James M. Ideman

The case arose from a 1993 fatal crash of a Westwind business jet at John Wayne Airport after it encountered wake turbulence from a preceding United Boeing 757 during a visual approach; the owners and operators sued the United States under the Federal Tort Claims Act alleging negligence by FAA Headquarters in aircraft classification, separation standards, training, and research on wake vortices, as well as negligence by local air traffic controllers. The court granted judgment for the government after a bench trial. It held that the discretionary function exception to the FTCA barred all claims against FAA Headquarters, and that the evidence failed to show any breach of duty or causation by the controllers.

torts & liabilityfederal powerprocedure

This case concerns whether wages paid by AAI Services, Inc. to foreign agricultural workers who had applied for Special Agricultural Worker (SAW) status under the Immigration Reform and Control Act of 1986 were exempt from federal employment taxes pursuant to 26 U.S.C. § 3121(b)(1). The bankruptcy court granted summary judgment to the United States, holding that the workers did not qualify for the exemption under the Ninth Circuit's decision in Moorhead v. United States. The district court reversed, concluding after de novo review that the SAW applicants satisfied the statutory requirements for the exemption because they performed agricultural labor on a temporary basis as contemplated by the provision and its legislative history. The matter was remanded for further proceedings consistent with that holding.

immigrationlabor & employmenttaxes

This case involved homeowners who sued Allstate Insurance after the company denied their 1995 claim for earthquake damage to four rental properties from the 1994 Northridge earthquake, citing the policies' one-year limitations period. The plaintiffs alleged breach of contract, bad faith, fraud, and negligent misrepresentation. The court granted Allstate's motion for judgment on the pleadings, holding that the limitations period began running on the date of the earthquake and that the plaintiffs' delayed claim filing and lawsuit were time-barred. It rejected arguments for tolling or waiver, noting that any potential tolling ended quickly when the inspector indicated no coverage would apply, and waiver was impossible after the period had expired. All claims were dismissed as they depended on the insurer's refusal to pay benefits under the time-barred policies.

propertyprocedurebusiness & regulatory

The case involved a 1991 securities fraud class action by shareholders against Occidental Petroleum, alleging the company misled investors about maintaining its dividend before cutting it; the parties reached a settlement providing no direct cash payout but promising limits on future dividend cuts through 1997, and class counsel sought nearly $3 million in fees based on claimed benefits to shareholders including a rise in stock price. After an initial approval of the fees followed by a Ninth Circuit remand for further explanation, the district court on reconsideration awarded approximately $1.1 million instead. The court reduced the requested hourly rates from $465–$495 to a $375 cap, finding them unreasonably high even for complex litigation and noting that some tasks could have been handled by lower-rate associates, while also concluding that expert opinions linking the settlement to any stock price increase were speculative and unsupported by direct evidence of benefit to the class.

procedurebusiness & regulatory

This case is an employment discrimination lawsuit brought by Andrew Jenkins, a Black male former employee of MCI Telecommunications Corp., and his wife against MCI and his supervisor, alleging that his termination after eleven years was due to race and gender discrimination as well as retaliation for complaining about workload. Jenkins had fallen significantly behind on duties including responding to customer emails, despite offers of assistance from management, and he was replaced by a Hispanic male. The court granted the defendants' motion for summary judgment on all claims. It reasoned that the federal civil rights claims under 42 U.S.C. §§ 1983 and 1985 failed for lack of state action, while the Title VII, FEHA, and related state claims failed because Jenkins admitted his performance deficiencies and provided no evidence that MCI's stated reason of poor performance was a pretext for unlawful discrimination or retaliation.

labor & employmentcivil rights

In Sussman v. American Broadcasting Companies, Inc., the owners and employees of Psychic Marketing Group sued ABC and its journalists after an undercover investigation involving a hidden camera and microphone, an ambush interview, and a national broadcast on PrimeTime Live exposed their 900-number psychic operations. Plaintiffs brought claims under the federal eavesdropping statute, state eavesdropping laws, common-law fraud and conspiracy, and spoliation of evidence. The court granted defendants' motion for summary judgment, dismissing the state statutory claims as time-barred, finding no triable issue of damages from the intrusions alone for the fraud claims (as opposed to the broadcast), holding that the federal statute does not impose liability on journalists who record their own conversations, and dismissing the spoliation claims for lack of prospective litigation. Some individual plaintiffs and defendants were also dismissed by stipulation.

free speechtorts & liabilityprocedure

This case involved whether federal income taxes assessed against debtor Lisa Lee Klein for tax years 1981 through 1987 were dischargeable in her Chapter 7 bankruptcy filing. The bankruptcy court ruled after a bench trial that the taxes, interest, and penalties were all discharged, and the district court affirmed the judgment in full. The core reasoning centered on the fact that Klein submitted an offer in compromise shortly after the assessments, which the IRS formally rejected in April 1989; this rejection restarted the 240-day priority period under Bankruptcy Code § 507(a)(7), which then expired well before the February 1991 bankruptcy petition, rendering the taxes non-priority and dischargeable. The district court reviewed the bankruptcy court's factual findings under the clearly erroneous standard and upheld the determinations that the rejection was effective and that Klein's later appeal letter did not constitute a new offer in compromise.

taxesprocedure

This case involves a malicious prosecution lawsuit filed in California federal court by attorney Donald Engel against CBS, its New York law firm Moses & Singer, and partner Stanley Rothenberg, arising from a 1984 breach of contract and copyright suit that CBS had brought against Engel in New York and lost on summary judgment. After the case was stayed, partially dismissed, and remanded with instructions to apply New York law, the court reconsidered prior rulings on venue and granted the defendants' motion to transfer. The court held that venue was improper in California under 28 U.S.C. § 1406(a) because the underlying events occurred in New York and the defendants reside there. It also found transfer appropriate for convenience under 28 U.S.C. § 1404(a), noting that New York is far more convenient for defendants and witnesses, New York law governs the claim including the complex "heightened injury" element, and Engel maintains professional ties to New York.

proceduretorts & liability

In this case, Polaris Pool Systems sued Letro Products under federal and California law for trademark and trade dress infringement, alleging that Letro's upcoming Legend pool cleaner too closely resembled Polaris' discontinued Model 180 in configuration and blue-and-white coloring. The court denied Polaris' motion for a preliminary injunction, finding that Polaris failed to show a likelihood of success on the merits because it could not establish a likelihood of consumer confusion between the products, despite a registered trademark. The court applied the multi-factor test for confusion and determined that the products' shared features were largely functional, the goods were not closely related in the market, and there was no evidence of actual confusion or bad intent by Letro. Polaris also did not demonstrate a possibility of irreparable injury, so neither prong of the preliminary injunction standard was met.

business & regulatoryprocedure

This case involves trademark infringement and counterfeiting claims under the Lanham Act and related state laws, where Clorox and other plaintiffs alleged that Blue Cross Laboratories and related parties manufactured and distributed counterfeit versions of products like Pine Sol, Mop & Glo, and Windex, leading to seizure orders and preliminary injunctions. Blue Cross filed counterclaims alleging wrongful seizure, conspiracy in restraint of trade under the Clayton Act, and common law unfair competition, while Morco Foods sought to amend its pleadings to add similar counterclaims and crossclaims. The court granted motions to dismiss the antitrust and state unfair competition counterclaims with prejudice, dismissed L&F Products from the wrongful seizure claim with prejudice, granted in part Morco's motion to amend its pleadings, and denied the motion to sever and stay the counterclaims. It reasoned that the Noerr-Pennington doctrine immunizes good-faith litigation from antitrust liability, that federal law preempts the state unfair competition claim, and that only the actual applicant for a seizure order can be sued for wrongful seizure under 15 U.S.C. § 1116(d)(11). The court also granted requests for judicial notice and found no waiver or collateral estoppel barring the remaining wrongful seizure claims.

business & regulatoryprocedure

The case involved the Internal Revenue Service appealing a bankruptcy court's declaratory judgment authorizing the Chapter 11 trustee for five related debtor companies to file a consolidated federal tax return, despite the estates not qualifying as an affiliated group under 26 U.S.C. § 1504. The district court vacated the bankruptcy court's order for lack of jurisdiction. The court reasoned that 11 U.S.C. § 505 grants authority only to determine the amount or legality of tax liabilities that have already arisen, not to issue declaratory relief on tax status or antecedent questions that might affect future returns. It further held that no actual controversy existed under the Declaratory Judgment Act because the trustee had not yet filed returns or proposed specific liabilities, placing the matter outside the statute's scope and within the federal tax exception.

taxesprocedurebusiness & regulatory

The case involved Aqua Queen Manufacturing, which was sued for patent infringement and related claims, seeking defense and indemnity from its insurer Charter Oak under a commercial general liability policy covering advertising injuries including "piracy." The court granted partial summary judgment to Aqua Queen, ruling that the insurer had a duty to defend because the policy's term "piracy" encompassed patent infringement occurring in the course of the insured's advertising activities. The decision was based on the policy language and precedent interpreting similar provisions, leading the court to order the insurer to defend the underlying action and reimburse defense costs, while denying judicial notice for most requested documents and rendering the insurer's summary judgment motion moot.

business & regulatory

The case involved federal criminal charges against Joseph Isgro, Raymond Anderson, and Jeffrey Monka for RICO violations, mail fraud, conspiracies, payola, false tax returns, and obstruction of justice, based primarily on testimony from witness Dennis DiRicco before a grand jury. The district court dismissed the indictment with prejudice, declaring a mistrial, after finding that prosecutors from the Organized Crime Strike Force had withheld exculpatory Brady material consisting of DiRicco's prior trial testimony that directly contradicted his grand jury statements and exonerated the defendants. The court reasoned that the government had not only failed to disclose this evidence despite repeated discovery requests and assurances but had also actively misrepresented its existence, withheld it from the grand jury, and engaged in a pattern of misconduct, warranting exercise of the court's supervisory power to dismiss rather than allow the case to proceed.

criminal lawprocedure

In Ward v. News Group International, Ltd., a public figure plaintiff sued Globe International and Peter Rigby for libel based on their republication of allegedly defamatory statements from a News of the World article concerning the plaintiff. The court granted the defendants' motion for summary judgment on the second cause of action. The ruling was based on the neutral reportage privilege, which applies to accurate and neutral republication of statements made by parties to a controversy involving a public figure; the plaintiff's consent to publication of his denial; and the principle that truth serves as an absolute defense to libel.

free speechtorts & liability

The case involved a Quaker organization and its employees challenging the employer sanctions provisions of the Immigration Reform and Control Act of 1986 (IRCA), which make it unlawful to knowingly hire unauthorized aliens or fail to verify work authorization through documentation. Plaintiffs argued that compliance would violate their sincerely held religious beliefs regarding the equality of human life and indirectly participating in a system that harms immigrants, seeking a declaration that the provisions violated the First Amendment's free exercise clause. The court granted the defendants' motion to dismiss under Rule 12(b)(6), holding that plaintiffs failed to state a claim. The core reasoning was that Congress's plenary power over immigration subjects such statutes to highly deferential review (upheld unless wholly irrational), and even under traditional free exercise analysis the government's compelling interest in controlling immigration outweighed any burden on plaintiffs' religious practices, with no feasible exemption possible as it would undermine the law's purpose of deterring illegal immigration.

immigrationreligious liberty

The Careau Group, doing business as Egg City, sued the United Farm Workers of America under NLRA section 303 to recover damages for alleged unfair labor practices in violation of NLRA section 8(b)(4). The union, certified under California's Agricultural Labor Relations Act to represent Egg City's agricultural workers, moved to dismiss for lack of subject matter jurisdiction, arguing it was not a labor organization under the NLRA. The court granted the motion and dismissed the case under Rule 12(b)(1), holding that the workers remained agricultural employees outside NLRA coverage and that Egg City's prior conduct, including treating the workers as exempt under the FLSA and failing to disclose changes in operations, estopped it from asserting federal jurisdiction.

labor & employmentfederal powerprocedure

The case involved five Hispanic and Black residents of Pomona, California, who sued the City and its City Council members, claiming that the at-large system for electing council members unlawfully diluted minority voting strength under Section 2 of the Voting Rights Act of 1965 and violated the Fourteenth and Fifteenth Amendments by being maintained for a discriminatory purpose. Plaintiffs sought a declaratory judgment, an injunction against future at-large elections, and a switch to single-member districts. After a nonjury trial, the court granted defendants' motion to dismiss under Federal Rule of Civil Procedure 41(b). The court concluded that plaintiffs failed to prove their claims, relying on the limited history of minority electoral success, the absence of significant racially polarized voting, and other Senate Report factors under the Voting Rights Act that did not support a finding of vote dilution or discriminatory intent.

electionscivil rights

The case involved a plaintiff suing her former employer and unnamed Doe defendants for wrongful termination, employment discrimination, and emotional distress claims arising from events including her pregnancy and reduced work hours. The defendant removed the action from California state court to federal court based on diversity jurisdiction under 28 U.S.C. § 1332, but the plaintiff moved to remand under 28 U.S.C. § 1441(b) on the ground that the Doe defendants were California citizens. The court granted the motion to remand, holding that removal is improper where any defendant properly joined is a citizen of the forum state, the Doe defendants were not fraudulently joined because viable claims were alleged against them, and their citizenship must be considered regardless of service.

labor & employmentproceduretorts & liability

In Southern Nights Music Co. v. Moses, the plaintiffs, who own copyrights to songs including 'Lookin For Love' and 'Take Me Home Country Road' and are represented by ASCAP for licensing, sued the defendant nightclub owner for allowing those songs to be performed at his establishment without a license. The court granted summary judgment to the plaintiffs, holding the defendant liable for copyright infringement under 17 U.S.C. § 106(4) and ordering him to cease unlicensed performances while awarding $2,130 in damages and $3,796 in attorney's fees and costs. The reasoning centered on the principle that a public entertainment proprietor is strictly liable for unauthorized performances on the premises, even without personal knowledge of the songs or specific instructions to performers, and that defenses such as the absence of a song list from ASCAP do not apply.

business & regulatoryproperty