Justia U.S. 1st Circuit Court of Appeals Opinion SummariesArticles Posted in Consumer Law
Tomasella v. Nestle USA, Inc.
The First Circuit affirmed the district court's dismissal of Appellant's claims in three putative class action lawsuits against Defendants - Nestle USA, Inc., Mars, Inc., and The Hersey Company - holding that Appellant did not plausibly state a claim for relief under Mass. Gen. Laws ch. 93A and that Appellant's unjust enrichment claim was foreclosed by the availability of a remedy at law.Appellant alleged that Defendant's failure to disclose on the packaging of their chocolate products that upstream labor abuses existing in their cocoa supply chains violated Chapter 93A and that Defendants had been unjustly enriched by this packaging omission. The district court dismissed the claims. The First Circuit affirmed, holding (1) Appellant did not plausibly state a Chapter 93A unfairness claim; and (2) Appellant's unjust enrichment claims must be dismissed because an adequate remedy at law was available to her through Chapter 93A. View "Tomasella v. Nestle USA, Inc." on Justia Law
Lee v. Conagra Brands, Inc.
The First Circuit reversed the judgment of the district court dismissing, for failure to state a claim, Plaintiff's complaint alleging that, by labeling Wesson brand vegetable oil (Wesson Oil) "100% Natural," Conagra Brands, Inc. violated Mass. Gen. Laws ch. 93A, holding that Plaintiff's complaint clearly alleged a Chapter 93A injury for pleading purposes.After learning that Wesson Oil contained genetically modified organisms (GMOs), Plaintiff sued Conagra, the manufacturer and distributor, alleging that, by labeling the oil "100% Natural," Conagra violated Massachusetts's prohibition against unfair or deceptive trade practices. The federal district court dismissed the complaint for failure to state a claim, concluding that Wesson Oil's label was neither unfair nor deceptive because it conformed to the Food and Drug Administration's labeling policy. The First Circuit reversed, holding that Plaintiff's claim may proceed because Plaintiff plausibly alleged that a reasonable consumer might think that the phrase "100% Natural" means that a product contains no GMOs, and then base her purchasing decision on that belief. View "Lee v. Conagra Brands, Inc." on Justia Law
Squeri v. Mount Ida College
The First Circuit affirmed the judgment of the district court granting Defendants' motion to dismiss Plaintiffs' complaint alleging that Defendants knew that Mount Ida College was on the brink of insolvency but concealed this information, holding that Plaintiffs' claims were properly dismissed.Mount Ida, a higher education institution in Massachusetts, permanently closed after providing its students six weeks' notice that it was closing. Plaintiffs, current and prospective students, brought a putative class action against Mount Ida, its board of trustees, and five Mount Ida administrators (collectively, Defendants), alleging seven Massachusetts state law claims. The district court dismissed the complaint. The First Circuit affirmed, holding (1) Plaintiffs' breach of fiduciary duty claim failed; (2) the district court did not err in dismissing Plaintiffs' violation of privacy claim; (3) no claims were stated for fraud, negligent misrepresentation, or fraud in the inducement; (4) Plaintiffs' allegations did not plausibly allege a breach of implied contract; and (5) the district court properly dismissed Plaintiffs' Mass. Gen. Laws ch. 93A claim. View "Squeri v. Mount Ida College" on Justia Law
Capitol Specialty Insurance Corp. v. Higgins
In this insurance dispute, the First Circuit affirmed the judgment of the district court ruling for Plaintiff on her action brought under Mass. Gen. Laws ch. 93A and ch. 176D and awarding trebled damages in the amount of $5.4 million but reversed and remanded for calculation of prejudgment interest based on actual damages and not the treble damages figure of $5.4 million, holding that Plaintiff's measure of damages was her "actual damages" because there was no "judgment" in her case.Plaintiff, who was injured in a car accident at age twenty after drinking at a nightclub, sued the nightclub's insurer (Defendant), alleging that Defendant violated chapters 93A and 176D. The federal district court ruled for Plaintiff and assessed actual damages of $1.8 million against Defendant. The court then trebled the award after concluding that Defendant's violations were willful. The First Circuit affirmed on the whole but reversed as to the calculation of prejudgment interest, holding that the district court did not err in finding Defendant's violation of chapter 93A and 176D but erred when it calculated prejudgment interest on the trebled damages award instead of the single damages award. View "Capitol Specialty Insurance Corp. v. Higgins" on Justia Law
O’Brien v. Deutsche Bank National Trust Co.
The First Circuit affirmed the district court's dismissal of Plaintiff's claims alleging that Defendants violated the Massachusetts Consumer Protection Act, Mass. Gen. Laws ch. 93A, and the Massachusetts Fair Debt Collection Practices Act, Mass. Gen. Laws ch. 93, 49, holding that both counts were time-barred.Plaintiff filed her complaint against the current holder of a mortgage on her property and the servicer of the mortgage loan, alleging that the loan was predatory because at its inception the lender knew or should have known that Plaintiff would not be able to repay it. Defendants removed the case to federal district court and then moved to dismiss the complaint. The district court dismissed the chapter 93A count as time-barred and the second count on the ground that chapter 93, 49 does not provide private right of action. The First Circuit affirmed the dismissal of both counts, albeit on different grounds, holding that both the chapter 93A claim and the chapter 93, 49 claims were time-barred. View "O'Brien v. Deutsche Bank National Trust Co." on Justia Law
Arabian Support & Services Co. v. Textron Systems Corp.
The First Circuit affirmed the judgment of the district court entering summary judgment in favor of Textron Systems Corporation (Textron) and dismissing Arabian Support & Services Company's (ASASCO) complaint alleging various Massachusetts state law claims, holding that the district court properly disposed of ASASCO's claims on summary judgment.ASASCO, a Saudi Arabian consulting company, sued Textron, a Massachusetts-based defense contractor, alleging violation of Mass. Gen. Laws ch. 93A, fraudulent inducement, intentional misrepresentation, negligent misrepresentation, quasi-contract/implied contract/promissory estoppel, and quasi-contract/unjust enrichment/quantum meruit. The district court granted Textron's motion for summary judgment on all counts. The First Circuit affirmed, holding (1) the district court properly granted summary judgment to Textron on ASASCO's chapter 93A claim; and (2) summary judgment was properly granted as to ASASCO's remaining claims. View "Arabian Support & Services Co. v. Textron Systems Corp." on Justia Law
Hamann v. Carpenter
The First Circuit reversed in part and affirmed in part the decision of the district court dismissing with prejudice Plaintiff's claims of alleging that he was denied the fruits of a profitable exclusive-seller agreement for the sale of a Ferrari when Defendant caused the breach of that agreement by threatening economic harm to the other party to the contract, holding that Plaintiff plausibly pleaded his claim of tortious interference with an existing contract.Plaintiff brought suit against Defendant alleging claims of tortious interference with an advantageous business relationship, tortious interference with an existing contract, and violations of Massachusetts's Consumer Protection Law, Mass. Gen. Laws ch. 93A, 11. The district court dismissed the suit, concluding that Plaintiff had failed plausibly to allege any impermissible motive or means of interference with Plaintiff's business relationships or existing contracts. The First Circuit reversed in part, holding (1) Plaintiff plausibly pleaded that Defendant harmed Plaintiff by tortiously interfering with the contract; and (2) the district court correctly dismissed Plaintiff's remaining claims. View "Hamann v. Carpenter" on Justia Law
Dumont v. Reily Foods Co.
The First Circuit reversed the judgment of the district court dismissing this putative class action alleging a violation of Massachusetts' consumer protection laws for failure to meet the heightened pleading standard of Fed. R. Civ. P. 9(b), holding that Plaintiff's complaint stated a plausible claim for relief.Plaintiff brought this action against Defendant New England Coffee Company, operating as a subsidiary of Reily Foods Company, alleging that she purchased Defendant's "Hazelnut Creme" coffee because she thought that the coffee contained hazelnut. When she discovered that the coffee contained no hazelnut, Plaintiff brought a putative class action arguing that the coffee's labeling violated Mass. Gen. Laws ch. 98A, 2(a). The district court concluded that the complaint failed to pass muster under the relevant pleading standard. The First Circuit reversed, holding (1) the complaint's allegations made it plausible that a fact-finder could reasonably regard the label as having the capacity to mislead; and (2) Plaintiff's claim under chapter 93A was not impliedly preempted by federal law. View "Dumont v. Reily Foods Co." on Justia Law
Posted in: Consumer Law
LimoLiner, Inc. v. Dattco, Inc.
The First Circuit affirmed the holding of the magistrate judge that Defendant, a repair company, was not liable under Massachusetts General Laws Chapter 93A, holding that Plaintiff, LimoLiner, Inc., did not meet its burden of showing that Defendant's technical violations of the Massachusetts Attorney General's regulations that govern motor vehicle repairs, 940 Mass. Code Regs. 5.05, caused Plaintiff the loss of any money or property.In rejecting Plaintiff's regulatory claim, the magistrate judge concluded that the Attorney General's motor vehicle regulations did not apply to disputes between businesses. The First Circuit certified to the Massachusetts Supreme Judicial Court (SJC) the question of whether the regulation does apply in such situations. The SJC answered yes, so the First Circuit remanded the claims of violation of the Attorney General's regulations for further findings. On remand, the magistrate judge found, among other things, that Defendant's regulatory violations did not automatically establish liability under Chapter 93A and that Plaintiff failed to show that Defendant's regulatory violations were unfair or deceptive. The First Circuit on other grounds, holding that Plaintiff did not show that Defendant's regulatory violations caused Plaintiff any loss of money or property. View "LimoLiner, Inc. v. Dattco, Inc." on Justia Law
Posted in: Consumer Law
MetalForming, Inc. v. Schechtl Maschinenbau GmbH
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