Justia U.S. 1st Circuit Court of Appeals Opinion SummariesArticles Posted in Arbitration & Mediation
Toddle Inn Franchising, LLC v. KPJ Associates LLC
The First Circuit affirmed the judgment of the district court judge confirming an arbitration award, holding that none of Appellant's legal theories for reversal were meritorious.KPJ Associates, LLC ran a daycare in Maine as a franchisee of Toddle Inn Franchising, LLC. When KPJ ended the franchise agreement on Friday and told Toddle it would open another daycare at the same site the following Monday Toddle filed a federal complaint alleging unfair competition under the federal Lanham Act and breach of contract and trade secret misappropriation under Maine law. Toddle then moved to compel arbitration and stay court proceedings. The judge compelled arbitration, and the arbitrator found for Toddle. The First Circuit affirmed, holding that the district court judge (1) did not lack subject matter in this case because Toddle did not present a frivolous Lanham Act claim; (2) did not err in ruling that Toddle did not waive its right to arbitrate by its litigation conduct; and (3) did not err in awarding additional attorneys' fees and costs. View "Toddle Inn Franchising, LLC v. KPJ Associates LLC" on Justia Law
Union Internacional, UAW Local 2415 v. Bacardi Corp.
The First Circuit affirmed the judgment of the district court summarily affirming an arbitration award dismissing Union Interacional UAW, Local 2415's wage grievance claim against Bacardi Corporation, holding that the Union did not identify an error in the arbitration award so egregious as to permit this Court to vacate it.The arbitrator found that the Union's claim was not procedurally arbitrable because the Union failed to comply with the contractual wage grievance procedure. On appeal, the Union argued that either the arbitrator should have deemed the procedural arbitrability defect waived or that the procedural defect did not justify dismissing the entire claim. The First Circuit affirmed, holding that, while the Union's waiver arguments had merit, the arbitrator acted within the scope of his authority in dismissing the entire claim for lack of procedural arbitrability. View "Union Internacional, UAW Local 2415 v. Bacardi Corp." on Justia Law
American Institute for Foreign Study, Inc. v. Fernandez-Jimenez
The First Circuit affirmed the judgment of the district court granting a preliminary injunction to the American Institute for Foreign Study, Inc. to enjoin class arbitration in this dispute with an au pair, holding that the agreement between the parties did not authorize class arbitration, and the au pair's claim was moot.The Institute, which places au pairs with host families in the United States, entered into a contract with Plaintiff, an au pair from Spain, that required the parties to arbitrate their disputes. Plaintiff filed a class arbitration demand against the Institute and its CEO, William Gertz (together, Defendants). Defendants subsequently filed suit seeking to enjoin class arbitration. The district court denied relief to Gertz and granted a preliminary injunction to the Institute. The First Circuit affirmed, holding (1) the agreement did not provide an affirmative basis to conclude that the parties agreed to class arbitration; and (2) Gertz's claim was moot. View "American Institute for Foreign Study, Inc. v. Fernandez-Jimenez" on Justia Law
Posted in: Arbitration & Mediation
UBS Financial Services Inc. v. Asociacion de Empleados del Estado Libre Asociado de Puerto Rico
The First Circuit affirmed the judgment of the district court confirming an arbitration award denying the claims brought by Asociacion de Empleados del Estado Libre Asociado de Puerto Rico (AEELA), holding that the district court did not abuse its discretion by confirming the award.AEELA was a private financial institution serving Puerto Rico government employees. AEELA suffered major investment losses when, in 2013, the market for municipal bonds in Puerto Rico crashed. AEELA initiated arbitration with UBS Financial Services, Inc., its former financial consultant, before the Financial Industry Regulatory Authority (FINRA), and a panel of arbitrators entered an award denying AEELA's claims. AEELA sought to vacate the award, arguing that one of the arbitrators had failed to disclose his professional connections to UBS. The district court confirmed the arbitration award. The First Circuit affirmed, holding that the district court did not err in finding that AEELA did not meet its burden of showing that the arbitrator was partial to UBS. View "UBS Financial Services Inc. v. Asociacion de Empleados del Estado Libre Asociado de Puerto Rico" on Justia Law
Posted in: Arbitration & Mediation
Torres-Burgos v. Crowley Liner Service, Inc.
The First Circuit affirmed the judgment of the district court granting summary judgment to Defendant on Plaintiff's challenge to an arbitration award in favor of Defendant, holding that the district court did not err.After Plaintiff was summarily dismissed from his employment he challenged his dismissal by filing a complaint and submitting the grievance to arbitration pursuant to his union's collective bargaining agreement with the union. The arbitrator issued an arbitral award dismissing Plaintiff's complaint. The district court dismissed Plaintiff's petition for judicial review. The First Circuit affirmed, holding that the district court did not err in finding that the arbitrator's ruling was not in manifest disregard of the law. View "Torres-Burgos v. Crowley Liner Service, Inc." on Justia Law
Bosse v. New York Life Insurance Co.
The First Circuit reversed the decision of the district court refusing to enforce arbitration clauses in the employment agreement between New York Life Insurance Company and Ketler Bosse, which expressly required that any disputes about arbitrability be referred to the arbitrator, holding that the district court abused its discretion.After New York Life terminated its business relationship with him Bosse brought this action alleging race discrimination in violation of 42 U.S.C. 1981 and 1985 and other state law claims. New York Life asked the court to compel arbitration and stay or dismiss the lawsuit, but the district court refused. The First Circuit reversed, holding (1) the district court's analysis contravened the Supreme Court's holdings in Henry Schein, Inc. v. Archer & White Sales, Inc., 139 S. Ct. 524 (2019), First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (1995) and other cases; and (2) the arbitration clause was clear, unmistakable, and unambiguous and should have been enforced on those terms. View "Bosse v. New York Life Insurance Co." on Justia Law
Emmanuel v. Handy Technologies, Inc.
The First Circuit affirmed the judgment of the district court granting Handy Technologies, Inc.'s motion to dismiss this putative class action and to compel individual arbitration, holding that the district court did not err in dismissing Maisha Emmanuel's suit.Emmanuel, who worked as a cleaner for Handy Technologies, Inc., brought this complaint on behalf of individuals who had worked for Handy as cleaners, alleging that Handy had misclassified the putative class members as independent contractors rather than employees, in violation of the Fair Labor Standards Act and Mass. Gen. Laws ch. 151, 1. Handy moved to dismiss and compel arbitration, arguing that the Independent Contractor Agreement that Emmanuel signed required arbitration of the claims at issue. The district court granted Handy's motion to compel arbitration and dismissed Emmanuel's putative class action claim. The First Circuit affirmed, holding (1) the district court did not err in ruling that, under Massachusetts law, Emmanuel had entered into an agreement to arbitrate; and (2) Emmanuel's unconscionability-based challenged to the ruling below failed. View "Emmanuel v. Handy Technologies, Inc." on Justia Law
Bryan v. American Airlines, Inc.
In this action brought under the Railway Labor Act (RLA), 45 U.S.C. 151 et seq., the First Circuit affirmed the judgment of the district court dismissing Plaintiff's claim against American Airlines, Inc. and later granting Allied Pilots Association's (APA) motion for summary judgment, holding that that APA did not breach its duty of fair representation and that Plaintiff could not maintain a claim against American Airlines.In 1999, Bryan's then-union submitted a grievance on his behalf alleging that his then-employer violated the terms of the applicable collective bargaining agreement and that APA, the successor to the previous union, breached its duty of fair representation under the RLA by withdrawing from pursuing his grievance to arbitration based on an allegedly inadequate investigation into the grievance's merits. Bryan also suit American Airlines, the successor to his previous employer, for his previous employer's alleged breach of the collective bargaining agreement. The district court disposed of the claims through dismissal and summary judgment. The First Circuit affirmed, holding (1) APA did not breach its duty of fair representation under the RLA; and (2) based on Bryan's own concession, he could not maintain a claim against American Airlines. View "Bryan v. American Airlines, Inc." on Justia Law
Axia NetMedia Corp. v. Massachusetts Technology Park Corp.
The First Circuit reversed the judgment of the district court vacating a portion of an arbitration award that voided the guaranty agreement at issue in this case, holding that, contrary to the conclusion of the district court, the arbitrator acted within the scope of his powers.Massachusetts Technology Collaborative (MTC) contracted with KCST USA, Inc. to operate and market a fiber optic network in western Massachusetts. MTC also secured a guaranty of KCST's obligations under the contract from KCST's parent company, Axia NetMedia Corporation. Axia later sued MTC over the guaranty agreement. MTC sought an order compelling arbitration, which the district court granted. The arbitrator found that MTC had materially breached the agreement with KCST, and, therefore, that the guaranty agreement was void for failure of consideration. The district court concluded that the arbitrator had exceeded the scope of his powers and vacated the award. The First Circuit reversed, holding that the arbitrator did not exceed the scope of his powers under section 10(a)(4) of the Federal Arbitration Act. View "Axia NetMedia Corp. v. Massachusetts Technology Park Corp." on Justia Law
Waithaka v. Amazon.com, Inc.
The First Circuit affirmed the district court's denial of Appellants' motion to compel arbitration in this putative class action, holding that the Federal Arbitration Act's (FAA) exemption for "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce" encompasses the contracts of transportation workers who transport goods or people within the flow of interstate commerce.Plaintiff was a delivery driver for Amazon.com, Inc. and its subsidiary, Amazon Logistics, Inc. (collectively, Amazon) who collected packages for delivery in Massachusetts and did not cross state lines during the course of his deliveries. Plaintiff filed this putative class action asserting misclassification of Amazon's drivers contracted with through its smartphone application as independent contractors and violations of Massachusetts labor laws. Amazon moved to compel arbitration pursuant to the mandatory arbitration provision of Plaintiff's employment agreement with Amazon. The district court denied the motion in part, concluding that Plaintiff's agreement was exempt from the FAA and that the provision was unenforceable based on Massachusetts public policy. The First Circuit affirmed, holding (1) the FAA does not govern the enforceability of the dispute resolution section of the agreement; and (2) the district court rightly refused to compel arbitration pursuant to state law. View "Waithaka v. Amazon.com, Inc." on Justia Law