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

Articles Posted in Civil Procedure
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The case involves William Rios, a part-time security guard for Centerra Group LLC, who was fired after being found asleep at his post. Rios, who has diabetes, sued Centerra alleging violations of the Americans with Disabilities Act (ADA). He claimed that he had an episode of hypoglycemic shock which caused him to fall asleep on the job, and thus, Centerra should have accommodated his disability. However, Rios did not present any evidence that Centerra knew about his hypoglycemic episode when it fired him.The district court granted summary judgment to Centerra on all claims. Rios appealed, challenging the district court's decisions on his ADA discrimination claim, ADA claim for failure to provide a reasonable accommodation, ADA claim for hostile work environment, ADA claim for retaliation, and the denial of his Federal Rule of Civil Procedure 56(d) motion seeking additional discovery to respond to the motion for summary judgment.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that Rios failed to present evidence from which a reasonable jury could find that Centerra held a discriminatory animus toward him based on his disability. The court also found that Rios failed to provide any evidence of discriminatory animus that would allow a reasonable jury to infer that Centerra's reasons for firing Rios were pretextual. The court further held that the district court did not abuse its discretion in denying Rios's Rule 56(d) motion given his failure to show good cause or due diligence in pursuing discovery for information regarding similarly situated employees. View "Sheridan v. Centerra Group, LLC" on Justia Law

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A defamation lawsuit was filed by Dana Cheng, a New York resident and political commentator, against Dan Neumann and Beacon, a Maine news outlet, for characterizing Cheng as "far-right" and a "conspiracy theorist" in an article. Neumann and Beacon sought dismissal of the case under both federal law and a New York anti-SLAPP law, which applies to meritless defamation lawsuits. The district court conducted a choice-of-law analysis, decided that New York law applied, and granted the motion to dismiss under New York's anti-SLAPP statute.The district court's decision was appealed to the United States Court of Appeals for the First Circuit. The appellate court agreed with the district court's ruling but for a different reason: it decided that Cheng's lawsuit had to be dismissed under binding First Amendment principles protecting free speech by the press. Back at the district court, Neumann requested attorneys' fees under the fee-shifting provision of New York's anti-SLAPP law. The district court denied Neumann's request after determining that Maine, not New York, law applied to the specific issue of attorneys' fees.Neumann appealed again, arguing that the district court erred in its choice-of-law analysis. The appellate court, noting the lack of clear controlling precedent on the issue, certified to the Supreme Judicial Court of Maine the question of which state's law applies to the attorneys' fees issue. View "Cheng v. Neumann" on Justia Law

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The case involves a 52-year-old native of the Dominican Republic, G.P., who unlawfully entered the United States twice and was convicted for drug trafficking both times. After serving his sentence for the second conviction, the Department of Homeland Security (DHS) intended to remove him again. However, G.P. expressed fear of retaliation in the Dominican Republic due to his cooperation with the government in prosecuting the leader of the drug trafficking organization. An asylum officer found his fear credible and placed him into withholding-only proceedings. G.P. applied for deferral of removal under the Convention Against Torture (CAT), but his application was denied by an immigration judge (IJ) and the Board of Immigration Appeals (BIA). G.P. appealed the decision, and the case was remanded for further consideration of his CAT claim.While his CAT claim was pending, G.P. was held in immigration detention. He brought an application for a writ of habeas corpus, arguing that there was "no significant likelihood of removal in the reasonably foreseeable future," and that he should therefore be released subject to supervision. The district court disagreed, and G.P. appealed.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court found that G.P.'s situation was distinguishable from the case of Zadvydas v. Davis, which G.P. cited as precedent. The court noted that G.P.'s detention was not indefinite or potentially permanent, as his CAT proceedings were still pending and there was no indication of bad faith or undue delay by the agency. Furthermore, G.P. did not dispute that if he was ultimately denied relief, the government would be able to remove him to the Dominican Republic. Therefore, the court concluded that G.P. had failed to show that there was "no significant likelihood of removal in the reasonably foreseeable future." View "G.P. v. Garland" on Justia Law

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A graphic designer, Cynthia Foss, filed a lawsuit against Marvic, Inc., Brady-Built, Inc., and Charter Communications, alleging copyright infringement. Foss claimed that Marvic and Brady-Built used a marketing brochure she created without her permission. She also sought a declaratory judgment that Charter Communications was not eligible for the Digital Millennium Copyright Act's safe-harbor defense.Previously, Foss had filed a similar lawsuit against Marvic alone, which was dismissed because she had not registered her copyright before filing the suit. This dismissal was affirmed by the First Circuit Court of Appeals. In the current case, the District Court dismissed Foss's copyright infringement claim against Marvic and Brady-Built on the grounds of claim preclusion, citing the dismissal of her earlier lawsuit. The court also dismissed her claim against Charter Communications for lack of jurisdiction and failure to state a plausible claim.The United States Court of Appeals for the First Circuit vacated the dismissal of the copyright infringement claim against Marvic and Brady-Built. The court found that the dismissal of Foss's earlier lawsuit was not a "final judgment on the merits" for claim preclusion purposes. However, the court affirmed the dismissal of Foss's claim against Charter Communications for lack of jurisdiction. The court also vacated the District Court's alternative merits-based dismissal of Foss's claim against Charter Communications. The case was remanded for further proceedings. View "Foss v. Marvic" on Justia Law

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The case revolves around the Employees Retirement System of the Government of the Commonwealth of Puerto Rico (ERS), which was established in 1951 as the Commonwealth's pension program for public employees. The appellants are seven individual beneficiaries of pensions paid by ERS. They had been litigating claims against UBS Financial Services Inc. (UBS) in the Commonwealth Court of First Instance related to UBS's role in issuing ERS pension funding bonds in 2008. Meanwhile, in January 2022, as part of its broad authority to promulgate orders necessary to carry out the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA), the district court confirmed the Modified Eighth Amended Title III Joint Plan of Adjustment (the Plan).The district court had previously confirmed the Plan, which implemented several changes related to ERS and its pension plan payments to retired Commonwealth employees. The Plan replaced the Committee with the Avoidance Action Trustee as the plaintiff with exclusive power to prosecute the Underwriter Action and recover damages that ERS incurred. The Plan also ordered the immediate dissolution of ERS.UBS filed a motion to enforce the Plan, requesting that the district court enjoin the ERS Beneficiaries from pursuing the Commonwealth Action. The district court granted UBS's motion and enjoined the ERS Beneficiaries from pursuing the Commonwealth Action. The district court concluded that the ERS Beneficiaries' Commonwealth Action claims were rooted in a generalized injury and were derivative of ERS's right to recover on its own behalf. The district court further rejected the ERS Beneficiaries' arguments that they were entitled to recover for non-derivative general tort claims against UBS under various Commonwealth statutes.The United States Court of Appeals for the First Circuit affirmed the district court's decision, concluding that the ERS Beneficiaries sought to raise derivative claims that belong exclusively to the Trustee or the Commonwealth. The court held that continued litigation of the FAC's derivative claims violates the terms of the Plan and PROMESA. View "UBS Financial Services Inc. v. Estate of Jose Nazario Serrano" on Justia Law

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The case involves an Indonesian family, Edwin Kurniawan Tulung, Elizabeth Angelia Karauwan, and their son Enrico Geraldwin Tulung, who fled to the United States in 2004 due to fear of persecution for their Christian faith. They entered the US on tourist visas and applied for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). Their application was denied by an Immigration Judge in 2009, a decision affirmed by the Board of Immigration Appeals (BIA) in 2011 on the grounds that past harm did not rise to the level of persecution and future persecution was not sufficiently likely. The family's petition for review was denied in 2012.The family filed their first motion to reopen based on changed country conditions in 2014, which was denied by the BIA. They did not appeal. In 2020, they filed their second motion to reopen, which was also denied by the BIA. Again, they did not seek judicial review. Instead, they filed three motions in 2022: a third motion to reopen, a motion to reconsider the denial of the second motion to reopen, and a motion to amend the second motion to reopen. The BIA denied all three motions.The United States Court of Appeals for the First Circuit affirmed the BIA's denial of the motions to reconsider and amend. However, it found that the BIA committed an error of law in reviewing the motion to reopen. The court held that the BIA incorrectly disregarded evidence by comparing it to conditions at the time of the previous motion to reopen, rather than at the time of the original merits hearing. The court vacated the BIA's denial of the motion to reopen and remanded for further proceedings. View "Tulung v. Garland" on Justia Law

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The case involves Scott Rosenthal, a Massachusetts resident, who filed a class action lawsuit against Bloomingdales.com, LLC, an Ohio-based company with its principal place of business in New York. Rosenthal alleged that Bloomingdales unlawfully intercepted and used information about his activity on its website. The company had commissioned third-party vendors to embed JavaScript computer code on its website, which was deployed onto Rosenthal's internet browser while he visited the site. This code intercepted, recorded, and mapped his electronic communications with the website. Rosenthal claimed that this violated the Massachusetts Wiretapping Act and the Massachusetts Invasion of Privacy Statute.The United States District Court for the District of Massachusetts dismissed Rosenthal's complaint for lack of specific personal jurisdiction over Bloomingdales. The court concluded that the defendant's conduct, which formed the basis of Rosenthal's claims, occurred outside of Massachusetts. The court also determined that Bloomingdales had not initiated contact with Massachusetts. Because the complaint failed to identify a 'demonstrable nexus' between Rosenthal's claims and Bloomingdale's contacts with Massachusetts, the court found no basis for specific jurisdiction over Bloomingdales.The United States Court of Appeals for the First Circuit affirmed the district court's dismissal. The court found that Rosenthal failed to provide "affirmative proof" that Bloomingdales purposefully deployed the JavaScript code to intentionally target users in Massachusetts. The court concluded that Rosenthal had not sufficiently established that Bloomingdales purposefully availed itself of what Massachusetts has to offer, thus failing to meet the requirements for specific jurisdiction. View "Rosenthal v. Bloomingdales.com, LLC" on Justia Law

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A group of former employees of Luxury Hotels International of Puerto Rico, operating as Ritz-Carlton Hotel Spa & Casino, sued the company for alleged violations of federal and Puerto Rico law in connection with their discharge after the hotel closed due to Hurricanes Irma and Maria. The employees claimed that Ritz-Carlton violated Puerto Rico Law 80 of 1976, which provides severance pay for employees wrongfully terminated, and the federal Worker Adjustment and Retraining Notification (WARN) Act, which requires employers to provide 60-day notice before mass layoffs.The case was initially filed in a Puerto Rico court but was later moved to the United States District Court for the District of Puerto Rico. After discovery, Ritz-Carlton moved for summary judgment. The District Court granted summary judgment to Ritz-Carlton on all the employees' claims, denied the employees' motion to strike Ritz-Carlton's exhibits, and dismissed the case. The employees appealed the decision.The United States Court of Appeals for the First Circuit affirmed the District Court's decision. The court found that the employees' termination was for "just cause" under Puerto Rico Law 80, as the hotel's closure constituted just cause for their discharge. Regarding the WARN Act claim, the court concluded that even if there had been a violation, various payments that Ritz-Carlton had made to the employees would completely offset Ritz-Carlton's monetary liability. View "Rivera-Pina v. Luxury Hotels International of Puerto Rico" on Justia Law

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In 2015, Universitas Education, LLC initiated a lawsuit against Jack E. Robinson, III, alleging violations of the Racketeer Influenced and Corrupt Organizations Act. Robinson defended himself until his death in November 2017. After Robinson's death, the focus of the case shifted to finding a proper party to substitute as a representative of his estate. Universitas identified Lillian Granderson, Robinson's mother, as a suitable substitute and filed motions to substitute her into the case and to enter default judgment against her. The district court granted both motions.On appeal, Granderson argued that the district court erred in granting Universitas' motion to substitute and motion for default judgment. The United States Court of Appeals for the First Circuit affirmed the district court's decision to substitute Granderson into the case, but vacated the default judgment. The court found that Granderson had defended the case and no entry of default had been entered against her, which was a requirement for a default judgment. The case was remanded back to the district court for further proceedings consistent with the appellate court's opinion. View "Universitas Education, LLC v. Granderson" on Justia Law

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The case involves Caitlin Corrigan, a graduate student at Boston University (BU), who sued the university under the Americans with Disabilities Act (ADA) for implementing a mandatory COVID-19 testing program. Corrigan claimed that due to a chronic medical condition, she could not comply with the program and that requiring her compliance would violate the ADA. BU rejected her proposed exemption, leading to her suspension for the fall semester. However, before the district court could reach the merits of Corrigan's claims, BU ended its mandatory testing program, leading the court to dismiss Corrigan's suit for lack of subject-matter jurisdiction, arguing that it had become moot.BU moved to dismiss Corrigan's suit for lack of subject-matter jurisdiction, and the district court granted the motion, applying mootness principles. The court determined that since BU had ended its mandatory testing program, an order requiring BU to provide Corrigan with a reasonable accommodation to the program would have no effect. The court also found that Corrigan's claim was not inherently transitory and that BU was unlikely to subject Corrigan to mandatory testing again. The court held that the monetary relief that Corrigan sought was legally insufficient to support a claim of jurisdiction.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court concluded that the district court appropriately applied mootness principles to dismiss Corrigan's suit and that Corrigan had not shown that her case comes within an applicable exception to those mootness principles. The court rejected Corrigan's arguments that the district court misread the mootness exceptions, misconstrued the facts, and ignored the import of the ADA's scheme for providing prospective relief. View "Corrigan v. Boston University" on Justia Law