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

The First Circuit affirmed the district court's dismissal of the complaint in this case for want of jurisdiction, holding that personal jurisdiction could not constitutionally be exercised over Defendant in Massachusetts.Defendant was an education institution incorporated in Alabama having its principal place of business there. Plaintiff, who had enrolled in Defendant's doctoral program in sports management, sued Defendant in a Massachusetts state court alleging breach of contract, unfair and deceptive business practices, unjust enrichment, and fraudulent inducement. Defendant removed the case to the federal district court then moved to dismiss the complaint for want of personal jurisdiction. The district court granted the motion, concluding that the court lacked general and specific jurisdiction over Defendant. The First Circuit affirmed, holding that the district court appropriately determined that neither general jurisdiction nor specific jurisdiction may constitutionally be exercised over Defendant in Massachusetts. View "Chen v. United States Sports Academy, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiffs' breach of contract action against Defendant, their insurer, holding that the district court properly dismissed for failure to state a claim Plaintiffs' claim that Defendant failed to defend and indemnify them in a state court action.Newton Covenant Church (NCC) was comprised of members of the Newton Presbyterian Church (NPC) who withdrew from the Presbyterian Church (USA) and affiliated with a non-Presbyterian organization. NPC and the Presbytery of Boston sued the NCC in the state superior court seeking, among other things, a declaratory judgment that NPC owned church property at 75 Vernon Street in Newton, Massachusetts. NCC submitted a notice to the Great American Insurance Company (GAIC) requesting a defense in the state court action under a Director and Officers insurance policy. GAIC denied coverage on the grounds that the named insured under the policy was NPC, not NCC. After the parties reached a settlement NCC and its individual officers (collectively, Plaintiffs) brought this action against GAIC for breach of contract. The district court dismissed the complaint. The First Circuit affirmed, holding that Plaintiffs' allegations were not reasonably susceptible of an interpretation that would state a claim covered under the policy. View "Newton Covenant Church v. Great American Insurance Co." on Justia Law

The First Circuit affirmed the judgment of the district court granting a preliminary junction to Defendant's former employer (Plaintiff), a healthcare company incorporated in Delaware, that enforced a nonsolicitation clause in the employment contract between the parties, holding that the district court did not err in applying Delaware law to assess whether Plaintiff had satisfied the "likelihood of success" requirement.The injunction sought by Plaintiff enforced a nonsolicitation clause in the parties' contract barring Defendant from engaging in certain work for his new employer, one of Plaintiff's competitors. The choice-of-law provision set forth in the employment contract explicitly stated that the agreement should be interpreted and enforced in accordance with Delaware law, without giving effect to its laws pertaining to conflict of las. The district court held that Massachusetts' choice-of-law rules permitted it to enforce the choice-of-law provision, thus premising its issuance of the preliminary injunction on its application of Delaware law. Defendant appealed, arguing that Massachusetts and not Delaware law applied to Plaintiff's breach of contract claims, and therefore, Plaintiff could not satisfy the likelihood-of-success requirement in seeking a preliminary injunction based on those claims. The First Circuit affirmed, holding that there was no merit in Defendant's challenge to the issuance of the preliminary injunction against him. View "NuVasive, Inc. v. Day" on Justia Law

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

In this dispute over the handling of brokerage accounts the First Circuit affirmed the judgment of the federal district court dismissing Plaintiffs' complaint against the Financial Industry Regulatory Authority (FINRA) for failure to state a claim, holding that Plaintiffs' complaint failed to state a plausible claim for breach of the covenant of good faith and fair dealing implied under Massachusetts law.Plaintiffs, a married couple, submitted their dispute with their quondam stockbroker over the handling of their brokerage accounts to FINRA for arbitration. A panel of arbitrators summarily dismissed Plaintiffs' claims. Plaintiffs then brought this action claiming that the arbitrators' failure to state an explained decision breached the implied covenant of good faith and fair dealing. The First Circuit affirmed, holding that the district court appropriately dismissed Plaintiffs' complaint because Plaintiffs did not plausibly allege a breach of the implied covenant. View "Lanza v. Financial Industry Regulatory Authority" on Justia Law

The First Circuit affirmed the judgment of the district court denying Defendant's motion for a new trial, in which Defendant sought to vacate seventeen convictions that he received and that resulted from two separate trials, holding that the district court did not err in denying Defendant's motion for a new trial.Following the verdicts in his second trial, Defendant filed a motion for a new trial, alleging that he had received ineffective assistance of counsel at his first trial and that the district court erred in denying his motion in limine to preclude guilty verdicts in the first trial from being used to impeach him at his second trial. The district court treated the motion as challenging not only the nine counts for which Defendant had been found guilty in the second trial but also the eight counts for which he had been found guilty in the first trial but for which no judgment of conviction had yet been entered. The district court denied the motion for a new trial. The Supreme Court affirmed, holding that Defendant was not entitled to relief as to any of his arguments. View "United States v. Silvia" on Justia Law

The First Circuit affirmed the entry of a preliminary injunction enforcing a covenant not to compete included in a restrictive covenant agreement (RCA) that Appellant signed in 2017, holding that the district court did not err in finding that the covenant not to compete was reasonable and in entering the preliminary injunction.After working almost three decades at CVS Pharmacy, Inc., Appellant accepted a new position at PillPack LLC, a direct competitor of CVS. CVS sued Appellant seeking to enforce the covenant not to compete. The district court entered a preliminary injunction enjoining Appellant from working at PillPack for eighteen months, finding that the covenant was reasonable and that Appellant's new position would violate the covenant. The First Circuit affirmed, holding that, under either the as-applied or the facial approach in evaluating the reasonableness of the restrictive covenant, CVS was likely to succeed on the merits of its claim for injunctive relief. View "CVS Pharmacy, Inc. v. Lavin" on Justia Law

The First Circuit affirmed the judgment of the district court against Kodak Alaris, Inc. based on the jury finding that Kodak was in breach of its contractual obligation to ITyX Solutions AG except as to the calculation of prejudgment interest, holding that the district court correctly rejected Kodak's motion for judgment as a matter of law or a new trial but that, as to the prejudgment interest award, the interest must be recalculated from a different date.Judgment in this case was entered against Kodak in the sum of $9,211,699.20, including prejudgment interest. The district court rejected Kodak's argument that the jury must have necessarily found that it was ITyX which actually breached the contract and that ITyX had breached the covenant of good faith and fair dealing. The court further rejected Kodak's various standing and damages arguments. The First Circuit affirmed the rulings of the district court in all respects except its award of prejudgment interest on damages, and, as to that prejudgment interest award, altered the date used and remanded. View "ITyX Solutions AG v. Kodak Alaris, Inc." on Justia Law

The First Circuit affirmed the district court's grant of summary judgment on Appellant's federal law claims under the Age Discrimination and Employment Act, and on the state-law claims for discrimination, retaliation based on a complaint of age discrimination, and failure to investigate and vacated the summary judgment on the state law claims for retaliation based on a report of gender discrimination, breach of contract, intentional interference with contractual relations, and defamation, holding that the court erred in granting summary judgment as to these claims.This lawsuit arose from events that led to Appellant's retirement from his position as Fire Chief for the Fire Department of the Town of Marshfield, Massachusetts. The district court granted summary judgment in favor of the Town on all of Appellant's federal and state law claims. The First Circuit affirmed in part and vacated in part, holding (1) summary judgment was properly granted as to some of Appellant's claims; but (2) as to the remaining state law claims, there was no analogue to the common law claims in the federal law claims that were addressed, and rather than attempt to resolve the state law issues that were in dispute as to these claims, their dismissal was directed without prejudice. View "Robinson v. Town of Marshfield" on Justia Law

The First Circuit affirmed the decision of the district court entering summary judgment against Plaintiff Jay Furtado and in favor of Defendants, attorney Amy Page Oberg and the law firm DarrowEverett LLP, and dismissing Plaintiff's claims of legal malpractice, breach of fiduciary duty, and misrepresentation, holding that summary judgment was properly granted.Plaintiff was one of three members of a limited liability company (LLC) for a gym. In 2008, Plaintiff engaged Oberg to help to establish the LLC. After the LLC stopped operations, Plaintiff brought this action. The district court entered summary judgment for Defendants. The First Circuit affirmed, holding that, even if there were any doubt that Plaintiff had waived on appeal an argument that a reasonable jury could find that a breach by Defendants proximately caused his harm, this Court would still conclude that summary judgment was proper in this case. View "Furtado v. Oberg" on Justia Law