This case involved an employee terminated by Chrysler Corporation after being arrested for allegedly stealing a spare tire from a company car, with charges later dismissed; the employee sued the UAW for breaching its duty of fair representation in handling his grievance and Chrysler for breaching the collective bargaining agreement. The court granted summary judgment to both defendants and denied the plaintiff's motions to amend the complaint or add the local union as a defendant. The core reasoning was that the plaintiff failed to exhaust internal remedies under the UAW constitution before filing suit, even though his failure to exhaust contractual remedies was excused by the expiration of the 90-day reinstatement period; statements from union officials did not provide a valid excuse for bypassing these procedures, and adding the local union would be futile for similar reasons.
The case involved an appeal from a bankruptcy court's dismissal of a complaint seeking a determination that attorney's fees awarded in a divorce decree were non-dischargeable in bankruptcy. The district court reversed that ruling and held the fees nondischargeable. It reasoned that under Section 17(a)(7) of the Bankruptcy Act, such fees qualify as alimony, maintenance, or support, drawing on Michigan case law defining alimony and decisions from other circuits applying analogous state laws.
This case involved a union and its fringe benefit funds seeking to enforce a default judgment against Leto Construction Company by garnishing accounts receivable owed to Leto by third parties. City National Bank, which held a perfected security interest in Leto's accounts receivable under Michigan's Uniform Commercial Code, intervened and successfully moved to quash the garnishments on the ground that its interest had priority over the plaintiffs' lien creditor status. On rehearing, the court reconsidered its prior ruling in light of the Michigan Supreme Court's decision in National Bank of Detroit v. Eames and Brown, Inc., which interpreted the Michigan Builders Trust Fund Act to create a trust for laborers and materialmen that attaches upon constructive payment and generally takes priority over security interests unless the creditor proves its loaned funds were actually used to pay such laborers. The court therefore granted rehearing, reversed its earlier order quashing the writs, and allowed the bank twenty days to petition for a hearing to demonstrate that its funds had been used for the protected purposes; absent such a showing, the garnishments would be upheld.
This diversity case involves a former Ford employee suing John Hancock Mutual Life Insurance for disability benefits under a group policy, with claims for breach of contract, intentional infliction of emotional distress, and breach of fiduciary duty. The court granted the insurer's motion for partial summary judgment, dismissing the two tort counts. Under Michigan law, damages for emotional distress are not recoverable in a breach of contract action involving a commercial insurance policy, and the plaintiff failed to allege facts showing tortious conduct independent of the contract breach or supporting a fiduciary duty claim, as the insurer-insured relationship is not fiduciary and the allegations amounted to mere legal conclusions. The breach of contract count remains for further proceedings.
This case involved Medicare beneficiaries who were denied coverage for portions of inpatient hospital care after their treating physicians and hospital review committees had initially certified the care as medically necessary. The plaintiffs argued that the Secretary of Health, Education, and Welfare could not override those certifications without first providing notice and a hearing, and they sought class certification along with summary judgment. The court held that jurisdiction existed under 42 U.S.C. § 405(g) because the constitutional claim was collateral to the benefits claim and the denial created a colorable risk of irreparable harm. It certified the case as a class action and ruled for the plaintiffs, finding that the Social Security Act and the Fifth Amendment's due process clause require a pretermination hearing before denying vested benefits in this context, distinguishing the facts from Mathews v. Eldridge due to the plaintiffs' advanced age and limited resources.
The case involved a truck driver discharged by Ellis Trucking for allegedly failing to follow instructions; after losing grievances through arbitration and an unsuccessful NLRB complaint, he sued the employer for breach of the collective bargaining agreement (lack of required warning letter) and the union for breach of the duty of fair representation and conspiracy, alleging collusion and inadequate handling of his grievance. The court granted the defendants' motions to dismiss the amended complaint. It held that the first count was barred as a matter of law because the arbitrator's decision was final and binding under the CBA and federal precedent. The second and third counts were dismissed as untimely under Michigan's three-year statute of limitations for tort claims, which the court applied to fair-representation and conspiracy allegations arising from the union's conduct in arbitration.
