This case concerned whether condominium association fees assessed after a debtor filed a Chapter 13 bankruptcy petition constitute pre-petition claims dischargeable under 11 U.S.C. § 1328(a) or post-petition claims that are not. The debtor had owned a condominium unit subject to ongoing assessments by the Maple Forest Condominium Association, had filed for bankruptcy while in arrears, and retained title to the property despite surrendering it in the plan, with no foreclosure yet completed by secured creditors. The bankruptcy court had ruled that all such fees were pre-petition claims subject to discharge, but the district court reversed that determination in part, holding that assessments for periods after the petition date are post-petition claims. The core reasoning was that the Bankruptcy Code defines dischargeable debts as those arising from pre-petition claims, while post-petition obligations generally remain the debtor's responsibility, and the fees here accrued based on the debtor's continuing ownership interest after filing.
This case involves an appeal from a bankruptcy court's confirmation of a Chapter 13 plan, centering on the valuation of a debtor's real property subject to a judgment lien. The creditor argued that the debtor made a binding judicial admission in an adversary proceeding answer stating the property was worth $975,000, which should have required the court to accept that higher value instead of the $575,000 figure used in the plan. The district court affirmed the bankruptcy court's order confirming the plan, holding that the isolated and contradictory statement did not constitute a binding judicial admission material to the bankruptcy. The court reasoned that the bankruptcy court had properly weighed evidence from hearings, including testimony on market conditions, to determine the property's value on the petition date.
The case involved a Wal-Mart employee who was terminated in 2009 after a background check revealed his 1997 sex offense conviction and registry status, despite having disclosed an earlier felony and remaining employed for years afterward under a new company policy on criminal checks. The plaintiff, proceeding pro se, alleged wrongful termination, breach of contract, and employment discrimination claims based on disparate treatment of registered sex offenders and his criminal record. The court granted the defendant's motion to dismiss, holding that Michigan law treats the employment as at-will with no protected status for felons or sex offenders under Title VII or state law, that the complaint failed to allege discrimination against any recognized protected class, and that the contract and discrimination claims lacked a plausible legal basis.
The case involved the sentencing of defendant Jesse Albert Young after his guilty plea to a federal drug offense committed before the Fair Sentencing Act of 2010 (FSA) took effect on August 3, 2010. The defendant objected to the presentence report's use of pre-FSA mandatory minimum penalties, arguing that the FSA's reduced penalties should apply because sentencing occurred after the law's enactment. The court overruled the objection and held that the FSA does not apply retroactively to offenses committed prior to its effective date. The core reasoning relied on the federal general savings statute (1 U.S.C. § 109), which preserves penalties under repealed laws unless the new statute expressly provides otherwise, combined with Sixth Circuit precedent in United States v. Carradine finding no such retroactive intent in the FSA.
This case involved a patent infringement dispute in which Automotive Technologies International sued Delphi and several vehicle manufacturers, alleging that Delphi's Passive Occupant Detection System (PODS) for regulating airbag deployment infringed four patents related to automotive sensor systems and vehicle diagnostics. The defendants counterclaimed for a declaratory judgment of patent invalidity based on anticipation by prior art. After conducting a Markman hearing to construe disputed claim terms such as 'plurality of sensor systems' and 'diagnosing the state of the vehicle,' the court considered multiple motions for summary judgment. The court granted four of the defendants' motions, finding the patents invalid, and terminated the remaining two motions as moot.
The case involved Prestige Pet Products, Inc. suing defendants for alleged infringement of its U.S. Patent No. 7,790,212 on a method for producing porkhide dog chews using gaseous smoke, seeking damages including under provisional rights from an earlier published application. Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim. The court granted the motion and dismissed the complaint without prejudice, holding that the patent claims had been narrowed during prosecution by adding references to gaseous smoke to overcome prior art rejections involving liquid smoke, so the initial 2002 publication was not substantially identical to the issued patent and could not support provisional rights under 35 U.S.C. § 154(d). The court dismissed with prejudice the specific claim for provisional rights based on the first publication but noted the later 2007 publication might support such rights.
