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

The case concerns parents of a child who suffered severe and permanent injuries at birth due to alleged negligence of the medical staff at Hospital Damas. The parents sued Fundación Damas, Inc., alleging that it operated the hospital at the time of the malpractice. The district court granted summary judgment to Fundación on the basis of issue preclusion, concluding that the parents were "virtually represented" in earlier proceedings by the parents of another child who also suffered injuries at the hospital.The United States Court of Appeals for the First Circuit reversed the district court's decision. The appellate court found that the theory of virtual representation, which the district court relied on, was inapplicable to this case. According to the Supreme Court's precedent, issue preclusion generally does not apply to those who were not party to the prior litigation. The court noted that the Supreme Court had rejected the broad theory of virtual representation, which was the basis for the district court's decision. The court explained that the exceptions to the rule against nonparty preclusion are narrow and specific, and none applied in this case. Therefore, the court reversed the grant of summary judgment and remanded the case for further proceedings. View "Santiago-Martinez v. Fundacion Damas, Inc." on Justia Law

The case involved an appellant, Jonathan Martins, who filed a lawsuit against Vermont Mutual Insurance Company. Martins' vehicle was involved in an accident with a vehicle insured by Vermont Mutual. He claimed that the insurance company failed to compensate him for the inherent diminished value (IDV) of his vehicle after the accident. The case was first heard in a district court that ruled in favor of Vermont Mutual, stating the standard Massachusetts automobile insurance policy did not provide coverage for IDV damages. Martins appealed this decision to the United States Court of Appeals for the First Circuit.The Court of Appeals reviewed the district court's decision and maintained that the district court correctly ruled in favor of Vermont Mutual. The court held that under Massachusetts law, a third-party claimant such as Martins could not maintain a direct cause of action against an insurer without first obtaining a final judgment against the insured party involved in the accident. The court also rejected Martins' argument that Vermont Mutual was estopped from denying liability for IDV damages because it had paid for other damages related to the accident. The court concluded that the insurer's obligation to make a reasonable settlement offer did not equate to admitting liability. Therefore, the court affirmed the district court's ruling in favor of Vermont Mutual. View "Martins v. Vermont Mutual Insurance Company" on Justia Law

In a case before the United States Court of Appeals for the First Circuit, an insurance company, Berkley National Insurance Company, sued two of its insureds, Granite Telecommunications, LLC and Atlantic-Newport Realty LLC, seeking restitution for both the payment it had made to settle a personal-injury lawsuit against the insureds and the costs it had incurred to defend them against that suit. The insurer, Berkley, also sought a declaratory judgement that it had no duty to defend or indemnify the insureds with respect to the personal-injury claims that they were facing. The District Court granted partial summary judgment in favor of Berkley, ordering the insureds to pay restitution for both the insurer's defense costs and its settlement payment. The insureds appealed the judgment.The Court of Appeals reversed the District Court's order, concluding that the rulings conflicted with Massachusetts law governing when a liability insurer who has chosen to defend its insureds may seek reimbursement from them. The Court stated that under Massachusetts law, a liability insurer can only seek reimbursement for an amount paid to settle a lawsuit if the insured has agreed that the insurer may commit its own funds to a reasonable settlement with a right to seek reimbursement, or if the insurer secures specific authority to reach a particular settlement which the insured agrees to pay. The Court found that the insurer, Berkley, did not meet any of these conditions, and as a result, it could not seek reimbursement from the insureds. Consequently, the Court vacated the grant of summary judgment to the insurer and dismissed the remainder of the appeal as moot. View "Berkley National Ins. Co. v. Atlantic-Newport Realty LLC" on Justia Law

A pregnant inmate, Lidia Lech, filed a lawsuit against several healthcare providers and staff at the Western Massachusetts Regional Women's Correctional Center (WCC), alleging that they ignored her serious medical symptoms and denied her requests to go to the hospital, resulting in the stillbirth of her baby. The district court permitted most of Lech's claims to proceed to trial, but granted summary judgment in favor of one of the correctional officers. The jury returned a verdict in favor of the defense. On appeal, the United States Court of Appeals for the First Circuit found that the district court abused its discretion in two evidentiary rulings. The first error was allowing the defense to use Lech's recorded phone calls to impugn her character for truthfulness. The second error was excluding testimony from Lech's friend, which would have corroborated her version of events. The court concluded that at least one of these evidentiary rulings was not harmless, vacated the jury verdict, and remanded for a new trial against most of the defendants. However, the court affirmed the district court's grant of summary judgment to the correctional officer, as well as the jury verdict in favor of one of the medical providers. View "Lech v. Von Goeler" on Justia Law

The case involves Nicholas Triantos, who sued various parties, including the law firm that represented Deutsche Bank in the foreclosure sale of his home, and the three partners of the firm. The district court dismissed his suit, and the law firm and its partners then moved for sanctions against Triantos under Federal Rule of Civil Procedure 11. The district court granted the motion and ordered Triantos to pay $10,000 in attorneys' fees and $32.00 in costs. Triantos appealed this order. The United States Court of Appeals for the First Circuit reversed and vacated the order. The court found that the district court had imposed sanctions under Rule 11 without following the rule's procedural requirements. The court explained that the law firm served its motion on Triantos only after the district court had dismissed the case, and it did not meet its obligation under Rule 11's safe-harbor provisions to serve the motion on Triantos twenty-one days prior to filing it with the court. The district court also erred by imposing sanctions without describing in its order the sanctionable conduct or explaining the basis for its decision. View "Triantos v. Guaetta & Benson, LLC" on Justia Law

In this case, the United States Court of Appeals for the First Circuit considered an appeal from a ruling by the United States District Court for the District of Puerto Rico concerning the restructuring of debts of the Commonwealth of Puerto Rico's public power company (PREPA) under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The appellants, GoldenTree Asset Management and Syncora Guarantee (the "Bondholders"), held around $1 billion of PREPA's roughly $8 billion in bonds and sought relief from the automatic stay on actions against PREPA's estate, hoping to appoint a receiver for PREPA.The Bondholders argued that the automatic stay lifted by operation of law, because the district court denied their latest motion for relief without first noticing and holding a hearing within the timeframe prescribed by 11 U.S.C. § 362(e)(1). However, the appellate court held that the Bondholders waived their right to a prompt notice and hearing on that motion for relief. The court reasoned that the Bondholders accepted a litigation schedule that postponed any hearing on their request for leave to seek the appointment of a receiver until after a parallel proceeding about whether—and to what extent—the Bondholders had any collateral to protect in the first place. The court therefore affirmed the judgment of the Title III court. View "GoldenTree Asset Management LP v. Financial Oversight and Management Board" on Justia Law

This case involves a medical malpractice suit against Hospital San Cristobal (HSC), Dr. Iris Vélez García, and Dr. Zacarías A. Mateo Minaya by the children of Ramona Rodríguez Rivera, who passed away while in the care of HSC. The plaintiffs alleged that their mother received negligent care at HSC during and following an abdominal surgery performed by Dr. Vélez and Dr. Mateo, leading to her death. The United States District Court for the District of Puerto Rico granted summary judgment in favor of the defendants.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court held that the district court did not err in excluding the plaintiffs' expert witness's testimony under Federal Rule of Evidence 702. The expert's report failed to identify the standard of care that HSC staff should have adhered to in their management of the patient's diabetes and how the staff deviated from that standard. Without this expert testimony, the plaintiffs could not establish a breach of the defendants' duty of care, a necessary element of a negligence claim. The appellate court also found no error in the district court's grant of summary judgment to the defendants as there was no evidence in the record that could show the defendants' negligence. View "Rivera Rodriguez v. Hospital San Cristobal" on Justia Law

The United States Court of Appeals for the First Circuit ruled on a case involving a commercial real estate transaction in Puerto Rico that failed to close. The sellers of the property, located in Valle Arriba Heights, had entered into agreements to sell their respective parcels to KRB Universal Investments, LLC, which later assigned its rights under the agreements to CPC Carolina PR, LLC ("CPC"). The conditions of the sale included the cancellation of restrictive covenants that limited the use of the property to residential purposes. CPC intended to lease the properties to Puerto Rico CVS Pharmacy, LLC ("CVS") for commercial use. However, CVS refused to proceed with the lease due to restrictive covenants and issues with the title insurance policy. The sellers sued CPC and CVS for negligence, alleging that they had been induced into an impossible contract and that CVS's actions had contributed to vandalism on the properties. The district court granted summary judgment in favor of CPC and CVS. On appeal, the appellate court affirmed the district court's decision, holding that the sellers' claims were time-barred and that they failed to establish the necessary elements of their negligence claims. View "Hamdallah v. CPC Carolina PR, LLC" on Justia Law

The United States Court of Appeals for the First Circuit reviewed an appeal concerning personal jurisdiction in a case centered on foodborne illness. Anthony Cappello, a resident of New Hampshire, had consumed a salad from a New Jersey deli, which he alleged was contaminated with E. coli. Following his diagnosis, Cappello filed a lawsuit against the deli, the company that sold the lettuce to the deli (Restaurant Depot, LLC), the distributor of the lettuce (D'Arrigo Brothers, Co.), the grower of the lettuce (Adam Brothers Farming, Inc.), and one hundred John Does. Cappello later dismissed his claims against all defendants except for Restaurant Depot and D'Arrigo Brothers. Both companies moved to dismiss the case for lack of personal jurisdiction, arguing that Cappello's claims did not arise from their contacts with New Hampshire. The District Court dismissed the case, and Cappello appealed. The Court of Appeals affirmed the lower court's decision, albeit on different grounds. The court held that Cappello failed to demonstrate the necessary element of relatedness required to establish specific personal jurisdiction under the due process clause. Neither defendant's contacts with New Hampshire were instrumental in the formation or breach of the contract related to the sale of the salad, nor were they related to the tort claims. The court found that the defendants' contacts with New Hampshire were not sufficiently related to Cappello's claims to establish personal jurisdiction. View "Cappello v. Restaurant Depot, LLC" on Justia Law

In this case, Virginia Cora Ward, as the administratrix of the estate of Edmund Edward Ward, brought a case against AlphaCore Pharma, LLC (ACP) and Bruce Auerbach. The decedent, Edmund Ward, was a participant in a clinical trial for a drug known as ACP-501, which was developed by ACP and administered by the National Institutes of Health (NIH). The trial took place in Maryland, where Ward traveled from his home in Massachusetts to receive treatment. Ward later withdrew from the trial due to deteriorating kidney function.In 2016, Ward filed a complaint against ACP, Auerbach, and several others, alleging fraudulent inducement to participate in the clinical trial. ACP and Auerbach moved to dismiss the case for lack of personal jurisdiction, arguing that they lacked sufficient contacts with Massachusetts. The United States District Court for the District of Massachusetts agreed with them and dismissed the case. Ward appealed to the United States Court of Appeals for the First Circuit.The First Circuit affirmed the district court's decision. The court held that neither ACP nor Auerbach had sufficient related and purposeful contacts in and with Massachusetts to establish personal jurisdiction. The court rejected Ward's claims that ACP and Auerbach had contacts with Massachusetts through their interactions with Ward's Massachusetts-based doctor, their alleged shipment of the drug to Massachusetts, their involvement in drafting the clinical trial protocol, and their alleged reimbursement of Ward's travel expenses. The court found that these claims were either unsupported by evidence or were not sufficient to establish personal jurisdiction. As a result, the court affirmed the district court's dismissal of the case against ACP and Auerbach for lack of personal jurisdiction. View "Ward v. Schaefer" on Justia Law