In Benson v. General Motors Corp., former GM employees sued the company and their union under Section 301 of the Labor Management Relations Act, alleging that GM breached a collective bargaining agreement by failing to give them preferential hiring consideration at a new plant, resulting in lower seniority and layoffs, and that the union breached its duty of fair representation by refusing to pursue grievances on the issue. The court treated the defendants' motion to dismiss as one for summary judgment. It held that the claims were barred by the six-month statute of limitations under Section 10(b) of the National Labor Relations Act, as suggested by the Supreme Court in United Parcel Service v. Mitchell, because the plaintiffs were hired between July 1979 and April 1980, would have known of their seniority status shortly thereafter, and did not file suit until March 1981.
This case involved the Interstate Commerce Commission seeking to enjoin Browning-Ferris Industries from interstate transportation of non-radioactive hazardous wastes, such as mercury compounds, without first obtaining ICC operating authority under 49 U.S.C. § 10921. The court denied the requested injunction and dismissed the suit after the ICC conceded that the transportation constituted private carriage or was incidental to a primary business operation, both of which are exempt from regulation. The court further held that the wastes were not "property" within the meaning of the Interstate Commerce Act, relying on prior ICC precedents that excluded materials with negative value from the definition of property and on congressional statements confirming no intent to expand the Commission's jurisdiction in this area.
This case involves a Title VII employment discrimination action under 42 U.S.C. § 2000e filed against Alabama By-Products and a union local. The plaintiff had named only the institutional defendants in the EEOC charge, and three individual defendants (the union president and two company supervisors) moved for dismissal because they were not named as respondents. The court granted the motions to dismiss, reasoning that the statute expressly authorizes civil actions only against the respondent named in the EEOC charge and that exceptions to this clear statutory language should not be created absent controlling precedent from the circuit court of appeals.
This case involved a motion by Aeroquip Corp. to enjoin several state-court defamation and malicious prosecution actions brought by defendants Chunn, Defco, and Air-Dro, which arose from statements and a contempt proceeding connected to a prior federal lawsuit over trade secrets, unfair practices, and breach of fiduciary duty that had settled with a consent injunction. The plaintiff argued that the state claims were compulsory counterclaims under Federal Rule of Civil Procedure 13(a) and that an injunction was needed to protect the federal judgment under an exception to the Anti-Injunction Act, 28 U.S.C. § 2283. The court denied the motion, holding that issuing such an injunction would improperly impose federal procedural rules on state courts in violation of the Rules Enabling Act and that the claims were not compulsory counterclaims under the logical-relationship test because they centered on post-filing statements and the bringing of the federal action itself. The court noted that any preclusive effect from the prior judgment or settlement was a matter for the state court to decide rather than grounds for federal injunctive relief.
This case involves consolidated product liability actions against General Motors Corporation in which juries awarded punitive damages that were later deemed excessive. Following a Fifth Circuit remand, the court applied the maximum recovery rule to reduce the verdicts to no more than $150,000-$200,000 per case and entered judgments on the original verdicts, with interest to run from the date of those verdicts under Alabama law. The court decided that plaintiffs could accept the reduced amounts or face a new trial, but held that any retrial must address both liability and damages because punitive awards are intertwined with liability determinations. The reasoning rested on findings that the original verdicts reflected passion and bias given the weak evidence, along with precedents requiring that issues not be tried separately when they are not distinct and separable.
This case involves plaintiff Credit Alliance Corp., as assignee of a conditional sales contract for a pneumatic drill, seeking a deficiency judgment against buyer Cornelius & Rush Coal Co. and guarantors after repossession and public sale of the equipment following default. Defendants asserted that the drill was defective, that oral warranties were breached, and that the sale was not conducted in a commercially reasonable manner, while also bringing counterclaims for breach of warranty and conspiracy. The court granted summary judgment to the plaintiff on both the main claim and the counterclaim, finding no genuine issues of material fact. The decision rested on the contract's waiver of defenses and setoffs against the assignee, its integration clause barring enforcement of alleged oral warranties, and evidence that proper notice was given and the sale procedures complied with commercial reasonableness standards under Alabama's UCC provisions.