This ERISA case involved plaintiff Paul Harmond, a participant in the Teamsters Joint Council No. 83 of Virginia Health and Welfare Fund, who sought payment of $66,757.49 in medical claims after a 1989 car accident with an uninsured motorist. The Fund refused payment, asserting subrogation rights under the plan's section 8.6 to the $100,000 uninsured motorist proceeds Harmond had already received and placed in escrow. The court reviewed the cross-motions for summary judgment de novo after the magistrate's report, interpreting the plan language to permit subrogation against any third party or entity, including the plaintiff's own insurer. It concluded that the trustees' denial of benefits absent subrogation was reasonable and not an abuse of discretion, granting summary judgment to the defendant Fund.
This case involved a long-term employee who was fired after an arbitrator found he cheated on a required requalification test by using a flow chart, in violation of company rules incorporated into the collective bargaining agreement; the arbitrator upheld the discharge as for just cause. The employee sued seeking to vacate the award, arguing the arbitrator exceeded his authority by misinterpreting the agreement and rules. The court dismissed the action, holding that the plaintiff lacked standing because he was not a party to the collective bargaining agreement and had not alleged union misconduct, and that even if standing existed, federal arbitration law and Supreme Court precedent require courts to defer to the arbitrator's decision so long as it draws its essence from the agreement. The core reasoning emphasized limited judicial review of labor arbitration awards under the Arbitration Act and policies favoring finality in grievance procedures agreed upon by unions and employers.
This admiralty case concerns the 1857 sinking of the steamship Central America off the South Carolina coast while carrying passengers and a large quantity of gold from California; in 1987, plaintiff Columbus-America Discovery Group located the wreck after extensive search efforts and sought title to recovered gold and artifacts. Multiple insurance companies that had insured portions of the gold asserted competing ownership claims. The court held that the insurers had abandoned any rights to the cargo more than a century earlier by failing to pursue recovery, destroying or discarding records, and taking no steps to locate or salvage the property despite knowledge of its loss. Because clear and convincing evidence established abandonment, the insurers' claims were dismissed and full ownership was awarded to the plaintiff.
The case involved a seaman who served as a cook on the Tug BARBARA McALLISTER and claimed he suffered a back injury during an operation to recapture a loose barge, alleging negligence by the defendant, unseaworthiness of the vessel, and entitlement to maintenance and cure under the Jones Act and general maritime law. A jury awarded the plaintiff $180,000, after which the defendant moved to set aside the verdict as excessive and for alleged errors including the court's failure to submit contributory negligence to the jury, its directed verdict on negligence and seaworthiness, and its handling of the maintenance and cure claim. The court reviewed the evidence on the circumstances of the incident, conflicting accounts of whether the injury occurred aboard the tug or stemmed from a preexisting condition, the plaintiff's post-incident activities, and comparable damage awards in similar maritime and personal injury cases to evaluate the verdict's reasonableness.
This case involved Ellen M. Edwards, a former federal employee at the Naval Aviation Depot, who was terminated effective April 9, 1986, for excessive unauthorized absences after being appointed as an instrument mechanic apprentice in 1983. Edwards appealed her removal to the Merit Systems Protection Board, alleging procedural defects, bad faith, and various forms of discrimination including handicap discrimination under 5 U.S.C. § 2302, but the Board upheld the termination without addressing any discrimination claims after a hearing focused solely on the reasonableness of the agency's action. She then petitioned the EEOC for review of discrimination issues, which was denied for lack of a properly raised claim, before filing in federal district court. The court granted the defendant's motion to dismiss for lack of jurisdiction under 5 U.S.C. § 7703(b)(1) and (b)(2), reasoning that district court review is available only for mixed cases where discrimination was substantively presented and decided by the MSPB, whereas here the claims were not raised or ruled upon at that stage, directing appeals instead to the Federal Circuit.
This case involved an insurance company suing a railroad company to recover for damage to a paper roller that occurred during shipment from Brazil to Virginia in early 1986. The railroad moved for summary judgment on the ground that the plaintiff had failed to file a proper written claim within the nine-month period required by the uniform bill of lading and ICC regulations. The court granted the motion and dismissed the action, holding that the preliminary notice sent by the shipper’s agent was insufficient because it did not assert liability or claim a specific amount of damages, and that actual notice to the carrier’s employees did not satisfy the mandatory written-claim requirement under federal law. The court reasoned that strict compliance with the bill-of-lading provisions, which are consistent with 49 U.S.C. § 11707 and 49 C.F.R. Part 1005, is a condition precedent to recovery and that no facts supported waiver or estoppel.