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

The First Circuit affirmed the order of the district court exercising its ancillary jurisdiction to enforce a resolution issue by the Puerto Rico Secretary of Justice (Secretary) directing the Municipality of Juana Diaz (Municipality) to indemnify two municipal police officers found liable under Puerto Rico tort law after a federal jury trial for using excessive force resulting in a death, holding that ancillary enforcement jurisdiction was appropriate.Appellee and other family members filed this action after the shooting death of their relative at the hands of police. The jury returned a verdict for Appellee with respect to her negligence claims against two municipal police officers in their personal capacities, and the district court entered judgment against the officers. After the Secretary issued a resolution under a Puerto Rico statute referred to as “Law 9” requiring the Municipality to pay the judgments against its officers, Appellee filed a motion requesting the garnishment of the Municipality’s assets. The district court granted the motion. The First Circuit affirmed, holding that the district court had jurisdiction to enforce the Secretary’s Law 9 resolution against the Municipality. View "Burgos-Yantin v. Municipality of Juana Diaz" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this contract action for lack of personal jurisdiction over the defendants in Maine, holding that the district court did not err in concluding that the exercise of jurisdiction over Defendants would not comport with due process.The underlying dispute involved agreements about Defendants’ interests in an Illinois limited partnership, Elm Street Plaz Venture, LLLP. LP Solutions LLC (LPS), a Maine company, offered to buy limited interests owned by Defendants, who mostly resided in Illinois. Defendants accepted the offer and made distribution payments. When Defendants later refused to deliver partnership distributions that LPS said were assigned to it, LPS sued Defendants in Maine. The case was removed to federal district court, which determined that there was no personal jurisdiction because Defendants' contacts with Maine did not make the exercise of personal jurisdiction foreseeable. The First Circuit affirmed, holding that Defendants could not foresee the exercise of jurisdiction. View "LP Solutions LLC v. Duchossois" on Justia Law

The First Circuit affirmed the district court’s order dismissing the case brought by Plaintiff seeking to have the district court address the same grievances she brought without success in the Massachusetts state courts, holding that Supreme Court case law divests federal courts of subject-matter jurisdiction in such cases.A bank commenced a summary process action in the Worcester Housing Court seeking to evict Plaintiff. Plaintiff counterclaimed. The Housing Court eventually entered final judgment awarding possession of the property to the bank. Plaintiff’s appeal was unsuccessful. Thereafter, Plaintiff filed a civil action against the bank in the United States District Court for the District of Massachusetts, alleging wrongful foreclosure and other claims relating to the same issues she addressed in the summary process action. The district court granted the bank’s motion to dismiss, concluding that the doctrine set forth in D.C. Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983) and Rooker v. Fidelity Trust Co., 263 U.S. 413, 415-16 (1923), deprived the federal courts of subject-matter jurisdiction. The First Circuit affirmed, holding that under the Rooker-Feldman doctrine, the district court lacked jurisdiction where Plaintiff’s federal suit sought to invalidate the antecedent state courts’ judgments. View "Klimowicz v. Deutsche Bank National Trust Co." on Justia Law

The First Circuit affirmed the decision of the district court that the exercise of specific personal jurisdiction against a German corporation did not offend the Fifth Amendment’s Due Process Clause, holding that on the facts of this case the exercise of jurisdiction would not violate due process.Plaintiff, a Maine corporation, sued Defendant, a German corporation, in federal district court in Maine for trademark infringement. As a basis for personal jurisdiction over Defendant, Plaintiff said that Defendant’s nationwide contacts with the United States supported specific jurisdiction under Fed. R. Civ. P. 4(k)(2). On prima facie review, the district court concluded that it could constitutionally exercise specific personal jurisdiction over Defendant under Rule 4(k)(2). The First Circuit affirmed, holding that Plaintiff met all three requirements to establish personal jurisdiction. View "Plixer International, Inc. v. Scrutinizer GMBH" on Justia Law

The First Circuit held that federal law requires prior FDA approval for a manufacturer of prescription eye drops to change the medication’s bottle so as to alter the amount of medication dispensed into the eye, and therefore, state law claims challenging the manufacturers’ refusal to make this change are preempted.Plaintiff sued in federal court on their own behalf and on behalf of a putative class of prescription eye solution purchasers, asserting that Defendants deliberately designed their dispensers to emit unnecessarily large drops. Plaintiffs alleged that Defendants’ practice was “unfair” under Massachusetts state law and twenty-five other states and allied claims for unjust enrichment and for “money had and received.” The district court dismissed the complaint without ruling on the merits, finding that FDA regulations preempted Plaintiffs’ suit. The First Circuit affirmed, holding (1) changing a product bottle so as to dispense a different amount of prescription eye solution is a “major change” under 21 C.F.R. 314.70(b); and (2) therefore, Plaintiffs’ state law claims were preempted. View "Gustavsen v. Alcon Laboratories, Inc." on Justia Law

In this action filed by Plaintiffs seeking to enjoin their property’s foreclosure sale, the First Circuit affirmed the district court’s dismissal of Plaintiffs’ complaint under Fed. R. Civ. P. 12(b)(6) and the denial of Plaintiffs’ request for injunctive relief, holding that the district court did not abuse its discretion in concluding that the statute of limitations applied to the bulk of Plaintiffs' claims.Plaintiffs obtained a loan from Countrywide Home Loans, Inc. to refinance their Massachusetts property. After Plaintiffs defaulted on their loan they initiated this action to void their transaction and enjoin their property’s foreclosure sale. The district court granted Defendants’ motion to dismiss the bulk of Plaintiffs’ claims as time-barred and denied Plaintiffs’ request for injunctive relief. The First Circuit affirmed, holding (1) the district court properly found that the statute of limitations applied to the majority of Plaintiffs’ claims; and (2) the remainder of Plaintiffs’ arguments were meritless. View "Harry v. Countrywide Home Loans, Inc." on Justia Law

The First Circuit dismissed this appeal in part for want of appellate jurisdiction and otherwise affirmed the district court’s dismissal of the underlying action asserting a claim under the Alien Tort Statute (ATS), 28 U.S.C. 1350, and common-law claims for negligence and civil conspiracy, holding that this Court lacked jurisdiction to consider two of Defendant's claims on appeal.Plaintiff’s complaint premised jurisdiction both on the ATS and on diversity of citizenship. Plaintiff also invoked the district court’s supplemental jurisdiction over the state law claims. The district court dismissed the ATS claim for want of subject-matter jurisdiction and declined to exercise supplemental jurisdiction over the state law claims. Defendant appealed. The First Circuit held (1) this Court lacked jurisdiction to consider Defendant’s request to purge certain unflattering comments from the district court’s opinion; (2) judicial estoppel barred Defendant’s argument that the district court, even after dismissing the ATS claim, had an alternative basis for federal subject-matter jurisdiction; (3) the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over Plaintiff’s state-law claim; and (4) this Court lacked jurisdiction to entertain Defendant’s claim that the district court erred in declining to grant his first motion to dismiss. View "Sexual Minorities Uganda v. Lively" on Justia Law

In this case brought pursuant to the Massachusetts Wage Act, the First Circuit affirmed the judgment of the district court granting summary judgment in favor of Plaintiff.Plaintiff brought an action against Defendant, which owned and operated the hospital at which Plaintiff worked, under the Massachusetts Wage Act. Plaintiff alleged that, at the time she was discharged, she was owed thousands of dollars in paid time off and extended sick leave. Defendant removed the case to the federal court on the basis of Labor Management Relations Act (LMRA), 29 U.S.C. 185(a), preemption. The district court granted summary judgment for Plaintiff, awarding her damages and reasonable attorneys’ fees and costs. The First Circuit affirmed, holding (1) federal subject-matter jurisdiction existed at the time of removal because there was then a colorable claim of complete preemption under LRMA, and even after that colorable federal question evaporated during pretrial discovery, the district court retained authority to exercise supplemental jurisdiction over the case; and (2) the district court properly found that Plaintiff was entitled to summary judgment. View "Lawless v. Steward Health Care System, LLC" on Justia Law

The First Circuit affirmed the district court’s dismissal of a complaint filed by George Gillis against William Chase in this third complaint against Chase, Gillis III, seeking to reopen Gillis I.Gillis was operating a truck at a construction site when he struck and fatally injured Edward Hansen. Gillis was charged with motor vehicle homicide in state court but was acquitted after a trial. Gillis then sought vindication by filing lawsuits. Gillis I asserted that William Chase, the police chief when Hansen’s death occurred, violated his constitutional rights by knowingly charging him with a crime without probable cause. The district court dismissed the case for failure to state a claim. In Gillis II, Gillis sued two different defendants, and the case was dismissed on summary judgment. Gillis III, against Chase alone, sought to reopen Gillis I. Gillis argued that Chase conspired to charge Gillis in the criminal case as the result of undue influence exerted by a defendant in Gillis II. The district court found that Gillis III was time barred and failed to state a claim. The First Circuit affirmed, holding that the district court’s judgment was not in error. View "Gillis v. Chase" on Justia Law

The First Circuit reversed the district court’s denial of Eric Blattman’s motion to compel Thomas Scaramellino to respond to questions regarding certain documents in this appeal arising out of a civil action brought in a Delaware federal court concerning a corporate merger between Efficiency 2.0 LLC (E2.0) and C3, Inc.As part of the Delaware action, Blattman attempted to depose Scaramellino, the founder of E2.0. At the deposition, Scaramellino refused to answer questions about the documents at issue by asserting attorney-client privilege and work-product protection. Blattman filed a motion to compel Scaramellino to respond to his questions regarding the documents. The district court denied the motion to compel based on Scaramellino’s assertion of the work-product protection. The First Circuit reversed, holding that the district court erred in ruling that Scaramellino was entitled to assert the work-product protection to defeat Blattman’s motion to compel. View "Blattman v. Scaramellino" on Justia Law