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

This case involved a series of shifting employment arrangements between Plaintiff and Defendant, TSI Semiconductors America, LLC (TSA). In 2009, Plaintiff began working for Tejas Silicon, Inc. under a written employment agreement (Agreement). In 2011, corporate restructuring led to Plaintiff’s termination with Tejas and the offer of new employment with TSA. The parties amended the Agreement in certain respects. After Plaintiff was furloughed in 2012, Plaintiff sued TSA in a California state court alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and California state law claims. TSA removed the case to federal district court. The district court entered summary judgment in favor of TSA, concluding that neither the reorganization, the non-renewal of the Agreement, nor the layoff constituted a termination without cause that triggered the duty to pay severance under the Agreement. The First Circuit reversed in part, affirmed in part, and remanded, holding (1) because genuine issues of material fact permeated the record, the district court erred in granting summary judgment for TSA on Plaintiff’s claim for severance benefits arising out of the 2011 reorganization; and (2) the district court did not err in granting summary judgment on Plaintiff’s claims regarding the 2012 non-renewal and the 2012 layoff. View "Mason v. Telefunken Semiconductors America, LLC" on Justia Law

In 1997, Quality Cleaning Products (QCP) entered into a distribution agreement with SCA Tissue North America (SCA) that designated QCP as a non-exclusive, authorized Puerto Rican distributor and wholesaler of SCA’s “Tork” brand product line. QCP claimed that SCA breached that agreement in 2001. In 2012, QCP filed this breach of contract action. The district court dismissed the action as time barred under the relevant three-year statute of limitations. The First Circuit affirmed after applying Puerto Rico’s statute of limitations and accrual rules, holding that QCP’s claim accrued in 2001, and thus the three-year statute of limitations had been far exceeded. View "Quality Cleaning Prods. R.C., Inc. v. SCA Tissue of N.A." on Justia Law

Plaintiff filed this putative class action against Defendants - Nisource Corporate Services Company and AGL Resources, Inc. - alleging that Defendants engaged in deceptive business practices by disguising credit sales of hot water heaters as leases to avoid making the disclosures required under federal and Massachusetts’ consumer protection laws. Plaintiff alleged three disclosure violations: (1) a federal claim under the Truth in Lending Act; (2) a state law claim under the Massachusetts Retail Installment Sales and Services Act (RISSA) and (3) a state law claim under the Massachusetts Consumer Credit Cost Disclosure Act (CCCDA). The district court found that Plaintiff did not qualify for protection in light of the state-law standards governing these transactions and dismissed her suit. The First Circuit affirmed on alternate grounds, holding (1) Plaintiff’s federal claim under TILA is barred by the statute of limitations; and (2) as to the pendent state law claims, which were timely, the Court affirmed dismissal for failure to state a claim. View "Philibotte v. Nisource Corp. Services Co." on Justia Law

Arborjet, Inc. (Plaintiff), which manufactures and sells an emamectin benzoate solution used to protect trees from pests called TREE-age, granted Rainbow Treecare Scientific Advancements, Inc. (Defendant) an exclusive right to distribute TREE-age pursuant to a sales agency contract. After termination of this agreement, Defendant began marketing and distributing ArborMectin, another emamectin benzoate combination meant to compete directly with TREE-age. Plaintiff sued Defendant seeking to enjoin Defendant’s sales of ArborMectin and alleging several claims. The district court granted Plaintiff a preliminary injunction to run during the litigation that was meant to enforce the contractual agreement and prohibit a trademark violation. The First Circuit affirmed in part and reversed in part the order comprising the preliminary injunction, holding (1) it was not clear error to find a likely showing that Defendant contributed to the creation of ArborMectin; (2) the district court did not err in entering the portion of the preliminary injunction based on Arborjet’s contract claim; but (3) ordering proper attribution of “Arborjet” and “TREE-age” was improper given the district court’s rulings on the Lanham Act claims. View "Arborjet, Inc. v. Rainbow Treecare Scientific Advancements, Inc." on Justia Law

Appellant, a family-owned retail clothing and footwear business with two stores in Massachusetts, had sold Nike footwear for approximately twenty-eight years before Nike notified Appellant that it was terminating the parties’ business relationship. Appellant sued Nike in Massachusetts state court, alleging contractual claims and a claim under Mass. Gen. Laws ch. 93A. Nike removed the suit to federal court and then moved to dismiss under Fed. R. Civ. P. 12(b)(6), alleging that its invoices included a forum selection clause requiring Appellant to file its claims in Oregon, not Massachusetts. The district court agreed and dismissed Appellant’s complaint. The First Circuit affirmed, holding that the forum selection clause was valid and enforceable, and the district court properly dismissed the present action. View "Carter's of New Bedford, Inc. v. Nike, Inc." on Justia Law

Plaintiff entered into a salvage contract with Defendant to obtain help when his boat went aground one night. Plaintiff later attempted to rescind the contract, claiming that he signed the contract under duress and disputing the sum owed to Defendant. The parties submitted the dispute to a panel of arbitrators pursuant to a binding arbitration clause in the salvage contract. Plaintiff then filed this lawsuit seeking a preliminary injunction against the arbitration and a declaration that the salvage contract was unenforceable. The district court denied the motion and stayed the case pending the outcome of the arbitration. The arbitration panel found in favor of Defendant and ordered Plaintiff to pay a salvage award. The district court affirmed the award. Plaintiff appealed, arguing that the district court erred in confirming the arbitration award without first addressing his claim that the arbitration clause was unenforceable. The First Circuit affirmed, holding that, where Plaintiff’s challenge to the validity of the arbitration clause itself came only after Defendant moved to confirm the panel’s award, the district court had no proper basis on which to refuse to confirm the arbitration panel’s award. View "Farnsworth, III v. Towboat Nantucket Sound, Inc." on Justia Law

Plaintiff, an attorney, filed a lawsuit against the Narragansett Indian Tribe alleging breach of contract. Plaintiff alleged that the Tribe contractually waived the sovereign immunity that would otherwise have prevented him from bringing this suit outside the tribal courts. The district court denied the Tribe’s motion to dismiss the case on sovereign immunity grounds. The Tribe did not appeal the denial of the motion to dismiss. Instead, the Tribe filed an untimely Fed. R. Civ. P. 59(e) motion for reconsideration. The district court denied the Rule 59(e) motion. The Tribe subsequently filed a notice purporting to appeal from both the denial of the motion to dismiss and the denial of the untimely Rule 59(e) motion. A prior duty panel of the First Circuit dismissed as untimely any appeal from the denial of the motion to dismiss. The First Circuit subsequently denied interlocutory review of the order denying its motion to reconsider, holding that it lacked jurisdiction to entertain such an appeal because the denial of the Tribe’s untimely 59(e) motion did not qualify as a collateral order that the Court may review prior to the end of the litigation in the district court. View "Luckerman v. Narragansett Indian Tribe" on Justia Law

Plaintiff was a life insurance agent with the New Life Insurance Company for more than forty years. In 2009, Plaintiff was informed that his agent contract would be terminated. In 2012 and 2014, Plaintiff filed two separate suits against New York Life, alleging, in addition to several common-law claims, age discrimination under both Massachusetts law and the federal Age Discrimination in Employment Act. The U.S. District Court of the District of Massachusetts consolidated the two cases. The district court then granted summary judgment for New York Life on all claims. The First Circuit affirmed, holding (1) Plaintiff’s state law age discrimination claims were time barred; (2) no reasonable jury could conclude that New York Life engaged in age discrimination under federal law in terminating his agent contract; and (3) no reasonable jury could conclude that the termination breached Plaintiff’s contract with New York Life or violated any of Plaintiff’s common law rights. View "Santangelo v. New York Life Ins. Co." on Justia Law

Home Orthopedics Corp. was a medical equipment supplier based in Puerto Rico. Raul Rodriguez, the president of another home medical supplier in Puerto Rico, attempted to collect a consulting fee Home Orthopedics agreed to pay him. Home Orthopedics refused to continue paying the fee when it discovered that the contract upon which it was based was fraudulent. Soon companies in the health insurance field started terminating their contracts with Home Orthopedics. Home Orthopedics filed an amended complaint seeking relief against numerous defendants - some of whom worked with Rodriguez and others of whom worked for the companies that terminated their contacts with Home Orthopedics - for violating, among other laws, the Racketeer Influenced and Corrupt Organizations Act (RICO). Specifically, Home Orthopedics alleged that Defendants conspired to help Rodriguez strong-arm more money from Home Orthopedics. The district court dismissed Home Orthopedics’ claims. The First Circuit affirmed, holding (1) Home Orthopedics failed to sufficiently allege a “pattern of racketeering activity” necessary to sustain its RICO claim; and (2) the district court did not err in denying Home Orthopedics’ motion to conduct limited discovery and then to amend its complaint for a second time. View "Home Orthopedics Corp. v. Rodriguez" on Justia Law

Advanced Flexible Circuits (AFC) entered into negotiations with GE Sensing & Inspection Technologies GmbH and GE Sensing, Division of Caribe GE International of Puerto Rico, Inc. (collectively, GE) for AFC to manufacture and supply thermal filaments for GE to use in its production of cardiac catheters. After GE terminated negotiations with AFC, AFC filed suit, alleging that GE was liable for pre contractual damages under the Puerto Rico doctrine of culpa in contrahendo. The district court granted summary judgment for GE. The First Circuit affirmed, holding (1) AFC offered no competent evidence permitting a finding of liability on its culpa in contrahendo claim, as GE’s termination of the negotiations was not arbitrary, unjustified, or otherwise wrongful; and (2) the district court did not abuse its discretion in sanctioning AFC for failing to comply with the court’s local rules. View "Advanced Flexible Circuits v. GE Sensing & Inspection Techs. GmbH" on Justia Law