This case was a class action lawsuit brought by inmates of Lehigh County Prison alleging that overcrowded and unsanitary conditions violated their Eighth and Fourteenth Amendment rights under 42 U.S.C. § 1983. The parties settled via a 1990 consent decree that imposed population caps, monitoring requirements, and other operational standards at the old facility, which was later replaced by a new prison. Defendants moved to terminate the decree under the Prison Litigation Reform Act's termination provision, 18 U.S.C. § 3626(b)(2), while plaintiffs challenged the provision's constitutionality and sought modification instead. The court rejected the constitutional challenges, held the termination provision valid, and granted the motion to end the decree because no current and ongoing constitutional violations existed. The ruling rested on statutory interpretation of the PLRA and findings that the decree's remedial purposes had been fulfilled by the new facility.
In United States v. Rankin, defendant Kevin Rankin, proceeding pro se, petitioned for a writ of coram nobis to vacate his 1989 convictions under 18 U.S.C. §§ 1001 and 1503 for making false statements and obstructing justice, which stemmed from an affidavit filed in a prior narcotics case; he also moved to reassign the case outside the Eastern District of Pennsylvania and to disqualify the U.S. Attorney’s Office. The court denied the petition and both motions. It found no basis under 28 U.S.C. §§ 144 or 455(a) for reassignment or disqualification, as no reasonable person would question the impartiality of judges in the district or the assigned judge based on events in the earlier case. The court further held that coram nobis relief was unavailable because Rankin failed to show that the convictions were invalid or produced continuing adverse consequences not also attributable to his separate narcotics conviction.
This case involved a lawsuit by a football referee against a college football player who assaulted him during a game at a state university. The plaintiff sought damages under 42 U.S.C. § 1983, claiming the defendant acted under color of state law by violating his constitutional rights. The court dismissed the case for lack of subject matter jurisdiction, holding that the player was not a state actor despite being on scholarship at a public institution and participating in a state-subsidized athletic program. The reasoning centered on insufficient state involvement in the player's conduct under multiple tests for determining state action, as the assault was a private act not fairly attributable to the state.
This case involved shoe manufacturers Hyde and Saucony suing their insurers for defense costs and indemnity related to liability in a federal CERCLA action over cleanup of a contaminated Pennsylvania landfill where the companies had disposed of hazardous waste. The court denied the plaintiffs' motion for partial summary judgment on the duty to defend and granted the defendant insurers' motions for summary judgment on all counts. The court held that the pollution exclusion clauses in the comprehensive general liability policies unambiguously barred coverage because the contamination resulted from gradual, not sudden and accidental, pollution. It rejected arguments that the exclusion was ambiguous or that the insurers had engaged in bad faith based on regulatory history or policy handling.
In Geiger v. AT & T Corp., plaintiff Carl Geiger sued his former employers AT & T and Devon Consulting after his work as an outsource contractor ended in 1993, claiming age discrimination under the ADEA and promissory estoppel based on statements made when he accepted an early retirement package in 1986. The court granted the defendants' motions for summary judgment. It found that Geiger failed to establish a prima facie case of age discrimination because AT & T's policy barring former employees from contractor roles applied to all former employees regardless of age or retirement status, and there was no evidence the policy was a pretext for discrimination. The promissory estoppel claim failed because any alleged promise of continued contractor work was not sufficiently clear or enforceable to override the at-will nature of the arrangement or create indefinite employment expectations. Related state-law claims were either time-barred or preempted by the Pennsylvania Human Relations Act.
This ERISA class action was brought by retirees from Sperry, Burroughs, and Unisys corporations challenging the company's 1992 termination of pre-existing post-retirement medical benefit plans, which had provided lifetime coverage, and their replacement with a new plan requiring increasing retiree contributions. The retirees asserted claims for breach of contract (based on alleged vesting of benefits), equitable estoppel, and breach of fiduciary duty under ERISA § 404(a). Prior rulings had granted Unisys summary judgment on contract and estoppel claims for most subclasses and after trial for the Sperry contract claims, while reinstating the fiduciary duty claims for all classes. In the present memorandum, the court addressed pending motions for summary judgment and partial summary judgment, analyzing the statute of limitations under 29 U.S.C. § 1113, the applicability of equitable tolling due to alleged misrepresentations, and the relief available, denying the Sperry retirees' motion while granting Unisys' motions in part and deferring in part.
