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

A Massachusetts corporation and its principals sued their quondam accountant and his firm (collectively, Defendants), alleging that Defendants negligently advised them to file amended corporate and personal tax returns that had the effect of substantially increasing the principals' liability and destabilizing the company. The district court granted summary judgment for Defendants but rejected their request for attorneys' fees. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) concluding that a three-year statute of limitations applied to bar the maintenance of Plaintiffs' tort and contract claims; (2) dismissing Plaintiffs' unfair trade practices claim; and (3) denying Defendants' request for attorneys' fees. View "RTR Techs., Inc. v. Helming" on Justia Law

The U.S. Department of Health and Human Services (HHS) received funds appropriated by Congress under the Trafficking Victims Protection Act. In 2006, HHS contracted with the U.S. Conference of Catholic Bishops (USCCB) to provide services to trafficking victims. At USCCB's insistence, the contract incorporated a restriction pursuant to which neither USCCB nor any of its subcontractors would use funding to counsel or provide contraceptive services and prescriptions or abortions to trafficking victims. The ACLU of Massachusetts (ACLUM) brought suit, alleging that HHS violated the Establishment Clause of the First Amendment. In 2012, the district court issued a declaratory judgment that HHS had violated the Establishment Clause. The federal defendants appealed. The First Circuit Court of Appeals vacated on grounds of mootness, where the 2006 contract expired in 2011. Remanded with instructions to dismiss. View "ACLU of Mass. v. U.S. Conference of Catholic Bishops" on Justia Law

Defendant was an attorney who litigated a case against the nations believed to be behind a 1972 terrorist attack on Puerto Ricans at an Israeli airport. Defendant and the American Center for Civil Justice (the Center) originally had an agreement on how to handle the litigation. However, Defendant misrepresented to clients that the Center had paid him for his work and convinced clients to revoke the Center's attorney's power of attorney. Thereafter, the Center filed suit against Defendant. In the meantime, Plaintiffs, the heirs of two individuals killed in the terrorist attack who signed retainer agreements with Defendant, filed this action against Defendant, alleging that the retainer agreements were void because Defendant secured their consent by deceit. After a jury trial, judgment was entered against Defendant. The First Circuit Court of Appeals affirmed, holding (1) the evidence was sufficient to support the conviction; (2) the non-testifying heirs proved deceit without testifying about their reliance on Defendant's misrepresentations; and (3) the district court did not err in its instructions to the jury. View "Estate of Berganzo-Colon v. Ambush" on Justia Law

Upon an investigation by the Maine Bureau of Insurance (Bureau) and the Maine Attorney General's Office (AG's Office) into the questionable business practices of Bankers Life and Casualty Company (Company), Appellant, the Company's employee, accepted responsibility for his own unlawful conduct. In exchange, several state officials (Appellees) representing the Bureau and the AG's Office agreed to take no further action against Appellant. Appellees, however, subsequently agreed to Appellant's termination in a separate agreement with the Company. Appellant filed a complaint against Appellees, asserting violations of 42 U.S.C. 1983 and 42 U.S.C. 1985(2). The district court dismissed the complaint, concluding (1) Appellees were entitled to absolute immunity on the section 1983 claim, and (2) Appellant failed to plead a plausible section 1985(2) claim. The First Circuit Court of Appeals affirmed, holding (1) Appellees met their burden in establishing they were entitled to absolute immunity for entering into the consent agreements with Appellant and the Company, and the district court did not err by refusing to invoke the doctrine of judicial estoppel on Appellees' immunity defense; and (2) because the complaint failed to allege any racial or class-based invidiously discriminatory animus underlying Appellees' actions, the district court properly dismissed Appellant's section 1985(2) claim. View "Knowlton v. Shaw" on Justia Law

This appeal involved litigation between Coverall North America, Inc. and its franchisees. Proceeding under federal diversity jurisdiction, the franchisees asserted a variety of state-law claims against Coverall. Which of the various plaintiffs were subject to the arbitration provisions of the Franchise Agreement was at issue in this appeal. Appellees were a subgroup of Plaintiffs who became Coverall franchisees by signing consent to transfer agreements, which by reference incorporated under franchise agreements that contained arbitration clauses. The district court determined that Appellees did not have to arbitrate their claims against Coverall because they did not have adequate notice of the arbitration clauses contained in the franchise agreements. The First Circuit Court of Appeals reversed, holding that the district court erred because (1) Massachusetts law, which governed this dispute, did not impose any such special notice requirement upon these commercial contractual provisions; and (2) in any event, any special notice requirement would be preempted by the Federal Arbitration Act. View "Awuah v. Coverall N.A., Inc. " on Justia Law

Several years ago, Plaintiffs entered into a fifteen-year lease with Defendant's predecessor in interest (Miller). The lease included a purchase option. After Defendant refused to allow Plaintiffs to exercise the purchase option on the ground that they were in default on their obligations under the lease, Plaintiffs instituted this action, demanding specific performance or damages. The district court granted summary judgment in favor of Plaintiffs and ordered specific performance of the purchase option, determining that Miller had waived a provision which prohibited Plaintiffs from subleasing without prior written permission and that all alleged defaults were inconsequential and immaterial. The First Circuit Court of Appeals affirmed, holding that summary judgment for Plaintiffs was proper, where (1) the district court correctly found that Miller waived the requirement that Plaintiffs obtain written permission before subleasing any portion of the premises; and (2) the district court properly found that Defendant had failed to present evidence of how alleged violations the lease provision requiring them to comply with state and municipal laws harmed her or Miller. View "Bachorz v. Miller-Forslund" on Justia Law

House of Flavors purchased equipment from Tetra and executed an agreement with Tetra to fund its installation. Under the agreement, Tetra paid for the installation, House of Flavors then transferred ownership of the installed system to Tetra, and Tetra leased the system back to House of Flavors. After House of Flavors began monthly lease payments, it sought to exercise the buy back option a year early. Notwithstanding the twelve percent estimate it quoted earlier, Tetra quoted a purchase price around forty percent of the equipment and installation costs. House of Flavors filed suit in federal district court, where it prevailed on its claims. The First Circuit Court of Appeals affirmed but remanded the case to reconsider the balance due between the parties. On remand, the judge recalculated the balance due and determined that, rather than owing House of Flavors, Tetra was in fact due $156,399. The First Circuit dismissed House of Flavors' appeal, holding (1) the attack on the recalculated figure was foreclosed by a jurisdictional objection, as the appeal was untimely; and (2) the appeal was jurisdictionally timely as to the district court's refusal to award attorneys' fees under a Utah statute, but the denial of attorneys' fees was affirmed. View "House of Flavors, Inc. v. TFG-Michigan, L.P." on Justia Law

In this appeal, Greater Omaha Packing Company (GOPAC) asked the First Circuit Court of Appeals to vacate a jury's unanimous finding that GOPAC supplied Fairbank Reconstruction Corporation with E. coli-tainted beef, which Fairbank then packaged and shipped to two supermarkets in Maine, resulting in two women who bought meat there becoming seriously ill. The Supreme Court affirmed, holding that there was no basis upon which to upset the jury's verdict, as (1) the evidence was sufficient for a reasonable jury to conclude that GOPAC's meat was contaminated and that such meat was included in the packages the two women purchased; and (2) the trial court did not err in admitting a video deposition of GOPAC's former expert witness. View "Fairbank Reconstruction v. Greater Omaha Packing Co." on Justia Law

This dispute between The Saint Consulting Group (Saint) and its liability insurer, Endurance American Specialty Insurance Company (Endurance), stemmed from Endurance's refusal to defend Saint in a lawsuit against Saint in the Northern District of Illinois. The district court dismissed Saint's lawsuit against Endurance based on an exclusion in the policy that stated explicitly that the policy does not apply to any claim based upon or arising out of any actual or alleged violations of the Sherman Anti-Trust Act or any similar provision of any state law. The First Circuit Court of Appeals affirmed, holding (1) because the second complaint alleged that Saint engaged in an anti-competitive scheme the exclusion was triggered; and (2) the policy did not cover the negligent spoliation claim in the first complaint. View "Saint Consulting Group, Inc. v. Endurance Am. Specialty, Inc." on Justia Law

Plaintiff was severely injured in a workplace accident and sued Trail King, the custom manufacturer of the trailer involved in the accident. The First Circuit Court of Appeals affirmed a jury's finding that Defendant had not been negligent nor in breach of any warranty. In the trial court in that diversity case, Plaintiffs belatedly attempted to amend their complaint to add another claim, one under Mass. Gen. Laws ch. 93A for unfair and deceptive trade practices. The trial judge denied the motion, finding the effort to amend untimely. Plaintiffs did not appeal this denial in their earlier appeal. This case concerned whether Plaintiffs may now maintain an independent suit for the ch. 93A claims against Trail King. The district court dismissed the claims with prejudice, finding that the doctrine of claim preclusion applied. Plaintiffs appealed, arguing that ch. 93A, 9(8) provides an exception to the normal rules of res judicata. The First Circuit affirmed, holding that under the facts of this case, Plaintiffs may not now bring this ch. 93A claim because of the failure to appeal from the denial of the motion to amend. View "Hatch v. Trail King Indus., Inc." on Justia Law