Justia Business Law Opinion Summaries

In a case involving cobalt mining in the Democratic Republic of Congo (DRC), the U.S. Court of Appeals for the District of Columbia Circuit held that the plaintiffs, former cobalt miners injured in mining accidents and their representatives, have standing to pursue damages claims, but not injunctive relief, against five American technology companies under the Trafficking Victims Protection Reauthorization Act of 2008 (TVPRA).Plaintiffs argued that the technology companies participated in a venture with their cobalt suppliers by purchasing the metal through the global supply chain, which allegedly involves forced labor. The court ruled that merely purchasing an unspecified amount of cobalt through the global supply chain does not amount to "participation in a venture" within the meaning of the TVPRA, and hence, the plaintiffs failed to state a claim for relief.The court also dismissed the plaintiffs' common law claims for unjust enrichment, negligent supervision, and intentional infliction of emotional distress, as they failed to demonstrate that the technology companies participated in a venture with anyone engaged in forced labor. Therefore, the court affirmed the district court's dismissal of the complaint. View "Doe v. Apple Inc." on Justia Law

The United States Court of Appeals for the Third Circuit reviewed a decision of the National Labor Relations Board (NLRB) regarding unfair labor practices alleged against New Concepts for Living, Inc. New Concepts sought review of an NLRB order determining that it engaged in unfair labor practices by pushing to decertify its employees' union. The NLRB affirmed the administrative law judge's dismissal of three charges against New Concepts but reversed his dismissal of five others.New Concepts, a nonprofit corporation providing services for people with disabilities, had been in a stalemate with its employees' union after the most recent collective bargaining agreement expired. Due to the union's inactivity, many employees expressed dissatisfaction and began a decertification movement. During this period, New Concepts suspended bargaining and issued memorandums to its employees about their right to resign from the union and stop the deduction of union dues. The NLRB found that these actions, as well as New Concepts' conduct during collective bargaining negotiations and a poll to assess union support, constituted unfair labor practices.The Court of Appeals disagreed, concluding that the NLRB's determinations were not supported by substantial evidence. The court found that New Concepts had both contractual and extracontractual bases for distributing the memorandums, did not unlawfully track employee responses, and provided adequate assurances against reprisals. Additionally, the court determined that New Concepts did not engage in bad faith bargaining and that its poll and subsequent withdrawal of recognition from the union were lawful. The court thus granted New Concepts' petition for review and denied the NLRB's cross-application for enforcement. View "New Concepts for Living Inc v. NLRB" on Justia Law

The case involves Suzy Martin, the owner and president of Smart Elevators Co., a certified minority- and woman-owned elevator service and repair company. The company, which historically did most of its business with the State of Illinois and the City of Chicago, saw its customer base change after a whistleblower complaint alleged that Martin and her company engaged in a bribery and kickback scheme with a University of Illinois Chicago employee. This led to an investigation by the Office of the Executive Inspector General for the Agencies of the Illinois Governor (OEIG), which concluded that Martin, Smart Elevators, and the University employee had engaged in a kickback scheme that violated Illinois ethics law and University policy and recommended that the University sever ties with Martin and her company.As a result of the report, the State and City ceased doing business with Martin and Smart Elevators, causing the company to lose millions in preexisting and potential contracts. Martin sued several State and City entities and officials under 42 U.S.C. § 1983, bringing “stigma-plus” procedural due process claims under the Fourteenth Amendment. The district court dismissed her amended complaint with prejudice.Upon appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court concluded that Martin's occupation was operating an elevator service and repair business, not just providing those services specifically to the State or City. The court also found that despite the loss of State and City contracts, Martin had not been denied her liberty to pursue her occupation as she remained the owner and operator of Smart Elevators, which continued to operate and even managed to secure a contract with the Department of Justice in 2021. As such, the court found no violation of Martin's occupational liberty rights. View "Martin v. Haling" on Justia Law

The case involves the Reporters Committee for Freedom of the Press, a nonprofit organization that sought to unseal court filings from federal criminal investigations. The District Court in Minnesota dismissed the application for lack of jurisdiction, and the case was appealed to the United States Court of Appeals for the Eighth Circuit.The Reporters Committee's application aimed to unseal electronic-surveillance filings, which were required to be filed under seal by a local rule. The District Court believed the request was too broad since the majority of the materials requested become unsealed after six months. The court suggested negotiations with the United States Attorney’s Office to reach a solution.The Reporters Committee subsequently filed an amended application, seeking an order directing the clerk of the court to presumptively unseal warrants and related documents after 180 days and to begin docketing the government’s applications for electronic surveillance regardless of whether a judge granted them. The Committee claimed these duties arose under the First Amendment and the common-law right of access to public records and documents.The District Court dismissed the application, concluding that the Committee lacked standing because all it had was a “generalized, abstract interest” in unsealing the records. This decision was affirmed by the Appeals Court, which held that the Committee failed to establish it suffered a “concrete” and “particularized” injury. It was also noted that the Committee did not sue anyone who could provide the relief it sought, hence there was a lack of adversity necessary for federal court adjudication. View "Reporters Comm. for Freedom of the Press v. United States" on Justia Law

A Vermont-based non-profit organization and an LLC challenged a superior court's dismissal of their complaint over a grant they did not receive. The plaintiffs, Housing Our Seniors in Vermont Inc. and Lakemont Retirement Community LLC, argued that the grant provided by the Newport Development Fund Grant Committee to another organization was wrongly awarded. The plaintiffs also alleged a conflict of interest in the committee.However, the Vermont Supreme Court upheld the lower court's decision, reasoning that the plaintiffs lacked standing to challenge the grant award. The court clarified that the plaintiffs had no legal right to receive the grant or to have any specific procedure in the allocation of the grant. The court also dismissed the plaintiffs' argument of specific rules governing the grant process asserting that the grant process was discretionary, and the eligibility criteria did not guarantee any particular process.Consequently, the court affirmed the superior court's dismissal for lack of standing, reinforcing that a legal entitlement or right is essential to establish an injury-in-fact for standing. View "Housing Our Seniors in Vermont Inc. v. Agency of Commerce & Community Development" on Justia Law

In this case, Bay, Ltd., a construction company, filed suit against The Most Reverend Wm. Michael Mulvey, Bishop of the Diocese of Corpus Christi, seeking to recover the value of unauthorized improvements made to a ranch leased from the Bishop by Michael Mendietta, a former Bay employee. Mendietta had used Bay's resources for these improvements without the company's consent. Bay also filed a separate lawsuit against Mendietta for damages related to his unauthorized actions, including the improvements to the ranch.Six years later, Bay and Mendietta entered into an agreement settling their claims. This agreement required Mendietta to pay Bay $750 per month to avoid a $1.9 million final judgment. The agreement allocated $175,000 of the settlement amount to Mendietta's homestead, but did not allocate specific values to the other injuries suffered by Bay, including the improvements to the ranch.After Bay dropped its claims against Mendietta and proceeded to trial against the Bishop alone, the jury awarded damages to Bay. However, the Bishop requested a settlement credit of $1.725 million (the total settlement amount minus the $175,000 allocated to Mendietta's homestead). The lower court denied this request, but the appellate court reversed, concluding that the unallocated amount of the settlement exceeded the jury's award to Bay.The Supreme Court of Texas affirmed the appellate court's decision, holding that the agreement between Bay and Mendietta constituted a $1.9 million settlement agreement. Because the agreement allocated $175,000 to an injury other than the one Bay sought to recover from the Bishop, the remaining $1.725 million was credited against the jury's verdict, resulting in a take-nothing judgment for Bay. View "BAY, LTD. v. MULVEY" on Justia Law

The dispute arose from an agreement between Columbia Plaza Associates (CPA) and Northeastern University regarding the development of a parcel of land in Boston. The contract stipulated that the developer for each phase of the project would be Northeastern or an affiliated entity, which could include CPA. The contract also specified that the developer of the garage parcel would be a joint venture between Northeastern and CPA.CPA claimed that Northeastern violated the agreement when it sought to develop a subparcel unilaterally and repudiated CPA's rights to that subparcel. CPA also argued that Northeastern's communication with a governmental agency amounted to a deceptive business practice.The court held that the agreement did not grant CPA development rights in any of the subparcels except for the garage parcel. The court also found no proof of an enforceable promise by Northeastern to build a hotel with CPA on the disputed subparcel. The court thus ruled in favor of Northeastern on all counts, including CPA's claims for breach of contract, breach of the implied covenant of good faith and fair dealing, intentional interference with advantageous economic relations, unjust enrichment, commercial fraud, unfair or deceptive business practices, and requests for declaratory and injunctive relief.The court further held that Northeastern was entitled to attorney's fees under the anti-SLAPP statute because it successfully dismissed CPA's claim of commercial fraud, which was based solely on Northeastern's petitioning activity. The court did not find CPA's claim to be a SLAPP suit. View "Columbia Plaza Associates v. Northeastern University" on Justia Law

In a complex commercial dispute with a series of administrative and legal challenges, the Supreme Judicial Court of Massachusetts found that the defendants, Bristol Asphalt Co., Inc. and others, did not meet the criteria to dismiss the case under the "anti-SLAPP" statute. The court outlined a simplified framework for considering anti-SLAPP motions, returning to the traditional approach set out in Duracraft Corp. v. Holmes Prods. Corp. The court also clarified that the appropriate standard of review for a ruling on a special motion to dismiss is de novo, rather than for an abuse of discretion.The dispute arose from the plaintiffs' efforts to open an asphalt plant in the same industrial zone as the existing plant owned by the defendants. The defendants launched a series of administrative and legal challenges to the plaintiffs’ efforts to obtain regulatory approval for the construction and operation of the proposed plant. The plaintiffs filed a three-count complaint alleging that the defendants' legal challenges constituted unfair or deceptive acts or practices, conspiracy in restraint of trade, and abuse of process. In response, the defendants filed a special motion to dismiss under the anti-SLAPP statute.The Supreme Judicial Court affirmed the lower court's denial of the defendants' special motion to dismiss, concluding that the defendants' petitioning activities were not entitled to the procedural protections of the anti-SLAPP statute. The court found that the defendants' challenges to the plaintiffs' proposed asphalt plant did not lack any reasonable factual support or arguable legal basis. Therefore, the plaintiffs' claims against the defendants were not based solely on the defendants' petitioning activities and were not subject to dismissal under the anti-SLAPP statute. View "Bristol Asphalt, Co., Inc. v. Rochester Bituminous Products, Inc." on Justia Law

Insight Terminal Solutions, LLC ("ITS") appealed against a decision by the Bankruptcy Appellate Panel of the Sixth Circuit. The dispute centered on a claim originally filed by Cecelia Financial Management, LLC ("Cecelia"), and later transferred to Bay Bridge Exports, LLC ("Bay Bridge"), in ITS's chapter 11 bankruptcy. ITS sought to disallow or reduce the claim, recharacterize the debt as an equity contribution, and hold John J. Siegel, Jr., the non-member manager of both ITS and Cecelia, liable for fraud. The Bankruptcy Court allowed the claim, rejecting ITS's arguments. On appeal, ITS argued that the Bankruptcy Court erred in refusing to admit incomplete deposition testimony from Siegel, who died before cross-examination could take place. ITS also contended that the court erred in applying the presumption of validity to the claim and in refusing to recharacterize the claim as equity. The Appellate Panel upheld the Bankruptcy Court's decision, finding no reversible error. It ruled that the Bankruptcy Court was within its discretion to exclude Siegel's incomplete testimony and found no error in the court's decision to allow the claim and refusal to recharacterize it as equity. View "In re Insight Terminal Solutions, LLC" on Justia Law

The case in question originated in the United States Court of Appeals for the Seventh Circuit. The dispute arose after the dissolution of a business partnership between Gregory Kleynerman and Scott Smith, which resulted in Smith obtaining a state court judgment of $499,000 against Kleynerman. This judgment was secured by Kleynerman's membership interest in Red Flag Cargo Security Systems LLC. Following this, Kleynerman filed for bankruptcy and valued his interest in Red Flag at $0. Smith argued in the bankruptcy court that the state court's judgment was a result of Kleynerman's fraud and thus could not be discharged. However, the bankruptcy court rejected this argument.After the bankruptcy case was closed, Kleynerman asked the state court to deem the $499,000 judgment discharged. Smith contended that under Wisconsin law, only debts secured by real property can be avoided. The state court agreed with Smith, which led Kleynerman to request the bankruptcy court to reopen the case and clearly state that both the $499,000 debt and the lien on Kleynerman’s interest in Red Flag no longer existed.The bankruptcy court reopened the case and the district court affirmed the decision. The appellate court agreed with the lower courts, stating that the bankruptcy judge had authority to reopen the case, and that Kleynerman had cause for reopening.Furthermore, the court held that the value of Kleynerman’s interest in Red Flag was a matter for the bankruptcy judge to decide before the discharge. Smith had an opportunity to object to Kleynerman's valuation of his interest in Red Flag but failed to do so until after the bankruptcy court had entered its discharge order. The court concluded that Smith's post-discharge subpoenas seeking information about the value of Kleynerman’s interest in Red Flag were a fishing expedition and an exercise in harassment, which was properly rejected by the bankruptcy judge. Therefore, the court affirmed the decision of the lower courts. View "Smith v. Kleynerman" on Justia Law