District Court, S.D. Iowa — appointed by William Jefferson Clinton
United States v. Shipley
District Court, S.D. Iowa · 2011-11-18 · cited 1×
In United States v. Shipley, the defendant, who had pled guilty to receipt of child pornography and been sentenced to incarceration followed by supervised release with various special conditions, moved under 18 U.S.C. § 3583(e)(2) to modify or strike several conditions related to computer use, camera possession, contact with minors, and treatment. The court granted the motion in part by revising the computer and internet restriction to require prior probation officer approval along with monitoring and disclosure rules, but denied the remaining requests. The core reasoning was that conditions of supervised release must be reasonably related to the § 3553(a) sentencing factors, involve no greater liberty deprivation than necessary, avoid unconstitutional vagueness, and permit only limited delegation to the probation office, with the other challenges deemed unripe because the defendant had not yet begun supervision and presented only hypothetical concerns.
criminal lawprocedure
Archer Daniels Midland Co. v. ECO, Inc.
District Court, S.D. Iowa · 2011-10-31 · cited 2×
The case concerns a contract dispute between Archer Daniels Midland Company and two Eco entities over the supply and warranties for equipment installed in ADM's Iowa cogeneration plant. ADM and Old Eco reached an agreement in July 2005 following proposals that included warranty terms limiting liability to one year from delivery or startup and excluding consequential damages; after Old Eco sold assets to Eco 2007, the parties disputed which entity bore responsibility for any claims. The court addressed cross-motions for summary judgment, examining whether the warranty disclaimers were incorporated into the contract, the timing of any breach notice, and whether Eco 2007 assumed Old Eco's liabilities under exceptions to the general rule of successor non-liability in Iowa law, such as through express or implied agreement in the asset purchase agreement. The opinion analyzes factual records of proposals, meetings, and the APA to determine the scope of any assumed contract obligations versus tort claims.
business & regulatorytorts & liabilityprocedure
Stowers v. Donahoe
District Court, S.D. Iowa · 2011-10-19 · cited 1×
In this case, a postal service employee sued the Postal Service, his national union, and local union branch, alleging that management repeatedly violated the collective bargaining agreement by forcing non-overtime-desired-list carriers to work mandatory overtime before exhausting the overtime-desired list, and that the unions failed to pursue or resolve related grievances in a timely or effective manner. The court addressed motions to dismiss filed by the Postal Service and the unions. The court denied the motions in relevant part, holding that the plaintiff had stated a plausible claim that the union breached its duty of fair representation by allowing grievances to languish without obtaining a binding or precedential resolution, which could excuse the usual exhaustion requirement for hybrid claims against the employer. The reasoning centered on the allegations that the unions' handling of overtime grievances created ongoing harm and rendered the grievance process ineffective.
labor & employmentprocedure
National Instruments Corp. v. Ensoft Corp.
District Court, S.D. Iowa · 2011-09-30
The case concerns National Instruments' allegations that EnSoft infringed two patents ('254 and '270) covering computer-implemented methods for detecting differences between graphical programs by creating data structures, matching objects, determining differences, and displaying them. Following PTO reexamination prompted by EnSoft, in which certain claims were initially rejected as obvious over prior art like the Horwitz article on textual program differencing, the parties filed claim construction briefs and EnSoft moved for summary judgment. The court addressed the motion and constructions, focusing on terms such as 'graphical programs' and 'graphical code,' the effect of prosecution history disclaimers or estoppel from reexamination arguments distinguishing textual prior art, and whether genuine disputes existed on infringement or validity issues.
business & regulatoryprocedure
Dowie v. Osburn
District Court, S.D. Iowa · 2011-09-27 · cited 1×
This case involves defendants' attempt to remove a state court action filed by plaintiff Justin Dowie to federal court on the basis of diversity jurisdiction under 28 U.S.C. § 1332. The court found multiple deficiencies in the amended notice of removal, including an insufficient allegation of the corporate defendant's principal place of business, an inadequate statement that the amount in controversy exceeds $75,000 exclusive of interest and costs, and a potential lack of complete diversity because one defendant shared Iowa citizenship with the plaintiff at the time the original petition was filed. The court explained that defendants bear the burden of establishing jurisdiction and that speculation or conclusory assertions do not suffice, citing precedents on the timing of citizenship assessments and the requirements for removal. It therefore ordered defendants to file a further amended notice addressing these issues by a set deadline.
procedure
Northland Truss System, Inc. v. Henning Construction Co.
District Court, S.D. Iowa · 2011-09-07
In this case, Northland Truss System sued Henning Construction seeking to vacate an arbitrator's order that joined Northland to an ongoing arbitration proceeding arising from the collapse of a barn built using trusses supplied under a 2007 contract between the parties. Northland asserted federal question jurisdiction under 28 U.S.C. § 1331 on the ground that the arbitrator manifestly disregarded federal law, and alternatively sought declaratory relief under the Declaratory Judgment Act. The court granted Henning's motion to dismiss, holding that the federal question claim was patently meritless because the complaint failed to show the arbitrator was aware of and intentionally disregarded governing precedent. The court also declined to exercise declaratory jurisdiction, reasoning that it would improperly interfere with the pending arbitration and exceed the limited review authority provided by the Federal Arbitration Act, which applies only to final awards rather than interim orders. The case was dismissed without prejudice.
procedurebusiness & regulatory