District Court, W.D. Pennsylvania — appointed by William Jefferson Clinton
International Ass'n of MacHinists & Aerospace Workers v. US Airways, Inc.
District Court, W.D. Pennsylvania · 2003-10-21
This case involves a labor dispute under the Railway Labor Act between the International Association of Machinists and Aerospace Workers and US Airways over the airline's plan to subcontract heavy maintenance work (S-Checks) on Airbus aircraft. The union argued that the subcontracting violated the scope-of-work provisions in the parties' collective bargaining agreement, which prohibits farming out covered work except in limited circumstances, and sought injunctive relief to maintain the status quo. The court determined that the dispute qualified as a major dispute rather than a minor one because it concerned an attempt to modify the existing agreement rather than merely interpret it. As a result, the court had authority to issue injunctive relief to preserve the status quo pending statutory settlement procedures under the RLA, without the usual equitable balancing required for minor disputes.
labor & employmentbusiness & regulatory
Sesac, Inc. v. Wpnt, Inc.
District Court, W.D. Pennsylvania · 2003-09-23
This case involved a copyright infringement lawsuit by SESAC against WPNT, Inc. for unauthorized broadcasting of songs, where a jury awarded substantial statutory damages on a per-song basis after finding willful infringement. The defendants moved for a new trial on damages or remittitur, arguing the verdict was excessive and should be reduced to a lump sum or aligned with license costs. The court denied the motion, holding that the jury followed the per-song verdict slip and instructions requested by the defendants, properly evaluated evidence of willfulness and credibility, and awarded damages within the statutory range that included a deterrent effect. The opinion stressed that the court would not substitute its judgment for the jury's fact-finding or Congress's statutory framework.
propertyprocedure
Doe v. Ward
District Court, W.D. Pennsylvania · 2003-09-16 · cited 4×
This case arose when plaintiff John Doe challenged Pennsylvania officials' application of Megan's Law community notification requirements to his out-of-state sex offense conviction, claiming lack of due process; although Doe brought federal constitutional claims under 42 U.S.C. § 1983, the court granted summary judgment and injunctive relief on state-law grounds under the Interstate Compact Concerning Parole, finding that the state could not impose notification without affording the same process given to in-state offenders. The defendants withdrew their appeal, making Doe the prevailing party. Doe then petitioned for attorneys' fees and costs under 42 U.S.C. § 1988. The court applied the lodestar method, requiring the fee applicant to document reasonable hours and market rates while allowing the opposing party to object with specificity, and explained that it would adjust the award for excessive, undocumented, or unsuccessful work but would not reduce fees on grounds not raised by the defendants.
civil rightscriminal lawprocedure
United States v. Bingham
District Court, W.D. Pennsylvania · 2003-07-08 · cited 1×
The case involved a defendant indicted on federal charges of conspiracy to distribute crack cocaine and heroin as well as possession with intent to distribute, who sought to suppress evidence seized pursuant to an anticipatory search warrant executed after a controlled buy at a co-defendant's residence. Following a suppression hearing, the district court orally denied the motion, after which the defendant entered a guilty plea; this memorandum opinion addresses the warrant issue in greater detail. The court explained that anticipatory warrants must satisfy the Fourth Amendment's probable-cause requirement at the time of issuance, not merely after the triggering event occurs, and found the supporting affidavit deficient because it lacked facts linking the anticipated drug transaction to the new premises or explaining the basis for expecting a crack buy within 72 hours. Nevertheless, the court denied suppression of the evidence, relying on the good-faith exception articulated in cases such as United States v. Loy and United States v. Williams.
criminal lawprocedure
Cary v. ALLEGHENY TECHNOLOGIES INC.
District Court, W.D. Pennsylvania · 2003-06-12
This case involved two Title VII claims of sex discrimination by plaintiff Cary against her employer Allegheny Technologies, alleging failure to promote her to Vice President of Human Resources and discriminatory discharge. After a jury trial that ended in a split verdict—finding for the company on the promotion claim but for the plaintiff on the discharge claim—the company filed a renewed motion for judgment as a matter of law or a new trial, challenging the sufficiency of the evidence, the admission of certain testimony, the weight of the evidence, and a supplemental jury instruction given after deadlock. The court denied the motion in full, concluding that the evidence supported an involuntary and discriminatory termination independent of the promotion claim, that the disputed evidence was relevant mainly to the claim on which the company prevailed, and that the modified Allen charge was appropriate in this civil context because it urged jurors not to surrender honest beliefs while emphasizing the costs of retrial. The court noted the civil rules' focus on just, speedy, and inexpensive resolution distinguishes such instructions from their use in criminal cases.
labor & employmentcivil rights
Krasinski v. Walsh (In Re Denochick)
District Court, W.D. Pennsylvania · 2003-01-14 · cited 1×
The case was a bankruptcy appeal in which the trustee sought to recover from the appellants, who had guaranteed a loan to the debtor, payments the debtor made to the lender in the year before filing for bankruptcy. The bankruptcy court held that the appellants qualified as creditors under the Bankruptcy Code because the payments reduced their contingent liability on the guarantee, and that the payments were not in the ordinary course of business. The district court affirmed, ruling that guarantors fall within the broad definition of creditor and that the appellants failed to carry their burden of showing the ordinary-course exception applied.
business & regulatory