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

In this breach of contract action the First Circuit affirmed as not clearly erroneous the district court's judgment in favor of Defendant after a bench trial finding no binding contract between the parties, holding that Plaintiff offered no persuasive argument that the district court committed clear error.The First Circuit in this case clarified the difference between facts sufficient to make a claim plausible for pleading purposes and facts sufficient to render a judgment against the claimant clearly erroneous. In a prior decision, the First Circuit reviewed a grant of a motion to dismiss for failure to state a claim and stated that the Court could "plausibly infer" that the parties had formed a contract. The Court emphasized that just because a complaint states a plausible claim for relief does not mean that the claimant has conclusively proven that claim. With the case before the First Circuit a second time, the Court held that by reading too much into its prior ruling, Plaintiff misapprended the manner in which the burden of proof rested once the district court tried the case to a decision and further provided no persuasive argument that the district court committed clear error on remand by determining that no contract existed between the parties. View "APB Realty, Inc. v. Georgia-Pacific LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendant and dismissing Plaintiff's claims that Defendant terminated his employment to deprive him of a significant equity incentive, holding that no reasonable factfinder could conclude that when Defendant fired Plaintiff it deprived Plaintiff of compensation that he had already earned by virtue of his past services.In his complaint, Plaintiff alleged that Defendant breached the implied covenant of good faith and fair dealing. The district court granted summary judgment for Defendant, concluding that Plaintiff had not presented sufficient evidence to show that, at the time of his discharge, Plaintiff was deprived of compensation that he had fairly earned and legitimately expected by virtue of his past work. The First Circuit affirmed, holding that the district court did not err in entering summary judgment in favor of Defendant. View "Suzuki v. Abiomed, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court entering summary judgment in favor of Brown University on Jane Doe's claims alleging several contract and tort claims arising from the university's sanctions against her for her second violation of the university's Code of Academic Conduct, holding that the district court did not err.Specifically, the Court held (1) the district court did not err in entering summary judgment with respect to Doe's claims alleging breach of contract, breach of the implied covenant of good faith and fair dealing, promissory estoppel, negligence, and negligent misrepresentation; and (2) the district court did not err in denying Doe's request for additional discovery under Fed. R. Civ. P. 56(d) on the grounds that Doe failed to show how the information to be obtained would have defeated summary judgment. View "Doe v. Brown University" on Justia Law

The First Circuit reversed the judgment of the district court granting a preliminary injunction prohibiting the Trustees of Boston College (BC) from imposing a suspension of one year on John Doe, a student, who was found to have engaged in the sexual assault of a female student, holding that the district court erred in finding a probability of success as to Doe's claim under Massachusetts contract law.The suspension decision in this case was the outcome of a disciplinary complaint filed against Doe, and the suspension decision was the outcome of the procedures set forth in BC's student sexual misconduct policy. In issuing the preliminary injunction the district court found Doe had shown a probability of success on the merits of the state law claim of violation of a contractual obligation of basic fairness. The First Circuit vacated the injunction, holding (1) to the extent the district court was attempting to base its ruling on a prediction of future developments in Massachusetts contract law, the court erred; and (2) where current Massachusetts law does not require the college discipline process Doe argues must be a part of a contractual obligation of basic fairness the court erred in granting the injunction. View "Doe v. Trustees of Boston College" on Justia Law

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

The First Circuit affirmed the judgment of the district court granting summary judgment for Insurer and dismissing Insured's complaint alleging breach of contract and violations of Massachusetts General Laws chapters 93A and 176D, holding that Insured failed to produce evidence in support of its assertions.In the complaint, Insured claimed that Insurer breached the parties' contract and violated chapters 93A and 176D in the way that Insurer handled Insured's claim for residential property damage. The district court granted summary judgment in favor of Insurer. The First Circuit affirmed, holding (1) the district court did not err in concluding that no reasonable jury could find that Insurer had violated chapter 176D; and (2) there was no breach of the contract. View "River Farm Realty Trust v. Farm Family Casualty Insurance Co." on Justia Law

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

The First Circuit affirmed the arbitrator's decision in favor of RMS Lifeline, Inc. in this dispute between RMS and Dialysis Access Center (DAC) and the district court's refusal to vacate that decision, holding that the district court was correct in denying DAC's challenge and confirming the award.In this multi-year arbitration-fueled litigation the arbitrator ultimately entered a decision for RMS, awarding it almost $2 million. The district court confirmed the award and dismissed DAC's complaint to vacate and/or modify the arbitration award. The First Circuit affirmed, holding that vacatur of the arbitration award was not warranted and that the district court properly confirmed the award. View "Dialysis Access Center, LLC v. RMS Lifeline, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court in favor of the Fay School, Inc. and Fay's Head of School as to Appellants' complaint alleging unlawful retaliation for demands for an accommodation for a certain condition of G., a twelve-year-old minor, holding that the district court correctly denied Appellants' claims.G., a former student of the Fay School, and her parents (collectively, Appellants) brought this suit against Fay after the school refused to remove wireless internet from its classrooms to accommodate G.'s alleged electromagnetic hypersensitivity (EHS), a sensitivity to electromagnetic fields. Appellants alleged, among other claims, unlawful retaliation for an accommodation for G.'s condition, in violation of Title V of the Americans with Disabilities Act, 49 U.S.C. 12203(a), breach of contract, and misrepresentation. The First Circuit affirmed, holding (1) damages are not an available remedy for a Title V retaliation claim premised upon an exercise of rights under Title III of the ADA; and (2) Appellants failed to raise triable issues of fact as to their contract and misrepresentation claims. View "G. v. Fay School" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Insurers in this action brought by Appellants claiming that Insurers' refusal to cover certain legal disputes constituted a breach of their insurance contract, holding that the clear and unambiguous language of the specific litigation exclusion barred coverage of the disputed litigation matters.Appellants filed suit against their primary insurance provider and their secondary insurance providers alleging that Insurers breached their contractual duty to reimburse Appellants for defense costs incurred in connection with the disputed matters. The primary insurer argued that the legal disputes fell under a "specific litigation exclusion" clause in the insurance policy that excepted from coverage claims related to prior matters specified therein. The district court granted summary judgment for Insurers, holding that the prior and disputed matters were sufficiently related such that the exclusion clause applied. The First Circuit affirmed, holding that the specific litigation exclusion barred coverage of the disputed matters because they all involved facts, circumstances, or situations alleged in the prior matters. View "UBS Financial Services Inc. v. XL Specialty Insurance Co." on Justia Law