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

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's putative class action against McNeil Nutritionals, LLC and Johnson & Johnson Consumer, Inc. challenging certain statements on the packaging of Lactaid products, holding that the district court correctly dismissed the complaint.Plaintiff brought this action claiming that Lactaid's labels violated federal labeling requirements, leading Plaintiff to have been mislead into purchasing Lactaid products, which she claimed were more expensive than other lactase supplements. The district court granted Defendants' second motion to dismiss. The First Circuit affirmed, holding that Plaintiff's claims were impliedly preempted by the statutory enforcement authority of the Food and Drug Administration. View "DiCroce v. McNeil Nutritionals, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this case on res judicata grounds, holding that Plaintiff's malicious prosecution claim was precluded under the doctrine of res judicata.At issue in this case arising from a dispute related to a foreclosure action was whether a prior dismissal with prejudice of a complaint filed by Plaintiff in 2017 precluded the claim brought in this 2020 case. The district court concluded that because the prior dismissal had been with prejudice, it constituted a final judgment on the merits, therefore having preclusive effect. The First Circuit affirmed, holding that Plaintiff's malicious prosecution claim was barred by res judicata and that Plaintiff was not entitled to relief on his allegations of error. View "Rivera-Rosario v. LSREF2 Island Holdings, Ltd., Inc." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this lawsuit against the Financial Oversight and Management Board for Puerto Rico (FOMB) and its executive director challenging the FOMB's alleged failure to review a sale agreement on untimeliness grounds, holding that the dismissal was proper, albeit on standing grounds.Appellants - several Puerto Rico corporations and individuals - brought this action claiming that the FOMB's alleged failure to review a $384 million loan sale agreement between the Economic Development Bank for Puerto Rico (BDE) and a private investment company violated their constitutional rights under the Fourteenth Amendment's Due Process and Equal Protection Clauses, and a statutory violation under the Puerto Rico Oversight, Management, and Economic Stability act . The district court granted the FOMB's motion to dismiss, concluding that the claims were time-barred. The First Circuit affirmed but on different grounds, holding that Appellants lacked standing because their complaint failed to allege that the FOMB's inaction caused their claimed injury. View "R&D Master Enterprises, Inc. v. Financial Oversight & Management Bd. for P.R." on Justia Law

The First Circuit vacated the judgment of the trial court against Plaintiff and a third-party defendant, holding that because the parties were unable to establish that no defendant shared state citizenship with any plaintiff remand was required.Plaintiff brought this lawsuit in federal district court, and Defendants counterclaimed. No party presented a possible basis for federal jurisdiction other than diversity jurisdiction under 28 U.S.C. 1332. After six years of litigation, a trial was held, and the trial court entered a eight-figure judgment against Plaintiff and a third-party defendant. The First Circuit vacated the judgment, holding that the parties have been unable to establish that no defendant shares state citizenship with any plaintiff, and therefore, remand was required so the parties can demonstrate that there is complete diversity. View "BRT Management LLC v. Malden Storage LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Triple-S Management Corporation and Triple-S Vida, Inc. (collectively, Triple-S) and dismissing this case brought by Dora Bonner, holding that the district court did not abuse its discretion in denying Bonner's discovery-related motions and did not err in considering the evidence at the summary judgment stage.Bonner brought several claims alleging that Triple-S denied her millions of dollars of proceeds from certain certificates and devised a scheme to defraud her. After denying Bonner's motion to compel discovery and extend the discovery deadline, the district court concluded that Triple-S had established as a matter of law that the persons behind the fraudulent scheme were not related to Triple-S. The First Circuit affirmed, holding that the district court (1) did not abuse its discretion in denying the motion to compel and motion for consideration; and (2) properly granted summary judgment for Triple-S. View "Bonner v. Triple-S Vida, Inc." on Justia Law

The First Circuit vacated the judgment dismissing on claim preclusion grounds Plaintiff's claims against Eastern States Exposition alleging violations of federal copyright infringement law and the U.S. Visual Artists Rights Act, holding that the district court erred.On appeal, Plaintiff argued that the claim preclusive order gave claim preclusive effect to the dismissal in a prior action that she brought even where the dismissal rested on several grounds, not all of which would on their own render the dismissal claim preclusive. In support of her claim, Plaintiff argued that federal res judicata law recognizes the "alternative-determinations" doctrine. The First Circuit vacated the judgment dismissing the claims at issue, holding (1) the assertedly preclusive dismissal rested on one ground that, on its own, would not allow the dismissal to be claim preclusive, even though the dismissal also rested on two counts that could have; and (2) federal res judiata law recognizes the alternative-determinations doctrine, which strips a dismissal of claim preclusive effect if the dismissal rests on multiple grounds, not all of which would on their own render the dismissal claim preclusive, and the doctrine applied in this case. View "Foss v. Eastern States Exposition" on Justia Law

The First Circuit reversed in part the order of the district court granting summary judgment rejecting Defendants' affirmative defense of qualified immunity against Plaintiff's procedural due process claim, holding that the district court erred in granting summary judgment on the federal claims against Defendants.Plaintiff brought this action against three former board members of the Town of Freetown Board of Selectmen, citing 42 U.S.C. 1983 and alleging deprivation of her right to procedural due process on the basis that Defendants removed her state court action to the federal district court. The district court rejected Defendants' argument for qualified immunity on summary judgment. The First Circuit reversed, holding that the doctrine of qualified immunity shielded Defendants from liability against Plaintiff's due process claim. View "Lawless v. Sadeck" on Justia Law

The First Circuit affirmed the judgment of the district court determining that this case could not be adjudicated and dismissing the suit, holding that there was no error.Plaintiff, a foreign counterterrorism corporation, brought this lawsuit seeking an order freezing some of its Massachusetts assets based on allegations that a former government official misappropriated billions of dollars from the corporation. Defendants argued that the funds were lawfully received in connection with clandestine operations that were sometimes undertaken alongside the United States government. The United States government then asserted the state secrets privilege and successfully got state secrets and other information excluded from the case. The district court dismissed the suit, concluding that it could not examine the claims and defenses or award the preliminary equitable relief sought without weighing the privileged information and risking disclosure of state secrets. The First Circuit affirmed, holding that Plaintiff failed to demonstrate that it was entitled to any of the relief it requested. View "Sakab Saudi Holding Co. v. Aljabri" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this suit brought by Plaintiff in the District of Puerto Rico against the Financial Oversight and Management Board for Puerto Rico (the FOMB) on jurisdictional grounds pursuant to Article III of the United States Constitution, holding that there was no error.Plaintiff brought this suit in his official capacity as both a member and the minority leader of the Puerto Rico House of Representatives, alleging that the FOMB violated the Territories Clause of the federal Constitution by nullifying a law that established the Commonwealth's budget and replacing it with the FOMB's own budget. The district court dismissed the claims for lack of jurisdiction. The First Circuit affirmed, holding that Plaintiff lacked Article III standing to bring his claims. View "Hernandez-Montanez v. Financial Oversight & Management Bd. for P.R." on Justia Law

In this suit brought under the Racketeering Influence and Corrupt Organizations Act (RICO), the First Circuit remanded this matter for further review, holding that the district court erred in dismissing the complaint based on the doctrine of forum non conveniens.Medtronic Medical CR SRL, a Costa Rica limited liability company, brought suit under RICO alleging that Defendants, Puerto Rico residents, orchestrated fraudulent schemes. The district court granted Defendants' motion to dismiss based on the doctrine of forum non conveniens, concluding that Costa Rica was an adequate alternative forum. The First Circuit remanded the case, holding that intervening and developing circumstances required reconsideration of the most efficient, prudential path forward. View "Medtronic Medical CR SRL v. Feliciano-Soto" on Justia Law