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

This three-way dispute between Link Development, LLC (Link), BD Lending Trust (BD), and RFF Family Partnership LP (RFF) stemmed from an unauthorized conveyance of a mortgage to BD on commercial property in Massachusetts, then owned by Link and now owned by RFF. Previous litigation resulted in settlement agreements between Link and BD and between RFF and BD. In this appeal, RFF challenged (1) the district court’s entry of summary judgment for Link and against RFF on RFF’s claims regarding the validity of the BD mortgage on the grounds that RFF was judicially estopped from challenging the validity of the mortgage, and (2) the court’s decision to exclude attorneys’ fees from damages that BD owed RFF for breach of the settlement agreement between RFF and BD, and the court’s refusal to enter judgment as a matter of law in favor of RFF on contract damages. The First Circuit (1) vacated the entry of summary judgment on RFF’s claims pertaining to the validity of the BD mortgage, holding that the district court abused its discretion in applying judicial estoppel; and (2) affirmed the district court’s decisions related to contract damages and the court’s award of attorneys’ fees under Chapter 93A of the Massachusetts General Laws. View "RFF Family Partnership, LP v. Link Dev., LLC" on Justia Law

Redondo Construction Corporation filed for Chapter 11 bankruptcy. Through the proceedings, Redondo filed three complaints against the Puerto Rico Highway and Transportation Authority for money owed under construction contracts, alleging that it was entitled to damages and prejudgment interest. The bankruptcy court ruled in Redondo’s favor and found that Redondo was entitled to prejudgment interest. The First Circuit vacated the award of prejudgment interest and remanded. On remand, the bankruptcy court awarded Redondo prejudgment interest on its contract claims under Article 1061 of the Puerto Rico Civil Code, accruing through the payment of principal. The Authority moved to amend the judgment. The bankruptcy court denied the Authority’s motion, and the district court affirmed. The First Circuit vacated the judgment, holding (1) Redondo did not forfeit its claim to prejudgment interest under Article 1061; but (2) 28 U.S.C. 1961 exclusively controls awards of postjudgment interest in federal court, and therefore, the bankruptcy court should not have extended the prejudgment interest accrual period past the entry of judgment. Remanded for a calculation of section 1961 interest and a recalculation of Article 1061 interest. View "P.R. Highway & Transp. v. Redondo Constr. Corp." on Justia Law

Copia Communications, LLC, a Massachusetts company, brought this action in federal district court in Massachusetts against Seawind Key Investments, Limited, a Jamaican resort operator, and Seawind’s alleged alter-ego, AMResorts, LP, a Pennsylvania limited partnership, alleging breach of contract. The subject contract was proposed and executed in Jamaica, performance on the contract occurred almost exclusively in Jamaica, and the contract was governed by the laws of Jamaica. Both defendants, neither of which operated any business or had any corporate presence in Massachusetts, moved to dismiss, arguing lack of personal jurisdiction and forum non conveniens. The district court dismissed the case without prejudice, finding that it lacked personal jurisdiction over the defendants. The First Circuit affirmed, holding that the exercise of personal jurisdiction over the defendants was barred by the due process clause of the Fifth Amendment. View "Copia Commc’ns, LLC v. AMResorts, LP" on Justia Law

LimoLiner Inc. contracted with Dattco, Inc. to repair a luxury motor coach that LimoLiner owned. LimoLiner later filed this action in Massachusetts state court alleging breach of contract, misrepresentation, negligence, replevin, and violation of 940 C.M.R. 5.05, a Massachusetts regulation. Dattco removed the case to federal district court. The magistrate judge found that Dattco breached the repair contract by failing to do all of the work that LimoLiner had requested. The judge also ruled for Dattco on all of LimoLiner’s other claims, awarding LimoLiner a total of $25,123 in damages. LimoLiner appealed, arguing, among other things, that the magistrate judge erred in ruling that Dattco may not be held liable under 940 C.M.R. 5.05 for certain actions and omissions that occurred on the job. The First Circuit certified a question concerning 940 C.M.R.’s intended scope to the Supreme Judicial Court of Massachusetts and thus did not decide the merits of LimoLiner’s regulatory claims. The Court otherwise affirmed, holding that the magistrate judge did not err in concluding that Dattco did not breach the parties’ oral contract to make the repairs in a timely manner and owed damages only for the loss of use of the vehicle for one limited period of time. View "Limoliner, Inc. v. Dattco, Inc." on Justia Law

These interlocutory appeals were from a district court order that, inter alia, compelled a law firm (Mintz Levin) to produce documents relating to a fraud allegedly committed by David Gorski in his operation of Legion Construction, Inc. in order to qualify for and obtain government contracts. Gorski and Legion appealed the portion of the order that required attorney-client privileged documents connected with Mintz Levin’s representation of Legion to be produced under the crime-fraud exception. The government cross-appealed the portion of the district court decision to exclude communications between Gorski and his personal attorney from the production order. The First Circuit (1) dismissed Gorski’s appeal for want of appellate jurisdiction, holding that the Court did not have jurisdiction over Gorski’s appeal but did have jurisdiction over Legion’s appeal and the government’s cross-appeal; (2) affirmed the production order as to Mintz Levin, holding that a prima facie case for the crime-fraud exception had been made; and (3) vacated the district court’s decision to exclude Gorski’s communications with his personal attorney from the production order, holding that the district court employed incorrect legal reasoning with regard to these documents. View "United States v. Gorski" on Justia Law

Mark Galvin was the guarantor of a defaulted promissory note on a loan secured by an interest in a Cessna 421C aircraft. The note and security agreement were assigned to Harley-Davidson Credit Corp. After the borrower defaulted on the note, Harley-Davidson repossessed and sold the aircraft through a third-party dealer for $155,000 and then sought to collect $108,681 from Galvin. Galvin did not pay. Harley-Davidson subsequently filed a breach of contract action against Galvin to collect the deficiency. The district court entered partial summary judgment in favor of Harley-Davidson, concluding that there was no dispute of material fact that the sale was “commercially reasonable.” The First Circuit reversed, holding that a genuine issue of material fact existed as to whether the sale was “commercially reasonable,” and therefore, summary judgment should have been denied. Remanded. View "Harley-Davidson Credit Corp. v. Galvin" on Justia Law

Relator filed a qui tam action on behalf of the United States, twenty-five states, and the District of Columbia, naming his former employer as the defendant and asserting several claims under the False Claims Act (FCA) and analogous state statutes. Thereafter, Relator filed three amended complaints adding five defendants. Defendants filed motions to dismiss. Relator subsequently filed a fourth amended complaint, asserting that he had an absolute right to amend his complaint under Fed. R. Civ. P. 15(a)(1). The district court granted Defendants’ motion to strike the fourth amended complaint after construing Relator’s filings as a request for leave to amend, concluding that Relator had not established good cause for amending his complaint once again. The district court then dismissed the case with prejudice, concluding that the FCA’s public disclosure bar deprived it of jurisdiction over certain allegations and that, as to the remaining allegations, the third amended complaint failed to state a cognizable claim. The First Circuit vacated the judgment below and remanded, holding that the district court (1) did not err in concluding that Relator exhausted his one-time right to amend under Rule 15(a)(1); but (2) appraised Relator’s request for leave to amend under the wrong legal standard. View "D'Agostino v. ev3, Inc." on Justia Law

Plaintiff worked for the Town of Camden for thirty-one years prior to being laid off. The collective bargaining agreement (CBA) between the police union and the Town provided for recall of qualified employees based on seniority. During the twelve-month period after Plaintiff was laid off, vacancies opened in the Camden Police Department, but the Town did not recall Plaintiff. Plaintiff and his wife brought this action under 42 U.S.C. 1983 alleging that the Town had deprived Plaintiff, without due process of law, of his property interest in his right to be recalled. The district court dismissed Plaintiff’s complaint for failure to state a claim. The First Circuit vacated the dismissal and remanded. On remand, the district court entered judgment for the Town, concluding that the CBA contained a condition precedent requiring Plaintiff to submit his address and phone number to the Town after his layoff in order to assert his recall rights and that Plaintiff did not submit such information post-layoff. The First Circuit vacated the judgment and remanded, holding that the CBA recall provision did not unambiguously create a condition precedent, and therefore, further fact-finding was necessary. View "Clukey v. Town of Camden, Maine" on Justia Law

Plaintiffs, property owners, entered into an oral contract with Defendant, a construction firm, for the assembly of a prefabricated house on a lot that they owned. The parties subsequently entered into a second oral agreement for the assembly of a smaller and cheaper home. Defendant failed to complete construction of Plaintiffs’ home as agreed. Citing diversity of citizenship, Plaintiffs filed suit in federal district court alleging breach of contract. Defendant counterclaimed for breach of contract. The jury found Defendant to have defaulted on its contractual obligations and awarded $150,000 in damages. Defendant appealed, challenging the sufficiency of the evidence. The First Circuit affirmed, holding that it could not be said that no rational jury could have found in favor of Plaintiffs. View "Magee v. BEA Constr. Corp." on Justia Law

Labonte Drywall Company signed a statewide agreement with Union, which allowed Labonte Drywall to hire Union carpenters for its business. The agreement required Labonte Drywall to allow an audit of its records. After Labonte Drywall did not respond to certain audit requests, Plaintiffs, the trustees for a group of Union-related benefits funds and their collection agency, filed this action against Labonte Drywall under ERISA and the Labor Management Relations Act, seeking enforcement of the agreement. After a bench trial, the district court found that Labonte Drywall had terminated the agreement, and therefore, Plaintiffs had no legal right to conduct the requested audit. The First Circuit affirmed, holding (1) the district court did not clearly err in finding that the Union had actual notice of Labonte Drywall’s letter terminating its obligations under the agreement; and (2) Labonte Drywall had no duty to submit to Plaintiffs’ audit requests. View "New England Carpenters Central v. Labonte Drywall Co., Inc." on Justia Law