News & Analysis as of

Motion to Dismiss

CDF Labor Law LLP

PAGA Update: Cal. Court of Appeal Confirms PAGA Plaintiffs Must Have a Timely Individual PAGA Claim

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In a decision with important implications for many pending Private Attorneys General Act (PAGA) lawsuits, a California Court of Appeal upheld the dismissal of a representative PAGA action as untimely because the plaintiff did...more

Marshall Dennehey

Court Affirms Dismissal of Lawsuit Over City Pothole Fall, Citing Lack of Evidence

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Baranowski v. City of Newark, Docket No. A-2262-23, NJ Super., App. Div., Mar 11, 2025 - The plaintiff tripped and fell in a pothole in the City of Newark. There were no complaints reported about this pothole prior to this...more

Littler

The Supreme Court Relieves ERISA Plaintiffs of a Pleading Requirement: What’s Next for ERISA Plan Fiduciaries?

Littler on

On April 17, 2025, the U.S. Supreme Court issued a decision that dealt a blow to benefit plan fiduciaries nationwide. The Court unanimously held in Cunningham v. Cornell University that a plaintiff asserting that a plan and...more

Marshall Dennehey

Examining the Limits of the State-Created Danger Doctrine

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Cappel v. Aston Twp. Fire Dep’t, 693 F. Supp. 3d 467 (E.D. Pa. 2023) - During the COVID-19 pandemic, the decedent’s family urgently called 911 as she struggled to breathe and had dangerously low blood-oxygen levels. However,...more

Clark Hill PLC

Ninth Circuit expands specific jurisdiction for e-commerce platforms

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In Briskin v. Shopify, Inc., the Ninth Circuit Court of Appeals, sitting en banc, reversed a district court’s dismissal of a proposed data privacy class action for lack of personal jurisdiction. In applying traditional...more

Fox Rothschild LLP

Two business court rulings offer insights on trade secret pleadings, employment agreements, and credibility

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Maven Advantage, Inc. and Square One Storm Restoration, LLC are competing roofing businesses. Maven alleged that two employees (Couch and Daniels) stole Maven’s trade secrets (customer lists) and then quit to work for Square...more

Morris James LLP

Chancery Dismisses Executive Compensation Action For Failure To Plead Demand Futility

Morris James LLP on

Eckert v. Hightower, C.A. No. 2024-0569-MTZ (Del. Ch. Mar. 24, 2025) - A board of directors approved compensation packages for the company’s CEO, who also was its controlling stockholder. The CEO was a member of the...more

Hogan Lovells

Federal district court denies Target’s motion to dismiss securities claims related to one of its ESG and DEI Initiatives

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In Craig v. Target Corporation, et al., the District Court for the Middle District of Florida considered whether Target Corporation (Target) committed securities violations by failing to disclose risks related to an ESG and...more

Husch Blackwell LLP

Supreme Court Decision Means Defense of ERISA Prohibited Transaction Claims Just Got More Difficult and More Protracted

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On April 17, 2025, the Supreme Court decided Cunningham v. Cornell University, unanimously holding that a plaintiff can state a valid claim under ERISA by merely alleging that a plan used “plan assets” to pay a service...more

Houston Harbaugh, P.C.

U.S. District Judge Refuses To Dismiss Copyright Infringement Claims against Musk and Tesla®* in Blade Runner 2049 Case

Houston Harbaugh, P.C. on

AI, Sci-Fi, and Copyright Collide in Alcon Entertainment LLC v. Tesla Inc. et al., Case No. 2:24-cv-09033, in the U.S. District Court for the Central District of California. In a fascinating twist of sci-fi meets reality,...more

Epstein Becker & Green

New York Court of Appeals Holds That Child Victims Act Claims Brought Against the State of New York Must Meet Statutory...

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In a unanimous ruling, the New York Court of Appeals held that the New York State Legislature did not alter the substantive pleading requirements of Section 11(b) of the Court of Claims Act (the “Act”) for claims brought...more

Alston & Bird

What to Expect from Georgia’s New Tort Reform Law

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Our Industrials & Manufacturing and Products Liability Groups break down how Georgia’s new law alters the tort landscape....more

Seyfarth Shaw LLP

PAGA Paraphrased – Williams v. Alacrity Solutions Group, Inc.

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PAGA claims brought under pre-reform PAGA must be brought within one year of a Labor Code violation experienced by the plaintiff and because a PAGA claim necessarily has both an individual and a non-individual component,...more

Akin Gump Strauss Hauer & Feld LLP

Federal Circuit: PTAB Decision of Invalidity Cannot Estop District Court Litigation on Different Claims from the Same Patent, Even...

The Federal Circuit recently refused to apply collateral estoppel to claims of a patent asserted in district court litigation based on a Patent Trial and Appeal Board (PTAB) decision finding similar claims from the same...more

Groom Law Group, Chartered

Cunningham v. Cornell: Supreme Court Lowers Bar for ERISA 406(a) Claims

On April 17, 2025, the Supreme Court ruled in Cunningham v. Cornell University that, to state a claim under ERISA section 406(a), plaintiffs need only allege the elements contained in section 406(a). Prior to the Supreme...more

Vedder Price

Cunningham v. Cornell University

Vedder Price on

On April 17, 2025, the U.S. Supreme Court issued a unanimous opinion on the requirements for plaintiffs to survive a motion to dismiss regarding an allegation that plan fiduciaries engaged in a prohibited transaction under...more

Groom Law Group, Chartered

One Court Permits Tobacco Premium Surcharge Claims to Proceed Beyond the Pleading Stage, While Dispositive Motions Remain Pending...

In fall 2024, plaintiffs filed a wave of putative class action lawsuits against employers challenging wellness programs that impose a health coverage premium surcharge on participants if they do use tobacco or do not complete...more

Tucker Arensberg, P.C.

Third Circuit Validates Pension Plan’s Right to Revise Withdrawal Liability Assessment and Its Enforcement in Federal Court

Tucker Arensberg, P.C. on

In Central States, Se. & W. Areas Pension Fund v. Laguna Dairy, S. de R.L. de C.V., No. 23-3206 (3d Cir. 2025 Mar. 27, 2025), the United States Court of Appeals for the Third Circuit (“Third Circuit”) reversed the district...more

Miller Canfield

ERISA in the Supreme Court: Implications of Cunningham v Cornell University

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On April 17, 2025, the U.S. Supreme Court issued a unanimous opinion in Cunningham v Cornell University, addressing the pleading standard applicable to prohibited transaction claims under the Employee Retirement Income...more

Morrison & Foerster LLP

Sec Lit IQ: MoFo’s Quarterly Federal Securities Litigation and Delaware Corporate Litigation Newsletter (Q1 2025)

In our second edition of MoFo’s quarterly federal securities and Delaware corporate litigation newsletter, we provide a rundown of select developments from the first quarter of 2025. The Ninth Circuit Confirms That...more

A&O Shearman

Supreme Court’s Cornell decision sets low pleading bar for ERISA claims

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In a decision poised to change the landscape of Employee Retirement Income Security Act of 1974 (“ERISA”) litigation, on April 17, 2025, the Supreme Court held in Cunningham et al. v. Cornell University et al. that a claimant...more

Patterson Belknap Webb & Tyler LLP

To Threat or Not to Threat, That is the DJ Question: Judge Rakoff Dismisses DJ Action and Finds the Court Does Not Have...

On April 1, 2025, United States District Judge Jed S. Rakoff granted Defendants Marut Enterprises LLC and Brett Marut’s (collectively, “Defendants”) motion to dismiss and entered final judgment against Foto Electric Supply...more

Proskauer - Employee Benefits & Executive...

Supreme Court Establishes Lower Pleading Standard for Prohibited Transaction Claims

In a unanimous decision, the U.S. Supreme Court ruled in Cunningham v. Cornell University that plaintiffs can satisfy the requirements for pleading prohibited party-in interest transactions under ERISA section 406(a) without...more

Kilpatrick

The Supreme Court Delivers Troubling Decision for ERISA Excess Fee Cases

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On April 17, 2025, the U.S. Supreme Court issued a unanimous opinion that has the potential to make it more difficult for defendants to have excess fee cases for 401(k) or 403(b) plans dismissed at an early stage of...more

Hogan Lovells

Tenth Circuit affirms dismissal of short seller’s claims against Overstock

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On October 15, 2024, the United States Court of Appeals for the Tenth Circuit issued an opinion in In re Overstock Securities Litigation affirming the District of Utah’s dismissal of putative class action claims under the...more

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