This case arose from a fire at a Super 8 motel started in the room of David Byers, a manager-in-training for Ham’s Restaurants, Inc., a subsidiary of Chelda, Inc., while Byers was staying there at the company’s expense during his training program. Hotel owners sued Chelda, Ham’s, and Byers for negligence and resulting damages, seeking to impose vicarious liability on the companies. The court granted summary judgment to Chelda on the ground that Byers was not its employee, but denied summary judgment to Ham’s because material factual disputes existed over whether Byers was acting within the course and scope of employment when the fire occurred. The ruling rested on evidence that Ham’s required and paid for Byers’ lodging as part of training, alongside conflicting accounts about his work schedule, the fire’s cause, and termination reasons.
In this case, defendant Anthony Charles Brown was arrested in 1999 for possessing cocaine base and initially charged by federal authorities with possessing with intent to distribute more than five grams, in violation of 21 U.S.C. § 841(a)(1). After Brown became a fugitive, a superseding indictment was filed in 2008 alleging fifty grams or more of the substance and referencing the corresponding penalty provision in § 841(b)(1)(A). Brown moved to dismiss the superseding indictment as barred by the five-year statute of limitations under 18 U.S.C. § 3282, arguing that the new charge did not relate back to the original indictment. The court denied the motion, holding that the superseding indictment related back because it was based on the same facts and did not broaden the charges or deprive Brown of notice, as the original indictment already encompassed the possibility of proving a higher drug quantity.
Patsy Bryant, a female employee at Yorktowne Cabinetry, sued the company under Title VII alleging sex discrimination for failing to promote her to a Line Lead position and for terminating her after she altered company time-attendance records. The court granted the defendant's motion for summary judgment on both claims. Bryant did not establish a prima facie case for the promotion denial because she lacked a college degree that the employer required for the role and offered no evidence that the requirement was pretextual. On the termination claim, Bryant admitted to changing the records, which constituted a legitimate nondiscriminatory reason for firing her, and she failed to show that the stated reason was a pretext for discrimination or that similarly situated male employees were treated differently.
The case involved a claim under Title II of the Americans with Disabilities Act brought by the estate of Rennie Hunt against the City of Danville, alleging that police officers failed to provide reasonable accommodations to Hunt, a qualified individual with a disability, during a hostage investigation and that the department failed to adequately train its officers. After discovery on remand from the Fourth Circuit, the district court addressed the defendant's motion for summary judgment. The court granted the motion, holding that exigent circumstances in the hostage situation relieved officers of any duty to accommodate under the ADA and that a failure-to-train claim was incompatible with the statute's requirement of an actual exclusion from or denial of services by reason of disability. The court further noted that Hunt's threat to an officer's life was a superseding cause of the events leading to his death.
This case involved an appeal by National Emergency Services (NES) from a bankruptcy court dismissal of its adversary complaint seeking to equitably subordinate the claims of creditor Buddy E. Williams under 11 U.S.C. § 510(c) in the chapter 11 bankruptcy of R.J. Reynolds—Patrick County Memorial Hospital. The underlying bankruptcy case was set to be dismissed upon resolution of this matter, meaning no assets would be distributed from the estate. The district court affirmed the dismissal, holding that equitable subordination applies only to reorder claims for purposes of distributing estate assets, so NES could obtain no relief. The court further reasoned that equitable subordination generally requires creditor misconduct under the Mobile Steel test, and NES had not alleged such misconduct or justified a new exception to that requirement.
This case involves a contract dispute between CPFilms, a Delaware corporation with its principal place of business in Virginia that manufactures solar control films, and Best Window Tinting, a California corporation, along with its officers, over unpaid amounts for delivered products under a credit agreement and dealer arrangement. The plaintiff originally filed suit in Virginia state court seeking $75,000 in damages, after which the defendants removed the action to federal court asserting diversity jurisdiction. The court denied the plaintiff's motion to remand, ruling that attorney's fees expressly provided for in the credit agreement as collection costs constitute a substantive right that may be included in the amount in controversy. Because these fees, when added to the claimed damages, exceed the $75,000 threshold under 28 U.S.C. § 1332, the requirements for federal diversity jurisdiction were satisfied and removal was proper.