District Court, W.D. New York — appointed by Ronald Reagan
Frommert v. Conkright
District Court, W.D. New York · 2011-11-17 · cited 8×
This ERISA case concerns Xerox employees who left the company, received lump-sum pension distributions, and later returned, raising questions about how prior distributions should be offset when calculating future benefits under the Retirement Income Guarantee Plan to prevent either underpayment or windfalls. After prior appeals, the Supreme Court held that the district court must defer to the Plan Administrator's interpretation of the plan unless unreasonable, remanding for further proceedings. On the pending motions, the court addressed the Administrator's proposed offset methodology, including use of a phantom account, and the enforceability of release forms signed by some plaintiffs. The core reasoning emphasized that plan interpretation is subject to deference under the Supreme Court's directive, while distinguishing issues of notice, disclosure, and equitable relief that may require separate analysis under ERISA provisions.
labor & employmentprocedure
Eastman Kodak Co. v. COLLINS INK CORP.
District Court, W.D. New York · 2011-11-04 · cited 9×
This case concerned a supply contract between Eastman Kodak Company and Collins Ink Corporation under which Collins provided ink for Kodak's commercial printers. After years of performance, Collins attempted to terminate the agreement immediately in October 2011 based on concerns about Kodak's finances, without providing the required 180 days' notice or following the contract's termination-for-cause procedures, and instead demanded cash-on-delivery payments. Kodak sued for breach of contract and sought a preliminary injunction to compel continued performance. The court granted the injunction, concluding that Kodak showed a likelihood of success on the merits, irreparable harm from disruption of its operations, and that the equities and public interest supported preserving the contractual status quo rather than allowing unilateral termination.
business & regulatoryprocedure
Davis v. J.P. Morgan Chase & Co.
District Court, W.D. New York · 2011-10-11 · cited 16×
This case involved five employees suing J.P. Morgan Chase & Co. on behalf of a class to recover unpaid overtime wages under the Fair Labor Standards Act and New York law. After preliminary approval of a settlement, conditional class certification, and a fairness hearing, the court decided to grant final approval of the proposed class action settlement as fair, reasonable, and adequate, and also awarded attorney fees. The core reasoning applied the presumption of fairness for arm's-length negotiations by experienced counsel after discovery, assessed procedural fairness through the negotiation process and substantive fairness via the nine Grinnell factors, and found objections unpersuasive while noting the limited judicial role of approving or rejecting the agreement as written.
labor & employmentprocedure
Medina v. Skowron
District Court, W.D. New York · 2011-08-18 · cited 3×
In Medina v. Skowron, a prisoner sued several New York Department of Correctional Services employees, claiming First Amendment retaliation, equal protection violations, and disability discrimination after his removal from an Alcohol and Substance Abuse Treatment program and a porter job at Wende Correctional Facility in 2008, allegedly in response to his grievances against staff. The court granted the defendants' motion for summary judgment and dismissed the remaining claims. On the retaliation claim, the court found no evidence of a causal link between the grievances and the removals, as the decisions were supported by documented reasons such as lack of progress in the program and security concerns. The equal protection claim failed because the plaintiff did not identify any similarly situated inmates treated differently, and the disability claims lacked supporting evidence of discrimination or denial of access based on disability.
criminal lawcivil rights
Colantuono v. Hockeborn
District Court, W.D. New York · 2011-08-11 · cited 21×
In this case, a legally blind inmate sued multiple New York Department of Correctional Services employees under 42 U.S.C. § 1983, alleging due process violations, equal protection violations, ADA violations, and related claims arising from a May 2009 Tier III disciplinary hearing at Elmira Correctional Facility. The hearing, based on a misbehavior report accusing the plaintiff of inappropriate physical contact with a staff member, resulted in a two-year SHU sentence that was later reversed; the plaintiff claimed he received inadequate assistance due to his disability, was denied requested witnesses, and suffered from lack of accommodations both before and after transfer to Sullivan Correctional Facility. The court granted the defendants' Rule 12(b)(6) motion to dismiss, holding that the plaintiff failed to state a plausible due process claim because any liberty interest was not clearly established and procedural protections were adequate, that ADA damages claims against state officials were barred by the Eleventh Amendment, and that the equal protection allegations were conclusory without facts showing discriminatory motive or disparate treatment of similarly situated inmates. The plaintiff's motion for counsel was denied as moot.
criminal lawcivil rightsprocedure
Caskey v. County of Ontario
District Court, W.D. New York · 2011-08-02 · cited 3×
The case concerned plaintiff Deborah Caskey’s claims that her employer, the County of Ontario, and supervisor John Cooley violated the Age Discrimination in Employment Act and New York Human Rights Law by abolishing her Finance Clerk position, replacing it with a Microfilm Machine Operator role filled by a significantly younger person, and retaliating against her. Defendants moved to dismiss under Rule 12(b)(6) and alternatively for summary judgment, arguing that many allegations were time-barred and that the complaint failed to state actionable claims. The court granted the motion in part, dismissing the retaliation claims entirely and barring consideration of time-barred incidents, while permitting the discriminatory discharge claim to proceed on the basis that the allegations plausibly supported an inference of age discrimination; it denied summary judgment as premature and the plaintiff’s discovery motion as moot. The decision applied the Twombly plausibility standard to the complaint’s factual allegations and the elements required for an ADEA claim.
labor & employmentcivil rights