This case involves a dispute over payment of medical benefits under an ERISA-governed employee welfare benefit plan, brought by a self-funded plan (Hornady Transportation LLC) against a medical provider (McLeod) and an insurer (BCBS-SC) for allegedly improper billing and payment practices. Defendants moved to dismiss under Rule 12(b)(6), arguing that state-law claims were completely preempted by ERISA and that the ERISA claims could not be asserted against the named defendants. The court declined to dismiss either set of claims at the pleading stage, finding that while ERISA preemption likely applies to the state claims, the novel facts and lack of controlling precedent create uncertainty, and plaintiffs had alleged plausible bases for at least some ERISA claims against each defendant. The rulings allow the case to proceed through discovery, with the issues to be revisited on summary judgment if appropriate.
In this case, plaintiff Brown sued the Lieutenant Governor's Office on Aging and several state officials under 42 U.S.C. § 1983 and the Family and Medical Leave Act, alleging retaliation for taking self-care medical leave. Defendants moved to dismiss the FMLA claim, asserting Eleventh Amendment immunity for the state agency and officials in their official capacities, lack of individual liability for damages against state supervisors, and qualified immunity. The court adopted the magistrate judge's recommendations with minor modifications, dismissing all claims for damages against the agency and officials but allowing the claim for injunctive relief (reinstatement) to proceed against two officials in their official capacities under the Ex parte Young doctrine. The core reasoning was that the Eleventh Amendment bars FMLA self-care suits for damages against unconsenting states and their employees, individual-capacity damage claims are foreclosed by Fourth Circuit precedent in Lizzi v. Alexander, and prospective injunctive relief remains available to address ongoing violations of federal law.
The case involved a constitutional challenge to South Carolina's "I Believe" Act, which directed the DMV to issue a specialty license plate featuring the words "I Believe" and a cross on a stained glass window. Plaintiffs, including religious leaders and organizations, argued that the law violated the Establishment Clause of the First Amendment by endorsing Christianity and the Free Speech Clause by granting unequal access to a government forum. The court granted summary judgment to the plaintiffs on their claims for declaratory and injunctive relief against state officials in their official capacities, finding the Act unconstitutional because it authorized a single plate with a uniquely Christian message through legislative action, rather than as a neutral accommodation or expression of diverse viewpoints. However, the court held that qualified immunity barred damages claims against the DMV director in her individual capacity. The core reasoning relied on Supreme Court precedents prohibiting government preference for one religious sect over others or over nonreligion.
This case involved two medical malpractice insurers, JUA and MedPro, disputing their respective shares of a $475,000 settlement paid to resolve claims against their mutual insureds for negligent post-surgical treatment of a hip infection between December 2002 and March 2004. The court allocated liability so that MedPro would pay $67,980.50 and JUA would pay the remainder. JUA's occurrence policies covered events during its policy periods ending October 1, 2003, while MedPro's claims-made policies with a retroactive date of October 1, 2003, excluded coverage for treatment provided before that date. Expert testimony indicated that 80 to 85 percent of the patient's injury occurred before September 2003, leading the court to prorate responsibility according to the policies' terms and the timing of the damage.
In this case, Carolina Pride, Inc. challenged South Carolina Code Ann. § 57-25-145, which prohibits most businesses offering sexually-oriented materials or entertainment from using off-premises outdoor advertising signs within one mile of a public highway. The plaintiff sought summary judgment declaring the Sign Statute unconstitutional under the First and Fourteenth Amendments, both facially and as applied, along with a permanent injunction barring its enforcement. The court granted the motion in full, relying on its prior analysis from the preliminary injunction stage that found the plaintiff likely to succeed on the merits. The ruling concluded that the statute violated the First Amendment by restricting commercial speech without sufficient justification, with no material factual disputes or new arguments from the parties altering that determination.
This case involved a challenge by the South Carolina Green Party and candidate Eugene Platt to the constitutionality of the state's sore-loser statute (S.C. Code Ann. § 7-11-10) as applied to Platt's 2008 bid for House Seat 115, where he sought nominations from multiple parties but lost the Democratic primary after signing the required party-loyalty pledge. The court granted summary judgment to the defendants (the State Election Commission and Charleston County Democratic Party), upholding the statute's application and barring Platt from appearing on the general-election ballot as the nominee of the Green Party or Working Families Party. The core reasoning was that the statute and pledge did not severely burden candidates' or parties' associational rights under the First and Fourteenth Amendments, advanced the state's important interests in preventing party raiding and ensuring orderly elections, and satisfied the applicable balancing test from Supreme Court precedent on ballot-access restrictions.