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HALEY HRDLICKA,
Plaintiff-Appellant,
v.
GENERAL MOTORS, LLC,
Defendant-Appellee.
   No. 22-1328
Appeal from the United States District Court for the Eastern District of Michigan at Port Huron.
No. 3:20-cv-11015—Robert H. Cleland, District Judge.
Argued: December 7, 2022
Decided and Filed: February 7, 2023
Before: SILER, GILMAN, and NALBANDIAN, Circuit Judges.


_________________________
OPINION
_________________________

RONALD LEE GILMAN, Circuit Judge. Haley Hrdlicka was employed by General Motors for over 30 years. After General Motors terminated her employment due to excessive absenteeism, she brought this employment-discrimination lawsuit. The district court granted summary judgment in favor of General Motors on all claims. For the reasons set forth below, we AFFIRM the judgment of the district court.



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DIGITAL MEDIA SOLUTIONS, LLC,
Plaintiff,

EMMANUEL DUNAGAN; JESSICA MUSCARI; ROBERT J. INFUSINO; STEPHANIE PORRECA,
Intervenor Plaintiffs-Appellants,
v.
SOUTH UNIVERSITY OF OHIO, LLC, et al.,
Defendants,

MARK E. DOTTORE,
Receiver-Appellee.
   No. 21-4014
Appeal from the United States District Court for the Northern District of Ohio at Cleveland.
No. 1:19-cv-00145—Dan A. Polster, District Judge.
Argued: July 19, 2022
Decided and Filed: February 7, 2023
Before: GIBBONS, ROGERS, and MURPHY, Circuit Judges.


_________________________
OPINION
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MURPHY, Circuit Judge. Before the modern bankruptcy laws, federal courts had long reorganized distressed corporate debtors using an equitable remedy: the appointment of a receiver in an “equity receivership” to gather and safeguard the debtor’s assets for a fair division among its creditors. These receiverships, although rare, continue to exist today. Receivers must administer the debtor’s property in accordance with the “historical practice” of courts of equity. Fed. R. Civ. P. 66. In this case, the receiver and several non-receivership parties entered into a settlement that was contingent on the district court’s issuance of a “bar order” that would permanently bar non-settling third parties from pursuing personal-liability claims against non-debtors who were not in the receivership. The district court approved this settlement and entered the requested bar order. This case therefore raises the question of whether historical principles of equity allowed the court to issue an injunction that protected the non-receivership assets of non-receivership parties. Because that type of non-debtor relief amounts to a remedy “previously unknown to equity jurisprudence,” the district court lacked the authority to issue the bar order. Grupo Mexicano de Desarrollo S.A. v. All. Bond Fund, Inc., 527 U.S. 308, 332 (1999). We thus reverse and remand for proceedings consistent with this opinion.