This case involved a plaintiff's products liability, negligence, and breach of warranty claims under Pennsylvania law against Medtronic concerning its MMT-522 Paradigm insulin pump and glucose monitoring system, a Class III medical device that received FDA premarket approval. The court granted the defendant's motion for summary judgment on all claims except the breach of express warranty claim. The core reasoning was that the Medical Device Amendments of 1976 expressly preempt state-law claims that impose requirements different from or in addition to federal ones applicable to PMA-approved devices, and the remaining claims either failed to identify parallel federal requirements or did not satisfy the summary judgment standard on issues such as manufacturing defects and failure to warn.
This case is a slip-and-fall negligence action brought by plaintiff Marion Felix against grocery store operator GMS, Zallie Holdings, Inc. and bottler Canada Dry Delaware Valley Bottling Company after she fell on a puddle of clear liquid in a frozen-food aisle at a ShopRite in Philadelphia. Both defendants moved for summary judgment, contending there was no evidence they had actual or constructive notice of the hazard or that Canada Dry created it. The court granted the motions under Pennsylvania premises-liability law, holding that the record contained insufficient facts from which a reasonable jury could find notice or causation, including the lack of evidence about how long the liquid had been present or its source. The court applied the summary-judgment standard requiring the non-moving party to show a genuine issue of material fact and found the plaintiff had not done so.
The case involved pro se petitioners who sought to vacate a FINRA arbitration award against E*Trade Securities under the Federal Arbitration Act, claiming the brokerage failed to execute stock trades properly and that the arbitration panel committed procedural errors. After the petitioners encountered repeated difficulties serving E*Trade despite its awareness of the filing, the court entered a default against the company. On E*Trade's motion to set aside the default, the court granted the motion but ordered E*Trade to pay the petitioners' costs and expenses of service plus a $10,000 sanction to the court, based on findings that E*Trade had engaged in dilatory conduct and failed to cooperate with service efforts.
This case involved parents of a student with Prader-Willi Syndrome and other disabilities who sued Nazareth Area School District under the Individuals with Disabilities Education Act (IDEA), claiming the district denied their child a free appropriate public education (FAPE) by failing to provide adequate physical therapy, sensory occupational therapy, executive functioning services, and transition planning, and seeking compensatory education. The court reviewed cross-motions for judgment on the administrative record following a due process hearing where the hearing officer had ruled in the district's favor. The court granted the district's motion, denied the parents' motion, and affirmed the hearing officer's decision, finding no denial of FAPE because the district had appropriately provided or offered the required services, transition plans were individualized and effective, any delays in services were not attributable to the district, and the administrative findings were supported by the record. The decision rested on deference to the hearing officer's evaluation of evidence, including progress reports and IEP documentation showing the student made meaningful educational gains.
The case concerned whether a physician's assistant employed by Crozer-Chester Medical Center qualified for the Fair Labor Standards Act's bona fide professional exemption from overtime pay. The court had previously granted summary judgment to the plaintiff, holding that his license to practice medicine only under physician supervision did not meet the requirements of the Department of Labor regulations interpreting the exemption. On the defendant's motion for reconsideration, the court examined the specific facts of the plaintiff's employment, job duties, licensing, and the text of the relevant regulations from both 1973 and 2004 versions, concluding that the plaintiff was not exempt and was entitled to overtime compensation. The court denied the motion, finding no clear error of law or manifest injustice, and also declined to certify the order for interlocutory appeal.
This case involves plaintiff Richard Nolan's claims against his former employer Arkema, Inc. for disability discrimination under the Americans with Disabilities Act and the Pennsylvania Human Relations Act after his termination in 2007 following a medical leave for intermittent explosive disorder and other conditions. Nolan alleged that Arkema failed to accommodate his restrictions, filled his shift supervisor position while he was out, and terminated him rather than allowing his return to work. The court denied Arkema's motion for summary judgment, finding genuine issues of material fact as to whether Nolan was disabled under the statutes, whether he was qualified for his position with or without reasonable accommodation, and whether Arkema's stated reasons for termination were pretextual, including evidence of a potential "100% healed" policy that could support a finding of discrimination.
