News & Analysis as of

Appeals Forfeiture

Morris, Manning & Martin, LLP

A Friendly DOL Amicus Brief on Forfeitures

On July 9th, the Secretary of Labor filed an amicus brief with the Ninth Circuit relating to the appeal of Hutchins v. HP, Inc. In that case, a participant claimed that forfeitures should have been used to offset plan...more

Jackson Walker

Fifth Circuit Criminal Opinions: Insights and Analyses Part IIII

Jackson Walker on

Hello all. Below is the May 2025 edition of the Fifth Circuit criminal and civil case summaries, with a special focus on cases of interest to white-collar practitioners. This past month, the Fifth Circuit issued published...more

Carlton Fields

Florida Appeals Court Decisions Week of June 30 - July 3, 2025

Carlton Fields on

U.S. Eleventh Circuit Court of Appeals - Lamonaco v. Experian - arbitration - Labriola v. Miami-Dade - employment, First Amendment - Wood v. Fla DOE - school, transgender, § 1000.071, First Amendment - USA v....more

Holland & Knight LLP

Supreme Judicial Court Clarifies Scope of Massachusetts Noncompetition Agreement Act

Holland & Knight LLP on

The Massachusetts Supreme Judicial Court (SJC) has ruled that a forfeiture clause triggered by a breach of a non-solicitation agreement is not a "forfeiture for competition agreement" under the Massachusetts Noncompetition...more

Proskauer - Employee Benefits & Executive...

Tenth Circuit Affirms Distinction Between Forfeiture and Penalty for Competition

In Lawson v. Spirit AeroSystems, Inc., the U.S. Court of Appeals for the Tenth Circuit upheld the forfeiture of certain stock awards for violating a covenant not to compete. Like the Seventh Circuit in LKQ Corp. v....more

Sheppard Mullin Richter & Hampton LLP

The Importance of Preserving Issues for Appeal

This Federal Circuit opinion analyzes claim construction arguments and requests for remittitur in the context of preserving issues for appeal. Background - Belanger is a manufacturer of car wash systems. Belanger owns...more

Morris James LLP

Delaware Supreme Court Clarifies Enforcement of Forfeiture-for-Competition Provisions

Morris James LLP on

LKQ Corp. v. Rutledge, C.A. No. 110, 2024 (Del. Dec. 18, 2024) - In this en banc decision, the Delaware Supreme Court answered a certified question from the United States Court of Appeals for the Seventh Circuit...more

Davis Wright Tremaine LLP

5th Circuit Holds That Jarkesy Invalidates FCC Forfeiture Order Against AT&T

The U.S. Court of Appeals for the 5th Circuit held that the Federal Communications Commission (FCC or Commission) violated AT&T's Seventh Amendment right to a jury trial and right to adjudication by an Article III court when...more

Wiley Rein LLP

Fifth Circuit Strikes Down FCC Forfeiture Order, Holds That It Violates Seventh Amendment Right to a Jury Trial

Wiley Rein LLP on

On April 17, 2025, the Fifth Circuit issued an opinion (“Op.”) holding unconstitutional a Federal Communications Commission (FCC or Commission) enforcement order. In that order, the Commission imposed civil penalties against...more

Troutman Pepper Locke

Feeling Competitive: The Reasonableness of Forfeiture-for-Competition Provisions

Troutman Pepper Locke on

In 2024, employers rushed to track the twists and turns of the Federal Trade Commission’s (FTC) noncompete ban, which attempted to limit the enforceability of agreements that restrict employees from working for a competitor...more

Epstein Becker & Green

Massachusetts High Court To Weigh In on Forfeiture-for-Solicitation Provisions in Era of Massachusetts Noncompetition Agreement...

Epstein Becker & Green on

On Monday, March 3, 2025, the Massachusetts Supreme Judicial Court (“SJC”) heard argument in Miele v. Foundation Medicine, Inc., regarding whether the Massachusetts Noncompetition Agreement Act, G. L. c. 149, § 24L (the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Seventh Circuit Rules Forfeiture-for-Competition Clauses Under Delaware Law Enforceable and Not Subject to Reasonableness Review

In 2021, LKQ Corporation (LKQ) filed suit against Robert Rutledge, its former plant manager, in the U.S. District Court for the Northern District of Illinois. LKQ alleged that Rutledge’s working for a competitor within nine...more

Perkins Coie

Split Ninth Circuit Opinion Imposes Due Process Requirements for “In Rem” Forfeiture of Foreign Assets

Perkins Coie on

In United States v. Nasri, the U.S. Court of Appeals for the Ninth Circuit held that the U.S. government must satisfy Due Process requirements before it can seek civil forfeiture of assets located abroad. The 2-1 split panel...more

McDermott Will & Emery

Equivalence Requires Element-by-Element Proof With Linking Argument

McDermott Will & Emery on

The US Court of Appeals for the Federal Circuit affirmed a district court determination that a patent owner had not provided the “particularized testimony and linking argument” required to demonstrate equivalence under the...more

McDermott Will & Emery

Unified Front: No Forfeiture by Failing to Raise Argument in Request for Rehearing

Addressing forfeiture of issues on appeal and sufficiency of the asserted prior art, the US Court of Appeals for the Federal Circuit upheld a Patent Trial & Appeal Board obviousness finding, explaining that a party does not...more

Adler Pollock & Sheehan P.C.

The Devil is in the Details: Waiver, Forfeiture, and the Critical Distinction for Appellate Advocates

Litigators and jurists alike frequently use the terms “waiver” and “forfeiture” interchangeably in federal appellate practice.  However, these are distinct concepts, and a savvy litigator will carefully consider them when...more

McDermott Will & Emery

Say Goodbye: Argument Not Presented in IPR Petition Is Waived

McDermott Will & Emery on

In a split decision, the US Court of Appeals for the Federal Circuit affirmed a Patent Trial & Appeal Board patentability determination, finding that the challenger’s appeal arguments were not raised in its inter partes...more

McDermott Will & Emery

No Smoking Gun Here: Soliciting Input Sufficient to Satisfy Commission’s Statutory Obligation

Addressing a decision by the US International Trade Commission finding a violation of Section 337, the US Court of Appeals for the Federal Circuit agreed with the Commission on a slew of issues, including its determination...more

McDermott Will & Emery

Your Gang Did What!? No Matter—No Forfeiture of IP

McDermott Will & Emery on

In a unique case blending intellectual property and criminal law, the US Court of Appeals for the Ninth Circuit agreed that a district court properly exercised jurisdiction over a motorcycle club and upheld the lower court’s...more

Patton Sullivan Brodehl LLP

Enforceability of Commercial Lease Co-Tenancy Provisions

A commercial lease co-tenancy clause conditions a retail tenant’s opening for business or continuing operations at the designated property upon another tenant opening for business or continuing operations at the same...more

Fuerst Ittleman David & Joseph

D.C. Circuit: U.C.C. Article 4A Does Not Govern Judgment Creditors’ Claims to Sanctioned Company’s Funds Held by Intermediary...

On August 16, 2022, the United States Court of Appeals for the D.C. Circuit issued its ruling in Estate of Jeremy Isadore Levine, et al. v. Wells Fargo Bank, N.A., No. 21-7036, –F.4th– (D.C. Circuit August 16, 2022), a case...more

Fox Rothschild LLP

Show Me The Money

Fox Rothschild LLP on

For years, tension has existed between federal and state criminal prosecutors over forfeitures. Criminal forfeitures result from the seizure (and, if necessary, the sale) of contraband such as cash from illegal activities or...more

Fitch, Even, Tabin & Flannery LLP

Failure to Raise Claim Construction Issue at Jury-Instruction Phase Constituted Forfeiture

On May 20, in Michael Philip Kaufman v. Microsoft Corporation, the Federal Circuit issued an opinion illustrating the importance of raising claim construction disputes at trial to avoid forfeiting arguments in post-verdict...more

Farrell Fritz, P.C.

Third Department Examines In Terrorem Clause

Farrell Fritz, P.C. on

The recent opinion by the Appellate Division, Third Department, in In re Strom Irrevocable Trust III, 2022 NY Slip Op 01356, provides a cautionary tale to estate litigators who conduct SCPA 1404 examinations in the face of a...more

Cozen O'Connor

Notice of Appeal - Spring 2021

Cozen O'Connor on

Precedential Opinions of Note - Government Must Prove Falsity Under Any Objectively Reasonable Standard - United States v. Harra (January 12, 2021), No. 19-1105 http://www2.ca3.uscourts.gov/opinarch/191105p.pdf Unanimous...more

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