In Alday v. Raytheon Co., No. 08-16984, an action alleging that defendant breached collective bargaining agreements (CBAs) with plaintiffs and violated the Labor Management Relations Act (LMRA) and the Employee Retirement Income Security Act (ERISA), the court affirmed summary judgment for plaintiff where 1) the language of the CBAs made clear that defendant's agreement to pay retiree medical insurance premiums continued beyond the term of the CBAs, even where its agreement to pay non-retired employee premiums did not; 2) defendant's leeway to amend its benefit plans did not allow it to alter the terms of the CBAs under which it agreed to provide company-paid health insurance to retirees; and 3) plaintiffs failed to allege sufficient facts supporting their claim for punitive and extra-contractual damages.
In Armstrong v. Schwarzenegger, No. 09-17144, a class action against California officials with responsibility over the corrections system and parole proceedings, seeking accommodations to plaintiffs' disabilities under the Americans with Disabilities Act, the Rehabilitation Act, and the Constitution, the court affirmed in part the district court's order granting plaintiffs' motion to require defendants to track and accommodate the needs of class members housed in county jails and to ensure a workable grievance procedure for such class members, holding that 1) defendants were responsible for providing reasonable accommodations to the disabled prisoners and parolees they housed in county jails; and 2) the district court made the findings required by the Prison Litigation Reform Act (PLRA) regarding the necessity for relief and the narrowness and lack of intrusiveness of the relief order. However, the court vacated in part on the ground that injunctions, whether controlled by the PLRA or otherwise, required evidence of rights violations commensurate with the scope of the relief being ordered.