This case involves an insurance company's subrogation claim against the manufacturers of an electric heater and its thermal control component, seeking recovery for payments made after a home fire allegedly caused by the heater. The court denied in part Square D Company's motion for summary judgment, finding triable issues on whether the heater had a design defect, but granted summary judgment to Square D on claims based on failure to warn. It granted Therm-O-Disc's motion for summary judgment in full, concluding that the plaintiff lacked evidence showing the thermal control was defective or that the company breached any duty of care. The rulings rested on the plaintiff's experts failing to identify defects, establish causation, or provide sufficient proof under products liability standards for negligence or strict liability.
The case involved a plaintiff obstetrician-gynecologist who sought short-term and long-term disability benefits from defendant Standard Insurance Company after suffering pancreatitis during pregnancy and undergoing gallbladder removal surgery; her claim was initially denied but partially reversed for four days of benefits. After filing suit under ERISA, which was removed to federal court, the court addressed motions regarding the record and judgment. The court denied the plaintiff's motion to supplement the record and granted the defendant's motion for judgment, finding that the denial of benefits was reasonable and supported by substantial evidence under the arbitrary and capricious standard, as medical records lacked objective findings supporting disability beyond the plaintiff's subjective complaints of fatigue.
healthcarebusiness & regulatorylabor & employmentfederal power
The case involved a plaintiff who filed state-law claims in New Mexico state court against Standard Insurance Company and its agent Dan Cobb for denial of disability benefits under employer-provided insurance policies. Standard removed the action to federal court on the ground that the claims were governed by ERISA rather than state law. The court held that the policies met all elements of an ERISA employee welfare benefit plan, thereby creating federal subject-matter jurisdiction and preempting the state claims. It granted Cobb's motion to dismiss the claims against him individually, partially granted and denied Standard's motion regarding extra-contractual damages, and denied the plaintiff's motion to amend the complaint as futile.
This case concerns non-union public employees of the City of Albuquerque who challenged the union's collection of fair share fees from them, alleging deficiencies in the required notice and improper inclusion of certain expenses. On remand from the Tenth Circuit, the district court granted the plaintiffs' motion for partial summary judgment in part, holding that the original fee notice violated their rights because it lacked independent auditor verification and a proper report as required by Hudson, though nominal damages had already been awarded for this. The court further found that the defendants failed to prove which portions of the fees were chargeable for collective bargaining purposes, entitling the plaintiffs to a full refund, and ruled that the union's indemnification of the city for related liabilities was void as contrary to public policy.
This case, a class action by non-union public employees, arises from the same facts as Wessel v. City of Albuquerque and challenges the adequacy of notices for fair share fees deducted from non-members, along with related indemnification clauses in union agreements with the City of Albuquerque. The court granted partial summary judgment to the plaintiffs, declaring that the original notices violated their constitutional rights by omitting independent auditor verification and proper allocation details, awarding nominal damages of one dollar, voiding the indemnification clauses, and ordering refunds of collected fees. It denied summary judgment on punitive damages and certain other claims, finding genuine issues of material fact regarding the defendants' efforts to protect non-members' rights. The decisions rest on Tenth Circuit precedent from Wessel, which applied Chicago Teachers Union v. Hudson requirements for sufficient notice to allow non-members to object to fees, and on the plaintiffs' status as a separate class not bound by the prior suit's limits on relief.
This case involved rig hands who worked on oil and gas wells suing their employer, Aztec Well Servicing Co., under the Fair Labor Standards Act for unpaid compensation for travel time to and from well sites, including overtime when travel extended their workweeks beyond 40 hours. After a jury returned a verdict for the plaintiffs, the court granted the defendant's renewed motion for judgment as a matter of law, vacating the prior judgment on liability. The court determined that the Portal-to-Portal Act excludes from compensation time spent traveling to and from the actual place of performance of principal activities, as well as preliminary or postliminary activities, unless they are integral and indispensable to those activities. The evidence, viewed in the light most favorable to the plaintiffs, showed only that the workers were sometimes required to travel with their supervisors and performed no compensable work en route, making the travel an ordinary, non-compensable incident of employment.
