In this Fair Labor Standards Act case, a conditionally certified class of aluminum factory workers at Alcoa's Massena West facility alleged that the company failed to pay them for time spent arriving early for shift changes, donning and doffing protective gear on the premises, walking from the locker room to the worksite, and showering after shifts. Alcoa moved for summary judgment, arguing these activities were not compensable. The court granted the motion, holding that the disputed activities were not integral and indispensable to the employees' principal duties under the FLSA, particularly because employees could don and doff gear at home and showering was not required to perform their work. The decision relied on precedents distinguishing preliminary and postliminary activities from compensable principal activities.
This case involved former Discovery Zone employees suing Blockbuster and Viacom for sexual harassment, discrimination, and retaliation under Title VII and New York Human Rights Law, alleging the defendants were liable as integrated employers due to partial ownership and a management services agreement. The court granted summary judgment to the defendants after limited discovery on the employer issue. The core reasoning was that the companies were not a single integrated enterprise, as Blockbuster provided only limited administrative services such as payroll and some legal support under the agreement without exercising centralized control over Discovery Zone's labor relations or day-to-day operations.
In Wahad v. Federal Bureau of Investigation, the plaintiff, a former Black Panther Party leader whose 1973 attempted murder conviction was later vacated, sought to amend his complaint under Federal Rule of Civil Procedure 15(a) to add a damages claim for due process violations under Section 6 of Article I of the New York State Constitution. The alleged violations involved municipal defendants suborning perjurious testimony, withholding exculpatory evidence, and fabricating physical evidence during his criminal trial, which were already the basis for federal claims under 42 U.S.C. § 1983. The court denied the motion to amend, holding that the proposed amendment could not withstand a motion to dismiss because New York law does not recognize an implied private right of action under the state due process clause. Drawing on Brown v. State of New York, the court reasoned that Section 1983 provides an adequate alternative remedy for the alleged violations, precluding the need to imply a state constitutional cause of action even if the federal remedy offers less comprehensive relief than a direct constitutional claim would.
This case arose from the 1986 arrest and prosecution of plaintiff Doris Sassower for resisting arrest, disorderly conduct, and theft of services following a restaurant dispute in White Plains, New York; her convictions were later vacated on appeal. She brought a Section 1983 malicious prosecution claim against the city and police officers, alleging violations of her constitutional rights. The municipal defendants moved for summary judgment, arguing that Sassower could not establish the required post-arraignment deprivation of liberty. The court denied the motion, finding genuine issues of material fact as to whether required court appearances and interference with her travel plans constituted a Fourth Amendment seizure under precedents like Albright v. Oliver and Murphy v. Lynn.
In Daniels v. Loizzo, plaintiff William Daniels brought a civil rights action under 42 U.S.C. § 1983 alleging that defendant police officers used excessive force during his 1987 arrest, resulting in permanent injuries. The court addressed his motion in limine to exclude evidence of his extensive prior criminal history, including convictions for assault, weapons offenses, escape, and drug conspiracy. The court granted the motion in part and denied it in part, ruling that evidence of an outstanding parole warrant was admissible under Rule 404(b) to show motive to resist arrest, while excluding details of unrelated incidents and older convictions under Rules 403 and 609 due to undue prejudice and lack of relevance to credibility or the issues in the case; more recent felony convictions were deemed admissible for impeachment subject to balancing. The decision applied the inclusionary approach to other-acts evidence while requiring limiting instructions and weighing probative value against prejudice.
This case involved a federal prisoner's motion under 28 U.S.C. § 2255 to vacate part of his sentence for supervised release violations. The petitioner had been resentenced to imprisonment plus a new term of supervised release under a statute enacted after his original conviction, which he argued violated the Ex Post Facto Clause. The court granted the motion, finding that the retroactive application of the new law was unconstitutional and that the claim was not procedurally barred due to ineffective assistance of counsel or actual innocence of the sentence. The decision rested on the principle that a statute increasing punishment cannot be applied to offenses committed before its enactment.