Donetta W. Ambrose

In this diversity case, Lee A. Donaldson sued Informatica Corporation under Pennsylvania law for wrongful discharge, alleging retaliation for filing an earlier lawsuit claiming violations of the Wage Payment and Collection Law over unpaid sales commissions. The U.S. District Court granted the defendant's motion for summary judgment after reviewing undisputed facts about Donaldson's performance improvement plans and termination. The court held that Pennsylvania does not recognize a public-policy exception to at-will employment for such retaliation because the WPCL lacks an express prohibition on retaliatory discharge or a private right of action for it. The court further noted that creating such an exception is a matter for the legislature, not judicial expansion of common-law torts, and denied the motion to strike exhibits as moot.

labor & employmentprocedure

In this case, hourly employees at a U.S. Steel coke plant brought a collective action under the Fair Labor Standards Act alleging that the company failed to compensate them for time spent walking to and from workstations after donning and before doffing required protective gear. The court had previously granted partial summary judgment dismissing claims for donning, doffing, and showering time but allowed the walking-time claims to proceed. Defendant moved to decertify the collective action under 29 U.S.C. § 216(b). The court denied the motion, reasoning that a common company policy of non-compensation for these activities created sufficient similarity among plaintiffs for collective treatment, with individual differences in walking times and routes primarily affecting damages calculations rather than liability determinations, which could be addressed through representative evidence at later stages.

labor & employmentprocedure

The case involved a plaintiff who sued her auto insurer, GEICO, after the company stopped paying first-party medical benefits following a car accident, alleging breach of contract, bad faith under Pennsylvania law, and violations of the Unfair Trade Practices and Consumer Protection Law. The court granted the defendant's motion for summary judgment, adopting the magistrate judge's recommendation and entering judgment for GEICO. The core reasoning was that GEICO properly relied on peer review reports finding further treatment unreasonable and unnecessary, the plaintiff presented no contrary medical evidence, the bad faith claim could not proceed without a contract breach, and the consumer protection claim was limited to nonfeasance with no private right of action.

business & regulatorytorts & liability

In this case, Plaintiff Braden, who worked as a Paternity/IRS Coordinator in the Domestic Relations Section of the Washington County Court of Common Pleas, sued the County for violating her FMLA rights by discharging her in retaliation for taking approved family and medical leave. The court had previously granted partial summary judgment, ruling the County was not a joint employer, and now addressed whether the County qualified as an integrated employer or if an employment relationship existed to support liability under the FMLA's retaliation provisions. The court granted the County's supplemental motion for summary judgment, concluding that no integrated employment relationship existed because the judicial system retained independent control over personnel matters, funding arrangements, and operations despite the County's provision of facilities and mandatory financial support. The court further clarified that the claim was based on retaliation for exercising FMLA rights rather than opposition to unlawful practices, requiring a direct employment relationship that was absent here.

labor & employmentprocedure

This case involved an inmate plaintiff suing multiple prison and hospital officials, including Commonwealth Defendants and Dr. Petras, over alleged incidents during periods of incarceration at facilities like Mayview State Hospital, with claims centered on due process violations related to medical treatment. The court adopted the magistrate judge's report after de novo review, granting summary judgment to the Commonwealth Defendants, denying summary judgment to Dr. Petras, and denying the plaintiff's cross-motion for summary judgment. The core reasoning was that the objections raised did not undermine the magistrate's findings on the absence of genuine issues of material fact for the Commonwealth Defendants, while disputes remained regarding Dr. Petras's actions under due process standards for non-emergency medication procedures. The decision followed Federal Rule of Civil Procedure 56 standards, viewing facts in the light most favorable to the non-moving party where appropriate.

criminal lawcivil rightshealthcare

Range Resources-Appalachia, LLC, an energy company holding oil and gas leases in Blaine Township, Pennsylvania, sued the Township after it enacted the Corporate Rights Ordinance, which declared that corporations are not 'persons' under the U.S. or Pennsylvania Constitutions and denied them protections under the Commerce and Contracts Clauses. The Township moved to dismiss, contending that Range lacked standing and failed to state a viable claim. The court denied the motion in full, holding that Supreme Court precedent has long recognized corporations as persons entitled to constitutional protections and that a township lacks authority to override that precedent. The decision emphasized that only the Supreme Court may depart from its own rulings on corporate constitutional rights, and lower courts remain bound to follow them.

business & regulatorycivil rightsfederal power

This case involves hourly employees at a U.S. Steel coke plant suing their employer under the Fair Labor Standards Act for unpaid time spent donning and doffing protective gear, showering, and walking to and from workstations. The court addressed the employer's motion for summary judgment, granting it in part and denying it in part. The core reasoning centers on long-standing collective bargaining agreements, including a 1947 supplemental agreement and a 2008 letter agreement incorporated into the Basic Labor Agreement, which exclude compensation for such preparatory and closing activities under Section 203(o) of the FLSA. The court determined that these bargained-for terms are enforceable and that the listed items qualify as clothes within the meaning of the statute, while leaving open certain issues such as potential walking time claims under other theories.

labor & employment

The case involved a breach of contract and quantum meruit claim by AES against Metalworking over subcontracted tank cleaning services at a New Jersey site, which AES stopped performing after alleging nonpayment. Metalworking moved to dismiss for lack of personal jurisdiction and improper venue or, alternatively, to transfer venue to New Jersey under 28 U.S.C. § 1404(a). The court denied the motions, holding that Metalworking's long-standing registration to do business in Pennsylvania and appointment of a registered agent established personal jurisdiction under Third Circuit precedent and satisfied venue requirements under 28 U.S.C. § 1391. For the transfer request, the court found that the balance of private and public interest factors, including the plaintiff's forum choice, convenience of parties and witnesses, and this district's greater interest in the contract dispute, weighed against moving the case.

procedurebusiness & regulatory

This is a products liability case in which plaintiffs Charles David, Sr. and Stephanie David seek damages from defendant Black & Decker for injuries Mr. David sustained to his hand while using a circular saw, alleging that a design defect caused the saw to accidentally energize. The court addressed cross-motions under Daubert and Federal Rule of Evidence 702 to exclude the testimony of plaintiffs' expert mechanical engineer Kai Baumann on defective design and causation and defendant's expert Dr. Gary Deegear on biomechanics and injury causation. After a hearing and review of the parties' submissions, the court denied both motions. It found each expert qualified, their methodologies sufficiently reliable based on testing, experience, and application to the facts, and their opinions relevant to the issues of design defect and causation. The court emphasized that any remaining disputes go to weight rather than admissibility and can be addressed at trial.

torts & liabilityprocedure

The case involved two Pennsylvania nonprofit hospitals, Sewickley Valley Hospital and The Medical Center, Beaver, that consolidated into a new entity, Valley Medical Facilities, on November 1, 1996, and sought Medicare reimbursement for claimed depreciation-related losses on their assets. The Secretary of Health and Human Services denied the claims after determining that the transaction was not a bona fide sale, as the value of assets transferred far exceeded the liabilities assumed and there was no evidence of arm's-length bargaining or reasonable consideration. The hospitals sued under the Administrative Procedure Act and Medicare provisions, arguing the denial was improper, but after cross-motions for summary judgment the district court adopted the magistrate judge's recommendation and upheld the Secretary. The court found the Secretary's conclusion supported by substantial evidence, including the hospitals' own post-transaction appraisals showing asset values greatly exceeding liabilities, and granted the Secretary's motion while denying the plaintiffs'.

healthcarebusiness & regulatoryfederal power

In this case, Nicole Ehrheart sued Verizon Wireless on behalf of herself and a class of others, alleging that Verizon violated the Fair and Accurate Credit Transaction Act (FACTA) by printing the full expiration date of her credit or debit card on an electronically printed receipt at the point of sale. Ehrheart did not allege actual damages from identity theft but sought statutory damages based on a claim of willful noncompliance with FACTA's truncation requirements. Verizon moved to dismiss the complaint, contending that the allegations at most supported a claim of negligence rather than willfulness. The court denied the motion, holding that the complaint plausibly alleged willfulness because it detailed Verizon's knowledge of FACTA through its contracts, industry alerts, FTC notices, and competitors' compliance, combined with its failure to act during the three-year grace period, satisfying the Twombly standard for pleading a knowing or reckless violation.

business & regulatoryprocedure

This case involved B & B Microscopes suing its former employee Luigi Armogida over ownership of an automated imaging system called KPICS that Armogida developed while working as an imaging specialist for B & B's customer, the Ohio Bureau of Criminal Investigation. The court found that B & B owned the KPICS system and related trade secrets because Armogida created it in the course of his employment duties using company training and resources, and that he breached his employment agreement's non-compete clause and misappropriated the trade secrets by filing a patent application and attempting to commercialize it after leaving. The court entered judgment for B & B, awarding an injunction against Armogida's use or sale of the system for twelve months, compensatory and exemplary damages totaling $31,400, and attorneys' fees.

labor & employmentbusiness & regulatoryproperty

In this case, former Pennsylvania Office of Attorney General employee Rita Cindrich sued current and former OAG officials, asserting claims under Pennsylvania's Whistleblower Law for alleged retaliation after reporting wrongdoing, plus First Amendment retaliation under 42 U.S.C. § 1983, defamation, civil conspiracy, and intentional infliction of emotional distress. Defendants moved for summary judgment on grounds including lack of protected whistleblowing or speech, issue preclusion for pre-2003 events, and sovereign immunity for state-law claims. The court granted summary judgment on the First Amendment claims due to issue preclusion and because the plaintiff was not speaking as a private citizen, on the state tort claims based on official immunity, and on one whistleblower claim because the March 2005 filing did not qualify as a report of wrongdoing, but denied summary judgment on the remaining whistleblower claims; it then dismissed the surviving state claim without prejudice under 28 U.S.C. § 1367.

labor & employmentfree speechcivil rightstorts & liability

The case involved a dispute over benefits under an accidental injury insurance policy issued by Hartford Life to AAA members, which provided daily hospital confinement and recuperation payments following a covered accident. Plaintiff George Pittas, who enrolled in the Basic Plan in 2002 for $300 daily benefits, was seriously injured in a 2003 car accident and submitted a claim after extended hospital stays; the parties disputed whether he qualified for $600 daily benefits due to an erroneous schedule of benefits sent to long-term AAA members and whether certain facilities met the policy's definition of a hospital. The court denied the plaintiff's motion for summary judgment and granted the defendant's motion in part, ruling that the policy terms, enrollment documents, and subsequent correction limited benefits to the $300 daily amount under the Basic Plan, with the daily rate fixed at the time of the accident. Certain claims regarding specific facilities were withdrawn or resolved by payment, leaving the core contract interpretation issue decided in the insurer's favor on the benefit amount.

business & regulatoryprocedure

The case involved Vanton Hicks suing his former employer, The Tech Industries, alleging race, age, and disability discrimination under Title VII, the ADEA, the ADA, and the PHRA, along with retaliation under the FMLA for taking protected medical leave. Both parties filed motions for summary judgment, with Hicks seeking judgment on his FMLA claim and the employer seeking dismissal of all claims. The court denied Hicks's motion in full and granted the employer's motion in part and denied it in part, finding insufficient evidence of pretext or discriminatory animus for the discrimination claims but identifying genuine factual disputes regarding whether the termination was motivated by the employee's FMLA leave.

labor & employmentcivil rights

The case involved a former Comcast employee's claim for long-term disability benefits under an ERISA-governed plan after being diagnosed with multiple sclerosis and approved for short-term benefits. The claims administrator terminated the benefits effective November 2004, determining that medical evidence did not show a functional impairment preventing gainful occupation, and the employee sued under ERISA § 502(a)(1)(B) alleging improper denial. The court granted the plaintiff's motion for summary judgment and denied the defendants' cross-motion, applying an arbitrary and capricious standard of review based on the plan's grant of discretionary authority and finding that the administrator's termination decision could not stand under the plan's terms regarding objective clinical findings.

labor & employmenthealthcare

This case involves claims of patent infringement by Erbe Elektromedizin GmbH and ConMed Corporation against Canady Technology and Dr. Jerome Canady concerning flexible endoscopic probes and electrosurgical equipment for argon plasma coagulation, specifically Erbe's '745 patent and ConMed's '175 patent. The court addressed the first step of the infringement analysis by conducting a Markman hearing to construe disputed claim terms in both patents. Applying established principles, the court interpreted the claims based on their ordinary and customary meaning to a person of ordinary skill in the art, drawing primarily from intrinsic evidence including the patent language, specifications, embodiments, and prosecution history, while noting that extrinsic evidence could be considered only if ambiguities remained unresolved.

business & regulatoryprocedure

In Totty v. Chubb Corp., plaintiff Helen Totty sued Chubb Corporation and Great Northern Insurance Company for breach of contract and bad faith under Pennsylvania law after the insurers denied coverage under a homeowner's policy for alleged damage to her 100-year-old home from construction vibrations on a nearby street. The defendants moved for summary judgment, asserting that policy exclusions for earth movement, settling, and structural movement barred the claim based on an engineering report attributing the damage to foundation settlement from dry weather and other non-covered causes. The court granted the motion in part and denied it in part, holding that the exclusions did not apply because the damage was not caused by "settling" or "structural movement" as those terms were used in the policy, allowing the breach of contract claim to proceed to trial on the basis of conflicting expert evidence while resolving other portions of the case.

propertyprocedurebusiness & regulatory

The case involved plaintiffs Rock Ferrone and Rock Airport of Pittsburgh suing Allegheny County and two officials, alleging that their emails to county council members were redirected and censored by defendants, in violation of federal constitutional and statutory rights under Sections 1983, 1985, and 1986, along with state tort claims. The court adopted the magistrate judge's recommendation and granted the motion to dismiss Counts II and III for failure to state a claim, denied dismissal as to Count I, and denied without prejudice as to the remaining state law counts. The core reasoning was that plaintiffs adequately alleged interference with their right to petition the government under the First Amendment for purposes of surviving dismissal on Count I, while other federal claims lacked sufficient allegations, and the state claims implicated unresolved issues of governmental and high public official immunity under Pennsylvania law.

free speechcivil rightsproceduretorts & liability

This case involves plaintiffs suing Metropolitan Life Insurance Company for alleged misrepresentations regarding life insurance policies, bringing claims including fraud and violations of Pennsylvania's Unfair Trade Practices and Consumer Protection Law (UTPCPL). Defendants filed a motion in limine to bar expert testimony on expectation or benefit-of-the-bargain damages. The court granted the motion in part, ruling that the expert may not testify as to the proper legal measure of damages, which the court will determine and instruct the jury on, but denied the request to exclude all evidence of losses beyond premiums paid. The core reasoning is that while pure expectation damages are not available in tort or UTPCPL actions, Pennsylvania appellate precedent allows recovery of actual losses that can extend beyond out-of-pocket amounts, such as the diminished value of surrendered policies.

business & regulatorytorts & liabilityprocedure