This products liability diversity case arose when plaintiff Natividad Seefeld, a line operator at LaMaur, Inc., was severely burned after a pressurized aerosol can exploded while she removed it from a hot water bath test at work. Defendant Crown, Cork & Seal Co., which supplied the empty cans, moved for partial summary judgment on the strict liability claims for manufacturing defect and failure to warn, conceding that design defect and other counts would remain. The court denied the motion, holding that genuine issues of material fact existed for trial under Minnesota strict liability standards from cases like Hudson v. Snyder Body, Inc. and Bilotta v. Kelley, including whether a cold-welded sideseam constituted a manufacturing defect present when sold, whether it proximately caused the injury, and whether the explosion and resulting harm were foreseeable such that a duty to warn existed. The court noted that knowledge of any defect would be imputed to Crown under strict liability and that the issues of duty, adequacy of warnings, and causation were questions properly left to the jury rather than resolved on summary judgment.
Northern States Power Company (NSP), which operates a nuclear power plant adjacent to the Prairie Island Mdewakanton Sioux Indian Community reservation, filed a declaratory judgment action seeking to preliminarily enjoin the Community from enforcing its newly adopted Nuclear Radiation Control Ordinance. The ordinance would require NSP to obtain tribal licenses for transporting radioactive materials across reservation lands (including roads and rail lines) and to submit environmental impact statements for waste management facilities, with associated fees, penalties, and broad regulatory oversight. The court granted NSP's motion for a preliminary injunction, restraining the Community from enforcing the ordinance or interfering with plant access, and stayed the Interior Board of Indian Appeals order affirming the ordinance. The core reasoning was that the ordinance directly regulates non-tribal activities, its approval by the Bureau of Indian Affairs was suspended pending appeal under federal regulations, and the Community's attempt to enforce it despite the suspension warranted interim judicial relief to maintain the status quo.
In McLean v. Carlson Companies, Inc., plaintiff Claire McLean sued her former employer in state court under a Minnesota statute prohibiting retaliation against whistleblowing employees, claiming she was fired for reporting violations of federal law in the administration of an employee benefit plan. The defendant removed the case to federal court, arguing that the Employee Retirement Income Security Act (ERISA) preempts the state claim. The court denied the plaintiff's motion to remand, holding that ERISA preempts the retaliatory discharge claim because it relates to an ERISA-covered employee benefit plan and that ERISA provides a civil remedy for such wrongs, thus establishing federal jurisdiction.
This case involves a motor carrier, Zurek Express, suing a shipper, Intermetro Industries, to recover alleged freight undercharges of $130,771.02 on 768 shipments based on filed tariff rates after Zurek failed to file a tariff page reflecting a negotiated discount. Intermetro moved to refer the matter to the Interstate Commerce Commission to assess the reasonableness of the tariff rates and to stay proceedings, while Zurek sought summary judgment. The court denied Zurek's summary judgment motion and granted the referral, holding that rate unreasonableness may be raised as a defense in an undercharge action and that the doctrine of primary jurisdiction applies because the ICC possesses expertise to ensure uniform regulation of rates. The decision rested on Intermetro's submission of expert affidavit evidence showing significant rate disparities compared to negotiated and other shipper rates, distinguishing the case from precedents lacking such proof.
In this case, First Bank System, Inc. and related entities sued the Secretary of Labor for a declaration that services provided to discretionary pension accounts did not violate ERISA's prohibited transaction provisions under 29 U.S.C. § 1106. The Secretary filed a counterclaim alleging that the services breached fiduciary duties under ERISA. The banks raised laches as an affirmative defense in reply. The court granted the Secretary's motion to strike the laches defense, reasoning that laches is unavailable against the United States in ERISA actions brought by the Secretary, who enforces interests distinct from those of private litigants.
This case involved the FDIC, acting as receiver for the failed Oak Park Bank, suing several former bank directors for $2.4 million in damages based on claims including breach of fiduciary duty under Minnesota law and gross negligence. The defendants moved to dismiss the fiduciary duty claim, arguing that the federal statute 12 U.S.C. § 1821(k) from FIRREA preempts state-law claims that do not allege at least gross negligence. The court granted the motion and dismissed the breach of fiduciary duty count, holding that the statute's language limits the FDIC to actions for gross negligence or more culpable conduct and does not preserve lesser state claims, while denying the other motions to dismiss or for a more definite statement.
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