The case involved Samuel Salomaa, a long-term Honda employee who sought long-term disability benefits under an ERISA plan after developing severe fatigue and related symptoms following a 2003 illness, which his physicians ultimately attributed to chronic fatigue syndrome rather than depression. The plan administrator denied the claim, finding insufficient evidence of disability, and the district court upheld that denial. On appeal, the Ninth Circuit reversed, holding that the administrator abused its discretion by failing to adequately consider the claimant's evidence, improperly discounting treating physicians' opinions, and not mitigating the effects of its structural conflict of interest as both payer and decision-maker. The court emphasized that ERISA requires a reasoned explanation and that the administrator's communications and evaluation fell short of that standard.
The case concerned a Medicare-certified hospice provider's challenge to a federal regulation implementing the statutory annual cap on aggregate Medicare reimbursements for hospice care, which resulted in a demand that the provider repay more than $2.3 million for fiscal year 2006. The district court ruled that the regulation was arbitrary, capricious, and invalid, set aside the repayment demand, and issued a nationwide injunction barring its enforcement. On appeal, the Ninth Circuit affirmed that the provider had standing and that the regulation was facially invalid under the first step of Chevron deference because it was inconsistent with the hospice cap statute, but it vacated the nationwide injunction as overly broad, holding that relief limited to the plaintiff alone was sufficient.
The case concerned Mark Stephen Forrester's conviction for conspiracy to manufacture and distribute ecstasy under federal drug laws, following a lengthy investigation involving surveillance and a raid on a clandestine lab. Forrester had initially represented himself at trial after being misadvised about his sentencing exposure, leading to a prior remand; on remand he entered a conditional guilty plea and received a 30-year sentence. On appeal, the Ninth Circuit affirmed the conviction, rejecting challenges to the drug scheduling, the indictment, a plea offer, and wiretap evidence. However, it vacated the sentence and remanded for resentencing due to ex post facto concerns and limitations on judicial fact-finding regarding the conspiracy's end date and applicable sentencing enhancements under the Ecstasy Act amendments.
The case involved Mark Stephen Forrester's conviction for conspiracy to manufacture and distribute ecstasy after a year-long investigation that included surveillance, informants, and a lab raid. Forrester initially represented himself at trial following a Faretta hearing where the court misinformed him about his sentencing exposure, leading to an earlier remand; on remand he entered a conditional guilty plea and received a 30-year sentence. The Ninth Circuit affirmed the conviction, rejecting challenges to the drug scheduling, the withdrawn plea offer, the indictment's sufficiency, and the wiretap evidence. It vacated the sentence and remanded because the district court did not make adequate findings on drug quantity and related sentencing factors.
The case concerned whether Merrimack Pharmaceuticals, Inc. was required under its restated articles of organization to redeem Albert Bolt's shares of Series A redeemable preferred stock upon his request. The court held that redemption was required because the company's net worth as of December 31, 2001, exceeded the $5 million threshold. It reached this conclusion by applying the ordinary meaning of net worth as total assets minus total liabilities under GAAP, which yielded more than $10 million on the balance sheet. The court further determined that the Series B preferred stock, listed in the mezzanine section between liabilities and equity, did not qualify as a liability that would reduce net worth.
In United States v. Crews, defendants Crews and Manus, both convicted felons, faced separate indictments for being felons in possession of a firearm after police executed a search warrant at their shared apartment and recovered a derringer along with related statements. The district courts granted the defendants' motions to suppress the evidence and statements, ruling that the supporting affidavit lacked probable cause. On appeal, the court reversed the suppression orders, concluding that the officers' reliance on the warrant was objectively reasonable under the good faith exception established in United States v. Leon, even assuming the affidavit was insufficient to show probable cause.