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

Defendant, a Canadian company, contracted with Plaintiff, a Massachusetts investment bank, to be its exclusive financial advisor for the sale of its business. The parties negotiated and executed the agreement from their respective home offices, contacting each other by phone, e-mail, and internet. Plaintiff later sued in Massachusetts Superior Court alleging breach of contract, among other claims. Defendant removed the case to federal district court. The district court subsequently dismissed the case, concluding that it could not exercise personal jurisdiction over Defendant consistently with the Due Process Clause. The First Circuit reversed, holding that, in light of the nature, number, origin, and duration of the parties’ contacts in this case, the exercise of long-arm jurisdiction by Massachusetts was consistent with fair play and substantial justice. View "C.W. Downer & Co. v. Bioriginal Food & Sci. Corp." on Justia Law

Dragon Systems, Inc. (Dragon), a voice recognition software company that faced a deteriorating financial situation, hired Goldman Sachs (Goldman) to provide financial advice and assistance in connection with a possible merger. In 2000, Lernout & Hauspie Speech Products N.V. (Lernout & Hauspie) acquired Dragon. When it was discovered that Lernout & Hauspie had fraudulently overstated its earnings, the merged company filed for bankruptcy, and the Dragon name and technology were sold from the estate. Plaintiffs, two groups of Dragon shareholders, filed suit against Goldman, alleging negligent and intentional misrepresentation, negligence, gross negligence, breach of fiduciary duty, and violations of Mass. Gen. Laws ch. 93A. A jury found in favor of Goldman on Plaintiffs’ common law claims, and district court found that Goldman had not violated chapter 93A. The First Circuit affirmed, holding (1) the district court correctly articulated the legal standard applicable to Plaintiffs’ chapter 93A claims and correctly applied that standard to its factual findings; and (2) Plaintiffs’ arguments that they were entitled to a new trial on their common law claims because of evidentiary errors and erroneous jury instructions were without merit. View "Baker v. Goldman, Sachs & Co." on Justia Law

An initial criminal complaint issued against Defendant on August 6, 2010 charging him with a drug-related offense. Over the next fourteen months, the government brought four superseding indictments against him. Five days before jury empanelment was set to begin, Defendant moved to dismiss the fourth superseding indictment, asserting impermissible trial delay. The government conceded a breach of 18 U.S.C. 3161(c)(1), which requires a criminal defendant to be brought to trial within seventy days of the filing of an indictment. The district court determined that the appropriate remedy for exceeding the statutory time limit was a dismissal of the fourth superseding indictment without prejudice and that Defendant’s Sixth Amendment right to a speedy trial had not been violated. Defendant was subsequently convicted. The First Circuit affirmed Defendant’s convictions, holding that the district court (1) properly decided that dismissal without prejudice was the appropriate remedy for the Speedy Trial Act violation; and (2) properly concluded that Defendant had not been deprived of his Sixth Amendment right to a speedy trial. View "United States v. Worthy" on Justia Law

Mother and Father had two minor children. The family lived in Canada for approximately three and a half years before Mother relocated the children to the United States, where the entire family had never lived together. Father filed a petition in a federal district court for the return of his children to Canada pursuant to the Hague Convention on the Civil Aspects of International Child Abduction and its implementing statute, the International Child Abduction Remedies Act. A federal district court granted Father’s petition, concluding (1) Canada was the children’s country of habitual residence, and they were wrongfully removed for purposes of the Hague Convention; and (2) there was no grave risk that returning the children to Canada would expose them to physical or psychological harm. The First Circuit affirmed, holding that the district court did not err in (1) finding that Canada was the children’s country of habitual residence; and (2) concluding that returning the children to Canada would not involve a grave risk of physical or psychological harm. View "Mauvais v. Herisse" on Justia Law

After a jury trial, Defendants, James Prange and John Jordan, were convicted of multiple fraud-related counts based on their participation in an FBI securities fraud sting. The district court sentenced both Defendants to concurrent terms of thirty months’ imprisonment for each count of conviction. The First Circuit affirmed Defendants’ convictions but remanded for resentencing, holding (1) the district court did not err when it permitted an undercover agent to interpret what he and Jordan meant by certain statements in their recorded face-to-face conversation; (2) Defendants failed to establish that the government entrapped them as a matter of law; (3) the district court did not abuse its discretion in submitted a superseding indictment to the jury; but (4) the district court procedurally erred when formulating Defendants’ guideline sentencing ranges. View "United States v. Prange" on Justia Law

After a jury trial, Defendant was found guilty of two counts of passing altered obligations of the United States with intent to defraud and one count of inducing the interstate transportation of currency with intent to defraud. The district court sentenced Defendant to a twenty-one-month term of immurement. Defendant appealed, challenging both his convictions and his sentence. The First Circuit affirmed, holding (1) an error in a jury instruction did not compromise the jury’s understanding of the reasonable doubt standard and therefore did not affect Defendant’s substantial rights; and (2) there was no sentencing error in this case. View "United States v. Pennue" on Justia Law

After a seventeen-day jury trial, Appellants, a brother and sister, were found guilty of multiple bankruptcy-related crimes designed to conceal the brother’s assets and avoid his obligations to creditors. Appellants appealed, challenging both their convictions and sentences. The First Circuit affirmed Appellants’ convictions and sentences, holding (1) the evidence was sufficient to support Appellants’ convictions on all counts; (2) the district court did not err in imposing a sixteen-level increase to Appellants’ base offense levels under the sentencing guidelines; (3) the brother’s settlement of the adversary proceeding in his bankruptcy case did not provide a basis for a judgment of acquittal on the criminal charges subsequently filed against him; and (4) the district court did not err in allowing the jury to hear evidence relating to the sister’s bankruptcy proceedings in 2000. View "United States v. Colon-Ledee" on Justia Law

Plaintiff filed a complaint against Titeflex Corporation, the manufacturer of Gastite, for an alleged product defect in Gastite corrugated stainless steel tubing (CSST). The complaint asserted four causes of action, each based on allegations of Gastite CSST’s vulnerability to lightning strikes. The District Court of Massachusetts dismissed for lack of standing, concluding that Plaintiff’s injury was too speculative. The First Circuit affirmed, holding that Plaintiff failed to allege either facts sufficient to assess the likelihood of future injury or instances of actual damage where it was clear that CSST was the source, and therefore, the alleged risk of harm was too speculative to give rise to a case or controversy. View "Kerin v. Titeflex Corp." on Justia Law

Appellants, Crystal Litz and Amanda Payne, earned more than $100,000 per year as project managers for The Saint Consulting Group, Inc. Appellants claimed unpaid overtime compensation under the Fair Labor Standards Act (FLSA). The district court granted summary judgment on the FLSA claim to Saint Consulting, concluding that Appellants were “highly compensated employees” and thus exempt from the overtime pay protections of the FLSA. The First Circuit affirmed, holding that Appellants were highly compensated employees exempt from the overtime protections of the FLSA, and therefore, the district court did not err in granting summary judgment for Saint Consulting. View "Litz v. Saint Consulting Group, Inc." on Justia Law

The decedent died from electrocution while working on a telephone pole that was the purported partial responsibility of Puerto Rico Electric Power Authority (PREPA). Appellants, the decedent’s sisters, filed a wrongful death suit against PREPA and others in federal district court. PREPA filed a motion to dismiss for lack of subject matter jurisdiction, arguing that an additional, non-diverse member of the decedent’s estate, who was not made a party to the action, was indispensable, and his joinder destroyed the parties’ complete diversity. The district court agreed and dismissed the entire action, including the decedent’s estate survivorship action as well as individual actions by estate members and Appellants, who were not the decedent’s heirs. The First Circuit reversed, holding that the district court erred in dismissing Appellants’ personal actions, as the non-diverse absent party was not required to adjudicate the action because the members of the estate requested voluntary dismissal of their claims, which eliminated the survivorship action, leaving only Appellants’ claims, which were jurisdictionally sound. View "Aguayo-Cuevas v. P.R. Elec. Power Auth." on Justia Law