Matthew Leonard worked at a concession stand owned and operated by a for-profit company during a baseball game at Busch Stadium in St. Louis.  Although he believed he was serving as a volunteer to raise money for Washington University, he later concluded that he should have been compensated as an employee under the Fair Labor Standards Act and Missouri’s minimum wage laws. 

A citizen domiciled in Haiti cannot sue a defendant domiciled in Maine and claim federal court jurisdiction based on diversity of citizenship because of an “arcane” exception to the general rule allowing a citizen of one state to sue a citizen of another state in federal court.  But it was enough to cause a federal District Court in Maine to throw out two defamation verdicts totaling  $14.5 million when the defendant raised the issue after losing a “long, arduous” trial.  (

The Supreme Court of North Dakota has refused to create an exception to the general rule that an unincorporated association may not hold title to real estate under state law.  It has denied a request by a nonprofit association to make an exception to recognize a deed the association claimed it received from the former owner.  (The Next Step v. Redmon, Supreme Ct., ND, No. 20150333, 5/26/16.)

The national Council for American-Islamic Relations Action Network may be liable for the failures of the unlicensed “attorney” for a local chapter after all.  The Circuit Court of Appeals for the District of Columbia has reversed a trial court decision dismissing claims by individuals who were not served even though they had paid the “attorney” to help them.