In this case, Educational Credit Management Corporation sought to alter or amend a prior court order in a Chapter 13 bankruptcy proceeding involving debtors David and Nancy Barnes. ECMC held claims for unpaid student loans, including collection costs calculated under 34 C.F.R. § 682.410(b)(2), which the bankruptcy trustee challenged as unreasonable and potentially unconstitutional under the enabling statute 20 U.S.C. § 1091. The court granted the motion, withdrawing the reference from the bankruptcy court on the constitutional question because it requires interpretation of non-title 11 federal law rather than mere application. The decision relied on 28 U.S.C. § 157(d) and Seventh Circuit precedent requiring district court review for significant issues involving non-bankruptcy statutes. The court also noted that a related bankruptcy ruling on 11 U.S.C. § 506 had been reversed, removing it as a potential basis to avoid the constitutional issue.
Printpack, Inc. sued a local union, its international affiliate, and the local's president after the union sent a letter to Printpack's customers warning of potential quality issues during contract negotiations and after alleged acts of sabotage at the plant, including pouring sand into equipment and disabling phone lines. The complaint asserted a federal claim for secondary activity under the NLRA, a state-law tortious interference claim, and a state claim for property damage under Indiana's criminal mischief statute. The court granted the defendants' motion to dismiss only to the extent the NLRA claim was asserted against the individual union president, holding that the statute regulates only labor organizations and not individual members. The court denied the motion in all other respects, finding that the state claims were not subject to preemption or jurisdictional dismissal because the federal claim survived and that the tortious interference allegations against the president stated a viable claim.
The case involves a patent dispute in which Genentech sought a declaratory judgment that a patent held by the Regents of the University of California was invalid and unenforceable, while UC counterclaimed for infringement. UC moved to dismiss the action against it for lack of jurisdiction under the Eleventh Amendment. The court granted the motion, determining that UC is an arm of the state entitled to sovereign immunity. The core reasoning was that, under the Supreme Court's Seminole Tribe decision, Congress lacks authority to abrogate Eleventh Amendment immunity through legislation enacted pursuant to Article I powers such as the patent clause, and no valid abrogation occurred under the Fourteenth Amendment.
The case centered on Genentech's claim that it was an intended third-party beneficiary under a 1978 option agreement between the University of California and Eli Lilly concerning licensing rights to UC's '877 patent on recombinant DNA methods for producing human growth hormone, which stemmed from federally funded research. After UC obtained a waiver allowing an exclusive license to Lilly that eliminated prior sublicensing obligations, Genentech sued for breach of alleged third-party rights alongside related patent issues. The court granted UC's motion for summary judgment, dismissing the third-party beneficiary claim. It reasoned that Genentech provided no evidence of a material change in position based on the original agreement and that contracting parties could modify or rescind terms without third-party consent under applicable contract principles.
In United States v. Thompson, the defendant was charged with income tax evasion under 26 U.S.C. § 7201 for the 1989-1991 tax years after the IRS determined he had understated his taxable income and taxes owed. Thompson, who later filed amended returns through an accountant showing different income figures, filed a pretrial motion seeking IRS documents detailing the government's tax computations and adjustments, which the government argued were protected work product under Fed. R. Crim. P. 16(a)(2). The court granted the motion, holding that the 1993 amendment adding Rule 16(a)(1)(E) requires the government to disclose a written summary of expert testimony—including the bases and reasons for the opinions—taking precedence over the work-product exemption. Because the IRS calculations constituted technical evidence to be presented by an expert witness, the documents forming the foundation of that testimony had to be produced to allow the defendant to prepare for cross-examination.
The case was a diversity jurisdiction negligence action arising from a 1993 trailer collision on an Indiana highway, in which plaintiff Baker sued defendant Schafer after the trailer detached from Schafer's vehicle and struck Baker's truck. Schafer moved for summary judgment on the ground that he was acting within the scope of his employment as superintendent of a political subdivision, so that the suit was barred by Baker's failure to give timely notice under the Indiana Tort Claims Act; Baker cross-moved for partial summary judgment on a negligence-per-se theory. The court denied both motions, holding that the causal link between Schafer's governmental duties and the accident was too attenuated to trigger the Act and that Baker could not reasonably have known of any governmental status, while disputed facts also precluded a per-se ruling. The court further noted that Schafer's post-accident conduct reinforced the impression that he was personally liable.
