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

After T G Plastics Trading Co., Inc. (“National Plastics”) allegedly fell behind on payments owed to Toray Plastics (America), Inc., Toray filed suit. The parties settled the lawsuit, and the terms of the settlement were memorialized in a Settlement Agreement. The Settlement Agreement provided that Toray would sell certain materials exclusively through National Plastics and pay National Plastics a twelve percent commission on all sales generated by National Plastics. When the parties began to dispute several aspects of the application of the Settlement Agreement, National Plastics sued Toray. The original complaint did not contain a jury demand. After two years of settlement negotiations, National Plastics amended its complaint to request a jury trial. A jury found Toray liable for breach of the Settlement Agreement and awarded National Plastics more than $2 million in damages. The First Circuit affirmed, holding (1) the district court did not err in allowing National Plastics to amend its complaint to add a jury demand, as National Plastics did not waive its right to a jury trial by a belated demand; and (2) the evidence was sufficient to support the jury’s finding of liability and its calculation of damages. View "T G Plastics Trading Co., Inc. v. Toray Plastics (America), Inc." on Justia Law

Rosana Claudio-de Leon (Claudio) and the University of the East of the Ana G. Mendez University System (SUAGM) entered into an employment contract that contained a forum selection clause precluding adjudication in federal court. Claudio, Luis F. Carrasquillo-Rivera, and the conjugal partnership Carrasquillo-Claudio (collectively, Appellants) filed suit against SUAGM in the district court, alleging, among other claims, pregnancy and gender discrimination. The district court dismissed Appellants’ Title VII pregnancy and gender discrimination claim and supplemental state law claims due to the forum selection clause. The First Circuit affirmed as modified, holding (1) the forum selection clause was applicable and enforceable; but (2) the district court should have dismissed the case without prejudice to permit Appellants to refile in the appropriate forum. Remanded. View "Claudio de-Leon v. Ayala" on Justia Law

In 1997, Appellant began working for Banco Popular de Puerto Rico (BPPR). After Appellant retired in 2009, BPPR made a final calculation of Appellant’s pension, which yielded monthly payments significantly lower than earlier estimates had suggested. Seeking the higher amount he had expected, Appellant brought claims under ERISA, a theory of estoppel, and Puerto Rico contract law. The district court (1) dismissed the ERISA and contract claims, concluding that Appellant failed to state a claim under ERISA and that ERISA preempted the commonwealth claims; and (2) granted summary judgment against Appellant on the estoppel claim, concluding that the unambiguous terms of the benefits plan precluded a claim for estoppel. The First Circuit affirmed, holding (1) Appellant could not recover under ERISA because he could not be awarded relief under the terms of BPPR’s retirement plan; (2) the district court properly held that Appellant’s commonwealth claims “relate to” the ERISA-regulated plan and, accordingly, they were preempted; and (3) because Appellant did not show any ambiguity in the plan, his equitable estoppel claim necessarily failed. View "Guerra-Delgado v. Banco Popular de P.R." on Justia Law

Plaintiff and Defendant entered into an asset purchase agreement (the Agreement) that contained a provision requiring submission of all disputes concerning the “validity, interpretation and enforcement” of the Agreement to an arbitrator for binding resolution. Plaintiff sued Defendant in federal district court, asserting claims for fraud and breach of contract arising out of the Agreement. Defendant answered the complaint, and the parties began discovery. Several months later, Plaintiff moved to stay proceedings pending arbitration. A magistrate judge denied the motion to stay on the ground that Plaintiff had waived its arbitral rights. The district judge summarily affirmed the denial of the stay. The First Circuit affirmed, holding that the district court did not err in concluding that Plaintiff, through its conduct, waived its right to demand arbitration. View "Joca-Roca Real Estate, LLC v. Brennan, Jr." on Justia Law

With the threat of foreclosure looming on his home, Plaintiff sued Bank for failing to consider him for a mortgage loan modification, which a California class action settlement agreement required Bank to do before attempting to foreclose on Plaintiff’s home. The complaint alleged breach of contract, violation of Mass. Gen. Laws ch. 244, 35A and 35B, violation of Mass. Gen. Laws ch. 93A, and breach of the implied covenant of good faith and fair dealing. The district court dismissed the complaint in its entirety. The First Circuit vacated in part and remanded Plaintiff’s claims for breach of contract and breach of the implied covenant of good faith and fair dealing, holding (1) Plaintiff’s statutory causes of action fell short of stating a cognizable claim; but (2) the district court improperly converted Bank’s motion to dismiss Plaintiff’s contract-based claims into a motion for summary judgment, warranting a remand of those claims. View "Foley v. Wells Fargo Bank, N.A." on Justia Law

Defendant, a Canadian company, contracted with Plaintiff, a Massachusetts investment bank, to be its exclusive financial advisor for the sale of its business. The parties negotiated and executed the agreement from their respective home offices, contacting each other by phone, e-mail, and internet. Plaintiff later sued in Massachusetts Superior Court alleging breach of contract, among other claims. Defendant removed the case to federal district court. The district court subsequently dismissed the case, concluding that it could not exercise personal jurisdiction over Defendant consistently with the Due Process Clause. The First Circuit reversed, holding that, in light of the nature, number, origin, and duration of the parties’ contacts in this case, the exercise of long-arm jurisdiction by Massachusetts was consistent with fair play and substantial justice. View "C.W. Downer & Co. v. Bioriginal Food & Sci. Corp." on Justia Law

This interlocutory appeal concerned a preliminary injunction entered against Joshua Powell in litigation resulting from several contracts between the company Powell founded and a new joint venture formed with a non-party. At issue before the First Circuit was whether the district court abused its discretion in issuing the preliminary injunction. The First Circuit left the preliminary injunction temporarily in place and remanded with instructions, directing that the district court review the matter of irreparable injury and vacate the preliminary injunction if it finds irreparable harm to be lacking, and if the court find irreparable harm and an otherwise sufficient basis for injunctive relief, that it hear the parties’ arguments on the appropriate scope and language of the injunction. View "JL Powell Clothing LLC v. Powell" on Justia Law

Alasko Foods, Inc. (“Alasko”), a Canadian corporation that sells frozen produce to retail outlets, and Foodmark, Inc. (“Foodmark”), a Massachusetts corporation that assists food manufacturers in marketing branded-label and private-label products to retailers, entered into a “U.S. Representation Agreement [and] Sales Management Agreement” wherein Alasko retained Foodmark to market Alasko’s products in the United States. Five years later, Alasko terminated the Agreement. Foodmark filed a complaint against Alasko, alleging that Alasko’s refusal to pay the “Non-Renewal Termination Fee” contemplated by the Agreement constituted a breach of the Agreement and of its covenant of good faith and fair dealing. A federal district court entered summary judgment for Foodmark and awarded $1.1 million in damages. The First Circuit affirmed, holding that there were no genuine issues of fact, and Foodmark was entitled to a termination fee in the amount calculated by the district court. View "Foodmark, Inc. v. Alasko Foods, Inc." on Justia Law

Plaintiff’s property was subject to a mortgage. Plaintiff discussed refinancing with a predecessor in interest to Wells Fargo Bank, N.A., as well as a mortgage broker and his firm, whom Plaintiff referred to as “agents” of Wells Fargo. Based on these discussions, Plaintiff began making improvements to increase the property’s appraised value. Ultimately, Plaintiff was unable to refinance her mortgage. Plaintiff brought suit against Wells Fargo, alleging, among other claims, a violation of N.H. Rev. Stat. Ann. 397-A:2(VI) (count one) and promissory estoppel (count five). The district court dismissed counts one and five of Plaintiff’s complaint, concluding both claims were inadequately pleaded. Plaintiff appealed, arguing, among other things, that although she could not claim a private right of action under section 397-A:2(VI), she did state a claim for common law fraud. The First Circuit affirmed, holding that the district court properly dismissed any state law fraud claim that Plaintiff belatedly attempted to advance and correctly dismissed Plaintiff’s promissory estoppel claim.View "Ruivo v. Wells Fargo Bank, N.A." on Justia Law

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