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

Lopez & Medina Corp. (L&M) filed a lawsuit against several insurers for Patriot Air, LLC, alleging that the insurers were liable for L&M’s breach of contract claims against Patriot Air. The district court dismissed L&M’s complaint, concluding that the relevant insurance policy did not provide coverage for contract claims. The First Circuit affirmed. L&M and its owner subsequently filed the complaint in this action seeking recovery in tort for Patriot Air’s negligence arising out of the same set of facts that underlay the previous suit’s breach of contract claims. The district court dismissed the case on the ground of res judicata. The First Circuit affirmed, holding that the district court correctly invoked res judicata in dismissing the action. View "Medina-Padilla v. US Aviation Underwriters, Inc." on Justia Law

A Corp., a Massachusetts plumbing corporation and franchisor, brought a trademark infringement action against All American Plumbing, Inc., an Arizona corporation with its principal place of business in Arizona, alleging that All American was improperly using A Corp.’s “Rooter Man” mark, or one confusingly similar, to advertise its plumbing business on its website. The district court dismissed the complaint, concluding that A Corp. failed to meet its burden to establish either general or specific jurisdiction. A Corp. appealed, challenging the district court’s conclusion as to the exercise of specific jurisdiction. The First Circuit affirmed, holding that A Corp.’s argument for specific jurisdiction failed. View "A Corp. v. All American Plumbing, Inc." on Justia Law

Relator, an employee of the University of Massachusetts Medical School (UMMS), sued UMMS alleging violations of the False Claims Act (FCA) and its Massachusetts counterpart. The district court dismissed Relator’s FCA claims against UMMS, concluding that UMMS is a state agency and, thus, exempt from the FCA. The district court denied Relator’s subsequent motion for leave to file a third amended complaint, concluding that the proffered complaint would be futile. The First Circuit affirmed, holding (1) UMMS is an arm of the state, not a “person” subject to suit under the FCA, and therefore, UMMS is exempt from suit by private parties under the FCA; and (2) Relator’s attempt to appeal the district court’s denial of leave to amend for want of appellate jurisdiction is dismissed for want of appellate jurisdiction. View "Willette v. Univ. of Mass." on Justia Law

Copia Communications, LLC, a Massachusetts company, brought this action in federal district court in Massachusetts against Seawind Key Investments, Limited, a Jamaican resort operator, and Seawind’s alleged alter-ego, AMResorts, LP, a Pennsylvania limited partnership, alleging breach of contract. The subject contract was proposed and executed in Jamaica, performance on the contract occurred almost exclusively in Jamaica, and the contract was governed by the laws of Jamaica. Both defendants, neither of which operated any business or had any corporate presence in Massachusetts, moved to dismiss, arguing lack of personal jurisdiction and forum non conveniens. The district court dismissed the case without prejudice, finding that it lacked personal jurisdiction over the defendants. The First Circuit affirmed, holding that the exercise of personal jurisdiction over the defendants was barred by the due process clause of the Fifth Amendment. View "Copia Commc’ns, LLC v. AMResorts, LP" on Justia Law

Robert Gadbois (Relator) filed this qui tam action in the District of Rhode Island alleging PharMerica Corp. had violated the False Claims Act (FCA) and several parallel state statutes. Relator then filed a seconded amended complaint. The district court dismissed Relator’s FCA claim, concluding that Relator’s action and an earlier-filed action pending in the United States District Court for the Eastern District of Wisconsin were based on substantially the same facts, and therefore, the district court lacked jurisdiction by virtue of the FCA’s first-to-file bar. The court dismissed Relator’s state-law claims as well. Relator appealed. During briefing, the Supreme Court decided Kellogg Brown & Root Services, Inc. v. United States ex rel. Carter, and the Wisconsin action was settled and dismissed, both of which dissolved the jurisdictional impediment to Relator’s action. Relator responded by broadening his appeal to include the possibility of supplementing his pleadings with the fact that the Wisconsin action was no longer pending. The First Circuit vacated the judgment of the district court to allow the court to consider Relator’s request for supplementation under Fed. R. Civ. P. 15(d), holding that Rule 15(d) is available to cure most kinds of defects in subject matter jurisdiction. View "Gadbois v. PharMerica Corp." on Justia Law

Relator filed a qui tam action on behalf of the United States, twenty-five states, and the District of Columbia, naming his former employer as the defendant and asserting several claims under the False Claims Act (FCA) and analogous state statutes. Thereafter, Relator filed three amended complaints adding five defendants. Defendants filed motions to dismiss. Relator subsequently filed a fourth amended complaint, asserting that he had an absolute right to amend his complaint under Fed. R. Civ. P. 15(a)(1). The district court granted Defendants’ motion to strike the fourth amended complaint after construing Relator’s filings as a request for leave to amend, concluding that Relator had not established good cause for amending his complaint once again. The district court then dismissed the case with prejudice, concluding that the FCA’s public disclosure bar deprived it of jurisdiction over certain allegations and that, as to the remaining allegations, the third amended complaint failed to state a cognizable claim. The First Circuit vacated the judgment below and remanded, holding that the district court (1) did not err in concluding that Relator exhausted his one-time right to amend under Rule 15(a)(1); but (2) appraised Relator’s request for leave to amend under the wrong legal standard. View "D'Agostino v. ev3, Inc." on Justia Law

Employee worked for Employer as a salesman. Employer is incorporated and headquarters in Kansas. The employment contract contemplated that Employee, a Massachusetts resident, would work from Massachusetts. Employer facilitated Employee’s work from Massachusetts by, inter alia, registering a sales office with Massachusetts and providing him with equipment. Employee brought this action in state court against Employer and its president (collectively, Defendants), alleging that Defendants violated the Massachusetts Wage Act by failing to pay him a commission he alleged he was due. Defendants removed the case to federal district court and then moved to dismiss for lack of personal jurisdiction. The district court granted the motion. The First Circuit reversed, holding Employee met the requirements of both the Massachusetts long-arm statute and the Due Process clause in establishing personal jurisdiction over Defendants. View "Cossart v. United Excel Corp." on Justia Law

In 2012, Plaintiff filed suit seeking money damages against the United States under the Federal Tort Claims Act, alleging that, in 1998-1999, he was wrongfully detained and deported as an unauthorized alien despite his true status as a United States citizen. The district court granted the government’s motion to dismiss the case as time barred, thus rejecting Plaintiff’s claim that the federal discovery rule applied in his case to preclude dismissal. The First Circuit affirmed on statute of limitations grounds, holding that delayed accrual under the discovery rule was foreclosed by the factual allegations in Plaintiff’s complaint. View "Dominguez v. United States" on Justia Law

In the underlying putative class action, counsel for the named plaintiffs obtained a collection of records owned by JPMorgan Chase Bank, N.A. (Chase). Plaintiffs sought to rely on the documents to pursue claims sounding in fraud, deceit, and conversion against Chase. A dispute arose as to whether portions of the Chase records were shielded from discovery and litigation under a provision of Bank Secrecy Act and related regulations. A magistrate judge reviewed all of the disputed documents in camera and concluded that the majority of the documents were not shielded by statute or regulation. Chase then initiated this mandamus proceeding, asking the First Circuit to intervene by declaring that the Act and related regulations shielded an additional fifty-five pages of Chase records from production or use in the putative class action. The First Circuit denied the petition for writ of mandamus, holding that, even assuming that the Act and regulations apply, the documents at dispute would not be shielded from discovery or use in litigation. View "In re JPMorgan Chase Bank, N.A." on Justia Law

Plaintiff filed a complaint against the Municipality of Carolina in the federal district court of Puerto Rico alleging gender-based employment discrimination and retaliation. Before trial, Carolina extended to Plaintiff what it labeled as an offer of judgment pursuant to Fed. R. Civ. P. 68. Later that day, Carolina informed the district court that no settlement had been reached. One half of an hour later, Plaintiff informed the court that she was accepting Carolina’s offer of judgment. The district court entered judgment for Plaintiff. Carolina appealed, arguing that because Plaintiff had rejected the offer of judgment prior to informing the court of her acceptance, the district court erred in entering judgment. The First Circuit affirmed, holding that because even an express rejection of a Rule 68 offer of judgment does not terminate a Rule 68 offeree’s power to accept the offer within the fourteen-day period, the district court did not err in entering judgment for Plaintiff. View "Garayalde-Rijos v. Municipality of Carolina" on Justia Law