Philip Pratt

This case involved consolidated actions by female AFDC welfare recipients and related organizations against the director of Michigan's Department of Social Services, seeking declaratory and injunctive relief to block the state's practice of publicly disclosing recipients' names, addresses, and benefit amounts upon request via a standard form. The disclosures had enabled abusive former partners to locate and harm some plaintiffs, prompting fears of recurrence. After consolidating the cases, addressing jurisdiction, and reviewing stipulated facts, the court certified a class of similarly situated recipients and granted summary judgment to the plaintiffs. The core reasoning was that the Michigan statute and policy were inconsistent with federal confidentiality mandates in the Social Security Act's AFDC provisions, as limited by the Jenner Amendment.

civil rightsfederal power

This case involved trust funds established for laborers seeking to recover unpaid pension, vacation, and health contributions from a surety company under the Miller Act for work performed by a subcontractor on a federal Coast Guard repair project. The defendant moved to dismiss the claims, which the court treated as a summary judgment motion after considering materials outside the pleadings. The court granted the motion in part and denied it in part, allowing recovery only for $14,219.31 in contributions owed for work through May 31, 1987, while dismissing claims for later work. The core reasoning centered on the Miller Act's notice requirements, which mandate that claimants provide timely written notice to the prime contractor within 90 days of the last labor performed for each claim, with the Act to be liberally construed to protect workers but with strict adherence to the notice proviso.

labor & employmentbusiness & regulatoryfederal power

Michigan Bell Telephone Company sued the Drug Enforcement Administration to recover approximately $24,800 in costs incurred from complying with subpoenas for subscriber and toll records issued in 1986 and 1987, and to establish a fee schedule for future requests. The court considered the defendant's motion to dismiss, treated as one for summary judgment due to evidence outside the pleadings. The court granted summary judgment to the DEA, holding that the Electronic Communications Privacy Act does not provide a cause of action allowing recovery of aggregate compliance costs from multiple requests, but instead requires challenges to individual subpoenas on a piecemeal basis. The decision was based on the statutory language and intent of 18 U.S.C. § 2706, which limits judicial review to specific disputes rather than overall burdensomeness of agency requests.

criminal lawbusiness & regulatoryfederal power

The case concerned a Chapter 11 bankruptcy reorganization of U.S. Truck Co., a trucking company, in which the debtor rejected its collective bargaining agreement with the Teamsters union after the bankruptcy court found rejection necessary to prevent collapse due to unsustainable losses. The union's negotiating committee filed claims for rejection damages exceeding $5 million, which the bankruptcy court largely awarded after trial, calculating lost wages as the difference between the original contract rates and post-rejection pay for affected employees. On appeal, the district court affirmed the standing of the committee to represent union members under labor laws such as the LMRA and NLRA, upheld damages for individual employees' lost wages including post-rejection amounts, but reversed any recovery of union dues. The court also disallowed claims for employees not properly listed or whose positions were eliminated without replacement by contractors.

labor & employmentbusiness & regulatory

The South Macomb Disposal Authority, a municipal body operating landfills, sued the EPA to challenge the constitutionality of CERCLA (as amended by SARA) after the EPA notified it of potential liability for hazardous waste contamination and sought a remedial investigation and feasibility study. The EPA moved to dismiss, arguing lack of subject matter jurisdiction, no case or controversy, and meritless claims. The court held that it lacked jurisdiction because CERCLA's review provisions, particularly section 113(h), bar pre-enforcement challenges to the statute's overall scheme, allowing constitutional issues to be raised only later if the EPA brings an enforcement or reimbursement action. It reasoned that Congress validly limited federal court jurisdiction by providing an adequate opportunity for review in subsequent proceedings, dismissing the suit without reaching the merits.

environmentfederal powerprocedurebusiness & regulatory

The case involves MGA, Inc.'s patent infringement lawsuit against Centri-Spray Corp. alleging that two of its mechanical accumulator products infringe U.S. Patent No. 3,570,656. Following a trial on Centri-Spray's defenses of laches and estoppel, the court determined that while the Rudlaff design was barred by these defenses, the Plumridge design was not, because the accumulation control feature central to the infringement claim differed substantially between the two devices. The court reasoned that laches could not be tacked from the earlier design to the later one without substantial similarity in the infringing activity, and since the control mechanisms operated differently, the claim against the Plumridge device could proceed.

business & regulatoryprocedure

The case involved Michigan Environmental Resources Associates suing Macomb County after the county board rejected its application to build a sanitary landfill site, alleging arbitrary decision-making and violations of due process rights under the U.S. and Michigan Constitutions as well as 42 U.S.C. § 1983. The court addressed whether the plaintiff had a constitutionally protected property interest arising from its landfill application under the county's solid waste management plan. The court granted the county's motion for summary judgment and dismissed the case, holding that no such property interest existed because the board retained substantial discretion to approve or reject sites even after favorable recommendations from review committees. The reasoning emphasized that the plaintiff held only a unilateral expectation rather than an entitlement, distinguishing the situation from cases involving granted licenses or court-ordered certificates of need, and noting the lack of supporting Michigan law or prior state court findings.

environmentpropertyprocedurecivil rights

The case involved Key Manufacturing Group suing Microdot for patent infringement regarding capped wheel nuts used in automobiles, specifically alleging that Microdot's products infringed U.S. patent 4,123,961 and its reexamined version either literally or under the doctrine of equivalents. The court determined that the patent was valid, that Microdot infringed under the doctrine of equivalents, and that the amended claims were substantively identical to the originals under 35 U.S.C. § 252, allowing liability for infringement prior to the reexamination certificate. The core reasoning was that the patent described a stainless steel cap welded to the nut body using a continuous ring or nubs on the cap face without affecting corrosion resistance or hardness, that prior art like the Luce patent did not render the invention obvious, and that claim amendments were clarifications rather than substantive changes.

business & regulatoryproperty

Mt. Holly Ski Area, a Michigan ski resort, sued Emerson Electric Company and GESCO for negligence and breach of implied and express warranties after purchasing a chairlift system whose 75-horsepower motor failed to operate when fully loaded, causing out-of-pocket costs and lost revenue. GESCO moved for summary judgment under Federal Rule of Civil Procedure 56(c). The court granted the motion, holding that the negligence claims were barred by Michigan’s economic loss doctrine because the dispute involved only economic harm in a contractual setting. The implied warranty claims failed for lack of privity between Mt. Holly and GESCO, and the express warranty claim failed because GESCO made no direct assurances to Mt. Holly and the contract limited remedies to repair or replacement from the manufacturer.

business & regulatoryproceduretorts & liability

The case involved former Michigan Bell management employees who retired between March and June 1982 and sued the company and its plan administrator under ERISA, alleging that misrepresentations about the future availability of benefits under the Management Income Protection Plan (MIPP) caused them to retire without those benefits; the plaintiffs also claimed the statements effectively amended the plan to cover them. The court addressed cross-motions for summary judgment, focusing first on standing and whether MIPP qualified as an ERISA plan. It held that the plaintiffs had standing as participants because they were former employees who could become eligible for plan benefits if their claims succeeded, and MIPP had been established by written instrument in 1980 with ascertainable benefits, beneficiaries, financing, and procedures. The court distinguished contrary precedents, noting that MIPP predated the plaintiffs' retirements and that success on the claims would yield actual plan benefits rather than mere damages.

labor & employmentprocedure

The Laborers’ Pension Trust Fund sued Family Cement Company and its officers Kathryn and Pietro Costa to collect unpaid fringe benefit contributions required under a collective bargaining agreement with the Laborers’ Union. The Costas had operated the business as an unincorporated entity that joined the Associated Cement Contractors of Michigan and later incorporated in 1984 without changing operations, ownership, or notifying the association, after which payments stopped, resulting in a debt of $14,135.19. The court entered judgment against the corporation and held the officers jointly and severally liable under the alter ego doctrine, finding the incorporation was not a bona fide change but a disguised continuance given identical management, business purpose, equipment, and control. It further held that the Fund was entitled to the unpaid contributions plus prejudgment interest and a remedial award of either liquidated damages or double interest under ERISA, 29 U.S.C. § 1132(g)(2), while directing calculation of the exact amounts based on the plan or statutory rates.

labor & employmentbusiness & regulatory

This case involved a class action filed in 1978 by youthful offenders against federal defendants alleging systematic violations of the Youth Corrections Act in classification, segregation, and rehabilitation programs for inmates. After the plaintiffs prevailed on most issues at trial and on appeal, the court had already found the government's position not substantially justified and granted a fee petition under the Equal Access to Justice Act; this opinion addresses the amount of fees and costs. The court awarded fees at the statutory $75 hourly rate without cost-of-living or special-factor increases, reduced certain claimed hours as excessive, and ordered a total of $225,358.63 in fees and costs.

criminal lawprocedurecivil rights

Jeffrey Allen, a Medicaid recipient with end-stage liver disease due to alcoholism, sued Michigan officials after his applications for funding a liver transplant at the University of Chicago were denied under state patient selection criteria requiring a documented two-year period of alcohol abstinence. Allen challenged the criteria as violating the federal Medicaid statute, the Fourteenth Amendment, and the Michigan Administrative Procedures Act. After a bench trial, the court found that the criteria had been developed by committees lacking expertise in alcoholism, statistical data on recidivism, or adequate state support, and that Allen's treating physicians supported the transplant as medically necessary with minimal relapse risk. The court ordered the defendants to approve Medicaid prior authorization for the procedure.

healthcarecivil rightsfederal power

This case is a class action brought by inmates at a federal prison who were sentenced under the Youth Corrections Act (YCA), alleging that the Bureau of Prisons violated the statute by failing to provide individualized treatment and by not segregating YCA inmates from adult prisoners. The court had previously found the Bureau in violation of the YCA and directed remedial measures, with some issues still pending on appeal. Plaintiffs then sought attorneys' fees under the Equal Access to Justice Act (EAJA), and the government conceded that plaintiffs were prevailing parties but argued its position was substantially justified. The court granted the fee motion, holding that the Bureau's pre-litigation conduct and defense were not substantially justified because the agency had intentionally disregarded the YCA's requirements for philosophical reasons, contrary to the statute's text, legislative history, and Supreme Court precedent interpreting it as mandating individualized treatment and segregation.

criminal lawfederal power

The case involved plaintiff Phillip H. Giles, a Black U.S. Postal Service employee terminated in February 1982 after being accused of stealing from the mail, who sued under Title VII of the Civil Rights Act of 1964 alleging racial discrimination because a similarly situated white coworker received only a suspension. The defendant moved for summary judgment, arguing that Giles's administrative complaint was untimely under EEOC regulations requiring contact with an EEO counselor within 30 days of learning of the alleged discrimination. The court analyzed the facts, including Giles's grievance arbitration, his contact with an EEO counselor who advised waiting for the arbitration outcome, and the subsequent formal complaint filed in March 1983, while applying standards from Rule 56 and precedents on genuine issues of material fact. The core reasoning focused on whether the filing deadlines were jurisdictional or subject to equitable tolling and estoppel due to the counselor's advice and the plaintiff's pursuit of the union grievance process.

civil rightslabor & employment

This case involved a lawsuit by McIntyre's Mini Computer Sales Group against several defendants, including Creative Synergy and its employees, alleging they stole the plaintiff's confidential customer list (a trade secret) during software consulting work and sold it to other defendants like Hanson, Delta, CRC, and Newman, with claims under RICO and Michigan common law for misappropriation and fraud. The court had previously dismissed the RICO counts and some fraud claims but allowed the trade secrets count to proceed. The present opinion addressed former defendant Newman's motion for sanctions under Fed. R. Civ. P. 11 (and 28 U.S.C. § 1927) on grounds that the claims against it were frivolous from the outset, along with a request for discovery to support the sanctions motion. The court denied both motions, reasoning that the plaintiff had conducted a reasonable pre-filing inquiry into the facts and law, it was not unreasonable to name Newman as a defendant initially, there was no evidence of bad faith or recklessness, and no extraordinary circumstances justified further discovery on sanctions.

procedurebusiness & regulatorytorts & liability

This case involved a federal civil rights lawsuit under 42 U.S.C. § 1983 brought by an inmate at Jackson Prison who was shot in the knee by a guard during a yard fight involving other prisoners; the plaintiff claimed violations of his Eighth and Fourteenth Amendment rights. A jury awarded the plaintiff $60,000 in actual damages but no punitive damages. The defendants moved for judgment notwithstanding the verdict or a new trial, arguing errors including the application of standards from the later-decided Whitley v. Albers case on use of force in prison disturbances. The court denied the motions, holding that JNOV was unavailable due to the lack of a prior directed verdict motion and that no manifest errors of law or fact justified a new trial, as the evidence showed the plaintiff was not involved in the fight and the shooting was not warranted.

civil rightscriminal lawprocedure

This case involves a distributor of used computer equipment that alleged some defendants stole its confidential customer list and sold it to others, leading to claims under the federal RICO statute as well as Michigan common law for misappropriation of trade secrets and fraud. The defendants moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6). The court analyzed the RICO elements, finding that while an enterprise and racketeering acts were adequately alleged, the complaint failed to plead a pattern of racketeering activity because the predicate acts arose from a single scheme rather than ongoing or multiple schemes, as required by the Supreme Court's guidance in Sedima. As a result, the RICO counts were dismissed, while the state-law claims remained for further consideration.

criminal lawbusiness & regulatoryproceduretorts & liability

This case involves plaintiffs Lawrence and Patricia Zahra seeking recovery of funds from defendant Stanley Charles based on multiple promissory notes issued between 1977 and 1984 with high interest rates. The court ruled on cross-motions for summary judgment, dismissing the RICO claim because the complaint failed to allege a qualifying enterprise separate from the defendant and did not sufficiently plead a pattern of racketeering activity. It denied dismissal of the federal securities fraud claim under the 1934 Act, finding insufficient evidence to determine whether the short-term notes were commercial or investment instruments, and likewise denied dismissal of the Michigan common-law fraud claim due to potential issues of intent. The court granted partial summary judgment on additional amounts owed after applying usury rules but denied other aspects of the usury motion and refused to certify the judgment as final under Rule 54(b).

business & regulatorycriminal lawprocedure

This case is a patent infringement suit in which MGA, Inc. alleged that Centri-Spray Corp. infringed U.S. Patent No. 3,570,656 covering machinery for mass-producing automobiles. After bifurcating the affirmative defenses of laches and estoppel, the court addressed the defendant's motion for summary judgment on those issues. The court held that laches barred recovery for infringement by the pre-1979 "Rudlaff" design because the patentee knew of the activity by 1971 yet waited until 1983 to sue, triggering a presumption of unreasonable delay and prejudice that the plaintiff failed to rebut, while excusable periods such as title disputes did not fully account for the gap; estoppel was not shown because the defendant was not misled; and laches could not be decided on summary judgment for the post-1979 "Plumridge" design due to factual uncertainty about when the plaintiff learned of it.

business & regulatoryprocedure