The case involved a plaintiff suing his long-term disability insurer under ERISA for denied benefits under an employer-sponsored plan, plus a Pennsylvania state law bad faith claim. The defendant moved to dismiss the state claim as preempted by ERISA and to strike demands for punitive damages and a jury trial. The court granted the motions, holding that ERISA preempts state laws relating to employee benefit plans and that the bad faith statute, even if it regulates insurance, is barred because it authorizes remedies like punitive damages outside ERISA's exclusive enforcement scheme. The court further noted that ERISA benefit claims are equitable, with no right to a jury trial.
This diversity case involves an employee who was terminated after a drug testing facility reported a positive result for marijuana from a random test arranged by his employer. The plaintiff claimed the lab performed the test negligently, leading to an erroneous result and his firing. The court considered the defendant's motion for summary judgment, which turned on whether Pennsylvania law would recognize a duty of care owed by the testing facility directly to the tested employee. Relying on existing precedent from Pennsylvania intermediate courts that declined to impose such a duty in third-party testing scenarios, the court predicted that the state supreme court would not recognize the duty and would instead leave any new protections to the legislature. The court therefore granted summary judgment to the defendant.
The case concerned a challenge under 42 U.S.C. § 1983 to the Pennsylvania Department of Public Welfare's determination that a nursing home resident was ineligible for Medicaid benefits until 2002 due to her husband's purchase of irrevocable commercial annuities with joint assets. The plaintiff argued that the annuities were for the sole benefit of the community spouse, were purchased for fair market value, and were actuarially sound, thus falling within exceptions in 42 U.S.C. § 1396p(c)(2) to the transfer penalty rules. The DPW maintained that the transfers were made with the intent to qualify for Medicaid and could still trigger ineligibility under the Medicare Catastrophic Coverage Act and related state regulations, even absent a below-market transaction. The court analyzed the federal statutory scheme, including spousal protections and actuarial soundness criteria from Transmittal 64, and concluded that no precedent supported imposing a penalty period for the purchase of actuarially sound annuities at fair market value for a spouse's sole benefit.
This case involves a Philadelphia police officer who was terminated after a drug test conducted by Drugscan, Inc. on behalf of the police department returned positive for marijuana, which the officer attributed to passive exposure during an on-duty investigation. The plaintiff sued Drugscan for negligence, among other claims, alleging failures in handling, testing, and record-keeping of his urine sample that led to his suspension and firing. The court granted Drugscan's motion to dismiss the negligence count, holding that the plaintiff failed to state a claim under Pennsylvania law. The core reasoning was that a drug testing laboratory owes no duty of care to an employee when performing tests solely for the employer, as there is no physician-patient relationship or other basis for liability, and the plaintiff was not a third-party beneficiary of the contract between the lab and the city.
This case involves Buckingham Township's challenge to federal and state approvals for improving U.S. Route 202 and building an interchange, alleging that agencies used flawed data and violated requirements under the APA, NEPA, FAHA, Clean Air Act, National Historic Preservation Act, and related state laws. The court reviewed the voluminous administrative record on cross-motions for summary judgment under APA standards, which limit review to the existing record without new fact-finding. It concluded that defendants complied with statutory mandates, as traffic projections and adjustments were adequately supported and explained, reasonable alternatives including rail options were considered, and environmental and historic preservation processes were properly followed. The court granted summary judgment to the defendants, finding no basis to set aside the project approvals.
This case is an appeal from a bankruptcy court order denying creditors Interpool Limited and Trac Lease relief from the automatic stay to sue non-debtor USA Waste in state court over transactions involving the debtors' waste management business. The district court affirmed that claims alleging alter ego, joint venture, and agency liability against USA Waste were property of the bankruptcy estate and thus subject to the stay, as the trustee had not abandoned them, and found no abuse of discretion in denying stay relief. It remanded for clarification on the separate tortious interference claim, which the court determined was not subject to the automatic stay but might still be addressed through the bankruptcy court's equitable powers under 11 U.S.C. § 105(a). The decision rested on de novo review of legal conclusions regarding estate property and discretionary review of the stay determination.