Robert Leon Jordan

This case involves a former employee of Fort Loudoun Electric Cooperative who, after being terminated for misconduct and later qualifying for long-term disability benefits under a settlement, sought reinstatement of his employer-sponsored health insurance based on an alleged unwritten policy waiving premiums for disabled employees. The court granted the defendants' motion for judgment and dismissed the action, holding that it lacked jurisdiction under ERISA. The core reasoning was that the alleged benefit did not constitute an ERISA "plan" because the employer exercised insufficient discretion in administering it, merely following the LTD carrier's determination in a mechanical manner rather than operating a formal benefit plan.

labor & employmenthealthcarebusiness & regulatory

The case involved a dispute between Networks USA X, Inc., the landlord, and Nationwide Mutual Insurance Company, the tenant, over whether Nationwide had underpaid rent and common area maintenance charges under a commercial lease for an office building in Tennessee. Networks claimed amounts for items like roof repairs, management fees, and back rent based on alleged square footage discrepancies, while Nationwide argued these were not its responsibility under the lease terms. The court granted summary judgment to Nationwide, finding that the lease excluded roof repairs from operating expenses, the square footage claim lacked contractual basis and was partly time-barred, and Networks failed to prevail on any claims, leading to dismissal of the case.

propertybusiness & regulatory

This case involved a former K-9 officer for the Scott County Sheriff's Department who sued the county under the Fair Labor Standards Act for unpaid overtime compensation related to the off-duty care and training of his police dog. The court found that the plaintiff was entitled to overtime pay for an estimated 1.5 hours per day over 874 days, totaling $21,719.98 in unpaid wages, plus an equal amount in liquidated damages, for a total judgment of $43,439.96, along with attorney's fees. The reasoning centered on the fact that the time spent feeding, training, and caring for the dog was compensable work, the county had notice of the FLSA requirements but failed to pay, and the plaintiff provided a reasonable estimate of the hours worked without contradiction from the defendant.

labor & employment

The case involved a debtor who filed for Chapter 11 bankruptcy in 1999, with a plan confirmed in 2000 requiring a minimum 24% payment on an unsecured creditor's claim of $61,652; after the debtor made minimal payments, the creditor obtained a state court judgment for breach of the plan. The debtor then filed an adversary proceeding in bankruptcy court claiming the state judgment improperly revived discharged prepetition debt in violation of the discharge injunction. The bankruptcy court granted the creditor judgment on the pleadings, and the district court affirmed on de novo review, concluding that the state court had interpreted and enforced the new post-confirmation contractual obligation under the plan rather than the discharged debt, and that the Rooker-Feldman doctrine barred federal review of the state judgment.

business & regulatoryprocedure

In this case, current and former hourly production workers at Koch Foods' chicken processing plants sued under the Fair Labor Standards Act, alleging they were not compensated for time spent retrieving, donning, doffing, and sanitizing required protective gear and equipment, washing hands, and walking to and from work areas, and that their unpaid meal periods were not bona fide because these activities occurred during them. The workers were paid based on production line time rather than their actual clock time. The court denied the plaintiffs' motion for summary judgment in full. It granted the defendant's motion for summary judgment in part as to Count I on the defense under 29 U.S.C. § 203(o) and the collective bargaining agreement but denied it in other respects, denied the defendant's motion as to Count II, and granted the plaintiffs' motion for court-ordered mediation. The rulings turned on the applicability of the statutory exemption and agreement to certain donning and doffing claims, the existence of factual disputes regarding good faith and meal period claims, and the procedural posture after prior decertification rulings.

labor & employment

This case involves production workers at Koch Foods' chicken processing plants in Tennessee who sued under the Fair Labor Standards Act for unpaid overtime wages. The plaintiffs claimed they were not compensated for time spent donning, doffing, and sanitizing protective gear, or for portions of their meal breaks, because pay was based only on production line time. After conditional certification of a collective action with about 150 opt-in plaintiffs, the defendant moved to decertify the class or, alternatively, for separate trials for the two plants. The court denied the motion, finding the plaintiffs similarly situated due to the common pay policy and that differences in job duties or plants could be addressed at trial without requiring separate proceedings. The decision applied the two-step FLSA collective action analysis and Rule 42(b) factors for separate trials.

labor & employmentprocedure

This case involves a claim for long-term disability benefits under an ERISA-governed employee benefit plan issued by Prudential to Mastercraft Boat Company. After initially approving benefits for the plaintiff based on a possible neuropathy diagnosis, Prudential terminated them upon expiration of the initial 24-month period under the plan's stricter "any gainful occupation" standard, following multiple medical reviews and an independent medical examination that concluded the plaintiff could work. The court applied the arbitrary and capricious standard of review and upheld the denial, concluding that Prudential's decision was supported by the administrative record, including the IME findings, despite the Social Security Administration's separate disability determination and the insurer's conflict of interest.

labor & employmenthealthcare

This case involves petitioner David Earl Miller's federal habeas corpus petition under 28 U.S.C. § 2254 challenging his 1982 Tennessee conviction for first-degree murder and death sentence, following unsuccessful direct appeals and state post-conviction proceedings. The court had previously denied the petition and granted summary judgment to the respondent warden on all claims. In the present ruling, the court denies Miller's Rule 59(e) motion to alter or amend the judgment, which challenged the disposition of eleven claims on grounds that the court overlooked relevant law or facts. The court reasons that Rule 59(e) relief requires a manifest error of law, newly discovered evidence, or an intervening change in law, none of which Miller established, as the prior analysis properly addressed the claims under AEDPA standards and the record showed insufficient support for issues like ineffective assistance of counsel.

criminal lawprocedurefederal power

The case involved a kidney dialysis provider, as assignee of benefits for a deceased patient with end-stage renal disease (ESRD), suing a group health plan for terminating coverage retroactively upon the patient's Medicare eligibility and recouping payments made for dialysis treatment. The provider claimed the termination violated the Medicare Secondary Payer Act (MSP), 42 U.S.C. § 1395y(b)(1)(C), which prohibits group health plans from taking into account ESRD-based Medicare eligibility or differentiating in benefits for such patients during a 30-month period. The court granted the provider's motion for summary judgment on its ERISA claim for unpaid benefits, denied the plan's motions, and dismissed its counterclaim for recouped amounts, holding that the plan's termination provision violated the MSP and that the denial of benefits was arbitrary and capricious. The court reasoned that the MSP addresses coverage terminations (not just benefit levels), distinguished contrary precedent as factually inapplicable, and relied on clarifying federal regulations requiring primary coverage during the coordination period. Defendant's reliance on non-enforcement by regulators did not validate its policy.

healthcarebusiness & regulatory

This case involves a contract dispute between Vehicle Protection Plus (VPP), which sells vehicle service contracts, and Premier Dealer Services (PDS), a claims administrator and subsidiary of insurer Great American. VPP alleged that PDS breached their Administrative Agreement by failing to properly transition as the third-party administrator for VPP's contracts, leading to lost business. The court granted VPP's partial motion for summary judgment on the breach of contract claim against PDS, finding the agreement was clear and integrated. It denied most of the defendants' summary judgment motion but granted it in part on damages related to the loss of one client (ADM), ruling that evidence of causation was speculative rather than supported by admissible facts. The court also denied the defendants' motion to strike portions of affidavits.

business & regulatoryprocedure

This case involves a dispute between L-S Industries, a plastic products manufacturer, and its former sales employee Christopher Matlack after his 2007 departure. LSI sued Matlack for breach of fiduciary duty, tortious interference with business, intentional interference with contracts, violation of the Tennessee Uniform Trade Secrets Act, and unfair competition, alleging he used confidential information and pursued conflicting business interests while employed. Matlack countersued for false light invasion of privacy, intentional interference with business relationships, and breach of contract, claiming LSI's communications damaged his reputation and that his commissions were improperly reduced by mischaracterizing a bonus as salary. On the parties' cross-motions for summary judgment, the court denied Matlack's motion for partial summary judgment, granted LSI's motion in part and denied it in part, and ordered additional briefing on the unfair competition claim, primarily due to insufficient legal argument on certain elements and genuine issues of material fact regarding the commission calculations.

labor & employmentbusiness & regulatoryproceduretorts & liability

In United States v. Kelley, a defendant charged in a drug conspiracy case moved to suppress evidence obtained from wiretaps on his telephones, joining arguments that the applications failed to satisfy Title III's necessity requirement, lacked probable cause, and warranted a Franks hearing to challenge alleged deficiencies in the supporting affidavits. The district court performed a de novo review of the magistrate judge's report recommending denial of the motion and adopted the recommendation. The court concluded that the affidavits sufficiently explained why alternative investigative methods were inadequate, established probable cause based on intercepted conversations linking the defendant to co-conspirators, and contained no material misrepresentations or omissions justifying a Franks hearing. The court therefore overruled the objections and denied the motion to suppress the wiretap evidence.

criminal lawprocedure

This case involved a married couple under age 62 with one minor child who filed for Chapter 7 bankruptcy and sought to claim a total $50,000 homestead exemption under a new provision of Tennessee Code section 26-2-301(f), which allows an enhanced $25,000 exemption for an individual with custody of minor children. The Chapter 7 trustee objected, and the bankruptcy court limited the couple to the $7,500 aggregate exemption available under subsection (a) for jointly owning spouses, ruling that subsection (f) applied only to unmarried persons. On appeal, the district court reversed, holding that the statute's use of the term "individual" does not exclude married debtors and that each spouse meeting the criteria of owning and residing in the home with a minor child in custody may claim the full $25,000 exemption. The court reasoned that the legislature had expressly addressed marital status and joint ownership in subsections (a) and (e) but omitted any such limitations in subsection (f), indicating that the enhanced exemption applies separately to each qualifying debtor.

propertyfamily lawprocedure

In Gupton v. Leavitt, Dr. Henry Gupton sued the Secretary of Health and Human Services after being excluded for five years from Medicare, Medicaid, and other federal health care programs based on his nolo contendere plea to attempted TennCare fraud, even though the charge was later dismissed following a diversionary period and the record was expunged. The court granted the Secretary's motion for summary judgment and denied the plaintiff's cross-motion, upholding the exclusion. It reasoned that 42 U.S.C. § 1320a-7(a)(1) and the statutory definition of "convicted" in § 1320a-7(i) expressly cover accepted nolo contendere pleas regardless of later expungement or diversion, and found no violations of due process, equal protection, or the Tenth Amendment. The exclusion was deemed a valid exercise of federal authority over participation in federal health programs, separate from state criminal proceedings or medical licensure.

healthcarecriminal lawfederal power

This case is a qui tam action under the False Claims Act brought by relator Kyle Fellhoelter against Valley Milk Products, L.L.C., Donald C. Utz, and Maryland & Virginia Milk Producers Cooperative Association, Inc. The relator alleged three schemes in which the defendants violated milk pricing and pooling rules under a USDA regulatory program known as the Appalachian Federal Order, resulting in improper payments from a settlement fund financed by milk processors. The court granted the defendants' motions to dismiss the amended complaint. The core reasoning was that the FCA claims failed because no government funds were involved in the program, the alleged conduct did not constitute presentment of false claims or use of false records under 31 U.S.C. § 3729(a)(1)-(2), and the allegations did not meet the requirements for a reverse false claim under subsection (a)(7) as interpreted by Sixth Circuit precedent requiring a sufficiently certain obligation owed to the government.

business & regulatoryfederal powercriminal law

In Steele v. United Parcel Service, Inc., a former UPS employee sued the company and Broadspire Services, Inc., the administrator of an ERISA-governed disability benefits plan, after receiving short-term and long-term disability benefits for health issues including depression and being terminated following a 12-month absence from work. Broadspire moved for judgment on the pleadings on the plaintiff's state-law claims against it. The court granted the motion and dismissed Broadspire, holding that the claims were preempted by ERISA because they concerned the administration of benefits under the plan and sought to impose an alternate enforcement mechanism outside ERISA's exclusive framework, regardless of any alleged improper motive. The court noted that the plan delegated claims administration to Broadspire in a fiduciary capacity and that the complaint did not allege facts taking the claims outside ERISA preemption.

labor & employmentfederal power

The case involves a breach of contract claim by plaintiff Dolphin Offshore Partners against defendant Industrial Resources Corp. (IRC), a Kentucky corporation, and the estate of its former president Malcolm Ratliff, who signed a 2002 stock purchase agreement on IRC's behalf while the company was administratively dissolved. IRC's corporate status was later reinstated, but the plaintiff sought summary judgment holding the estate personally liable for over $600,000 in damages. The court granted the motion, ruling that under Kentucky law as stated in Forleo v. American Products of Kentucky, Inc., reinstatement does not relieve corporate officers of personal liability for debts incurred in the corporation's name after dissolution, and distinguished Fairbanks Arctic Blind Co. v. Prather & Associates because that case addressed a reinstated plaintiff corporation rather than officer liability for a defendant corporation. The court also denied the estate's motion to strike references to the unpublished Forleo decision, finding it the most applicable authority on the precise issue presented.

business & regulatory

This case originated as a state court condemnation action for expansion of the Gatlinburg Airport, involving property owner Grant Cantwell and liens against property he sold to Magnetic Ideas, Inc. After the IRS filed a federal tax lien against Magnetic based on its recorded fee simple title to one tract, Cantwell obtained a state court default judgment setting aside the conveyance without notifying the IRS. The federal district court granted the United States' motion for summary judgment and denied Cantwell's, ruling that federal tax lien law determines the attachment of liens to state-created property rights and that the later state judgment could not defeat the already-attached federal lien. The core reasoning was that Magnetic held record title when the tax lien was filed, making that interest subject to the lien under 26 U.S.C. § 6321, and principles of federal supremacy and third-party rights prevented reformation or nullification of the lien.

taxespropertyfederal powerprocedure

This case involved environmental nonprofit groups suing the U.S. Forest Service under the Freedom of Information Act to obtain additional internal records about alternatives considered for the Walnut Mountain Project, a proposed land management plan in the Cherokee National Forest. The agency had released some documents but withheld others under FOIA Exemption 5 as deliberative materials, including drafts and internal emails reflecting opinions and debates. The court granted summary judgment to the Forest Service and denied the plaintiffs' cross-motion, holding that the withheld records qualified for the exemption and that the agency had not acted in bad faith despite delays in responding to the request and appeal. The decision rested on the agency's Vaughn index, supporting affidavits, and the absence of evidence overcoming the presumption of good faith in the agency's handling of the FOIA request or the underlying project.

environmentfederal powerprocedure

This case under the Individuals with Disabilities Education Act concerned whether Roane County Board of Education's proposed placement of a hearing-impaired child with cochlear implants in a collaborative Head Start program would provide a free appropriate public education in the least restrictive environment, and whether the county was required to continue providing mapping services for the implants. The parents had sought reimbursement for a private preschool placement and ongoing mapping services, following a due process hearing where the officer approved the county's placement but ordered continued mapping. The court affirmed the hearing officer's placement decision, finding the proposed program met IDEA standards based on expert evidence regarding acoustic needs and program features, but modified the mapping ruling to limit the county's responsibility to the period through October 13, 2006, consistent with the 2004 statutory amendment excluding such services from school obligations.

civil rights