Latest 2 Cases: Henley v. Payne (Civil Rights), Bearden v. E.I. Du Pont De Nemours and Co. (Contracts)

Man’s Best Captive

SHERRY F. COLB

Cornell law professor Sherry F. Colb considers whether an explanation for the affection dogs express for their humans might be explained by the Stockholm Syndrome, the condition that afflicts many kidnapped people and other abuse victims in which they form an attachment, sometimes called a trauma bond, that manifests as seeking the abuser’s approval and craving closeness rather than trying to escape. Colb argues that even though pet owners might not intend abuse, the unpredictable repetition of house arrest and silent treatment, followed by intermittent returns, might amount to abuse in the minds of these animals we hold as pets.

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Henley v. Payne

Docket: 18-13101

Opinion Date: December 30, 2019

Judge: Martin

Areas of Law: Civil Rights, Constitutional Law

The Eleventh Circuit held that Heck v. Humphrey, 512 U.S. 477, 114 S. Ct. 2364 (1994), did not bar plaintiff's civil action for false arrest under 42 U.S.C. 1983. In this case, plaintiff was arrested as he rode his bicycle through the grounds of a former elementary school and was charged with criminal trespass. Plaintiff was released from jail three weeks later and later pleaded guilty to unrelated charges. The court held that Heck did not apply to the circumstances around plaintiff's plea agreement, and the district court wrongly dismissed plaintiff's section 1983 claim. Determining that the district court had jurisdiction over plaintiff's state claims against Deputy Payne, the court affirmed the dismissal of the malicious arrest and intentional infliction of emotional distress claims. However, the court vacated the dismissal of the false imprisonment claim where plaintiff alleged that he was unlawfully detained for the time between his arrest and when his arrest warrant was procured. Finally, the court affirmed the district court's sua sponte decision to dismiss the claims against Sheriff Millsap under its 18 U.S.C. 1915 authority.

Bearden v. E.I. Du Pont De Nemours and Co.

Docket: 18-14345

Opinion Date: December 30, 2019

Judge: William Holcombe Pryor, Jr.

Areas of Law: Contracts, Labor & Employment Law

At issue was the word "retirement" in the Award Terms of stock options granted to plaintiff by his employer E.I. du Pont de Nemours and Company. Under the terms of the award, an employee who leaves the company "due to retirement" keeps the original expiration date of his stock options, but an employee who leaves for other reasons must exercise his stock options by his last day of employment. Applying Delaware law, the Eleventh Circuit held that an employee is eligible for retirement within the meaning of the Award Terms only upon satisfying both the age and years-of-service requirement. Therefore, plaintiff's 10 years of service with DuPont fell short of the years-of-service requirements within Section IV of the Pension Plan. Accordingly, the court affirmed the district court's grant of summary judgment to DuPont.