This case involved the International Brotherhood of Teamsters seeking reimbursement of attorney fees and expenses from plaintiff William Bender after successfully moving to hold him in contempt for violating a 1978 court order requiring the merger of Local 1 with Local 107, specifically by disbursing union funds. The court awarded the IBT $3,548.88 in fees plus $297.44 in expenses, a fraction of the over $31,000 requested. The decision was based on Third Circuit precedent allowing recovery of reasonable costs in civil contempt proceedings to make the injured party whole, but limited to the portion of the motion related to the willful violation involving fund disbursement, excluding time spent on non-contemptuous conduct or unrelated matters, and applying a lodestar calculation to determine reasonable hours and rates.
The case concerned the constitutionality of 26 U.S.C. § 9012(f), which makes it a crime for a political committee to spend more than $1,000 to support presidential or vice-presidential candidates who accept public funding. Plaintiffs sought a declaration that the provision was valid, while defendants argued it infringed on protected rights. The court held that section 9012(f) is unconstitutional on its face. Relying on Buckley v. Valeo, the court reasoned that independent expenditures by political committees constitute fully protected speech rather than contributions, and the statute could not be justified as a regulation preventing corruption or its appearance because the evidence failed to show a sufficient link between such spending and quid pro quo arrangements. The court also addressed justiciability, finding the actions ripe and authorized under 26 U.S.C. § 9011(b).
This case arose from a 1975 lawsuit by Local 1 and its officers, including William Bender, against the International Brotherhood of Teamsters (IBT) and Local 107, challenging an IBT-ordered merger of the small broadcast workers local into the larger truck drivers local under section 301 of the Labor Management Relations Act, along with a pendent back-salary claim by Bender. After the district court upheld the merger but awarded Bender pre-merger salary, the Third Circuit affirmed the merger ruling but vacated the salary judgment for lack of pendent jurisdiction and remanded for consideration of whether diversity jurisdiction could be alleged under 28 U.S.C. § 1653. On remand, Bender amended the complaint to drop the merger claim, all other parties, and the IBT, leaving only himself (a New York citizen) against Local 107 (Philadelphia-based with no New York members) in an effort to create complete diversity. The court held that such amendments exceeded the narrow technical scope of § 1653, which does not permit post-judgment transformation of the lawsuit by dropping parties and claims, and that complete diversity was absent in any event under the rule of Strawbridge v. Curtiss because both unions had Pennsylvania members.
This case involved a former township Director of Roads and Public Property who sued Bristol Township and its commissioners after his position was eliminated, claiming the termination was retaliation for refusing to withhold services from wards represented by opposing political factions and that it occurred without required procedures. The court granted summary judgment to defendants on the First Amendment associational rights claim, ruling that Elrod v. Burns and Branti v. Finkel do not protect a nonpartisan employee discharged for disobeying orders he viewed as politically motivated. It denied summary judgment on the procedural due process claim, determining that the township ordinance mandating discharge only for just cause, read with Pennsylvania Local Agency Law provisions for notice and hearing, created a protected property interest in continued public employment.
In United States v. Kurtz, the United States obtained a judgment against defendant Kurtz and sought to garnish his wages from garnishee Allstate-Cornell Uniform. The garnishee moved to set aside the judgment, arguing first that Pennsylvania law prohibits wage garnishment and second that the wages at issue had already been paid to Kurtz before the judgment was entered. The court denied the motion, holding that binding Third Circuit precedent establishes that the Pennsylvania wage garnishment bar does not apply to the United States, with the Consumer Credit Protection Act imposing only its own limits on both federal and state entities. The court further reasoned that Pennsylvania Rule of Civil Procedure 3111(b), made applicable by Federal Rule of Civil Procedure 69, provides that service of the writ of execution attaches wages in the garnishee's possession and those coming due before entry of judgment.
This case involves claims by merchant seamen for mental distress and psychic injuries resulting from a ship collision with a bridge in Virginia. After liability was established against the vessel owners in the Eastern District of Virginia, the plaintiffs sought to pursue their damages claims in the Eastern District of Pennsylvania. The court granted the defendant's motion to transfer the cases back to the Eastern District of Virginia pursuant to 28 U.S.C. § 1404(a), reasoning that the accident occurred there, that court is familiar with the litigation and has appointed a special master, and it is far more convenient for parties and witnesses than Pennsylvania, where the only connections are the plaintiffs' attorney and a trial psychiatrist.
