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

Plaintiffs, citizens of Rhode Island, brought state law contract claims against Defendants, alleging, among other claims, breach of an oral contract. After the Rhode Island state court dismissed the only non-diverse defendant from the case, the remaining defendants removed the lawsuit to federal court on the basis of diversity jurisdiction. Plaintiffs filed a motion to remand to state court, correctly pointing out that, at the time of removal, the dismissal of the non-diverse defendant was not final. The district court denied Plaintiffs’ motion to remand, granted summary judgment in favor of Defendants, and awarded attorneys’ fees to defendant Southworth-Milton, Inc. (Southworth). Plaintiffs appealed the judgment in favor of Southworth and argued that the case should be remanded to state court. The First Circuit affirmed, holding (1) remand to state court was not required, and the district court had jurisdiction, because despite Defendants’ failure to comply with the statutory removal requirements, complete diversity existed at the time of judgment, and Plaintiffs failed to object to the statutory procedural defect in a timely manner; and (2) the district court correctly granted summary judgment and awarded attorneys’ fees in favor of Southworth.View "Universal Truck & Equip. Co. v. Southworth-Milton, Inc." on Justia Law

Jeffrey Healey and Edward Given, residents of the Massachusetts Treatment Center, were each civilly committed as a sexually dangerous person. Plaintiffs brought separate suits, which were later consolidated, challenging the conditions of their confinement and the adequacy of their sexual offender treatment. Plaintiffs sought equitable relief against the Massachusetts Department of Corrections and other state officials (collectively, the DOC). Both plaintiffs alleged violations of the Constitution and state statutory provisions, and Healey alleged that the DOC was not in compliance with the terms of a management plan (Plan) for the Center developed by the DOC during the course of prior litigation. The district court granted Plaintiffs declaratory and injunctive relief on some claims and entered judgment in favor of the DOC on the remaining claims. The First Circuit (1) reversed the declaratory judgment in favor of Healey on his contempt claim as well as injunctive relief compelling the Commonwealth’s compliance with the Plan’s provisions; and (2) affirmed the district court’s judgment in favor of Defendants in all respects with the exception of the judgment for Plaintiffs regarding the constitutionality of the pharmacological evaluation and treatment provided by Defendants, as that portion of the judgment was not challenged on appeal.View "Healey v. Dennehy" on Justia Law

Defendant, a law firm, contracted with Plaintiff for Plaintiff to provide title insurance on two mortgages that Defendant took as security from a client indebted to Defendant. Upon foreclosure of liens that were superior to those of Defendant, Defendant sought coverage from Plaintiff under the insurance policies, which seemingly provided coverage for priority liens. Defendant requested indemnification, and Plaintiff sought declaratory judgment, arguing that coverage for priority liens was not intended by either party. A federal district court granted summary judgment in favor of Plaintiff, concluding that because Defendant was aware of the prior mortgages, it could not expect to receive coverage it did not bargain for. The First Circuit affirmed, holding that Plaintiff had conclusively shown that Defendant was aware that its bargain with the client for security of its debt would result in junior mortgages, and the insurance policies clearly excluded such encumbrances from coverage.View "First Am. Title Ins. Co. v. Lane Powell PC" on Justia Law

Police officers discovered Thomas Locke, a US Airways mechanic at Logan International Airport, filching company property. US Airways entered into a “Last Chance Agreement” with Locke in lieu of termination and provided for Locke’s return to work. Logan International Airport, however, denied Locke’s application for renewal of his security badge. Thereafter, US Airways concluded that Locke had violated the terms of the Agreement and terminated his employment. Locke subsequently filed suit against US Airways, alleging that US Airways breached the Agreement by interfering with his application for a security badge at Logan Airport and by preventing him from transferring to Philadelphia International Airport. The district court granted summary judgment for US Airways. The First Circuit affirmed, holding that there was no triable basis for Locke’s contentions in the record. View "Locke v. US Airways, Inc." on Justia Law

From 2005 to 2010, Plaintiff, a Maine resident, worked as a salesman for Alpha Networks, which was based in California, pursuant to a written employment agreement. Plaintiff left Alpha having received no commissions on his sales in 2009 or 2010. Plaintiff then filed suit. A jury concluded that Alpha had not promised to pay Plaintiff commissions after 2008 but concluded that Plaintiff was entitled to damages in the amount of $70,331 under quasi-contract. After trial, the parties disputed whether California or Maine law governed whether and to what extent the jury’s damages award should be augmented with additional remedies. Under California law, Plaintiff would be entitled to an additional award of $7,799, but under Maine law, Plaintiff would be entitled to an additional $140,663, as well as attorneys’ fees and costs. The district court concluded that California law applied. The First Circuit vacated the award and remanded, holding that Maine substantive law governed enforcement of the quasi-contractual relationship found to exist between the parties in 2009 and 2010.View "Dinan v. Alpha Networks, Inc." on Justia Law

In 2008, Plaintiff purchased a home in Bar Harbor, Maine from Defendants for $2.9 million. After his purchase, Plaintiff spent in excess of $1.5 million in repairs to the property. Plaintiff brought suit against Defendant to recover damages for the repairs, alleging, among other claims, breach of contract, fraud, and negligent misrepresentation. A federal district court entered summary judgment in favor of Defendants, concluding (1) Maine’s implied warranty of habitability did not apply under the circumstances of this case, and Defendants had no duty of disclosure; and (2) Defendants were not entitled to attorney’s fees. The First Circuit affirmed, holding that the district court (1) properly granted summary judgment for Defendants on Plaintiff’s breach of contract, fraud, and negligent misrepresentation claims; and (2) properly entered judgment on the record for Plaintiff on Defendants’ counterclaim for attorney’s fees. View "Thompson v. Miles" on Justia Law

At issue in this case was whether alleged misrepresentations made by Defendants were made “in connection with” a transaction in covered securities under the Securities Litigation Uniform Standards Act of 1998 (SLUSA). Plaintiffs, investors in a licensed non-diversified investment company, filed a putative class action in Puerto Rico court against the Fund and others alleging fraud or misrepresentation in violation of Puerto Rico law after the Fund invested the majority of its assets in notes sold by Lehman Brothers, resulting in the Fund adopting a plan of liquidation. Defendants removed the action to the federal district court, asserting that it fell within the ambit of the SLUSA. Plaintiffs unsuccessfully sought remand on jurisdictional grounds. Ultimately, the district court granted Defendants’ motions to dismiss premised on SLUSA preclusion. The First Circuit vacated the judgment of dismissal and remitted with instructions to return the case to the Puerto Rico Court, holding that the link between the misrepresentations alleged and the covered securities in the Fund’s portfolio was too fragile to support a finding of SLUSA preclusion under Chadbourne & Parke LLP v. Troice. View "Hidalgo-Velez v. San Juan Asset Mgmt., Inc." on Justia Law

Mark Hansen was a former vice president of Wilcox Industries Corp. After Hansen left Wilcox, he founded his own company, Advanced Life Support Technologies. Wilcox filed a complaint against Hansen, alleging that Hansen stole Wilcox’s customers and spread false and damaging information about Wilcox’s products. Hansen tendered his defense to Wilcox’s insurer, Sentry Insurance Company. Sentry denied coverage, stating that it did not have a duty to defend or indemnify Hansen against Wilcox’s claims. Hansen subsequently filed suit seeking a declaration that Sentry owed a duty to defend and indemnify him with respect to Wilson’s complaint. The district court granted summary judgment for Wilcox, concluding that Hansen did not qualify as an “insured” under Wilcox’s policy. The First Circuit affirmed, holding (1) Sentry owed no duty to defend or indemnify Hansen in the underlying litigation; and (2) there was no evidence in the record that would permit a reasonable jury to find that Sentry breached any contract with Hansen. View "Hansen v. Sentry Ins. Co." on Justia Law

After an oil drilling rig owned by BP Exploration & Production, Inc. and BP America Production Company (collectively, BP) sank of the Gulf Coast of Louisiana and caused a massive oil spill, Packagen, a manufacturer of packaging products, sought to sell containment boom to BP. Packagen began producing boom after the oil spill, but BP never paid for any of the boom manufactured by Packagen. Packagen filed a five-count complaint against BP in federal district court, invoking diversity jurisdiction and alleging various state-law claims. The district court granted summary judgment in favor of BP. The First Circuit affirmed, holding that the district court did not err in granting summary judgment on Packagen’s negligent and intentional misrepresentation claims, breach of contract claim, unjust enrichment and quantum meruit claim, and promissory estoppel claim. View "Packgen v. BP Exploration & Prod., Inc." on Justia Law

The lawsuit underlying this action alleged that Glynis McCormack’s ward sexually and physically abused a younger boy. In this declaratory judgment action, the district court ruled that Metropolitan Property and Casualty Insurance Company, McCormack’s insurer, had a duty to defend McCormack in the underlying lawsuit. Metropolitan appealed, arguing that the alleged harmful conduct was excluded from coverage under the governing policy. The First Circuit affirmed, holding that, under the facts of this case, McCormack’s policy would cover the harm alleged in the complaint, and therefore, Metropolitan had a duty to defend McCormack in the underlying action. View "Metro. Prop. & Cas. Ins. Co. v. McCarthy" on Justia Law