The case involved a union suing employers under the Worker Adjustment and Retraining Notification (WARN) Act after a paper mill sale resulted in the dismissal of 232 workers with less than 60 days' notice, seeking back pay and benefits for those not rehired. The defendants moved to dismiss, arguing the claims were time-barred under a six-month federal statute of limitations borrowed from the National Labor Relations Act. The court denied the motion, holding that Vermont's six-year general statute of limitations for civil actions applies instead. The core reasoning was that, absent an express limitations period in the WARN Act, courts borrow the most analogous state limitations period unless a federal one provides a closer fit to the statute's policies and practicalities, which was not the case here given the Act's emphasis on class actions and worker protections.
This case concerns a challenge by disability claimants to final regulations issued by the Secretary of Health and Human Services on August 1, 1991, governing the evaluation of medical evidence, including opinions from treating physicians, in Title II and Title XVI Social Security disability determinations. Plaintiffs argued that the regulations conflicted with the Second Circuit's established treating physician rule and sought an injunction to prevent their use. After initial proceedings and additional briefing, the court held that no injunction was warranted. The core reasoning was that the Secretary possesses statutory authority under 42 U.S.C. § 405(a) to promulgate such regulations, that federal courts lack broad power to enjoin validly issued rules absent a showing they are arbitrary and capricious, and that the regulations could be reconciled with circuit precedent on review of individual claims.
This case concerned an appeal from a bankruptcy court's ruling on whether the Carriage House Property in Vermont was part of the bankruptcy estate of debtors James and Ruth Gabelhart. The district court affirmed the bankruptcy judge's decision that the property was not estate property. The core reasoning was that James Gabelhart had created a valid Vermont business or private trust called C & H Associates and held title to the property solely in his capacity as trustee, as shown by the deeds and the timing of the trust declaration, so the property fell outside the estate under bankruptcy code sections 541(a)(1) and 541(b)(1). The court also noted that a state court had already resolved the related mortgage discharge issue and that the bankruptcy judge properly declined to address it.
In White v. Sullivan, a class of Vermont SSI recipients sued the Secretary of Health and Human Services, claiming that the agency's policy of treating the portion of VA benefits paid to a veteran for a dependent's support as unearned income to the dependent improperly reduced the dependent's SSI benefits. The court granted the plaintiffs' motion for summary judgment and denied the defendant's, holding that 42 U.S.C. § 1382a(a)(2)(B) does not authorize counting such funds as income to the dependent unless they are actually received by the dependent. Applying Chevron analysis, the court found the statute's plain meaning requires actual receipt and rejected the agency's broader interpretation as inconsistent with the ordinary understanding of the term and prior case law distinguishing debt relief from third-party support payments.
This case was a class action brought by SSI recipients Lucy Farley and David Devoid challenging the Secretary of Health and Human Services' use of Retrospective Monthly Accounting procedures under 20 C.F.R. § 416.420 and POMS § SI 02005.060. Those rules counted nonrecurring income received only in an applicant's first month of eligibility toward benefit calculations for the first three months, even when no such income was received in months two and three. The plaintiffs contended that the method violated the Social Security Act, the Due Process Clause, and the APA's notice-and-comment requirements. The court adopted the Magistrate Judge's Report and Recommendation, certifying the class, granting summary judgment to the plaintiffs on the statutory claim, and dismissing the due process and APA claims as moot. The core reasoning was that the statute requires benefits to be reduced only by income actually received in the relevant month and does not authorize the Secretary to treat first-month nonrecurring income as if it continued for three months.
In this case, taxpayer Payne sought to recover funds levied by the IRS from her bank accounts to satisfy unpaid 1982 federal income taxes on wages her late husband earned working for the Panama Canal Commission in Panama. Payne argued the wages were exempt from taxation under the Panama Canal Treaty, that she had not signed the return, or under 26 U.S.C. Section 911. The court rejected these claims, noting the Supreme Court's decision in O'Connor v. United States that the Treaty does not provide an exemption, that Payne had signed the return, and that Section 911's foreign income exclusion does not apply to wages paid by a US agency like the PCC. Therefore, the court granted the government's motion for summary judgment to reduce the tax assessment to judgment.