Claude M. Hilton

The case involved Northern Trust Bank suing Wells Fargo Bank over an $8 million loan repayment made by debtor El-Atari to Wells Fargo using funds borrowed from Northern Trust, after El-Atari's bankruptcy filing. The court granted Wells Fargo's motion for summary judgment and dismissed the case. The core reasoning was that Northern Trust, as a creditor, lacked standing to pursue claims challenging the transfer because those claims belonged to the bankruptcy estate under Fourth Circuit precedent in National American Insurance Co. v. Ruppert Landscaping Co., and only the bankruptcy trustee could assert them regardless of the legal theory.

procedurebusiness & regulatory

The case concerned whether The Medicines Company timely filed a patent term extension application for its anticoagulant drug ANGIOMAX under the Hatch-Waxman Act after receiving FDA approval. The court held that the application was timely, interpreting the 60-day filing period under 35 U.S.C. § 156(d)(1) to begin on the next business day following the FDA's after-hours transmission of the approval letter on December 15, 2000. The reasoning focused on the statute's remedial purpose to compensate for regulatory delays, consistency with the FDA's own business-day practices for submissions, the need for fair notice to applicants, and ensuring patent holders receive the full period Congress intended.

business & regulatoryhealthcare

The case involves a plaintiff suing a grocery store operator for negligence after she slipped and fell in a store aisle in 2005, claiming she was injured by sugar, flour, or a lollipop stick on the floor. The court granted the defendants' motion for summary judgment. The core reasoning was that the plaintiff failed to make a prima facie case of negligence, as she did not know what caused her fall, had not seen or felt any hazard before falling, could only speculate about any dangerous condition, and provided no evidence that any such condition proximately caused her injuries.

torts & liability

The case involved homeowners who defaulted on two mortgage loans originated to purchase property in 2006 and who filed suit just before a scheduled foreclosure, seeking declaratory judgment and quiet title on grounds that note transfers through securitization split the notes and deeds of trust, that credit enhancements or swaps would produce an unlawful double recovery, and that no party had authority to foreclose. The district court granted summary judgment to the defendants. The court reasoned that the first note was validly endorsed and transferred, MERS properly assigned deed-of-trust rights to the servicer Litton, Litton held authority to collect and foreclose under Virginia law, and the plaintiffs' securitization-splitting and double-recovery theories had no basis in statute or precedent because credit default swaps are separate contracts and foreclosure by trustees of securitized mortgages is routine.

propertybusiness & regulatory

The case was a challenge under the Administrative Procedure Act to the Patent and Trademark Office's denial of a patent term extension application for the anticoagulant drug ANGIOMAX, filed by The Medicines Company under the Hatch-Waxman Act. The PTO denied the extension as untimely, accepting the FDA's determination that approval occurred on December 15, 2000, which started the 60-day filing clock under 35 U.S.C. § 156(d)(1) one day before the February 14, 2001 submission. The court vacated the PTO's decision and remanded for reconsideration, holding that the PTO had independent authority to interpret the distinct statutory trigger of when the product "received permission" for commercial marketing and was not bound by the FDA's approval date analysis under § 156(g)(1)(B)(ii).

business & regulatoryhealthcarefederal powerprocedure

The case involved Citigroup suing a Chinese resident who registered and used the domain name citybank.org to provide links to financial services and receive compensation from third-party vendors, claiming a violation of the Anticybersquatting Consumer Protection Act. The court granted the plaintiff's motion for summary judgment, finding the defendant liable for registering and using the domain name. The decision rested on evidence that the defendant had a bad faith intent to profit from the domain, including its commercial use for click-through revenue without any rights to the marks, and that citybank.org was confusingly similar to Citigroup's distinctive and famous CITI and CITIBANK trademarks used for banking services. The court awarded the maximum statutory damages of $100,000, attorneys' fees, and a permanent injunction against further infringement.

business & regulatory

This case involved high school students suing iParadigms, LLC, operator of the Turnitin plagiarism-detection service, for copyright infringement after the company archived their submitted papers despite disclaimers on the works; iParadigms filed counterclaims against the students for indemnification under its usage policy, trespass to chattels, violations of the Computer Fraud and Abuse Act, and the Virginia Computer Crimes Act arising from one student's unauthorized submissions. The court granted summary judgment to iParadigms on the students' copyright complaint and to the students on all counterclaims. The core reasoning was that the students had agreed to the clickwrap terms authorizing archiving, iParadigms' use qualified as fair use under copyright law for the educational purpose of detecting plagiarism, and iParadigms failed to show any actual or economic damages supporting its counterclaims.

propertyprocedurebusiness & regulatorytorts & liability

The case Burandt v. Dudas involved plaintiff Corliss Burandt challenging the U.S. Patent and Trademark Office's denial of his petitions to reinstate U.S. Patent No. 4,961,406, which had expired due to nonpayment of maintenance fees by the prior assignee. Burandt sought judicial review under the Administrative Procedure Act and a writ of mandamus, arguing that the delay was unavoidable and that he should not be bound by the assignee's actions since he held equitable title. The court granted summary judgment to the defendant, dismissing the case, because Burandt failed to demonstrate that the delay in paying the fees was unavoidable under 35 U.S.C. § 41(c)(1), as he provided no evidence regarding the assignee's reasons for nonpayment and had not monitored the patent for years. Additionally, mandamus relief was unavailable since an adequate remedy existed under the APA and the USPTO had no clear nondiscretionary duty to reinstate the patent.

business & regulatoryproperty

The case involved Steven Hatfill's claims against The New York Times for defamation and intentional infliction of emotional distress arising from 2002 opinion columns by Nicholas Kristof that discussed the FBI's investigation into the 2001 anthrax mailings and highlighted the agency's failure to adequately examine Hatfill, a former biodefense researcher with relevant expertise and clearances. The district court granted the defendant's motion for summary judgment on all counts. It reasoned that the columns contained no provably false statements of fact, that Hatfill was a public figure who could not show actual malice, and that the reporting was not outrageous or intended to cause severe distress under Virginia tort standards for intentional infliction of emotional distress.

free speechtorts & liability

In Walker v. Johnson, a death-row inmate sentenced in 1998 challenged the constitutionality of Virginia's three-drug lethal injection protocol under the Eighth Amendment's prohibition on cruel and unusual punishment, seeking injunctive relief via 42 U.S.C. § 1983. The district court granted summary judgment to the defendants and dismissed the case. The court reasoned that the protocol—administering high doses of sodium thiopental, pancuronium bromide, and potassium chloride with multiple safeguards such as dual IV lines, trained personnel, saline flushes, and backup procedures—did not create a substantial risk of serious harm. It further held that the plaintiff failed to show the defendants acted with deliberate indifference to any such risk, consistent with precedents like Nelson v. Campbell and Farmer v. Brennan.

criminal lawcivil rights

The case involves Eplus Technology suing Amtrak and its Office of the Inspector General over two alleged contracts: a 2001 Server Contract for computer equipment and a 2002 Wireless Contract for a national project. Plaintiff claimed Amtrak breached the Wireless Contract and that OIG improperly investigated the Server Contract and directed Amtrak to stop all business with Plaintiff, leading to claims for breach of contract, breach of implied covenant of good faith and fair dealing, tortious interference with contract, and tortious interference with prospective business advantage. The court granted the defendants' motions to dismiss under Rule 12(b)(6), holding that Plaintiff failed to allege a valid enforceable contract for the Wireless Contract, that OIG is not a suable entity separate from Amtrak, and that the tort and good faith claims require either a valid contract or business expectancy which were not properly pled.

business & regulatoryproceduretorts & liability

This case involved charges against the defendant for driving on a suspended license and without a valid license on J.J. Kingman Road, which leads to Fort Belvoir. The Magistrate Judge dismissed the charges after finding the road was not a public highway under Virginia law. On appeal, the District Court reversed, holding that the road qualifies as a highway because it is open to public use for vehicular travel during daytime hours without significant restrictions, distinguishing it from cases involving private roads or limited access.

criminal lawfederal power

The case involved a prisoner suing prison officials and medical staff under 42 U.S.C. § 1983, claiming violations of his constitutional rights through inadequate treatment for chronic pain conditions, denial of a wheelchair, and related deprivations that allegedly caused pain and hunger. The court granted the motion to dismiss by several defendants on the ground that the plaintiff failed to exhaust administrative remedies, as required, by not appealing the rejections of his grievances. Claims against the remaining defendants were dismissed under 28 U.S.C. § 1915A because the facts alleged did not show deliberate indifference to serious medical needs, given that the plaintiff had received prompt examinations, pain medications, and temporary wheelchair access. The court explained that negligence or disagreement with treatment decisions does not amount to an Eighth Amendment violation.

civil rights

This case involved Christopher Lamparello's registration and operation of the website www.fallwell.com to express viewpoints critical of Jerry Falwell's positions on issues including homosexuality. Falwell and Jerry Falwell Ministries asserted claims for federal trademark infringement, false designation of origin, unfair competition, and cybersquatting under the Lanham Act, based on the domain name as a colorable imitation of Falwell's registered mark. The court granted summary judgment to the defendants on their counterclaims, holding that the elements of trademark infringement were met because the mark was used in commerce in connection with goods or services in a manner likely to confuse consumers, and that the action was filed within the applicable five-year statute of limitations. It denied statutory damages and attorney fees, however, because the primary motive was not commercial profit. The court ordered Lamparello to cease use of the mark and transfer the domain name.

business & regulatoryfree speech

This case involved a prisoner at Southampton Correctional Center who filed a § 1983 complaint alleging numerous constitutional violations by prison officials, including retaliation through false disciplinary charges, interference with mail and grievances, harassment, inadequate investigation of an assault, poor conditions in segregation, sleep deprivation, and challenges to prison policies on correspondence and disciplinary fines. The court considered cross-motions for summary judgment and dismissed several defendants at the outset due to lack of personal involvement in the alleged deprivations. It granted summary judgment to the remaining defendants, finding no genuine issues of material fact and determining that the claims failed to demonstrate violations of the plaintiff's constitutional rights under applicable legal standards for prison administration and summary judgment motions.

criminal lawcivil rightsprocedure

In Hayes v. Crown Central Petroleum Corp., shareholders alleged that a proxy statement for a merger contained a false opinion that the merger price was fair, asserting claims under Sections 14(a) and 20(a) of the Securities Exchange Act of 1934 as well as Maryland state law claims for breach of fiduciary duty. The court granted the defendants' motion to dismiss all counts in the Second Amended Complaint. The federal claims were dismissed because the plaintiffs failed to plead with particularity facts creating a strong inference that the defendants knowingly issued a false opinion, as required by the Private Securities Litigation Reform Act, despite adding language that the defendants "knew" the opinion was false. The state law claims failed because the merger required a two-thirds vote and the alleged controlling shareholder could not dictate the outcome, so it was treated as a minority shareholder with no breach of fiduciary duty.

business & regulatoryprocedure

The case concerned whether a defendant who falsely denied a prior arrest under oath on a naturalization application could be convicted under 18 U.S.C. § 1015(a) even though the parties stipulated the falsehood was not material to the citizenship decision. The court ruled that materiality is not an element of the offense and found the defendant guilty on the stipulated facts. The statute's text contains no materiality requirement, and Congress removed any such language from the provision's predecessor in 1909 without restoring it in later recodifications. The court applied Supreme Court precedent from United States v. Wells, which interpreted a similar false-statement statute to lack a materiality element based on its plain language.

criminal lawimmigration

This case is a federal habeas corpus petition under 28 U.S.C. § 2254 filed by Virginia inmate Douglas Haskett challenging his 1999 conviction for rape in state court. Haskett raised four claims of ineffective assistance of counsel, including failures to investigate statements, call sentencing witnesses, make a timely motion to strike, and move to suppress DNA evidence. The district court granted the state's motion to dismiss, ruling that the state supreme court's rejection of the claims on the merits was neither contrary to nor an unreasonable application of Strickland v. Washington, that the claims were either refuted by the record or procedurally defaulted, and that no prejudice was shown. The opinion reviews the trial evidence, including DNA analysis and victim testimony, and applies the exhaustion and procedural default rules before addressing each claim.

criminal lawprocedure

The case involved a plaintiff who registered the domain name banco-chile.com and, after losing a WIPO arbitration to Banco de Chile over alleged trademark infringement under the Uniform Dispute Resolution Policy (UDRP), sued the Department of Commerce (DOC) for declaratory relief. The plaintiff challenged the UDRP's implementation as violating due process, the nondelegation doctrine, and the Administrative Dispute Resolution Act, seeking to enjoin its use. The court dismissed the claims against the DOC, holding that the plaintiff lacked standing under the three-part test from Lujan v. Defenders of Wildlife. The plaintiff failed to show a concrete injury in fact traceable to DOC actions, as the UDRP arose from private contracts between ICANN and registrars rather than direct government mandate, and any injury would not be redressable by an injunction against the DOC.

business & regulatoryfederal powerprocedure

This case involved a former State Farm employee suing for disability discrimination and retaliation under the Americans with Disabilities Act after the company notified him of termination during a 1997 reorganization, which took effect in 1999, citing his back injury and complaints about treatment. The court granted the defendant's motion for summary judgment and dismissed the case. The discrimination claim was time-barred because the plaintiff filed his EEOC charge in December 1999, more than 300 days after receiving notice of termination in October 1997. On the retaliation claim, the plaintiff failed to establish a causal connection between his protected complaints and the adverse action, as no evidence showed the relevant supervisor knew of the complaints before issuing performance ratings, and the termination rested on legitimate nondiscriminatory performance reasons.

labor & employmentcivil rightsprocedure