The case involved Zotos International, a cosmetics manufacturer, which sought to exempt a chemical ingredient used in its products from FDA-mandated labeling disclosure under the Fair Packaging and Labeling Act by claiming trade secret status. After a lengthy administrative process, the FDA denied the exemption, concluding based on cited publications and patents that the ingredient and its use were not confidential. Zotos challenged this denial in court under the Administrative Procedure Act, and the district court granted summary judgment to the plaintiff on Count II. The court held that the FDA's determination was arbitrary and capricious because the agency failed to provide adequate notice of the evidence it relied upon or a sufficient opportunity for Zotos to respond before final agency action.
The case involved a former employee of Arabian national origin who sued his employer for alleged discrimination in employment decisions including promotions, pay, and termination, bringing claims under Title VII of the Civil Rights Act of 1964 and various other constitutional and statutory provisions. The court granted the employer's motion to dismiss the Title VII claims based on race, color, religion, and sex because those grounds were not raised in the EEOC complaint, and it dismissed most other claims for lack of jurisdiction, failure to exhaust administrative remedies, or failure to state a viable cause of action. The court permitted the plaintiff to proceed on certain national origin claims under Title VII and Section 1981 only if he filed a more definite statement specifying the facts, and it struck requests for punitive damages and a jury trial on the Title VII claims. The core reasoning was that administrative exhaustion requirements limit the scope of judicial claims and that the cited provisions do not support the alleged bases of discrimination or relief.
This case concerned a request for attorney's fees, costs, and expenses after a successful sex discrimination claim under Title VII of the Civil Rights Act of 1964 was resolved at the administrative level before the Department of the Interior. The district court held that federal administrative agencies have discretion to award such fees in Title VII cases, endorsing the analysis in Smith v. Califano. However, the court declined to decide the amount or appropriateness of fees itself, citing its lack of firsthand knowledge of factors like case complexity and attorney skill, and instead remanded the matter to the agency for initial resolution. The ruling noted that the agency's prior reluctance to award fees was understandable given prior uncertainty but that the path was now clearer following recent precedent.
This FOIA case involves the St. Louis Post-Dispatch and its Washington bureau chief seeking disclosure of FBI investigatory files compiled over a decade, including those related to phone record subpoenas issued during a 1971 grand jury probe into the Pentagon Papers leak. The defendants withheld 68 documents or portions under multiple exemptions, including those for national security, confidential sources, and privacy. Plaintiffs challenged the withholdings and sought in camera review, while defendants moved for summary judgment. The court ruled that in camera inspection of the documents is warranted on a case-by-case basis to enable de novo assessment of the exemption claims, given the plaintiffs' credible challenges and the availability of public Vaughn indices to guide the review.
The case involved importers seeking refunds of a 10% supplemental duty on dutiable imports collected under Presidential Proclamation 4074, issued in August 1971 to address a balance-of-payments crisis during a declared national emergency. Defendants moved to dismiss the suits for lack of subject-matter jurisdiction. The court granted the motion, holding that the U.S. Customs Court possessed exclusive jurisdiction under 28 U.S.C. § 1582 because the claims concerned the classification, rate, and amount of duties and related exactions within the Secretary of the Treasury’s authority. The court noted that the statutory language, the surcharge’s integration with existing tariff schedules, and Congress’s subsequent enactment of specific surcharge authority in the Trade Act of 1974 all confirmed the Customs Court’s exclusive role, leaving no jurisdiction in district court even for plaintiffs who had not filed timely administrative protests.
In Lucas v. United States, plaintiff Theodore Lucas sued the federal government under the Federal Tort Claims Act for assault, battery, false arrest, and personal injury, seeking damages after deputy U.S. Marshals arrested him outside a highly secured Superior Court courtroom during a murder trial involving Black militants. The court, after a bench trial, entered judgment for the United States and dismissed the case. It found that Deputy Parker had approached Lucas while investigating a potential security breach near the courtroom, that Lucas became belligerent and physically grabbed the deputy causing him to lose balance, and that this conduct gave the deputies probable cause to arrest Lucas for assaulting a federal officer. The court reasoned that the arrest was made in good faith during official duties, that Lucas was aware Parker was a marshal, and that under D.C. common law the United States could not be held liable on a respondeat superior theory when the arresting officers themselves would not be liable.