Michael James Davis

The case concerned a federal criminal defendant who repeatedly refused to stand when the court was called to order or recessed, in violation of the court's rules of decorum and a prior order, citing her religious beliefs as the reason. The court held the defendant in criminal contempt under 18 U.S.C. § 401 for misbehavior in the court's presence that obstructed the administration of justice and revoked her pretrial release. The decision was based on the long-standing tradition and functional purpose of the rising requirement in maintaining courtroom order and respect, along with precedents such as In re Chase that upheld similar requirements even against religious objections. The court noted the defendant's inconsistent conduct, as she stood when introduced to prospective jurors, undermining her claim that religious beliefs prevented compliance.

criminal lawreligious liberty

This case involved former Seagate employees over age 40 who brought a collective action under the ADEA alleging that the company's 2004 Special Incentive Retirement Plan and reduction in force had a disparate impact on older workers, resulting in higher termination rates for them. After conditional certification and discovery, the court addressed Seagate's motion for decertification, to strike expert testimony, and for summary judgment on the disparate impact claim. The court granted decertification in part, allowing only those terminated through the RIF to proceed as a collective action, and granted summary judgment to Seagate on the disparate impact claim. The core reasoning was that the plaintiffs' statistical analysis, showing a drop from 66.64% to 65.23% in the proportion of employees over 40 after the measures, was not substantial enough under Eighth Circuit precedent to support an inference of age-based discrimination, and improperly included SIRP participants.

labor & employmentcivil rights

The case involved recording companies suing Jammie Thomas-Rasset for willfully infringing their copyrights in 24 sound recordings by downloading and distributing them via the Kazaa peer-to-peer file-sharing network. After three trials resulting in escalating jury verdicts up to $1.5 million in statutory damages, the court granted the defendant's motion to reduce the award to $2,250 per song (totaling $54,000), holding that the higher amount violated due process because it was severe, oppressive, and wholly disproportionate to the offense committed by a first-time consumer infringer for personal use. The court also granted the plaintiffs' request to amend the judgment to include a permanent injunction barring the defendant from directly or indirectly infringing the copyrights through reproduction or distribution and requiring destruction of unauthorized copies, but declined to enjoin making the works available to the public because the Copyright Act does not recognize a making-available right.

propertycivil rightsprocedure

This case concerned whether a mortgage executed solely by James Larson on property he owned in Ortonville, Minnesota, could be voided by his wife Angelia Larson under state law. Angelia Larson, who had been separated from her husband for about twenty years but remained legally married, sued Wells Fargo after learning of the 2004 mortgage, which she had not signed. The court granted Angelia Larson’s motion for summary judgment and denied Wells Fargo’s, holding that the mortgage was void. The decision rested on Minn. Stat. § 507.02, which requires both spouses’ signatures for any conveyance of homestead property, with no applicable exceptions or equitable estoppel defense because Angelia Larson had no knowledge of the mortgage, received no benefit from it, and had not lived on the property.

family lawproperty

This case involved claims by systems, business, and technical consultants employed by Lawson Software that they were misclassified as exempt from overtime under the FLSA and Minnesota state law, seeking unpaid wages for work performed. The court granted the defendants' motion to decertify the conditionally certified FLSA collective action and dismissed the opt-in plaintiffs without prejudice. It also granted summary judgment to Lawson on the FLSA, MFLSA, and unjust enrichment claims of the named plaintiffs, dismissing those claims with prejudice. The decertification was based on material differences in the consultants' job duties, minimal supervision, and the likelihood that individualized defenses would require fact-specific inquiries making collective treatment inefficient. Summary judgment rested on the conclusion that each named plaintiff's primary duties involved the exercise of discretion and independent judgment on matters of significance, qualifying them for the administrative exemption.

labor & employmentprocedurebusiness & regulatory

This case involved a proposed class action by current and former employees of Augsburg Fortress Publishers against the publisher, its parent Evangelical Lutheran Church in America, and individual officers, challenging the 2010 termination of a defined-benefit pension plan that had been underfunded for years. The plaintiffs asserted claims under ERISA for breach of fiduciary duties and related violations, along with state-law claims including breach of contract, promissory estoppel, and violation of the Minnesota Consumer Fraud Act. The court granted the defendants' motions to dismiss in part, ruling that the plan qualified as a church plan exempt from ERISA because it was established and maintained by a church-affiliated organization, thereby requiring dismissal of the federal claims. It also dismissed the consumer-fraud claim on the ground that the plan was not a sale of merchandise offered to the general public. The court allowed certain state-law claims against ELCA to proceed.

labor & employmentfederal power

In Chambers v. Travelers, a former Managing Director sued her employer after termination in 2008, alleging defamation, breach of contract, statutory wage violations, age discrimination, and interference with ERISA benefits related to pension and severance. The U.S. District Court granted the defendant's motion for summary judgment on all counts. The court determined there were no genuine disputes of material fact, the termination was for cause based on performance and management concerns uncovered in an environmental assessment of subordinates, and each claim failed as a matter of law due to lack of evidence showing pretext, false statements, contractual breaches, or specific intent to interfere with benefits.

labor & employmentcivil rights

This case involved a dispute over Medicare coverage for skilled nursing facility services provided to beneficiary Robert Bushnell, specifically enteral feedings administered through a gastric tube after his hospitalizations for pneumonia. United Healthcare Insurance Company, which provided Bushnell's Medicare Advantage plan, sought to terminate coverage and appealed adverse decisions by the Medicare Appeals Council, arguing the services did not qualify as posthospital SNF care. The court granted summary judgment to defendants Kathleen Sebelius and Michael Starkowski, denying United's motion, and held that the feedings were covered for the relevant periods in 2008. The core reasoning was that substantial evidence in the record showed the services met Medicare requirements under 42 C.F.R. § 409.31, including being for a condition treated in the hospital or for which the beneficiary was admitted to the SNF, and that they could only practically be provided in an SNF setting.

healthcarefederal powerbusiness & regulatory

The case involves Bank of Montreal suing Avalon Capital Group, Inc. and several individual executives of Lakeland Construction Finance, LLC, after the bank lost approximately $100 million on loans to Lakeland, with allegations of fraud, intentional and negligent misrepresentation, aiding and abetting, civil conspiracy, alter ego liability, unjust enrichment, and conspiracy to breach contract. The court dismissed all claims against the individual defendants (Bassett, Burke, Machacek, and Murray) and most claims against Avalon, allowing only the unjust enrichment claim and part of the alter ego claim against Avalon to remain. Dismissals were primarily due to the amended complaint's failure to plead the specifics of alleged misrepresentations with particularity under Rule 9(b), the absence of allegations that individuals controlled Lakeland, and the legal principle that breach of contract does not constitute a tort that can support a conspiracy claim.

business & regulatoryproceduretorts & liability

The case involved a Hispanic Assistant City Attorney suing the City of Minneapolis for race discrimination and retaliation after repeated failures to be promoted due to low scores on an oral examination, alleging disparate impact under Title VII, the Minneapolis Civil Rights Ordinance, and 42 U.S.C. § 1981. The court had previously entered judgment for the defendant after dismissing the claims. In this order, the court denied the plaintiff's post-judgment motions to recuse the judge and to vacate the judgment under Federal Rule of Civil Procedure 60(b)(6), reasoning that the recusal motion was untimely and without sufficient basis and that no extraordinary circumstances existed to justify relief from the final judgment.

civil rightslabor & employment

This case arose from a 2008 incident in which Minneapolis police stopped plaintiff Vladimir Teichberg and two companions near a rail yard during the Republican National Convention, conducted an investigative detention lasting about 45 minutes, and temporarily seized his camera equipment and computer while seeking a search warrant, which was ultimately denied. Plaintiff sued the officers and the city under the First, Fourth, and Fourteenth Amendments, the Privacy Protection Act, and various state-law tort claims, alleging the stop and seizure were unlawful. The court granted defendants' motion for summary judgment, holding that the officers had reasonable suspicion justifying the stop and that the equipment seizure was reasonable in scope and duration under the Fourth Amendment. It further found no viable First Amendment claim and concluded that the officers were entitled to official immunity on the state claims because their actions were discretionary and not shown to involve malice or willful misconduct, with the city therefore also immune.

criminal lawcivil rightsfree speechprocedure

This case concerns an insurance coverage dispute arising from a 2005 single-vehicle accident in which a passenger's hand was amputated while riding in a semi-tractor owned by Nathan Peterson and hauling a trailer owned by Holicky Bros. Great West Casualty Company, which had issued a 'filings only' policy to Holicky to satisfy federal motor carrier financial responsibility requirements, sought a declaration that its policy provided no coverage for the claims, while General Casualty, Holicky's primary auto insurer, argued otherwise. The court granted Great West's motion for summary judgment and denied General Casualty's, holding that Great West's policy did not provide coverage by its terms and that the federal minimum coverage requirements had already been satisfied through payments and policies issued by Progressive and General Casualty. The reasoning focused on policy language, premium allocations reflecting relative risk exposure, and the operation of the BMC 91X filing with the Department of Transportation.

business & regulatorytorts & liabilityfederal power

The case involved a dispute over the termination of a Sales Representative Agreement between Warren E. Johnson Companies and Unified Brand, Inc., under which the plaintiff sold kitchen products for commissions. The plaintiff alleged that the termination violated the Minnesota Termination of Sales Representative Act and breached an implied covenant of good faith and fair dealing. The court granted the defendant's motion to dismiss, dismissing the MTSRA claim without prejudice and the related portion of the good faith claim with prejudice. The core reasoning was that the agreement's choice-of-law provision required application of Mississippi law, which precluded the Minnesota statutory claim, and that the termination complied with the contract's express terms allowing termination with or without cause upon 30 days' notice.

business & regulatoryprocedure

This case involved African American current and former employees suing multiple related insurance companies under the ING umbrella for racial discrimination and retaliation, asserting violations of the Minnesota Human Rights Act, the Minneapolis Civil Rights Ordinance, 42 U.S.C. § 1981, and Title VII. The court granted in part and denied in part the defendants' motion to dismiss, finding personal jurisdiction over ING America, ING Payroll, and Lion Holdings based on evidence of centralized operations and integrated payroll and employment systems. It granted plaintiffs 30 days to amend their complaint to properly allege an employment relationship with the remaining defendants, dismissed the request for injunctive relief due to lack of standing, and dismissed ING Financial as it was not shown to be a separate legal entity. The court left intact the discrimination and retaliation claims against ReliaStar and ReliaStar New York, which defendants did not contest as employers.

civil rightslabor & employment

This case is a putative class action brought by owners of 2004-2006 Ford Freestar and Mercury Monterey minivans alleging that a design defect in the torque converter caused transmission failures by stripping splines and leading to loss of propulsion. The plaintiffs asserted six claims under Minnesota law: breach of express and implied warranties, unjust enrichment, breach of the duty of good faith and fair dealing, strict product liability, and negligence. On Ford's Rule 12(b)(6) motion, the court dismissed the express and implied warranty claims as to two named plaintiffs and dismissed the good-faith, strict-liability, and negligence claims in full, reasoning that the pleadings failed to allege required elements such as a basis-of-the-bargain representation or viable tort duties. The court denied Ford's motion to strike the class allegations, holding that individualized issues did not clearly predominate at the pleading stage and that discovery on class issues was warranted before deciding certification.

torts & liabilityprocedure

The case involved a challenge by the Sierra Club to federal approvals for a proposed four-lane highway bridge across the Lower St. Croix River, specifically contesting the National Park Service's 2005 Section 7 Evaluation under the Wild and Scenic Rivers Act that found the bridge would not directly and adversely affect the river's scenic and recreational values. The court granted summary judgment to the plaintiff on that claim, vacating the 2005 evaluation and permanently enjoining further action on the bridge project until a compliant evaluation is issued, while dismissing the remaining claims under NEPA, the Transportation Act, and other statutes. The core reasoning was that the 2005 evaluation was arbitrary and capricious under the Administrative Procedure Act because the agency failed to acknowledge or explain its reversal from the 1996 evaluation, which had reached the opposite conclusion about a similar bridge's visual impacts despite comparable minimization and mitigation measures.

environmentprocedure

The case involves defendants Capers and Williams objecting to a magistrate judge's recommendation to deny their motions to suppress evidence from an October 16, 2009 traffic stop and vehicle search, as well as certain statements and wiretap communications. After de novo review with minor factual modifications, the court found the stop lawful based on observed speeding and driving without headlights, that the drug dog Bandit had alerted at the passenger door, and that the seizure and search were reasonable in scope and duration. The court also determined that the officer's drawing of a firearm was a reasonable response with no impact on the stop's legality and that objections to wiretap evidence and translations lacked merit or were moot. The court adopted the report and recommendation and denied the motions to suppress in full.

criminal lawprocedure

This case involved recording companies suing Jammie Thomas-Rasset for willfully infringing copyrights in 24 sound recordings by illegally downloading and distributing them via the Kazaa peer-to-peer file-sharing network. After a second jury trial awarded $1.92 million in statutory damages, the court considered motions for remittitur, a new trial, and to amend the judgment. The court granted in part Thomas-Rasset's motion by reducing the damages to $2,250 per song (three times the statutory minimum), finding the original award grossly excessive relative to actual damages and deterrence needs under the Copyright Act, while denying a new trial on evidentiary and other grounds. It also granted the plaintiffs' motion to add a permanent injunction barring future infringement and requiring destruction of unauthorized copies. The court reasoned that statutory damages must bear some relation to actual harm and that the reduced amount represents the maximum a jury could reasonably award without constituting a shocking injustice.

business & regulatoryprocedure

This case involves current and former Qwest call center employees who alleged they were not compensated for pre-shift computer boot-up and log-in time and post-shift log-out and shut-down time, despite company policies requiring such activities. Plaintiffs sought class certification for claims under state wage laws in Minnesota, Colorado, Oregon, and Washington, along with partial summary judgment, while defendants moved to decertify a conditional class. The court granted certification for five subclasses covering employees in those states who performed the uncompensated activities during specified time periods, finding that common company-wide scheduling, time-monitoring, and compensation policies applied uniformly across locations. It denied the motion for partial summary judgment. The core reasoning centered on the predominance of shared factual and legal issues regarding whether the off-the-clock work was compensable and consistently unrecorded in the Total View system.

labor & employmentbusiness & regulatory

The case involved Trevor Cook's motion to stay a non-public SEC investigation into possible securities violations by Universal Brokerage FX, Inc. and related entities, of which Cook was a part owner, due to concerns over a parallel criminal grand jury investigation. Cook had not filed a complaint and sought the stay based on the overlap between the civil and criminal matters and potential Fifth Amendment issues. The court denied the motion for lack of subject matter jurisdiction, holding that no civil action had been properly commenced under the Federal Rules and that the SEC's decision to investigate is committed to its discretion by statute. The court further noted that challenges to SEC investigations generally require a subpoena enforcement proceeding or a specific claim under the Administrative Procedure Act alleging improper agency action, neither of which applied here.

business & regulatorycriminal lawfederal powerprocedure