The case concerns Educational Credit Management Corporation's appeal of a bankruptcy court order that discharged most of Michael Rhodes's student loan debt under the undue hardship exception in 11 U.S.C. § 523(a)(8). The district court reversed, holding that Rhodes failed to satisfy any prong of the Brunner test adopted by the Ninth Circuit. Rhodes, a 52-year-old with multiple degrees and no diagnosed medical impairments preventing work, could maintain a minimal standard of living by participating in an Income-Based Repayment Plan requiring payments of only $10 per month. Additional circumstances did not show his financial difficulties were likely to persist, as he had voluntarily left higher-paying positions for lower-stress jobs, and he had not demonstrated good-faith repayment efforts given his refusal to pursue available repayment options and his choice not to maximize income.
This case stems from a 1990 maritime personal injury lawsuit in the Western District of Washington against a fishing vessel, its corporate owners, and their president, James Gowdy, which was stayed when one corporate defendant filed for Chapter 11 bankruptcy in Florida. The Florida bankruptcy court issued orders restricting the vessel's movements and requiring security deposits, which Gowdy allegedly violated, leading that court to hold him in contempt and prompting this Court to issue an arrest warrant and an order to show cause regarding civil contempt. The Court determined it lacks subject matter jurisdiction to proceed with an evidentiary hearing on the contempt allegations. The core reasoning is that federal district courts may punish only contempt of their own authority under 18 U.S.C. § 401, the relevant orders originated from the bankruptcy court for the Southern District of Florida (a unit of that district's court), and this Court had released the vessel from its custody without reasserting jurisdiction over it.
In Oldja v. Warm Beach Christian Camps & Conference Center, plaintiff Ted Oldja sued the camp operator after suffering a hand injury on its zip line when he wrapped his fingers in the primary load-bearing rope, bringing claims for negligence (including breach of the duty of ordinary care and the duty to disclose), product liability, negligence per se under Washington Administrative Code provisions, and common carrier liability. The court granted the defendant's motion for summary judgment in part and denied it in part, dismissing the product liability claim (which the plaintiff did not oppose), the duty-to-disclose claim, the WAC-based claims, and the common carrier claim, while allowing the ordinary-care negligence claim to proceed. The decision applied Federal Rule of Civil Procedure 56 to find no genuine issues of material fact on the dismissed claims, noting that Washington's narrow common-carrier statute does not encompass zip lines and that the Restatement section on disclosure did not create liability under the facts presented.
This case arose after three players on a softball team were disqualified from the 2008 Gay Softball World Series under NAGAAA's Rule 7.05, which limited rosters to a maximum of two heterosexual players, leading to forfeiture of their second-place finish and recommended suspensions. The plaintiffs sued, claiming NAGAAA was a public accommodation under Washington's Law Against Discrimination and had unlawfully discriminated based on actual or perceived sexual orientation. The court granted partial summary judgment to the defendant, ruling that NAGAAA qualifies as a public accommodation but that the First Amendment protects its right to exclude players whose participation would impair its expressive activity of promoting gay amateur athletics. Injunctive relief was denied because the plaintiffs did not demonstrate a real and immediate threat of repeated harm, as their injuries resulted from the manner in which the hearing process was applied rather than from the written policy itself.
This case involves an Indonesian investors' association alleging that various defendants operated a Ponzi scheme, defrauding thousands of investors of hundreds of millions of dollars through false representations about investment returns and qualifications at meetings in Indonesia and elsewhere, while misusing funds for personal businesses and assets. Plaintiffs brought claims including under RICO against categories of defendants based in Asia, Utah, and Washington state, including a bank that provided financial support. The court granted the motion to dismiss filed by two individual defendants but denied the motions of the remaining defendants after reviewing standing under Sprint Communications, subject-matter jurisdiction, and the sufficiency of the allegations.
This case involves a bank suing borrowers for allegedly submitting a false loan application that inflated their income to obtain a $1,350,000 loan secured by real property, then defaulting on payments by stopping monthly installments as required by the promissory note and deed of trust. The plaintiff sought summary judgment on claims including fraud in the inducement, negligence, breach of contract, and judicial foreclosure. The court granted the motion, awarding damages for the loan principal, interest, late charges, and fees, and ordering foreclosure on the property at 1275 Chuckanut Drive, Bellingham, Washington, because the defendants provided no evidence or legal authority to contest the facts or raise a genuine issue for trial, despite their pro se arguments about moral obligations, economic conditions, and document authenticity.