This case involved claims by chicken growers Larry and Eva Harden against Pilgrim’s Pride Corporation (PPC) after PPC rejected their broiler-grower contracts during its Chapter 11 bankruptcy. The Hardens alleged violations of the Age Discrimination in Employment Act (ADEA) and the Packers and Stockyards Act (PSA), seeking damages from the contract terminations. The district court granted PPC’s motion for summary judgment and dismissed the claims with prejudice. The court reasoned that the Hardens were independent contractors rather than employees under the hybrid economic-realities/common-law-control test, so the ADEA did not apply. It further held that the PSA claims failed because the statute prohibits certain unfair practices in livestock dealings but did not support liability on the facts alleged.
The case concerned motions to stay proceedings in a bankruptcy matter where chicken growers Larry and Eva Harden asserted claims against Pilgrim’s Pride Corporation (PPC) for age discrimination under the ADEA and violations of the Packers and Stockyards Act after PPC rejected their grower contracts during its chapter 11 reorganization. PPC moved to stay the case pending resolution of its summary-judgment motion in the bankruptcy court, while the Hardens sought a stay until they exhausted administrative remedies, including obtaining an EEOC right-to-sue letter and completing a USDA investigation. The court granted PPC’s motion to stay and denied the Hardens’ motion. It reasoned that PPC had waived any failure-to-exhaust defense, the Hardens had satisfied ADEA prerequisites by timely filing an EEOC charge and waiting sixty days before suit, and no primary-jurisdiction or other administrative barriers prevented advancement of the PSA claims, thereby conserving judicial and party resources.
business & regulatorylabor & employmentprocedurefederal power
This case involved copyright owners suing the owner of a sports bar for unauthorized public performances of their songs, including "Mr. Roboto" and "Jump," through a DJ and karaoke services. The court granted the plaintiffs' motion for summary judgment, finding that the defendant infringed the copyrights by allowing the performances without obtaining the required ASCAP license despite repeated notices. The decision was based on undisputed evidence that the songs were performed at the bar and the defendant had failed to secure a license after multiple opportunities to do so. As a result, the court issued an injunction against future unlicensed performances, awarded $50,000 in statutory damages, and granted attorneys' fees and costs.
In CRG Partners, LLC v. United States Trustee, the district court reviewed a bankruptcy court's denial of a $1 million fee enhancement to a restructuring firm that had assisted a Chapter 11 debtor in achieving full creditor payment. The bankruptcy court had applied the standard from the Supreme Court's Perdue decision in a civil rights fee-shifting case to reject the enhancement request. The district court reversed, holding that Perdue does not govern fee enhancements in bankruptcy proceedings under 11 U.S.C. § 330, which instead use the lodestar method adjusted by Johnson factors only in rare and exceptional circumstances. The case was remanded for the bankruptcy court to apply the correct legal standard.
This case arose from grievances filed by the Office and Professional Employees International Union on behalf of pilot Craig Hilton against his former employer CareFlite, a medical air-transport company, after CareFlite denied an extension for Hilton to obtain an Airline Transport Pilot Certificate and then terminated him for lacking the certification. CareFlite sued for a declaratory judgment that the grievances were not arbitrable under the collective bargaining agreement, leading to prior rulings that one grievance was arbitrable while the other was not, and remanding the question of whether the union and Hilton had independent state or federal claims outside the CBA. The court granted CareFlite partial summary judgment, holding that the Railway Labor Act's mandatory arbitration mechanism preempts the portion of Count II before the court because it requires interpretation of the CBA. However, the court denied summary judgment on Count III, concluding that the RLA does not preclude independent claims of retaliation under RLA section 2, Third and Fourth, as those do not depend on CBA interpretation and raise genuine factual disputes about anti-union animus versus legitimate business reasons.
This case involves a bankruptcy trustee's claims that payments made by Mirant Corporation and its subsidiaries to various banks under financing agreements for European power-generation facilities were fraudulent transfers avoidable under federal or state law. After Mirant filed for Chapter 11 protection, the debtor-in-possession and later its successor, MC Asset Recovery, sued the lender and investor banks alleging the transactions lacked reasonably equivalent value. The district court conducted a de novo review of the bankruptcy court's proposed findings, denied the defendants' motion to dismiss, and granted their converted motion for summary judgment. The court determined that Georgia's Uniform Fraudulent Transfer Act did not apply, that the Federal Debt Collection Procedures Act was inapplicable because there was no debt owed to the United States, and that New York law governed the participation agreements, under which no viable fraudulent-transfer claim existed. It further held that the reorganized creditors had not been paid in full and that any avoidance actions were properly vested in the plaintiff, but ultimately concluded the claims failed as a matter of law.