In Ward v. Shalala, Ms. Joan Ward appealed the denial of her application for Social Security disability benefits, claiming onset of disability in 1987 due to cardiac problems before her insured status expired in 1990. The District Court reviewed the ALJ's decision under 42 U.S.C. § 405(g), examining whether it was supported by substantial evidence from medical records and testimony showing she could perform sedentary or light work. The court held that the ALJ's finding of no disability was supported by substantial evidence and rejected additional claims of bias and constitutional violations as waived or meritless. It therefore granted summary judgment to the Secretary and denied Ward's motion.
This case involved plaintiff Alfred DiSabatino's claims that his former employers, the DiSabatino family construction companies, and their comptroller violated COBRA's notice requirements under ERISA after his 1993 termination by failing to provide timely and properly delivered information about his rights to continue health insurance coverage. The court granted the plaintiff's motion for partial summary judgment, finding that the initial May 1994 notice was substantively inadequate and the subsequent August 1994 notice was both untimely and not individually addressed to the plaintiff and his spouse, in violation of federal law. It partially granted the defendants' summary judgment motion by rejecting claims for extracontractual or punitive damages due to lack of demonstrated injury from the notice failures, but awarded the plaintiff a statutory penalty for the violations and his reasonable attorneys' fees based on the defendants' lack of justification and the need for deterrence. The core reasoning centered on the plain requirements of COBRA for continuation coverage notices following qualifying events like termination and the application of ERISA's fee-shifting factors.
This case arose from injuries William Windley sustained in 1992 while machining an air preheater at a Delaware power plant, when the rotor unexpectedly rotated and crushed him; he and his wife sued the preheater's designer and manufacturer, ABB Air Preheater, along with other parties, alleging a dangerously defective design that lacked safe access for maintenance. ABB moved for summary judgment under Delaware's Builders' Statute (10 Del.C. § 8127), a six-year statute of repose for claims involving construction of improvements to real property. The court granted the motion, holding that ABB had furnished construction of the preheater, that the 69,900-pound unit qualified as an improvement to the power plant because it was a permanent addition enhancing the property's utility, and that the repose period had begun upon substantial completion in 1961 and thus expired long before the suit. The decision rested on undisputed facts that ABB manufactured the unit and on the statutory definition of construction and improvement, with no need for further discovery because the Windleys filed no Rule 56(f) affidavits.
This case concerned a dispute between Albert H. Marta and Mutual Life Insurance Company of New York over Marta's obligation to pay contingent interest under a note and mortgage he assumed in 1972 for an apartment complex, calculated as 20% of annual gross revenue exceeding $100,000. Marta stopped making payments after 1977 and sought a declaratory judgment that none were owed, claiming an oral waiver or modification by MONY, while MONY counterclaimed for the unpaid amounts plus fees. The court granted MONY partial summary judgment, ruling that the statute of frauds barred any oral modification of the written loan documents, that no-waiver clauses prevented waiver by inaction or conduct, and that laches did not apply absent proof of an intervening prejudicial change in conditions. The decision left issues of prejudgment interest and attorneys' fees for further briefing.
In Kondrath v. Arum, plaintiffs Dave Tiberi, a professional boxer, and his manager Mark Kondrath sued boxing promoter Bob Arum, Top Rank, the IBF, and various officials, judges, and others, alleging they formed a RICO enterprise that fixed IBF title fights, including the 1992 Toney-Tiberi bout in Atlantic City, along with related claims under the New Jersey racketeering statute, fiduciary duty violations, fraud, and breach of contract. The defendants moved to dismiss or transfer the case from the District of Delaware. The court granted the motion to transfer venue to the District of New Jersey under 28 U.S.C. § 1404(a), finding that the convenience of parties and witnesses, the location of key events and evidence in New Jersey, and the interests of justice all favored transfer, while dismissing the remaining motions as moot.
This case involved Matlack, Inc. filing a lawsuit under the Freedom of Information Act (FOIA) against the Environmental Protection Agency (EPA) to obtain documents linking the company to a landfill site in Ohio, after the EPA had requested information from Matlack and named it a potentially responsible party under environmental law. The EPA released the requested documents with some redactions following the initiation of the suit, leading Matlack to seek an award of attorney's fees and costs. The court applied a two-part test to determine eligibility and entitlement for fees, first assessing whether Matlack had substantially prevailed by showing the lawsuit was necessary and caused the disclosure, and then evaluating factors such as public benefit, commercial interest, and the reasonableness of the government's withholding.