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

After Hurricane Maria damaged its business, Coco Rico, LLC sued its insurer, Universal Insurance Company, for failing to pay its insurance claim and won. The jury awarded Coco Rico higher damages for its business interruption loss claim than it had requested, plus extra, consequential damages. This appeal centers on the district court's rulings on several post-verdict motions: Universal sought to eliminate or reduce the jury's damages awards, while Coco Rico sought attorneys' fees and prejudgment interest from Universal. After the district court denied the motions, both parties appealed.The United States District Court for the District of Puerto Rico denied Universal's renewed motion for judgment as a matter of law on the consequential damages claim and its motion for a new trial or reduction of the contractual damages award. The court reduced the jury's BI & EE award from $873,000 to $750,000, in line with the insurance policy maximum, but rejected Universal's argument that the award should be further reduced to $686,098. The court also denied Coco Rico's motion to amend the judgment to add attorneys' fees and prejudgment interest.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed with Universal that there was no evidentiary basis for the jury to award consequential damages or higher business interruption loss damages than Coco Rico had established at trial. The court reversed the district court's ruling denying Universal's motions regarding the damages awards and affirmed its ruling denying Coco Rico's motion for attorneys' fees and prejudgment interest. The court held that the jury's award of $873,000 for business interruption loss exceeded the evidence presented, which supported only $686,098, and that there was no evidence to support the $250,000 consequential damages award. The court remanded the case for further proceedings consistent with its opinion. View "Coco Rico, LLC v. Universal Insurance Company" on Justia Law

The case involves a representative action under the Fair Labor Standards Act (FLSA) filed by Mamadou Bah against Enterprise Rent-A-Car Company of Boston, LLC, and Enterprise Holdings, Inc. Bah alleged that the defendants failed to pay overtime wages to assistant branch managers before November 27, 2016. Bah sought conditional certification of a class of similarly situated employees and requested the issuance of notice to potential opt-in plaintiffs. The defendants moved to stay the issuance of notice pending a motion to dismiss, which the district court granted. The district court later dismissed Bah's claims against Enterprise Holdings, Inc. for failure to state a claim, leading to further amendments to the complaint.The United States District Court for the District of Massachusetts initially dismissed Bah's claims against Enterprise Holdings, Inc. without prejudice, leading to the filing of an amended complaint. The district court eventually denied a motion to dismiss the second amended complaint, but by then, the statute of limitations had expired for potential opt-in plaintiffs. The district court conditionally certified a class and authorized notice, but the claims of the opt-in plaintiffs were dismissed as untimely. Bah requested equitable tolling of the statute of limitations due to the delay in issuing notice, which the district court denied.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the district court did not abuse its discretion in denying equitable tolling. The court found that the delay in issuing notice was attributable to Bah's own pleading errors and that the opt-in plaintiffs did not demonstrate the requisite diligence. The court affirmed the district court's decision to deny equitable tolling and dismiss the claims of the opt-in plaintiffs as untimely. View "Kwoka v. Enterprise Rent-A-Car Company of Boston, LLC" on Justia Law

Efrain Oliveras-Villafañe, Mirta Rosario-Montalvo, and their conjugal partnership (collectively, "Appellants") filed a lawsuit against Baxter Healthcare SA and related entities ("Appellees"), alleging unlawful discrimination. Oliveras worked for Baxter from 1990 until 2019, holding various positions, including Engineering Director. In 2018, he was transferred to a lower position, which he claimed was part of a discriminatory effort to remove senior Puerto Rican personnel. In 2019, his position was eliminated, and he chose termination over accepting two part-time roles. He filed a discrimination charge with the EEOC in May 2019.The United States District Court for the District of Puerto Rico granted summary judgment in favor of the Appellees. The court found that the Appellants failed to comply with Local Rule 56(c) and disregarded non-compliant facts. It dismissed the Title VII claims, ruling that the EEOC charge did not encompass the February 2018 transfer and was untimely. The court also found that the Appellants did not establish a prima facie case of discrimination regarding the March 2019 termination. The remaining claims were dismissed based on the Appellants' concessions.The United States Court of Appeals for the First Circuit affirmed the district court's judgment. The appellate court noted that the Appellants failed to challenge the district court's finding that the EEOC charge did not encompass the February 2018 transfer, leaving an independent ground for affirmance. The court emphasized that arguments must be clearly articulated and supported, and the Appellants' failure to address the exhaustion issue was fatal to their appeal. Thus, the district court's decision was upheld. View "Oliveras-Villafane v. Baxter Healthcare SA" on Justia Law

Four businesses involved in the cultivation, manufacture, possession, and distribution of marijuana within Massachusetts, in compliance with state laws, sued the Attorney General of the United States in 2023. They claimed that the Controlled Substances Act (CSA) exceeded Congress's powers under Article I of the U.S. Constitution and violated the Due Process Clause of the Fifth Amendment. They sought a declaratory judgment and an injunction to prevent the enforcement of the CSA against their intrastate activities.The United States District Court for the District of Massachusetts dismissed the plaintiffs' claims for failing to state a claim upon which relief could be granted. The court reasoned that the Supreme Court's decision in Gonzales v. Raich, which upheld the CSA's application to intrastate marijuana activities under the Commerce Clause, was controlling. The District Court also found no precedent for recognizing a fundamental right to cultivate, process, and distribute marijuana, thus rejecting the plaintiffs' substantive due process claim.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the District Court's dismissal. The First Circuit held that the CSA's regulation of intrastate commercial marijuana activities was within Congress's power under the Commerce Clause and the Necessary and Proper Clause. The court found that Congress had a rational basis for concluding that intrastate marijuana activities substantially affect interstate commerce. Additionally, the court rejected the plaintiffs' substantive due process claim, holding that there is no fundamental right to cultivate, manufacture, possess, and distribute marijuana. The court emphasized that historical practices and recent state legislative trends do not establish such a fundamental right. View "Canna Provisions, Inc. v. Bondi" on Justia Law

David Keane's employment with Expeditors Hong Kong Limited (Expeditors HK) was terminated on December 11, 2023. Keane subsequently filed a lawsuit against Expeditors HK and Expeditors International of Washington, Inc. (Expeditors US) in the District of Massachusetts, alleging federal and state law claims related to his termination. Expeditors HK is a wholly owned subsidiary of Expeditors US. The defendants moved to dismiss the claims for lack of personal jurisdiction, forum non conveniens, and improper venue for the federal law claim.The United States District Court for the District of Massachusetts granted the defendants' motion to dismiss. The court dismissed the claims against Expeditors HK and the non-contract claims against Expeditors US for lack of personal jurisdiction. The contract claims against Expeditors US were dismissed under the doctrine of forum non conveniens. The court found that Keane failed to provide sufficient evidence to support his assertion that Expeditors HK was an alter ego of Expeditors US.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's dismissals. The appellate court held that the Massachusetts federal district court lacked personal jurisdiction over Expeditors HK. Regarding the claims against Expeditors US, the court found that Keane could not prevail without proving wrongful termination by Expeditors HK, and he failed to allege sufficient facts or legal theories to impute Expeditors HK's actions to Expeditors US. The court concluded that Keane's complaint did not provide adequate grounds to disregard the corporate formalities between Expeditors US and Expeditors HK. View "Keane v. Expeditors International of Washington, Inc." on Justia Law

Broc Waltermeyer, an incarcerated federal inmate, alleged that he received inadequate medical treatment for his chronic knee pain while at the Federal Correctional Institute in Berlin, New Hampshire. He claimed that despite receiving various non-surgical treatments, including cortisone injections, pain medication, special shoes, knee braces, access to a low bunk, and a cane, he continued to experience pain. Waltermeyer argued that he should have been provided with knee replacement surgery, which was recommended to be deferred by an outside specialist until he was older.The United States District Court for the District of New Hampshire dismissed Waltermeyer's complaint, holding that his claims failed because he had an alternative administrative remedy. The district court also denied his motion for a preliminary injunction, as he had been transferred to a different facility, making the defendants no longer responsible for his care. Waltermeyer then amended his complaint to seek only money damages, leading to the current appeal.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's dismissal. The court held that Waltermeyer's claims were meaningfully different from those in Carlson v. Green, where the Supreme Court recognized a Bivens-type Eighth Amendment claim against federal prison officials for deliberate indifference to serious medical needs. The court found that Waltermeyer received substantial treatment, albeit not the treatment he preferred, and that the medical procedures administered were in accordance with doctors' recommendations. The court concluded that the differences in the nature of the medical care provided and the absence of gross inadequacy or deliberate indifference made Waltermeyer's case distinct from Carlson, thus precluding the extension of a Bivens remedy. View "Waltermeyer v. Hazlewood" on Justia Law

The case involves Leika Joanna García-Gesualdo, who filed an employment discrimination lawsuit against Honeywell Aerospace of Puerto Rico, Inc., and Honeywell International, Inc. García-Gesualdo alleged that Honeywell discriminated against her in violation of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA). The EEOC investigated her claims but decided not to proceed further, issuing a right-to-sue letter on March 29, 2022. García-Gesualdo filed her lawsuit on July 7, 2022, 100 days after the EEOC's decision.The United States District Court for the District of Puerto Rico dismissed García-Gesualdo's claims as time-barred, agreeing with Honeywell that the complaint was filed more than ninety days after the EEOC issued the right-to-sue letter. The court noted that García-Gesualdo's attorney received emails from the EEOC on March 29 and April 6, indicating that a new document was available on the EEOC's portal. The district court concluded that the ninety-day period began on either March 29 or April 6, making the July 7 filing untimely.The United States Court of Appeals for the First Circuit reviewed the case and reversed the district court's dismissal. The appellate court held that neither the March 29 email nor the April 6 email provided sufficient notice of García-Gesualdo's right to sue. The court emphasized that the emails did not unambiguously indicate that the EEOC had terminated its processes or that the ninety-day period to file a lawsuit had begun. Therefore, the appellate court concluded that the facts establishing untimeliness were not clear on the face of the pleadings, and the case was remanded for further proceedings. View "Garcia-Gesualdo v. Honeywell Aerospace of Puerto Rico, Inc." on Justia Law

A Salvadoran national filed two petitions for review of decisions by the Board of Immigration Appeals (BIA). The first petition challenges the BIA's January 2024 decision upholding the denial by an Immigration Judge (IJ) of his applications for withholding of removal under the Immigration and Nationality Act (INA) and protection under the Convention Against Torture (CAT). The second petition challenges the BIA's March 2024 denial of his motion to reopen his administrative proceedings to seek a continuance or administrative closure while his U visa petition is pending.The Department of Homeland Security initiated removal proceedings against the petitioner in May 2022 for entering the United States without inspection. An immigration court found him removable and designated El Salvador as the country of removal. The petitioner applied for asylum, withholding of removal under the INA, and protection under the CAT. The IJ denied his applications, finding that his proposed particular social group (PSG) was not cognizable and that he failed to establish a sufficient likelihood of harm if removed to El Salvador. The BIA vacated and remanded for further findings, but the IJ again denied relief. The BIA dismissed the appeal, affirming the IJ's findings.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the BIA may have endorsed the IJ's use of an improper "ocular visibility" standard in evaluating the social distinction of the petitioner's proposed PSG. The court also noted ambiguity in the BIA's analysis regarding the scope of the petitioner's PSG. Consequently, the court granted the first petition, remanded for further proceedings, and dismissed the second petition as moot. The petitioner may renew his applications for withholding of removal and CAT protection on remand. View "Alvarez Mendoza v. Bondi" on Justia Law

In 2019, New Hampshire filed two lawsuits in state court against 3M Company and other chemical companies, alleging that they produced defective PFAS products, negligently marketed them, and concealed their toxicity, leading to widespread contamination of the state's natural resources. One lawsuit sought damages for PFAS from aqueous film-forming foam (AFFF), while the other sought damages for non-AFFF PFAS contamination. The latter, referred to as the "Non-AFFF Suit," is the subject of this appeal.The Non-AFFF Suit proceeded in state court, and over the next three years, the court dismissed some of New Hampshire's claims. In August 2021, New Hampshire filed a second amended complaint. In December 2021, New Hampshire disclosed over 200 sites allegedly contaminated with non-AFFF PFAS. In April 2022, 3M removed the case to federal court, arguing that the contamination involved MilSpec AFFF PFAS, which it produced for the U.S. military, thus invoking the federal officer removal statute. New Hampshire moved to remand the case, and the district court agreed, citing that 3M's removal was untimely and did not meet the federal officer removal statute requirements.The United States Court of Appeals for the First Circuit reviewed the case and concluded that it had appellate jurisdiction. The court assumed, without deciding, that the alleged commingling of MilSpec AFFF PFAS and non-AFFF PFAS satisfied the nexus requirement for federal officer removal. However, it found that 3M's removal was untimely. The court determined that New Hampshire's filings in 2019 and 2020 provided sufficient information for 3M to ascertain removability, starting the 30-day removal clock well before 3M filed for removal in April 2022. Consequently, the court affirmed the district court's decision to remand the case to state court. View "New Hampshire v. 3M Company" on Justia Law

Kilvert, a Rhode Island company, acquired a commercial property and claimed that SBC Tower, a Delaware company, breached their lease agreement by failing to pay fifty percent of the payments received from subleases. Kilvert filed a Commercial Property Eviction Complaint in Rhode Island district court, seeking eviction and damages. SBC Tower removed the case to the United States District Court for the District of Rhode Island based on diversity jurisdiction. Kilvert moved to remand, arguing that Rhode Island law grants exclusive jurisdiction over landlord-tenant disputes to state district courts.The United States District Court for the District of Rhode Island agreed with Kilvert and granted the motion to remand, holding that Rhode Island law mandates that the state district court is the proper court for this action, making removal improper. SBC Tower appealed the decision.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court determined that the Rhode Island statute in question, R.I. Gen. Laws § 8-8-3(a)(2), allocates jurisdiction among state courts and does not divest federal courts of jurisdiction in cases where diversity jurisdiction is present. The court held that the statute does not preclude removal to federal court and that the federal court has the authority to hear the case. Consequently, the First Circuit reversed the district court's judgment and remanded the case for further proceedings. View "289 Kilvert, LLC v. SBC Tower Holdings LLC" on Justia Law