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

This case involves the Boston Parent Coalition for Academic Excellence Corp., which challenged the temporary admissions plan for three selective public schools in Boston. The admissions plan was based on students' grade point averages (GPAs), zip codes, and family income, rather than on standardized test scores. The Coalition claimed that the plan had a disparate impact on White and Asian students and violated the Equal Protection Clause of the Fourteenth Amendment and Massachusetts law.The United States Court of Appeals for the First Circuit found that the Coalition's claim lacked merit. It held that the Coalition failed to show any relevant disparate impact on White and Asian students, who were over-represented among successful applicants compared to their percentages of the city's school-age population. The court also found that the Coalition failed to demonstrate that the plan was motivated by invidious discriminatory intent. It pointed out that the Plan's selection criteria, which included residence, family income, and GPA, could hardly be deemed unreasonable.The court noted that any distinction between adopting a criterion (like family income) notwithstanding its tendency to increase diversity, and adopting the criterion because it likely increases diversity, would, in practice, be largely in the eye of the labeler. It emphasized that the entire point of the Equal Protection Clause is that treating someone differently because of their skin color is not like treating them differently because they are from a city or from a suburb.The court also rejected the Coalition's appeal of the district court's denial of its motion under Federal Rule of Civil Procedure 60(b), which sought relief from the judgment based on newly discovered evidence that some members of the School Committee harbored racial animus. The court found that the district court did not abuse its discretion in denying the motion, as the Coalition had failed to show that the newly discovered evidence was of such a nature that it would probably change the result were a new trial to be granted.The court therefore affirmed the judgment of the district court. View "Boston Parent Coalition for Acad. Excellence Corp. v. The School Committee of the City of Boston" on Justia Law

In this dispute, two renewable-energy generating companies, Tyngsboro Sports II Solar, LLC and 201 Oak Pembroke Solar LLC, appealed to the United States Court of Appeals for the First Circuit after their class-action lawsuit was dismissed by the District Court for the District of Massachusetts due to lack of subject-matter jurisdiction. The plaintiffs had a longstanding disagreement with defendants, utility companies National Grid USA Service Company, Inc. and Massachusetts Electric Company, over certain tax-related fees charged to them. The plaintiffs sought redress in federal court after unsuccessful petitions to state authorities.The plaintiffs argued that the district court had jurisdiction due to the case's connection to federal tax law, however, the appellate court disagreed, stating that the plaintiffs' complaint did not bring any claim that arose under federal law. The plaintiffs had brought forth four claims against National Grid, including a request for declaratory relief, a state-law claim for a breach of the covenant of good faith and fair dealing, a state-law claim for restitution and unjust enrichment, and a state-law claim for violating a statutory requirement that public utilities assess only just and reasonable charges.The appellate court affirmed the district court's dismissal of the case, finding that the plaintiffs could not establish federal-question jurisdiction simply by asserting a state-law claim to which there was a federal defense. The court noted that the state-law claims did not necessarily raise a federal issue, and to the extent that one did, the issue was not substantial. As such, the court concluded that the district court lacked jurisdiction over the claims. View "Tyngsboro Sports II Solar, LLC v. National Grid USA Service Co., Inc." on Justia Law

Brian Smith, a Rhode Island resident, sued Prudential Insurance Company of America for breach of fiduciary duty after the company terminated his long-term disability benefits under an insurance policy. The policy stated a three-year limitations period to file a lawsuit, which began on the date Smith was required to submit proof of his disability, not on the date Prudential allegedly breached the policy by stopping payment. Consequently, by the time Smith filed his lawsuit, the limitations period had expired. Smith appealed to the United States Court of Appeals for the First Circuit after the United States District Court for the District of Rhode Island granted summary judgment in favor of Prudential on the grounds that Smith's lawsuit was filed too late.Smith argued that enforcing the limitations scheme would violate Rhode Island public policy. While the Court of Appeals found compelling reasons to believe that the limitations scheme might indeed contravene Rhode Island public policy, they also recognized that reversing and remanding on that ground would potentially expand Rhode Island law. Consequently, the Court of Appeals decided to certify the public policy question to the Rhode Island Supreme Court. The certified question is whether, in light of specific state laws and Rhode Island public policy, Rhode Island would enforce the limitations scheme in this case to bar Smith's lawsuit against Prudential. View "Smith v. Prudential Insurance Company of America" on Justia Law

In this case, a law firm, Thompson, MacColl & Bass, LLC, P.A. (TM&B), was sued by its former client, ST Engineering Marine, Ltd. (STEM), for professional negligence. STEM owned a vessel that was arrested due to several entities, including Sprague Operating Resources, LLC (Sprague), asserting maritime liens for unpaid services. STEM had sought advice from TM&B to analyze these lien claims. TM&B advised STEM that Sprague's lien was valid and should be paid. Acting on this advice, STEM paid Sprague and subsequently sued TM&B, alleging that TM&B's advice was negligent as it failed to consider the unsettled state of relevant maritime lien law.The United States Court of Appeals for the First Circuit affirmed the decision of the United States District Court for the District of Maine, which had found in favor of STEM. The Court of Appeals held that TM&B breached its duty of care to STEM by failing to conduct adequate legal research and by not appropriately counseling STEM about the uncertainty of Sprague's lien claim. The court also found that TM&B's negligence was the actual and proximate cause of STEM's loss, concluding that STEM would have prevailed in contesting Sprague's lien claim but for TM&B's erroneous advice. The court ordered TM&B to pay STEM $261,839.04 in damages. View "ST Engineering Marine, Ltd. v. Thompson, MacColl & Bass, LLC, P.A." on Justia Law

In this case, the Gibson Foundation, a charitable arm of Gibson Brands, sued Rob Norris and The Piano Mill Group, alleging that they breached a contract and bailment when they refused to return a piano that had been used by entertainer Liberace, upon Gibson Foundation's request. The piano was initially transferred from Gibson Brands to Norris and Piano Mill. The United States Court of Appeals for the First Circuit concluded that the breach-of-bailment claim was not time-barred, reversing the lower court's decision. The court explained that a reasonable juror could find that Gibson Brands, the original owner of the piano, and Norris and Piano Mill had a mutual agreement where Gibson Brands would avoid storage costs by leaving the piano with Norris and Piano Mill, who would benefit from using the piano for promotional opportunities. Therefore, the six-year statute of limitations for certain contract claims applied, rather than the three-year limit for tort claims. However, the court affirmed the lower court's decision that a genuine issue of material fact existed as to whether Gibson Foundation, or its predecessor in title, Gibson Brands, owned the piano in question, which is necessary to establish a valid contract or bailment. The court also affirmed the lower court's denial of summary judgment to Gibson Foundation on the breach of contract claim, noting that a reasonable juror could find that Gibson Brands had given the piano to Norris and Piano Mill as a gift. View "Gibson Foundation, Inc. v. Norris" on Justia Law

The First Circuit reversed the order of the district court dismissing this case at the pleading stage for lack of standing, holding that Malcom Wiener had Article III standing to sue Defendants, MIB Group, Inc. and its executive vice president, based on additional attorney's fees and costs Wiener insured to respond to Defendants' actions in a separate lawsuit.In 2018, Wiener sued AXA Equitable Life Insurance Company, his former life insurance company, for negligence. After the jury returned a verdict in favor of Wiener the district court granted AXA's motion to dismiss for lack of subject matter jurisdiction. The court of appeals reversed the decision granting AXA's motion to dismiss. Meanwhile, Wiener brought this suit against Defendants, alleging that he incurred out-of-pocket loss in the form of attorney's fees and costs and to respond to Defendants' actions in the related lawsuit. The district court dismissed the action, concluding that Wiener lacked Article III standing. The First Circuit reversed, holding that a past, out-of-pocket loss is a basis for Article III standing, and therefore, Wiener had standing to bring this suit. View "Wiener v. MIB Group, Inc." on Justia Law

The First Circuit granted the government's petition for rehearing en banc in these consolidated appeals regarding Defendants' 2016 convictions for violating the Maritime Drug Law Enforcement Act, 46 U.S.C. 70501 et seq. (MDLEA), holding that 46 U.S.C. 70503(e)(1) does not limit the subject matter jurisdiction of federal courts under Article III of the United States Constitution.Defendants pleaded guilty unconditionally to the underlying charges, but a panel of the First Circuit vacated the convictions and ordered the underlying charges dismissed. The government petitioned for rehearing en banc. The First Circuit granted the petition, vacated the panel's ruling, and affirmed Defendant's convictions, holding that section 70503(e)(1) merely limits the substantive reach of the MDLEA and that Defendants' claims on appeal failed. View "United States v. Davila-Reyes" on Justia Law

The First Circuit affirmed the judgment of the district court affirming U-Nest Holdings, Inc.'s motion for relief from judgment in a 2019 federal court action under Fed. R. Civ. P. 60(b)(6), holding that the district court did not err in its ruling.In 2021, U-Nest filed a case in the United States District Court for the District of Rhode Island asserting that it had been fraudulently induced to enter into a prior state court settlement agreement that was embodied in a judgment entered in 2020 in a 2019 federal court action. The federal district court stayed the 2021 action to allow U-Nest to first file a motion for relief from judgment in the 2019 action. U-Nest then filed the motion for relief from judgment, which the district court denied. The First Circuit affirmed, holding that the district court did not err in finding that U-Nest did not support its claim of fraud and/or of misrepresentation. View "U-Nest Holdings, Inc. v. Ascensus College Savings Recordkeeping Services, LLC" on Justia Law

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