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 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

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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

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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

Posted in: Contracts
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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

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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

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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

Posted in: Contracts
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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

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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

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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

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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

Posted in: Consumer Law, Contracts