Justia U.S. 1st Circuit Court of Appeals Opinion Summaries

After Mark Jones repeatedly failed to pass an examination to receive a license required by his employer of all persons in that position, by a date of which he had many months' notice, he requested for the first time that the date be extended due to his medical condition. When his employer declined, and Jones declined to pursue an open alternate position at lesser pay, his employment ended. He then sued under both federal and state disability laws. The district court entered summary judgment for the employer. The First Circuit Court of Appeals affirmed, bypassing the question of whether Jones met the definition of "disability" and holding that the reasonable accommodation provisions of both statutes did not save his case. View "Jones v. Nationwide Life Ins. Co." on Justia Law

A pipeline owner and a natural gas supplier entered into a contract for the transportation of the supplier's natural gas. The parties later became embroiled in a dispute and submitted their dispute to binding arbitration. After the arbitrators issued a decision largely favorable to the supplier, the pipeline owner sought to vacate the decision in the district court. The district court entered judgment in favor of the supplier. The First Circuit Court of Appeals affirmed, holding (1) the arbitration panel's decision to make the pipeline owner by for the lateral costs was not in manifest disregard of the law; and (2) the panel did not compromise on the matter of the destination-end heating costs, which it imposed on the supplier for the future but declined to make the ruling retroactive; and (3) even assuming that the arbitrators committed misconduct by considering in their decision two documents among the three that the panel attached to its written decision, the misconduct could not have been prejudicial. View "Bangor Gas Co., LLC v. H.Q. Energy Servs. (U.S.) Inc." on Justia Law

Defendant was convicted, after a four-day trial, of attempting to kill a federal witness with intent to prevent testimony and communication with law enforcement. Defendant was sentenced to 360 months' imprisonment. Defendant appealed, challenging several of the district court's evidentiary rulings and asserting that the prosecution's allegedly improper closing argument severely prejudiced his case. The First Circuit Court of Appeals affirmed the conviction, holding (1) the district court did not err in admitting certain documents and testimony at trial; and (2) statements made by the prosecutor in rebuttal to defense counsel's closing argument, though perhaps improper, did not amount to plain error. View "United States v. Watson" on Justia Law

Milford-Bennington Railroad Company, Inc. (MBR) appealed an award of summary judgment to Pan Am Railways, Inc., Boston and Maine Corporation, and Springfield Terminal Railway Company (collectively, "Pan Am") in a dispute arising from Pan Am's actions under a contract to provide MBR with access to Pan Am's railroad tracks. The district court held that Pan Am did not breach its duty of good faith and fair dealing when it exercised its contractual right to exclude an MBR employee from its trackage for violating a safety rule. The First Circuit Court of Appeals affirmed, holding that even if Pan Am was bound by a duty of good faith and fair dealing when exercising its right to exclude the employee from its trackage, Pan Am did not breach that duty. View "Milford-Bennington R.R. Co. v. Pan Am Rys., Inc." on Justia Law

Petitioner, a native and citizen of Venezuela, sought review of a final order of the Board of Immigration Appeals (BIA). The order upheld both an immigration judge's (IJ) determination that Petitioner's asylum application was time-barred and the IJ's denial of his application for withholding of removal on the merits. The First Circuit Court of Appeals (1) dismissed as to the asylum claim, holding that it lacked jurisdiction to review that decision, as the Court is without jurisdiction to review agency findings regarding timeliness of an asylum application unless the petitioner challenges the decision on constitutional or legal grounds; and (2) denied as to the claim for withholding of removal, as substantial evidence supported the BIA's determination. View "Cabas v. Holder" on Justia Law

The State enacted an Act in 2011 pursuant to which health insurers were required to disclose, upon written request from a public school district, aggregate loss information pertaining to any group policies held by the district's employees. Maine Education Association Benefits Trust, which managed a statewide health insurance plan for a substantial segment of Maine's public school work force, subsequently filed suit in the district court, seeking to permanently enjoin the law prior to its enforcement. The Trust alleged that because its information constituted a confidential trade secret, the Act's disclosure requirement resulted in an uncompensated taking proscribed by the Fifth Amendment. The district court denied the Trust's motion for a preliminary injunction. The Supreme Court affirmed, holding that the Trust did not have a reasonable likelihood of success on the merits of its takings claim. View "Me. Educ. Ass'n Benefits Trust v. Cioppa" on Justia Law

The issue in this case concerned a procedural requirement that must be satisfied in order to file suit under Title I of the Americans with Disabilities Act of 1990 (ADA). Pursuant to this requirement, a claimant must exhaust administrative remedies and file her Title I suit within ninety days after receiving a right-to-sue notice from the EEOC. The district court, citing this requirement, concluded that Plaintiff's Title I suit, which was filed 144 days after the EEOC sent the notice, was brought too late. To explain the delay, Plaintiff suggested that she did not receive the right-to-sue notice until nineteen days before she filed suit. The district court concluded that there is a presumption of timely receipt of a mailed notice and that Plaintiff did not furnish sufficient record evidence to rebut this presumption. The Supreme Court affirmed but on other grounds, holding that the action was time-barred, as Plaintiff had constructive notice of the ninety-day filing requirement, and yet her suit was commenced well after the expiration of that filing period. View "Loubriel v. Fondo del Seguro del Estado" on Justia Law

Appellant Loan Modification Group, Inc. (LMG) appealed from a jury verdict awarding $414,000 in damages against LMG for breach of partnership duties and responsibilities owed to Appellee, Lisa Reed. The First Circuit Court of Appeals affirmed, holding (1) the jury was entitled to find that although Reed and LMG's partnership was formed in anticipation of and carried out in accordance with the Home Affordable Modification Program (HAMP), it could be fully performed within one year and need not last for the entire four-year duration of HAMP, and thus, the jury could have reasonably rejected application of the Statute of Frauds; (2) the evidence supported the jury's finding that a partnership existed, whether based on an express oral partnership agreement or on an implied partnership agreement; (3) having found that the partnership was never terminated and that LMG breached its fiduciary duties, the jury's damages award was proper; and (4) there was adequate evidentiary support to sustain the jury's damages award. View "Loan Modification Group, Inc. v. Reed" on Justia Law

Appellant was among a number of homeowners in multiple states claiming that their mortgage companies wrongfully demanded an increase in flood insurance coverage to levels beyond the amounts required by their mortgages. In this case, the First Circuit Court of Appeals concluded that the pertinent mortgage provision explicitly gave the lender discretion to prescribe the amount of flood insurance. However, the Court held that the district court dismissal of Appellant's complaint must be vacated, as (1) a supplemental document given to Appellant at her real estate closing entitled "Flood Insurance Notification" reasonably may be read to state that the mandatory amount of flood insurance imposed at that time would remain unchanged for the duration of the mortgage; and (2) given the ambiguity as to the Lender's authority to increase the coverage requirement, Appellant was entitled to proceed with her breach of contract and related claims. View "Lass v. Bank of America, N.A." on Justia Law

This putative class action was one of a number of breach-of-contract suits being brought against financial institutions nationwide by mortgagors who claimed that they were improperly forced to increase flood insurance coverage on their properties. The plaintiff in this case asserted that Bank of America's demand that he increase his flood coverage by $46,000 breached both the terms of his mortgage contract and the contract's implied covenant of good faith and fair dealing. The district court concluded that the pertinent provision of the mortgage unambiguously permitted the lender to require the increased flood coverage and, hence, it granted the defendants' motion to dismiss the complaint. The First Circuit Court of Appeals vacated the judgment of dismissal in favor of the Bank, holding that the mortgage was reasonably susceptible to an understanding that supported the plaintiff's breach of contract and implied covenant claims. Remanded. View "Kolbe v. BAC Home Loans Servicing, LP" on Justia Law