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

In this dispute over who was the first-to-file relator in a case brought under the False Claims Act (FCA), 31 U.S.C. 3729 et seq., the First Circuit reversed the judgment of the district court ruling that the first-to-file rule was jurisdictional, holding, for the first time in this circuit, that the first-to-file rule is not jurisdictional and that the Court had jurisdiction over Mark McGuire's crossclaim.The FCA's first-to-file rule prohibits relators other than the first to file from bringing a related action based on the facts underlying the pending action. In this case, the government successfully intervened in several qui tam suits against Millennium Health. Millennium settled with the government, setting aside fifteen percent of the settlement proceeds as a relator's share. McGuire brought a crossclaim for declaratory judgment that he was the first to file and was thus entitled to the fifteen-percent share. The district court dismissed the crossclaim for lack of subject-matter jurisdiction, finding that the first-to-file rule was jurisdictional. The First Circuit reversed, holding (1) the first-to-file rule is not jurisdictional, and therefore, the district court had subject-matter jurisdiction over McGuire's crossclaim; and (2) McGuire was the first-to-file relator and has stated a claim that he is entitled to the relator's share of the settlement. View "McGuire v. Estate of Robert Cunningham" on Justia Law

In this case brought by Puerto Rico general obligation bondholders (Bondholders), the First Circuit affirmed the district court's dismissal of the Bondholders' complaint seeking injunctive and declaratory relief claiming that they possessed a priority and property interest over certain revenues of the Puerto Rico government, holding that the district court correctly dismissed the Bondholders' complaint.This case arose from the restructuring of Puerto Rico's public debt under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act of 2016 (PROMESA). The Bondholders sought declarations to confirm their property rights to certain revenues of the Puerto Rico government, determine that the diversion of the revenues constituted an unconstitutional taking, and specify appropriate uses for those revenues. The district court dismissed certain counts of the Bondholders' complaint as seeking improper advisory opinions, another count presenting a takings claim as unripe, and almost all the remaining counts as barred under section 305 of PROMESA. The First Circuit affirmed, holding that the district court properly dismissed all counts. View "Aurelius Capital Master, Ltd. v. Commonwealth of Puerto Rico" on Justia Law

The First Circuit affirmed the decision of the district court ruling that the Town of Weymouth’s local ordinance, as applied to a project in which Algonquin Gas Transmission, LLC sought to build a natural gas compressor station in Weymouth, was preempted by the Federal Energy Regulatory Commission's (FERC) issuance of a certificate of public convenience and necessity (CPCN) authorizing construction of the Weymouth Compressor Station.Algonquin received a CPCN from FERC authorizing the project, but that certificate was conditioned upon the receipt of a consistency determination from the Commonwealth of Massachusetts pursuant to the Coastal Zone Management Act (CZMA). To complete its CZMA review the Commonwealth required Algonquin to furnish a permit from Massachusetts Department of Environmental Protection, which, in turn, refused to issue such a permit until the Town of Weymouth approved the project under its local ordinance. Wemouth denied Algonquin’s permit applications. Algonquin ultimately commenced this action against Weymouth arguing that the local ordinance, as it applied to the compressor station, was preempted under federal law. The district court granted summary judgment for Algonquin. The First Circuit affirmed, holding that application of Weymouth’s ordinance to the proposed compressor station was foreclosed by federal law under the theory of conflict preemption. View "Algonquin Gas Transmission v. Weymouth Conservation Commission" on Justia Law

The First Circuit affirmed the judgment of the district court determining that Appellant was barred from relitigating his argument that Plaintiffs should be compelled to arbitrate various tort claims, holding that the district court did not err in denying Appellant’s motion to compel arbitration.At issue in this procedurally complicated case was whether Appellant’s association with a certain law firm required that Plaintiffs’ various tort claims, including their claims of legal malpractice, be submitted to arbitration. After adopting a magistrate judge’s report and recommendation and applying principles of collateral estoppel derived from Rhode Island law, the district court denied Appellant’s motion to compel. The First Circuit affirmed, holding that Appellant waived any claim of error regarding the magistrate judge’s analysis under Rhode Island collateral estoppel law. View "Patton v. Johnson" on Justia Law

The First Circuit reversed the district court’s dismissal of claims against Schechtl Maschinenbau GmbH, a German company, holding that, contrary to the conclusion of the district court, the exercise of personal jurisdiction over Schechtl comported with due process.Stephen Knox’s hand was injured at his work when he operated a machine manufactured by Schechtl. The machine had been sold to Knox’s employer by MetalForming, Inc., an American company located in Georgia and Schechtl’s U.S. distributor. Knox sued both Schechtl and MetalForming in Massachusetts state court. MetalForming removed the case to Massachusetts federal district court and filed crossclaims against Schechtl. The district court granted Schechtl’s motion to dismiss, concluding that Schechtl had not purposefully availed itself of the privilege of doing business in Massachusetts. The First Circuit reversed, holding that Knox and MetalForming met their burden of demonstrating that Schechtl purposefully availed itself of the privilege of conduct activities within Massachusetts. View "MetalForming, Inc. v. Schechtl Maschinenbau GmbH" on Justia Law

The First Circuit affirmed the decision of the district court dismissing Plaintiff’s action on the grounds that the lawsuit was, in essence, an appeal from a state-court judgment, and therefore, the court lacked jurisdiction to hear it under the Rooker-Feldman doctrine, holding that the district court correctly held that it lacked jurisdiction to hear Plaintiff’s claims.This appeal arose from Plaintiff’s legal challenge seeking to void two Massachusetts Superior Court conditions of probation imposed on the adult male who was convicted of statutory rape after impregnating Plaintiff when she was a minor. One of those conditions ordered the defendant to acknowledge paternity of the child. The district court decided that it did not have jurisdiction over the claims. The First Circuit affirmed, holding that because the relief Plaintiff sought was based on her claim that the Massachusetts Supreme Judicial Court erred in the adjudication of her case, the district court properly dismissed this case for want of jurisdiction. View "Tyler v. Supreme Judicial Court of Massachusetts" on Justia Law

The First Circuit affirmed the order of the district court dismissing Plaintiff’s contract and tort claims for lack of personal jurisdiction, holding that the federal court in Puerto Rico lacked personal jurisdiction over Defendants.Plaintiff, a Puerto Rico tour company, brought this diversity suit in the United States District of Puerto Rico, alleging that a California youth soccer organization and related defendants breached duties that the organization owed to Plaintiff under Puerto Rico contract and tort law. The allegations centered around Defendants’ acts of first requesting that Plaintiff make an offer for a potential soccer trip to Puerto Rico for some of the organization’s teams and their families and then declining after further communications to book the tour. The district court dismissed the claims for lack of personal jurisdiction. The First Circuit affirmed, holding that the exercise of specific jurisdiction in the forum over the out-of-forum defendants did not conform to the federal constitutional test. View "PREP Tours, Inc. v. American Youth Soccer Organization" on Justia Law

In this case against members of the Rhode Island Board of Bar Examiners the First Circuit reversed the district court’s grant of attorneys’ fees in favor of Plaintiff and affirmed the court’s dismissal of Plaintiff’s amended complaint, holding that Plaintiff’s supposed “prevailing party” status was not justified.Plaintiff, an individual with attention deficit/hyperactivity disorder and anxiety, filed suit against members of the Board challenging the Board’s denial of his request for certain accommodations to assist him in taking the Rhode Island bar exam. The district court issued a temporary restraining order (TRO) requiring the Board to permit Plaintiff the requested accommodations, dismissed Plaintiff’s amended complaint, and allowed Plaintiff’s motion for attorneys’ fees. On review, the First Circuit held (1) Plaintiff’s success in gaining a TRO did not warrant an award of attorneys’ fees; and (2) the district court’s decision to allow the Board’s motion to dismiss the damage claim in the complaint was correct. View "Sinapi v. Rhode Island Board of Bar Examiners" on Justia Law

The First Circuit dismissed as moot a school district’s challenge to the district court’s order compelling the school district to determine a student’s eligibility for an Individualized Education Program (IEP) without first obtaining its own evaluations and reversed the district court’s award of attorneys’ fees to the student’s parents, holding that the challenge to the order was moot and the attorneys’ fee award was mistaken.M.S., a student formerly enrolled in the Westerly School District in Westerly, Rhode Island, suffered from Lyme Disease and other tick-borne illnesses. Plaintiffs, M.S.’s parents, unsuccessfully sought to have Westerly determine that M.S. was eligible for an IEP under the Individuals with Disabilities Education Act. During the dispute, the district court entered an order forcing Westerly to forego conducting its own evaluations and decide immediately if M.S. was eligible for an IEP, resulting in a determination that M.S. was not eligible. The court then awarded Plaintiffs attorneys’ fees as the prevailing parties. On appeal, the First Circuit held (1) because M.S. and Plaintiffs have since moved out of the Westerly school district, this Court lacked the power to review the order that Westerly determine M.S.’s eligibility without first conducting its own evaluations; and (2) the attorneys’ fees award was not proper because Plaintiffs were not the prevailing parties. View "J.S. v. Westerly School District" on Justia Law

The First Circuit granted a writ of advisory mandamus sought by the Rhode Island Department of Education and Training (Department) and directed the district court to vacate its denial of a motion to quash a federal grand jury subpoena of certain Department records, holding that the District of Rhode Island erred in ruling that the attorney-client privilege is categorically unavailable to a state government in receipt of a federal grand jury subpoena.A federal grand jury sitting in the District of Rhode Island subpoenaed certain records from the Department. The Department moved to quash the subpoena to the extent it sought to compel production of documents containing confidential communications between Department staff and legal counsel. The district court denied the motion to quash, concluding that, as a categorical matter, the attorney-client privilege does not shield communications between government lawyers and their clients from a federal grand jury. The First Circuit granted the Department’s petition for a writ of advisory mandamus directing the district court to quash the subpoena, holding that this Court does not sustain the categorical rule that a state government has no attorney-client privilege that can be invoked in response to a grand jury subpoena. View "In re Grand Jury Subpoena" on Justia Law