitled to disclosure and that the trial court's rulings were proper. The appellate court affirmed the judgment and sentence of thirty-five years imprisonment.
The case concerned whether Atlantic Tobacco Co. could pierce the corporate veil of two insolvent companies, Honeycutt Truck Stop, Inc. and Hassman Enterprises, Inc., to hold Joseph and Barbara Honeycutt personally liable for unpaid debts. The trial court had directed verdicts for both defendants, but the appeals court held that the directed verdict was proper only as to Barbara Honeycutt because the evidence showed no domination or control by her over the corporations. As to Joseph Honeycutt, who was president and sole shareholder, the court found sufficient evidence of complete control, commingling of corporate funds to pay personal mortgages, and resulting depletion of assets available to creditors, so the claim should have gone to the jury under the mere instrumentality rule. The judgment was therefore affirmed in part and reversed and remanded in part.
The case involved William Shaffner, a long-term Westinghouse employee who sustained a back injury while lifting a motor at work in April 1987, filed a workers' compensation claim, and was later terminated in June 1987 for alleged misrepresentation regarding the extent of his disability after the company learned he had attended an amusement park. Shaffner sued for wrongful discharge, claiming retaliation for instituting the workers' compensation proceeding in violation of N.C. Gen. Stat. § 97-6.1. The jury found in favor of the employer, determining that the termination was not because of the claim, and the trial court denied Shaffner's motion for judgment notwithstanding the verdict. On appeal, the court affirmed, holding that there was no close temporal connection between the claim and the firing, that the employer challenged the extent rather than the fact of the disability, and that the evidence supported the jury's verdict when viewed in the light most favorable to the defendant.
This case involved a workers' compensation claim by an employee of Duke University Medical Center who suffered a back injury on the job in 1986 and sought temporary total disability benefits. The employer appealed the Industrial Commission's award, arguing there was insufficient evidence that the employee could earn no wages, that findings on the extent and permanency of disability were inadequate, and that the findings did not support the benefits conclusion. The Court of Appeals affirmed the award, holding that the Commission had exclusive fact-finding authority and that competent evidence from physicians, a vocational counselor, a supervisor, and the employee himself supported the finding of total wage-earning incapacity caused by the injury. The court further reasoned that the Commission properly applied the burden of proof and that no specific termination date was required for temporary total disability benefits given the uncertain duration of such claims.
This case involved plaintiffs suing a hospital, doctors, and an anesthesiologist for medical malpractice, alleging negligence in recommending and administering electroconvulsive therapy (ECT) that caused hip fractures, along with related failures in documentation, advice, and precautions; a spouse also claimed loss of consortium. The trial court granted summary judgment to the hospital and later dismissed the remaining claims against other defendants for failure to prosecute after the plaintiffs refused to proceed to trial. The appeals court affirmed both rulings, holding that the interlocutory appeal from the partial summary judgment did not stay the other claims and that the hospital's conduct was not a proximate cause of the injuries because the treating physicians already knew of the patient's pain complaints from direct communications. The court also determined that the issues against each defendant were severable, supporting the dismissal under procedural rules.
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