The case concerned a bankruptcy debtor's appeal from the bankruptcy court's decision that it lacked jurisdiction to enter or enforce a consent order on sanctions for alleged violations of the automatic stay by a creditor. The debtor claimed the creditor violated the stay through online disparaging comments and misappropriation of copyright and trademark rights related to her book. The district court affirmed the ruling, concluding that the motion did not arise under the Bankruptcy Code for purposes of jurisdiction under 28 U.S.C. § 1334(b) because the allegations did not establish a willful violation of 11 U.S.C. § 362(a) that would support sanctions under § 362(k). The core reasoning was that bankruptcy courts have limited jurisdiction, parties cannot consent to it, and expansive interpretations of stay violations involving intangible property rights would improperly broaden the court's authority, consistent with precedents like Inslaw.
federal powerprocedurepropertybusiness & regulatory
This case involves a patent infringement lawsuit brought by the University of Virginia Patent Foundation against General Electric Company over U.S. Patent No. 5,245,282, which covers a method for three-dimensional magnetic resonance imaging using a specific pulse sequence. During the litigation, the Patent Foundation canceled a dependent claim and made arguments during ex parte reexamination that narrowed the scope of the independent claim by requiring a finite magnetization recovery period, leading to the issuance of a reexamination certificate. GE sought summary judgment establishing intervening rights that would bar liability for any infringement occurring before the reexamination certificate issued, while the Patent Foundation moved to certify prior rulings on claim scope and intervening rights for interlocutory appeal. The court denied both motions, finding that GE had not presented sufficient evidence of good-faith reliance on the original patent's scope or invalidity to support either absolute or equitable intervening rights, and that the rulings did not meet the criteria for immediate appellate review.
This case involves a breach of contract dispute in which ProTherapy Associates sought liquidated damages from nine nursing facilities and their operator after the facilities allegedly violated non-solicitation clauses in therapy services agreements by indirectly hiring 57 former ProTherapy employees through a replacement provider. The court had previously sent the compensatory damages claim to arbitration, leaving only the liquidated damages issue for resolution. Applying Florida law due to a forum selection clause, the court granted summary judgment on liability to ProTherapy against the nine facilities, determining that the restrictive covenants were reasonable and enforceable and that the liquidated damages provision was valid, but ruled that the operator Kissito could not be held liable because it was not a party to the contracts. The court withheld entry of an award pending further briefing on the appropriateness of joint and several liability.
This case concerns a patent infringement lawsuit brought by the University of Virginia Patent Foundation against General Electric, alleging infringement of U.S. Patent No. 5,245,282 on a method for producing three-dimensional magnetic resonance imaging using a specific pulse sequence cycle. After GE requested ex parte reexamination of the patent at the PTO, the Patent Foundation canceled a dependent claim and made arguments distinguishing the independent claim based on a non-zero magnetization recovery period, leading the PTO to confirm the patent. The court had granted partial summary judgment to GE and now denies the Patent Foundation's motion for reconsideration. The core reasoning is that the patent owner's statements during reexamination constitute prosecution history that limits claim scope and precludes interpretations disclaimed to overcome prior art references such as the '658 and '301 patents.
This case involved a dispute over underinsured motorist (UIM) coverage under an auto insurance policy issued by Travelers to the Trigo family. Following a 2008 car accident in which minor Tomas Trigo suffered serious injuries, the at-fault driver's $50,000 liability limit proved insufficient, and the plaintiffs sought a declaratory judgment that the policy's $100,000 UIM limit per vehicle could be stacked to provide $200,000 total coverage because separate premiums were paid for two cars. The court granted summary judgment to Travelers and denied the plaintiffs' motion, holding that the policy's limit-of-liability provision unambiguously capped recovery at $100,000 regardless of the number of insured vehicles or premiums paid. The court found no ambiguity arising from the declarations page or the UIM endorsement and applied Virginia precedent permitting clear anti-stacking language in such policies.
Liberty University and several individuals sued federal officials, challenging the constitutionality of the Affordable Care Act's individual and employer mandates requiring minimum essential health coverage or payment of penalties, along with related religious exemptions and potential funding of abortion services. The district court granted the defendants' motion to dismiss the case for lack of jurisdiction and failure to state a claim. The court found the claims unripe because the provisions do not take effect until 2014, plaintiffs lacked standing on certain issues, and the mandates were within Congress's taxing and commerce powers without violating religious liberty or free association rights under the exemptions provided. The opinion addressed but rejected novel characterizations of the claims as involving compelled speech or association.