In Greene v. Palakovich, petitioner Eric Greene sought federal habeas corpus relief after his 1996 state conviction and life sentence for second-degree murder, robbery, and conspiracy arising from a 1993 store robbery and killing. The court considered a magistrate judge's report and recommendation that denied Greene's multiple claims but proposed granting a certificate of appealability solely on his Sixth Amendment confrontation clause challenge to the admission of redacted confessions from non-testifying co-defendants at his joint trial. Overruling the respondents' objections on grounds including the applicability of Gray v. Maryland, harmless error, and procedural exhaustion, the court approved and adopted the report in full, thereby denying the habeas petition while issuing the certificate of appealability on that single claim because reasonable jurists could disagree on the merits under AEDPA standards.
In this case, plaintiff Brenda Schwartz sued her employer Citizens Financial Group and plan administrator Liberty Life Assurance Company of Boston under ERISA after her short-term disability benefits were terminated retroactively, alleging she was unable to work due to multiple sclerosis and related conditions. The defendants moved for summary judgment, arguing that the court lacked subject matter jurisdiction because Citizens' self-funded short-term disability plan was not an employee welfare benefit plan covered by ERISA but instead qualified as a payroll practice exempt from the statute. The court agreed after reviewing the plan documents, funding source from general assets, and lack of insurance features, granting defendants' motion and dismissing the action with prejudice while denying the plaintiff's cross-motion. The decision turned on the absence of ERISA applicability rather than the merits of the benefits denial or procedural fairness claims.
Marie Gallagher sued Sunrise Assisted Living under the Americans with Disabilities Act, claiming that her allergies to facility pets constituted a disability and that the employer failed to accommodate her by keeping animals away from her work area, resulting in her constructive discharge. The court granted the defendant's motion for summary judgment. It concluded that Gallagher was not disabled under the ADA because her allergies did not substantially limit a major life activity such as breathing, and that she failed to establish a prima facie retaliation claim due to lack of protected activity or adverse employment action.
Plaintiffs owned a multi-unit dwelling that had been subdivided into apartments before a 1979 township zoning ordinance restricted the area to single-family detached dwellings; after state courts upheld enforcement against them and denied nonconforming-use status, plaintiffs sought to limit the units to family use only, which the township rejected while pursuing daily fines in ongoing state litigation. Plaintiffs then filed a federal action under the Fourteenth Amendment, seeking declaratory and injunctive relief to halt the state proceedings on due-process grounds. The court granted the township’s motion to dismiss, holding that the Younger abstention doctrine required federal courts to refrain from interfering with the parallel state enforcement action, which implicated important state interests in zoning and provided an adequate forum for constitutional claims without any showing of bad faith or extraordinary circumstances.
The case involved a student diagnosed with Tourette’s Syndrome who sued the Neshaminy School District under the Individuals with Disabilities Education Act (IDEA), 42 U.S.C. § 1983, and § 504 of the Rehabilitation Act, alleging an improper suspension without a required manifestation determination, repeated failure by the district to participate in scheduled due process hearings, and noncompliance with a hearing officer’s order for out-of-district placement and services. The district moved to dismiss the complaint, primarily arguing that the plaintiff had not exhausted administrative remedies under IDEA and that the other claims were likewise barred. The court denied the motion, holding that the allegations sufficiently pleaded futility of exhaustion due to the district’s conduct and that the plaintiff had stated viable claims under all three statutes when the facts were taken as true.
In this case, plaintiff Michael Henderson sued Nationwide Mutual Insurance Company for breach of contract and statutory bad faith after the insurer denied his claim for theft coverage on a damaged BMW, alleging the denial involved racial bias and unreasonable investigation. The defendant moved to dismiss the entire complaint for lack of subject matter jurisdiction under diversity rules and to dismiss the bad faith count for failure to state a claim. The court denied both motions. It held that the amount in controversy requirement was satisfied because the complaint's good-faith demand for over $100,000 could include punitive damages and other relief available under Pennsylvania's bad faith statute if racial discrimination were proven. It also found the complaint alleged sufficient facts to state a viable bad faith claim.
