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

Articles Posted in Contracts
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Paulo Trindade, a former employee of Grove Services, Inc., sued his previous employer for breach of contract and violations of the Massachusetts Wage Act, claiming he had been underpaid on his sales commission compensation for the years 2014, 2015, and 2016. Following a bench trial, the United States District Court for the District of Massachusetts ruled in part for Trindade and in part for Grove, awarding Trindade $330,597 in damages. Both parties appealed. The United States Court of Appeals for the First Circuit affirmed the lower court's judgment. The Court of Appeals agreed with the district court's conclusion that Trindade's amended complaint, which included a claim for unpaid wages for 2016, related back to his original complaint, making the claim timely under Massachusetts law. The Court of Appeals also concluded that the district court was correct in its decision to award the damages it did, including an amount for the late payment and underpayment of Trindade's 2016 commission. View "Trindade v. Grove Services, Inc." on Justia Law

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The United States Court of Appeals for the First Circuit upheld a district court's decision concerning a wage dispute between an employee and his former employer. The employee, Paulo Trindade, claimed that his former employer, Grove Services, Inc., breached their contract and violated the Massachusetts Wage Act by short-changing him on his sales commission compensation. Grove Services challenged the timeliness of Trindade's Wage Act claim relating to the 2016 commission, but the court agreed with the district court that the claim related back to his original complaint, making it timely. The First Circuit also upheld the district court's damages award. Trindade was awarded $330,597 in damages, which included compensation for late and unpaid wages for the 2016 commission, subject to mandatory trebling under the Wage Act, and damages for the 2014 breach of contract. View "Trindade v. Grove Services, Inc." on Justia Law

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In this case, Defendant-Appellee Martin Andersson purchased an insurance policy for his vessel from Plaintiff-Appellant Great Lakes Insurance SE. The vessel ran aground off the coast of the Dominican Republic, and Great Lakes brought a declaratory judgment action to determine coverage under the policy. Andersson filed counterclaims for breach of contract and equitable estoppel. Great Lakes' motion for summary judgment was denied, and Andersson was granted partial summary judgment on his breach of contract claim. Great Lakes appealed, claiming the district court erred in refusing to apply the policy's definition of seaworthiness.The United States Court of Appeals for the First Circuit held that under the absolute implied warranty of seaworthiness, the insured vessel must be seaworthy at the policy's inception, and if not, the policy is void. The court affirmed the district court's ruling, stating that Great Lakes' argument that the absolute implied warranty required the vessel to carry up-to-date charts for all geographic areas covered by the policy in order to be considered seaworthy was unsupported by admiralty case law and was unreasonable.Additionally, the court held that Great Lakes' argument that the express terms of the policy required updated paper charts for every location that could be navigated under the entirety of the policy coverage area was unsupported by the express language of the policy itself. The court found no precedent supporting the claim that updated paper charts for every location covered by the policy were required to be onboard the vessel at the inception of the policy. As a result, the Court of Appeals affirmed the district court's decision in favor of Andersson. View "Great Lakes Insurance SE v. Andersson" on Justia Law

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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

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The First Circuit affirmed the judgment of the district court dismissing all breach of contract claims brought by Universal Trade-in & Investment Company (UTICo) against Ukraine, the Ukrainian Prosecutor General's Office (UPGO), and the Bureau for Representing Ukrainian Interests in International and Foreign Courts, and denying UTICo's motions to amend the complaint and several of its discovery-related requests, holding that there was no error.UTICo, which was instrumental in helping the defendants investigate and freeze millions of dollars of worldwide assets that had been expatriated from Ukraine, alleged, among other things, that the defendants breached their contractual duties. The district court dismissed the breach of contract claims and entered judgment in favor of the Ukrainian defendants. The First Circuit affirmed, holding that the district court (1) did not err in granting summary judgment on the portion of the breach of contract claim related to Swiss assets that were transferred to the Ukrainian treasury; and (2) did not err in denying UTICo's three motions to amend. View "Universal Trading & Investment Co. v. Bureau for Representing Ukrainian Interests" on Justia Law

Posted in: Contracts
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The First Circuit reversed the judgment of the district court concluding that the City of Malden had violated the Massachusetts Wage Act, Mass. Gen. Laws ch. 149, 148 (the Wage Act) and Mass. Gen. Laws ch. 44, 53C (the Municipal Finance Law), holding that there was no violation of the Wage Act or Municipal Finance Law in this case.Plaintiffs, City of Malden police officers, sued the City, arguing that a term in the collective bargaining agreement (CBA) that set the hourly rate for police detail work aligned with how they were historically paid and that a ten percent deduction for an administrative fee resulted in a reduction in their wages as set forth in the CBA, in violation of the Wage Act. The district court ruled that the contract term was ambiguous and, after hearing witness testimony, ruled that the City violated the Municipal Finance Law and the Wage Act. The First Circuit reversed, holding (1) the contract term was unambiguous in favor of the City; (2) any reduction in the calculated rate still resulted in a higher payout than contemplated in the CBA, and therefore, there was no Wage Act violation; and (3) the district court clearly erred in finding that the City had violated the Municipal Finance Law. View "Owens v. City of Malden" on Justia Law

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In this action arising out of the curtailment of classes and services at the University of Rhode Island (URI) during the COVID-19 pandemic, the First Circuit affirmed the judgment of the district court dismissing some of Plaintiffs' claims early in the litigation and granting summary judgment in favor of Defendant on the remaining claims, holding that the district court did not err.Plaintiffs, students who remained enrolled at URI during the pandemic, filed separate putative class actions against URI alleging breach of contract and unjust enrichment. Specifically, Plaintiffs argued that URI had breached its contract when it stopped providing in-person, on-campus instruction. The district court dismissed certain claims and then, following the completion of discovery, granted summary judgment on the remaining claims. The First Circuit affirmed, holding that Plaintiffs failed to make out a genuine issue of material fact as to whether URI had either an express or implied contract to provide in-person services and activities. View "Burt v. Bd. of Trustees of University of R.I." on Justia Law

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The First Circuit certified to the Massachusetts Supreme Judicial Court (SJC) the unresolved question of what is meant, in the context of a franchise agreement, by "performing any service," as that phrase is used in the Massachusetts Independent Contractor Law (ICL), Mass. Gen. Laws ch. 149, 148B(a).Plaintiffs, owners and operators of 7-Eleven franchises in Massachusetts, filed a putative class action against 7-Eleven, Inc. for alleged violations of the Massachusetts ICL, the Massachusetts Wage Act, and the Massachusetts Minimum Wage Law, challenging 7-Eleven's decision to classify them as independent contractors rather than employees. The district court ruled in favor of 7-Eleven and then, after remand, ruled for 7-Eleven again. At issue was whether Plaintiffs performed "any service" for 7-Eleven under the Massachusetts ICL. The First Circuit certified to the Massachusetts SJC the following question: Do Plaintiffs perform "any service" for 7-Eleven within the meaning of the Massachusetts ICL where they perform various contractural obligations under their franchise agreement and 7-Eleven receives a percentage of the franchise's gross profits. View "Patel v. 7-Eleven, Inc." on Justia Law

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The First Circuit affirmed the decision of the district court entering summary judgment in favor of Allstate Insurance Company and dismissing the counterclaims brought by two of Allstate's former agents - James Fougere and Sarah Brody-Isbill - and A Better Insurance Agency, Inc. (ABIA) (collectively, Appellants), holding that there was no error.At issue in the underlying case were spreadsheets that Allstate alleged contained trade secrets misappropriated by Brody-Isbill and Fougere, thus breaching their contracts with Allstate. Allstate filed suit alleging claims for, among other things, breach of contract and trade secrets, violations of the Defend Trade Secrets Act, 28 U.S.C. 1836. Appellants counterclaimed, alleging claims for, inter alia, wrongful interference with contractual relations and violations of Mass. Gen. Laws ch. 93A. The district court granted summary judgment for Allstate and dismissed Appellants' counterclaims. The First Circuit affirmed, holding that the district court (1) did not err in dismissing Appellants' counterclaims; and (2) did not abuse its discretion in granting summary judgment to Allstate on liability for its trade secret and contract claims against Appellants. View "Allstate Insurance Co. v. Fougere" on Justia Law

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The First Circuit affirmed the judgment of the Title III court confirming a plan of adjustment that permitted the discharge of the Commonwealth of Puerto Rico from its obligation to pay Plaintiff the entire amount of a settlement it had entered into with the Commonwealth regarding the Commonwealth's milk regulation scheme, holding that there was no error.Plaintiff and the Commonwealth of Puerto Rico litigated for years their dispute over the Commonwealth's milk regulation scheme. The dispute was resolved by settlement, after which the Commonwealth entered Title III proceedings to adjust the Commonwealth's sovereign debt. Under the plan of adjustment, the Commonwealth was no longer obligated to pay Plaintiff the full amount specified in the parties' settlement. Plaintiff subsequently brought this action challenging that decision. The Title III court discharged the Commonwealth from its obligation to pay Plaintiff the full amount specified in the settlement and overruled Plaintiff's objections to the Plan. The First Circuit affirmed, holding that Plaintiff's arguments on appeal failed. View "Financial Oversight & Management Bd. for P.R. v. Cooperativa de Ahorro y Credito" on Justia Law