This case concerns a commercial dispute between Carbon Processing and Reclamation (CPR) and Valero Marketing & Supply Co. over alleged agreements for the purchase of petroleum slurry byproduct from Valero's Memphis refinery, including negotiations for a one-year evergreen contract and related three-year barge leases. CPR asserted claims for breach of contract, promissory estoppel, and violations of the Tennessee Consumer Protection Act based on meetings, writings, and representations about slurry volume and contract duration. The district court addressed cross-motions for summary judgment and granted them in part and denied them in part, holding that some contract-formation and estoppel issues presented triable questions of fact while dismissing other claims due to insufficient evidence of reliance, causation, or statutory applicability.
The case involved the conviction of defendant Romilus Caraway for one count of being a felon in possession of a handgun under 18 U.S.C. § 922(g), based in part on testimony from government witness Ms. Latasha Johnson. After trial, the government discovered and disclosed an undisclosed grand jury transcript of Johnson's testimony, which defense counsel had requested under the Jencks Act but was not provided during trial. Defendant moved for a new trial on the basis of this newly discovered evidence, arguing it contained inconsistent statements that could have been used for impeachment. The court granted the motion, ruling that the nondisclosure, though inadvertent, was prejudicial error under the Jencks Act because the transcript's inconsistencies deprived the defendant of a fair opportunity to cross-examine the witness.
This ERISA case involved a dispute between Electric Energy, Inc. (EEI), the fiduciary of a self-funded employee health plan, and covered person Jack Lambert over reimbursement of medical benefits. Lambert was injured in a 2005 car accident; the Plan paid over $124,000 in benefits, and Lambert later received a $650,000 settlement from third parties. EEI sought to recover the full amount paid under the Plan’s explicit reimbursement and subrogation clause, which applied regardless of whether the settlement made Lambert whole and without deducting attorney fees. The court granted EEI’s motion for summary judgment, holding that the unambiguous Plan terms required full reimbursement from the settlement proceeds and that ERISA authorized enforcement of those terms.
This case was an appeal from a bankruptcy court order granting Telesis Community Credit Union's motion to lift the automatic stay in the Chapter 11 bankruptcy of debtor 460 Tennessee Street, LLC. The central dispute concerned whether the debtor's assignment of rents from its leased commercial property to Telesis, secured by a deed of trust and promissory note, constituted an absolute assignment or only a security interest in the rental revenues. The bankruptcy court determined it was an absolute assignment after finding that the loan documents used clear, unambiguous language describing the assignment as absolute, irrevocable, and unconditional, granted the debtor only a revocable license to collect rents, and aligned with factors from prior precedent such as In re Kingsport Ventures. On appeal, the district court applied de novo review to the legal conclusions and considered the debtor's claims of ambiguity arising from similar language appearing in both documents, while noting the standard of review limited reversal absent clear error.
In Williams v. Hooah Security Services, LLC, security guard employees sued their employer and its owner for unpaid minimum wages and overtime under the Fair Labor Standards Act (FLSA), alleging both individual and enterprise coverage. The defendants moved to dismiss the case for lack of subject matter jurisdiction, claiming the plaintiffs could not establish the required interstate commerce connections since operations were local to Shelby County, Tennessee. The court denied the motion, reasoning that FLSA coverage requirements constitute elements of the plaintiffs' claims rather than prerequisites for federal jurisdiction, following Supreme Court precedent in Arbaugh v. Y & H Corp. The court declined to convert the motion to one for summary judgment and proceeded under Rule 12(b)(1) standards but found jurisdiction proper under 28 U.S.C. § 1331.
In Jiglov v. Hotel Peabody, GP, a kitchen mechanic at the hotel who is Russian Orthodox Christian sued his employer after it denied his request to swap shifts so he could observe Orthodox Easter in 2008. The dispute centered on whether the hotel had a duty under Title VII to accommodate the plaintiff's religious practices by allowing a colleague to cover his Sunday shift despite a conflicting late-night contractor project that the colleague was scheduled to supervise. The court granted in part and denied in part the defendant's motion for summary judgment. It reasoned that genuine issues of material fact existed as to whether a reasonable accommodation was possible without undue hardship and whether the employer had engaged in an interactive process, while dismissing other aspects of the claims where no such facts were shown.
