This case concerns whether West Publishing Corp. violated the Driver’s Privacy Protection Act (DPPA) by purchasing entire state driver’s license databases and reselling the personal information to third parties for potential future uses. The court denied West’s motion for judgment on the pleadings, concluding that the DPPA does not permit resellers to obtain information solely for resale or to disclose bulk data absent a specific permitted purpose listed in 18 U.S.C. § 2721(b). The core reasoning rests on the statute’s text, which generally prohibits obtaining or disclosing personal information except for enumerated uses and restricts resale by authorized recipients to those same limited purposes, while also finding that plaintiffs adequately alleged injury for standing purposes based on invasion of the privacy rights the DPPA protects.
In Janson v. LegalZoom.com, Inc., a class of plaintiffs sued the online legal document provider alleging that its use of automated questionnaires to prepare customized documents such as wills, business formation papers, and other instruments amounted to the unauthorized practice of law under Missouri statutes. The court granted LegalZoom summary judgment on claims involving patent and trademark applications but denied it as to other documents, while granting plaintiffs' motion for partial summary judgment. The decision turned on the finding that LegalZoom's process—collecting customer answers, reviewing data for errors, and populating standardized attorney-drafted templates—constituted assisting in the drawing of papers affecting or relating to secular rights for a valuable consideration. The court rejected arguments that the fully automated nature of the service or the fact that documents take effect only upon customer signature exempted it from regulation.
The case involved disabled adult Missouri residents over age 21 who were denied Medicaid coverage for medically necessary incontinence briefs, which the state classified as non-covered hygiene items, while covering them for those under 21 and for institutionalized adults. Plaintiffs sought declaratory and injunctive relief under the Medicaid Act, the Americans with Disabilities Act, and the Rehabilitation Act, arguing that the denial forced institutionalization contrary to federal requirements. The court granted plaintiffs' motion for summary judgment and issued a permanent injunction, declaring the state's policy unlawful. It reasoned that the policy violated the Medicaid Act's reasonable standards and home health services provisions, and breached the ADA and Rehabilitation Act's integration mandate under Olmstead v. L.C. by failing to provide community-based services equivalent to those offered in institutions, as waiver programs did not guarantee access or availability.
Missouri Beverage Company sued Shelton Brothers for violating Missouri franchise law by unilaterally terminating their oral agreement under which MoBev distributed Shelton's imported beers in the state. The court granted summary judgment to Shelton and denied MoBev's motion, holding that no franchise relationship existed under Mo. Rev. Stat. § 407.400. The core reasoning was that the required "community of interest" element was absent, as Shelton's products accounted for 1% or less of MoBev's annual sales, MoBev made no substantially franchise-specific investments, and MoBev was not economically dependent on Shelton.
Deckard sued his former employer Hostess for failing to provide the COBRA notices required under ERISA when he became eligible for the company health plan in 2004 and when his employment ended in 2006. The bankruptcy court granted summary judgment to Hostess on the claims and denied attorney fees, noting that Deckard had received continuous coverage at no cost to himself, all medical claims were paid in full, and he therefore suffered no damages or success on the merits. On appeal, the district court affirmed, applying Hardt v. Reliance Standard Life Ins. Co. to hold that without at least some success on the merits there was no basis to award fees.
In Smith v. Astrue, the plaintiff sought judicial review of the Social Security Commissioner's denial of disability insurance and supplemental security income benefits for the period before January 18, 2008, claiming disability due to migraines and other conditions. The court reversed the ALJ's decision and remanded the case, instructing the ALJ to reconsider the plaintiff's residual functional capacity (RFC) by accounting for limitations caused by her chronic migraine headaches. The reasoning centered on the ALJ's failure to adequately consider the impact of the migraines on the plaintiff's ability to perform work-related activities, despite evidence from treating physicians and the plaintiff's testimony about frequent debilitating headaches.
