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Decision levers
AI-measured from their own opinions — each lever cites its cases
Willing to revisit precedentStrong stare decisis
In Generale Bank the court enforced a forum-selection clause by directly applying and following Supreme Court precedents on fundamental fairness without questioning their validity. Generale Bank, New York Branch v… ↗
PurposivismTextualism
In Travelers Insurance the court applied ERISA's preemption provision based on whether surcharges related to employee benefit plans, and in NBC v. SBA it parsed FOIA exemptions according to their statutory criteria. Travelers Insurance v. Cuomo ↗ National Broadcasting Co. v. Uni… ↗
Deference to government powerSkepticism of government power
In Travelers Insurance the court preempted state hospital surcharges under federal ERISA and FEHBA rather than deferring to state regulatory choices, and in NBC v. SBA it required production of one agency document after finding exemptions inapplicable. Travelers Insurance v. Cuomo ↗ National Broadcasting Co. v. Uni… ↗
In this case, landlord Billy Williams sued the City of Newburgh, its Community Development Agency, and agency employee Barbara Jacobs over events following his participation in a Section 8 housing rehabilitation program. Williams alleged breach of an agreement to refer tenants, a violation of his procedural due process rights under 42 U.S.C. § 1983, and tortious interference with his lease agreements after Jacobs reported another tenant's unreported income, leading to lost subsidies, foreclosures, and his eviction of Jacobs for nonpayment. A jury awarded Williams $9,600 on the tortious interference claim but rejected his other claims. The court denied the defendants' motion for judgment as a matter of law, finding sufficient evidence supported the jury's verdict on interference, and denied Williams's motion for a new trial, finding no basis to overturn the rejection of the § 1983 claim or the damages amount. The decision rested on the strict standards for setting aside verdicts and the lack of evidence of jury bias or perjury.
This case involves related fraud actions brought by investors in certain real estate partnerships against the entities that created and managed the partnerships along with various professionals involved. The defendants moved to disqualify plaintiffs' counsel and dismiss the complaints on the grounds that the complaints relied heavily on confidential information improperly obtained from Hirschhorn, who had served as in-house counsel to several defendants. The court granted the motions, disqualifying plaintiffs' counsel from further participation and dismissing both actions without prejudice. The core reasoning was that Hirschhorn's disclosures to plaintiffs' attorneys violated the Code of Professional Responsibility by revealing client secrets to the direct disadvantage of his former clients, and that the attorneys' use of that information warranted disqualification and dismissal.
This case involves an appeal by a law firm, Shaw, Licitra, and Travelers Indemnity Company from a bankruptcy court order awarding the firm $26,687.50 in attorneys' fees under 11 U.S.C. § 506(c) for services benefiting the secured creditor in a Chapter 11 proceeding concerning a debtor's building and assigned rents. The bankruptcy court also required the firm to return the remaining balance of a $50,000 retainer to Travelers. The district court affirmed the order, holding that the bankruptcy court did not abuse its discretion in calculating the fees due under the statute.
In DuFort v. Aetna Life Insurance, plaintiff Harvey DuFort sued Aetna and its employee for breach of a disability insurance policy, bad faith, and intentional infliction of emotional distress after Aetna discontinued benefits for his claimed back condition. The defendants moved for summary judgment, arguing that all claims were barred by a March 1989 general release DuFort signed as part of a $102,000 settlement. The court granted the motion in part and denied it in part, finding that the release precluded some claims but that factual issues regarding economic duress and mental incompetence at the time of signing prevented full dismissal. The core reasoning focused on whether DuFort had established incompetence as a matter of law to void the release and on the applicability of rescission requirements in this context.
This case involved challenges by insurance companies and associations to New York statutes that imposed 13%, 11%, and 9% surcharges on hospital rates paid by commercial insurers, self-insured plans, and HMOs, along with a related Department of Insurance interpretive letter. Plaintiffs argued that these measures were preempted by the federal ERISA and FEHBA statutes. The court granted plaintiffs' summary judgment motion in part and denied defendants' cross-motion, ruling that the Tax Injunction Act did not bar the claims, that all three surcharges were preempted by ERISA, that the 11% and 13% surcharges were also preempted by FEHBA, and that parts of the interpretive letter were preempted by ERISA. The core reasoning was that the surcharges directly related to employee benefit plans regulated by ERISA and had more than a tangential effect on them, triggering federal preemption under the statute's broad provisions, while FEHBA similarly displaced conflicting state requirements for federal employee plans.
In this case, NBC filed a FOIA request seeking access to ten specific SBA documents concerning the financial transactions and operations of SBICs Wood River and Bridger and the company Apex they financed. The SBA withheld the documents under multiple FOIA exemptions, including Exemption 4 for confidential commercial and financial information and Exemption 5 for deliberative process materials. After in camera review, the court held that Documents 1-4 and 6-10 qualified for exemption because their disclosure would impair the government's ability to obtain similar information or reveal internal agency deliberations, while Document 5 did not meet the criteria for any claimed exemption and must be produced. The court therefore granted the parties' cross-motions for summary judgment in part and denied them in part.