This case involves an appeal under 42 U.S.C. § 405(g) challenging the Commissioner of Social Security's denial of disability insurance benefits, where the plaintiff alleged disability onset in March 2005 but the ALJ determined it began only in September 2007. The magistrate judge reviewed the record and found that the ALJ's decision to deny benefits for the earlier period was not supported by substantial evidence, particularly in the evaluation of medical opinions and the plaintiff's impairments. The district court adopted the recommendation after de novo review, reversing the Commissioner's decision and remanding the case for additional consideration. The core reasoning centered on the need for further administrative proceedings to properly assess the evidence.
In United States v. Kang, the defendants were charged with conspiracy to commit mail, wire, and securities fraud under 18 U.S.C. § 371, along with related money laundering counts, based on alleged accounting manipulations at Medical Manager Corporation to inflate stock prices and facilitate acquisitions, culminating in a 2000 merger with WebMD. After a jury convicted the remaining defendants, the court considered their Rule 29 motion and supplemental briefing on timeliness. The court granted acquittal on the fraud conspiracy count, holding that the statute of limitations had expired because the conspiracy's objectives were achieved with the September 2000 merger and the post-merger overt acts (such as 2003 interviews concealing information) could not properly be viewed as in furtherance of the conspiracy under Grunewald v. United States. The court reasoned that acts of concealment after the main goals are attained do not extend the conspiracy's duration, and post-merger salary or enrichment alone does not demonstrate ongoing concerted activity posing the dangers of conspiracy.
This case concerns a plaintiff's application for disability insurance benefits and supplemental security income under the Social Security Act, which the Commissioner denied after an administrative law judge found her not disabled based on conditions including back pain, arthritis, carpal tunnel syndrome, obesity, hypertension, and sleep apnea. The plaintiff sought judicial review, and a magistrate judge recommended reversing the denial. The district court adopted that recommendation, reversed the Commissioner's decision, and remanded the case for further administrative proceedings. The court determined that the administrative decision failed to properly evaluate the medical evidence and applicable regulatory listings in accordance with the Act.
The case concerned whether defendant Henry Terrill Johnson’s two prior South Carolina convictions for failure to stop for a blue light qualified as violent felonies under the Armed Career Criminal Act, which would trigger a fifteen-year mandatory minimum sentence for his federal felon-in-possession conviction. The court held that the convictions did not constitute violent felonies under the ACCA’s residual clause even though the indictments alleged intentional conduct. Applying the categorical approach required by Supreme Court precedent such as Begay v. United States, the court reasoned that the statute encompasses conduct that is neither inherently violent nor aggressive, can be committed without serious risk of physical injury, and includes a mitigating-circumstances exception not found in traditional violent felonies.
This case involves a limitation of liability action filed in U.S. federal court by the owners and charterer of a container vessel after it collided with a Dutch-owned dredge in Chinese territorial waters near Tianjin, resulting in a claim for approximately $826 million in damages. The petitioners sought exoneration or limitation under maritime law while also moving to dismiss on forum non conveniens grounds, and the claimants moved to transfer venue and lift the restraining order. The court granted the motion to dismiss, holding that China provides an available and adequate alternative forum with significantly stronger connections to the dispute, including the location of the collision, the investigation by Chinese authorities, ongoing proceedings in the Tianjin Admiralty Court, and the lack of any U.S. ties involving the vessels, crews, or events. The court reasoned that private interest factors, such as access to evidence and witnesses, and public interest factors, such as China's greater interest in resolving the matter, strongly favored dismissal over retaining the case in the United States. Claimants' remaining motions were denied as moot.
The case involves plaintiff Jelani Aiken, a South Carolina resident, who sued Waffle House, Inc. (a Georgia corporation) and its employee Maurice Kemp (also a South Carolina resident) in state court for assault, battery, and negligence arising from an alleged knife attack at a Waffle House restaurant, seeking liability against the company under respondeat superior. After neither defendant responded, the state court entered default and a damages judgment solely against Waffle House, dismissing all claims against Kemp. Waffle House removed the case to federal court on diversity grounds, and Aiken moved to remand, arguing lack of diversity jurisdiction. The court denied the remand motion, reasoning that the dismissal of the non-diverse defendant was voluntary, allowing diversity to be assessed at the time of removal when complete diversity existed between Aiken and Waffle House.