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

Articles Posted in Contracts
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The First Circuit affirmed the judgment of the district court dismissing this case against Allscripts Healthcare Solutions, Inc. (AHS) on personal jurisdiction grounds but vacated the dismissal as to Allscripts Healthcare, LLC (Allscripts), holding that the district court improperly granted the motion to dismiss as to Allscripts.Dr. Juan M. Rodriguez-Rivera (Rodriguez) brought this action against AHS and Allscripts in Puerto Rico federal court after his electronic patient records from his medical practice were destroyed. AHS and Allscripts filed a motion to dismiss. The district court granted the motion, finding that the disputes should be arbitrated, that it lacked jurisdiction over both AHS and Allscripts, and that Rodriguez's complaint failed to state a claim as a matter of law. The First Circuit affirmed in part and vacated in part, holding (1) the district court improperly granted the motion to dismiss for lack of personal jurisdiction with respect to Allscripts; (2) whether a valid arbitration existed was a factual matter to be resolved by the district court; and (3) the district court erred in concluding that Rodriguez's complaint failed to state a claim against Allscripts. View "Rodriguez-Rivera v. Allscripts HC Sol., Inc." on Justia Law

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The First Circuit affirmed the judgment of the district court granting Defendant's motion to dismiss this case brought against him by Plaintiff, his previous employer, for lack of personal jurisdiction, holding that the district court did not err.Plaintiff brought this lawsuit against Defendant in the District of New Hampshire, alleging that he breached his employment contract and violated a non-solicitation of employees clause by encouraging three of Defendant's employees to quit their employment and join him at his new company. The district court dismissed the case for lack of personal jurisdiction. The First Circuit affirmed, holding that the requirements for personal jurisdiction were not met in this case. View "Vapotherm, Inc. v. Santiago" on Justia Law

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The First Circuit affirmed the judgment of the district court entering summary judgment in favor of Defendant Thomas Wakefield and dismissing Plaintiff Pleasantdale Condominiums LLC's claims alleging nondisclosure of material information under a Maine statute, holding that Defendant was entitled to summary judgment as a matter of law.After it purchased an apartment complex Plaintiff sued Defendant, the seller, alleging claims for fraud and negligent misrepresentation. Both counts were based on the alleged violation of Me. Rev. Stat. Ann. tit. 33, 173(5). The district court concluded that Defendant was entitled to summary judgment on both counts. The First Circuit affirmed, holding that Defendant was entitled to summary judgment as a matter of law on Plaintiff's claim for fraud in the nature of active concealment. View "Pleasantdale Condominiums, LLC v. Wakefield" on Justia Law

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The First Circuit affirmed in part and reversed in part the judgment of the district court dismissing Plaintiff's complaint against Harvard University for breach of contract and other related claims, holding that the district court erred in dismissing Plaintiff's breach of contract claim.The day before Plaintiff was about to graduate from Harvard three female Harvard students accused him of sexual assault. Following a disciplinary hearing, Harvard withheld Plaintiff's undergraduate degree. Plaintiff sued, and the district court dismissed the complaint for failure to state a claim. The First Circuit reversed in part, holding (1) at the pleadings stage, Plaintiff's allegations, taken as true, stated a plausible breach of contract claim; and (2) the district court properly dismissed the remaining counts of Plaintiff's complaint. View "Sonoiki v. Harvard University" on Justia Law

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In this case arising from losses that SAS International, Ltd. (SAS) claimed to have suffered during the COVID-19 pandemic the First Circuit affirmed the judgment of the district court granting General Star Indemnity Company's motion to dismiss the complaint under Fed. R. Civ. P. 12(b)(6), holding that there was no error.SAS filed an amended complaint alleging a breach of contract count based on three coverage provisions and a declaration that the relevant policy covered its claims. The district court granted General Star's motion to dismiss all of SAS's claims, holding that COVID-19 and the virus that causes it were not covered causes of loss. The First Circuit affirmed, holding that the district court did not err in granting General Star's motion to dismiss. View "SAS International Ltd. v. General Star Indemnity Co." on Justia Law

Posted in: Contracts
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The First Circuit affirmed the judgment of the district court dismissing the claims brought by Legal Sea Foods under Massachusetts law against Strathmore Insurance Co. following Strathmore's denial of Legal's request for coverage losses it claimed to have suffered during the COVID-19 pandemic, holding that there was no error.The second amended complaint asserted two breach of contract counts, one count of a violation of Chapter 93A of the Massachusetts General Laws, and a declaratory judgment count. The district court dismissed all claims for failure to state a claim upon which relief can be granted. The First Circuit affirmed, holding that the district court did not err by granting Strathmore's motion to dismiss for failure to state a claim. View "Legal Sea Foods, LLC v. Strathmore Insurance Co." on Justia Law

Posted in: Contracts
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The First Circuit affirmed the order of the district court granting summary judgment for Arch Insurance Co. and dismissing this diversity case brought by Graphic Builders, LLC, a general contractor, seeking to enforce a performance bond issued by Arch as surety for a subcontractor hired to work on a major project for Graphic, holding that the district court did not err.On appeal, Graphic argued that the district court erred in concluding that Arch's obligation to provide the warranty performance it sought was conditioned on termination of the subcontractor and that both the bond's language and relevant precedent supported its position. The First Circuit disagreed and affirmed, holding that the district court properly granted summary judgment for Arch. View "Arch Insurance Co. v. Graphic Builders LLC" on Justia Law

Posted in: Contracts
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The First Circuit affirmed the judgment of the district court entering summary judgment in favor of Dr. Peter Millett and dismissing Joseph Shea's alleged breach of oral contract action, holding that the statute of frauds barred this Court from enforcing any agreement against Millett so as to require him to pay Shea from July 1, 2016 onward.In 2010, Millett spoke with Shea at a medical conference seeking Shea's help in negotiating a certain deal. Shea understood this conversation to create a binding contract. In 2017, Shea brought this lawsuit asserting that he was owed payments beyond a final payment made on June 30, 2016. The district court entered summary judgment in favor of Millett, concluding that any agreement between the parties was unenforceable under the Massachusetts statute of frauds, Mass. Gen. Laws ch. 259, 1, 7. The First Circuit affirmed, holding that there was no enforceable contract between the parties requiring Millett to pay Shea after June 30, 2016. View "Shea v. Millett" on Justia Law

Posted in: Contracts
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In this action brought for the nonpayment of a promissory note the First Circuit affirmed the rulings of the district court entering summary judgment against SBK Holdings USA, Inc. and denying SBK's motion to set aside the judgment, holding that there was no error.Unibank for Savings sued Edgar and Elina Sargsyan and 999 Private Jet, LLC based on their nonpayment of a promissory note secured by a Gulfstream aircraft. The district court granted Unibank's unopposed motion for a preliminary injunction authorizing it to repossess the aircraft. SBK subsequently moved to intervene, asserting an alleged superior security interest in the aircraft. The district court allowed the intervention. The district court entered summary judgment against SBK and denied its subsequent motion to set aside the judgment. The First Circuit affirmed, holding that Unibank held a perfected security interest in the aircraft, while SKB did not. View "UniBank for Savings v. SBK Holdings USA, Inc." on Justia Law

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The First Circuit affirmed the judgment and order of the district court granting summary judgment for Lender and denying Borrowers' motion for reconsideration in this lawsuit brought by Lender seeking repayment and foreclosure of a loan, holding that the district court did not err.Borrowers defaulted on a loan extended by Lender. The loan was subject to the Farm Credit Act, 12 U.S.C. 2001 et seq., which sometimes requires the lender to restructure the loan rather than foreclose. Borrowers applied to restructure the distressed loan, but Lender rejected the application. Lender eventually brought this action, and the district court ultimately granted summary judgment for Lender. The First Circuit affirmed, holding (1) a lender need not accept a plan of restructuring that the borrower cannot perform; and (2) the district court did not err in finding that Lender properly considered and rejected the requested restructuring. View "Puerto Rico Farm Credit, ACA v. Eco-Parque del Tanama Corp." on Justia Law

Posted in: Banking, Contracts