In Johnson v. Connecticut, plaintiff Carl Johnson, an African American employee of the State of Connecticut Judicial Branch since 2002, alleged that he was passed over for promotion from a temporary per diem Juvenile Detention Transportation Officer position to a full-time role in 2005 because of his race, in violation of Title VII and the Connecticut Fair Employment Act. The defendant moved for summary judgment, contending that the hiring process was nondiscriminatory and that the same-actor inference should apply since the same supervisor hired and declined to promote him. The court denied the motion, holding that genuine issues of material fact existed as to whether race was a motivating factor, based on evidence that the hiring panel may not have followed the required guidelines for interviews, rankings, and reviews of personnel files, along with discrepancies in candidate scoring and comments.
In this ERISA case, the plaintiff sued her long-term disability insurer alleging that the denial of benefits was influenced by the defendant's structural conflict of interest as both administrator and payer. The dispute centered on a motion to compel the deposition of Susan Barnett, a company employee who prepared the occupational analysis relied upon to terminate benefits. The court granted the motion to compel but limited the scope of questioning to whether Barnett's analysis was affected by a conflict of interest. The core reasoning was that the plaintiff had raised colorable allegations of bias, which could support a showing of good cause to permit discovery outside the administrative record in an arbitrary-and-capricious ERISA review.
This case arose from individual investors' state-law claims against Connecticut Community Bank, the custodian of their retirement accounts that had channeled assets to Bernard Madoff's firm, alleging breach of contract, negligence, breach of fiduciary duty, CUTPA violations, theft, and fraud for failing to safeguard assets and misrepresenting account values and due diligence. The bank removed the consolidated action to federal court under SLUSA's removal provision after state-court consolidation. The district court granted the bank's motions for judgment on the pleadings and denied the plaintiffs' motions to remand, holding that the claims were preempted by SLUSA because they concerned alleged misrepresentations in connection with the purchase or sale of securities. The court relied on the complaints' allegations that the bank misrepresented the nature and safety of the BLMIS investments and on precedents interpreting SLUSA's "in connection with" requirement broadly.
This case concerns the Schaghticoke Tribal Nation's challenge to a Department of the Interior Reconsidered Final Determination that the group did not meet the criteria for federal acknowledgment as an Indian tribe under 25 C.F.R. Part 83. The tribe sought review under the Administrative Procedure Act, claiming the decision was arbitrary and capricious, tainted by improper political influence in violation of due process, and issued by an official lacking proper authority under the Appointments Clause and Vacancies Reform Act. After addressing evidentiary motions and reviewing the administrative record plus limited extra-record materials, the court denied the tribe's summary judgment motion and granted the cross-motions filed by federal respondents and intervenors. The court held that the agency applied consistent methodologies supported by precedent and evidence, conducted a transparent process, and did not exceed its authority or violate constitutional requirements.
Glenda Galin sued the IRS seeking a declaratory judgment that she held at least a 50% equitable ownership interest in Connecticut property and an injunction to stop its auction for her ex-husband's tax liabilities. After the IRS auctioned the property, the government moved to dismiss on grounds of judicial estoppel, citing Galin's prior Chapter 7 bankruptcy filing in which she represented that she owned no real property and disclosed no interest in the Southbury Property. The court converted the motion to one for summary judgment and granted it, holding that Galin was judicially estopped from asserting an ownership claim because bankruptcy law requires full disclosure of all legal or equitable interests and neither ignorance of the law nor reliance on faulty legal advice excuses the prior inconsistent position.
The case involved three family members whose applications to adjust their status to permanent U.S. residents had been pending since 2004 without final adjudication, primarily due to incomplete FBI name checks and other security screenings. The plaintiffs sought mandamus and injunctive relief to compel the Department of Homeland Security, USCIS, FBI, and other defendants to decide the applications within a set time under the Administrative Procedure Act. The court denied the defendants' motion to dismiss for lack of jurisdiction and failure to state a claim, holding that agencies have a nondiscretionary duty to act within a reasonable time and that a three-year delay without evidence of specific security issues qualified as unreasonable.