Gentex sued former employees Sutter and Walko along with their new employer Armor for violations of the Computer Fraud and Abuse Act, the Pennsylvania Uniform Trade Secrets Act, breach of contract, and tortious interference, alleging that the employees copied and shared proprietary files related to Advanced Combat Helmet designs in violation of nondisclosure agreements. The court granted default judgment against Sutter and Walko based on their intentional destruction of relevant electronic evidence, including files on CDs, thumb drives, and computers after litigation holds were implemented, which caused irretrievable prejudice to Gentex. The motion was denied as to the corporate defendants because genuine issues of material fact remained regarding whether Armor engaged in spoliation through premature lifting of the litigation hold or destruction of backup tapes. The court found default judgment proportional for the individuals due to the willful nature of the destruction, the resulting prejudice, and the need for deterrence in cases involving electronic evidence.
This case involved a minor student whose cell phone was confiscated by school officials for violating school policy, after which officials searched the phone, found explicit self-taken photos, and turned it over to county law enforcement. Prosecutors then threatened felony child pornography charges unless the student completed a re-education course on sexual violence, and the student sued county officials and the county alleging unreasonable searches and seizures under the Fourth Amendment as well as First Amendment violations regarding the protected images, seeking both equitable relief and damages. The court denied the defendants' motion for judgment on the pleadings under Rule 12(c), reasoning that the allegations sufficiently stated claims against the county for municipal liability based on failure to train or supervise investigative functions, as opposed to prosecutorial decisions, and that factual disputes could not be resolved at this stage.
In Bryan v. Astrue, the plaintiff sought Social Security Disability Insurance benefits based on multiple medical conditions, but an ALJ denied the claim after finding that only one impairment was severe and that the plaintiff retained residual functional capacity for certain work; the district court and magistrate judge upheld the denial, though the Third Circuit remanded for further consideration of the back impairment's impact and the ALJ's evaluation of the plaintiff's testimony and conflicting medical evidence. Following the partial remand, the plaintiff moved for attorneys' fees and costs under the Equal Access to Justice Act. The court denied the motion, holding that the government's position was substantially justified because it had a reasonable basis in both law and fact, including established precedent on an ALJ's discretion to assess credibility and weigh subjective complaints of pain against other evidence, and because the Third Circuit had affirmed most of the ALJ's findings. The decision emphasized that the EAJA is not a loser-pays statute and that the government's prelitigation and litigation positions need only be reasonable, not correct.
This case involves an insurance company's complaint seeking a declaratory judgment that it has no duty to defend or indemnify several defendants against claims in underlying consolidated federal litigation arising from a kickback scheme involving juvenile detention facilities in Luzerne County. The defendants, including operators of the facilities and related entities, moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6). The court denied the motion, holding that the underlying complaints alleged knowing violations of constitutional rights through false imprisonment and related conspiracy claims that fell within policy exclusions for expected or intended injury and knowing violations of rights under Coverage A and B. Because the duty to indemnify is narrower than the duty to defend, the absence of a duty to defend also supported the insurer's position on indemnity.
In Rockledge Development Co. v. Wright Township, the plaintiff mortgage holder sued the township and its supervisors under 42 U.S.C. § 1983, claiming a violation of Fourteenth Amendment procedural due process. The company alleged that the township's decision to withhold building and zoning permits from the property owners—without notifying the mortgagee—deprived it of its property interest in the mortgaged lot. The court granted the defendants' motion for summary judgment, holding that no deprivation of a protected property interest occurred. Drawing on persuasive precedent, the opinion reasoned that the township's actions did not immediately or drastically diminish the mortgagee's interest, as the company retained the ability to foreclose or take possession upon default, unlike cases involving tax sales. Because the first element of a procedural due process claim was unmet, the court did not reach issues of timeliness or available procedures.
This case involves Pennsylvania residents suing Southwestern Energy Production Company over alleged groundwater contamination from hydraulic fracturing and drilling at a nearby well, which exposed them to toxic chemicals and reduced their property values; the plaintiffs asserted claims including negligence, private nuisance, strict liability, and trespass. The defendant moved to dismiss the strict liability count and emotional distress damages except as to one plaintiff. The court denied dismissal of strict liability, holding that the complaint sufficiently pleaded facts supporting an abnormally dangerous activity under Restatement (Second) of Torts §520 factors, while dismissing emotional distress claims for all but plaintiff C.S. due to the lack of alleged physical injury and granting leave to amend for inconvenience and discomfort damages.