This case concerns a dispute in bankruptcy proceedings over a security interest in a mobile home purchased in Virginia by the bankrupt and his wife. The Philadelphia National Bank held a properly perfected lien under Virginia law, noted on the certificate of title, but did not file any documentation of the lien in New York after the home was moved there. The bankruptcy trustee claimed superior title to the vehicle, and the referee ruled in the trustee's favor based on the bank's failure to refile within four months under UCC Section 9-103(3). On review, the court held that Section 9-103(4) controlled instead, because the property was covered by a certificate of title requiring indication of the security interest for perfection, making Virginia law determinative and eliminating any need to refile in New York. The court therefore vacated the referee's order and granted the bank's petition for reclamation of the mobile home.
In Wright v. McMann, a state prisoner confined at Clinton State Prison sued under the Civil Rights Act (42 U.S.C. §§ 1981, 1983, 1985) and 28 U.S.C. § 1343, alleging that prison officials assaulted him, placed him in unsanitary solitary confinement without clothing or adequate warmth, denied him access to legal materials and religious services, and subjected him to other punitive conditions following a disciplinary violation. The district court granted the defendant's motion to dismiss the complaint for failure to state a claim. The court reasoned that the complaint did not allege exceptional circumstances warranting federal interference in the internal management of state prisons, failed to demonstrate a violation of the plaintiff's rights under the Eighth or Fourteenth Amendments, and that the plaintiff was required to exhaust available state court remedies before seeking relief in federal court, as no showing was made that such remedies were inadequate.
In Cowen v. New York Stock Exchange, the plaintiff, a former securities salesman registered with the Exchange, alleged that the Exchange and his employer Mohawk Valley Investing Company conspired to terminate his employment and block his future work in the securities business after he engaged in an improper bond purchase and resale that violated Exchange rules, seeking treble damages under the Sherman and Clayton Acts. The court converted the defendants' motions into ones for summary judgment under Rules 12 and 56 and granted them, dismissing the complaint. The core reasoning was that the plaintiff offered no evidence the Exchange acted to block his further employment, that any related issues appeared addressed in prior arbitration between the plaintiff and Mohawk, and that the antitrust conspiracy claim therefore could not be sustained on the record.
This case concerned whether an active-duty U.S. Air Force member, injured while working off-duty as a bartender at a base exchange tavern, qualified for workers' compensation benefits under the Nonappropriated Fund Instrumentalities Act (5 U.S.C. § 150k-1), which extends Longshoremen's Act coverage to civilian employees of nonappropriated fund instrumentalities. The Deputy Commissioner found coverage and awarded benefits based on combined military and civilian earnings, but the insurance carrier and employer sued to set aside the order. The court held that the claimant was not a 'civilian employee' under the statute and vacated the award. It reasoned that the statutory language explicitly requires civilian status, that military personnel receive separate disability retirement benefits for such injuries, and that ignoring the word 'civilian' would improperly amend the statute rather than interpret it.
The case involved a plaintiff suing General Motors for allegedly converting a Chevrolet dealership agency valued at two million dollars, which she claimed belonged to a corporation of which she was the principal stockholder. The defendant moved to dismiss the complaint, arguing that the action was barred by the statute of limitations and that the plaintiff lacked the capacity to sue individually as a stockholder for harms to the corporation. The court granted the motion to dismiss, holding that a stockholder cannot maintain an individual action for conversion of corporate assets, as any such claim belongs to the corporation itself, and the corporate entity could not be disregarded without allegations of fraud or subterfuge. The court did not reach the statute of limitations defense.
In Dwight v. United States, shareholders of a corporation whose property had been condemned by New York State for highway purposes sought to recover income taxes assessed against them as transferees after the IRS disallowed nonrecognition of gain under Section 337 of the 1954 Internal Revenue Code. The corporation had adopted a plan of liquidation after the state filed its map vesting title but before the amount of just compensation was finally determined and paid. Following its earlier decision in Driscoll Bros. & Co. v. United States, the court held that the involuntary transfer constituted a “sale” on the date title passed, so the liquidation plan came too late to qualify for Section 337 treatment. The motion to dismiss the refund suit was therefore granted.
