The case involved a federal prisoner's request to extend the one-year deadline under the Antiterrorism and Effective Death Penalty Act (AEDPA) for filing a motion to vacate his sentence pursuant to 28 U.S.C. § 2255 after his 1994 armed robbery convictions became final in October 1996. The court denied the motion for a 60-day extension, finding that the defendant had not demonstrated "extraordinary circumstances" beyond his control that made it impossible to file on time, as required for equitable tolling of the AEDPA's statute of limitations. The defendant's cited reasons—limited access to transcripts and prison lockdowns restricting library time—were deemed insufficient, as he had ample prior opportunity to prepare and the issues were within his control. The ruling emphasized that the AEDPA's one-year limit, running from the finality of conviction, is subject to tolling only in exceptional cases per Ninth Circuit precedent.
This case is a putative class action alleging race discrimination in employment, in which four African-American employees of Walt Disney World claimed that Disney had a pattern and practice of failing to promote them to supervisory positions. Multiple similar employment discrimination suits were pending in the same district, and plaintiffs in one of them had moved before the Judicial Panel on Multidistrict Litigation to transfer and consolidate all the cases. The plaintiffs here moved to stay pretrial proceedings, including class certification discovery, until the MDL Panel ruled. The court granted the stay, relying on its inherent authority to manage its docket for judicial economy and efficiency, after finding that a stay would conserve resources if consolidation occurred, that the defendant had not shown prejudice, and that any delay would be brief.
This case involved a dispute between two creditors, Thomas C. Thompson Sports, Inc. (TCT) and Farmers & Merchants Bank, over priority to approximately $249,000 in funds that Championship Auto Racing Teams (CART) owed to bankruptcy debtor Norman Turley after redeeming his one share of CART stock. The bankruptcy court granted summary judgment to the Bank, and the district court affirmed. The court held that the interpleaded funds constituted proceeds of a certificated security rather than a general intangible arising from a franchise agreement. It reasoned that the Bank had perfected its security interest by taking physical delivery of the CART stock certificate pursuant to a pledge agreement, whereas TCT had not obtained possession of the certificate despite its own security agreement and financing statement covering general intangibles. The decision turned on the characterization of the collateral under the Uniform Commercial Code and the requirements for perfecting an interest in certificated securities.
This case involved a former U.S. Postal Service employee who sued under the Rehabilitation Act, alleging she was terminated due to a foot injury that limited her ability to perform mail carrier duties. The employer countered that the termination resulted from the employee lying on her pre-employment medical questionnaire and misrepresenting the severity of her injury, as shown by surveillance video and witness statements indicating she could walk without a limp. The court applied the burden-shifting framework for employment discrimination claims, finding that the employer had produced evidence of legitimate, nondiscriminatory reasons for the firing. Summary judgment was granted to the defendant because the plaintiff failed to present sufficient evidence creating a genuine issue of material fact that those reasons were a pretext for discrimination. A separate sexual harassment claim had been voluntarily dismissed earlier.
This case involved a state prisoner who sued Los Angeles County Sheriff Sherman Block under 42 U.S.C. § 1983, alleging that conditions at the County Jail, including overcrowding and exposure to inmates with tuberculosis, along with denial of medical testing, violated his Eighth Amendment rights against cruel and unusual punishment. The district court reviewed the magistrate judge's amended report and recommendation and granted the defendant's motion for summary judgment. The court determined that the plaintiff failed to present evidence showing deliberate indifference by the defendant or the existence of an unconstitutional policy or custom. Judgment was entered in favor of defendant Block, as there was no genuine issue of material fact regarding an Eighth Amendment violation.
In Hill v. Ralphs Grocery Co., over 250 former employees of Ralphs Grocery sued the company, its managers, and their union (Local 37) after being laid off or terminated due to the 1993 closure of the company's central bakery plant, claiming breach of the collective bargaining agreement under Section 301 of the LMRA, breach of the union's duty of fair representation, fraud, conspiracy, WARN Act violations, and other claims. The district court granted Ralphs' motion for summary judgment on the breach of contract claim, ruling that the agreement did not prohibit the plant closure because it expressly contemplated such an event through its severance pay provisions and included no language barring shutdown before the three-year term ended. The court applied Federal Rule of Civil Procedure 56 standards, finding no genuine issue of material fact on that claim or others where the agreement's terms controlled, while denying the union's motion for summary judgment on several remaining causes of action.