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

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

In this breach of contract case, defendant DHL Express (USA), Inc. ("DHL") appealed from a judgment on the pleadings for plaintiff C.A. Acquisition Newco LLC ("Newco"). The district court concluded that DHL had terminated the contract and awarded the $50,000 per month provided for in the contract in the event of a "termination." In total, the court entered final judgment for Newco in the amount of $413,333 plus interest. The First Circuit Court of Appeals vacated the judgment of the district court, holding that the contract was ambiguous as to whether DHL's actions constituted a termination under the contract. Remanded. View "C. A. Acquisition Newco, LLC v. DHL Express (USA), Inc." on Justia Law

A pipeline owner and a natural gas supplier entered into a contract for the transportation of the supplier's natural gas. The parties later became embroiled in a dispute and submitted their dispute to binding arbitration. After the arbitrators issued a decision largely favorable to the supplier, the pipeline owner sought to vacate the decision in the district court. The district court entered judgment in favor of the supplier. The First Circuit Court of Appeals affirmed, holding (1) the arbitration panel's decision to make the pipeline owner by for the lateral costs was not in manifest disregard of the law; and (2) the panel did not compromise on the matter of the destination-end heating costs, which it imposed on the supplier for the future but declined to make the ruling retroactive; and (3) even assuming that the arbitrators committed misconduct by considering in their decision two documents among the three that the panel attached to its written decision, the misconduct could not have been prejudicial. View "Bangor Gas Co., LLC v. H.Q. Energy Servs. (U.S.) Inc." on Justia Law

Milford-Bennington Railroad Company, Inc. (MBR) appealed an award of summary judgment to Pan Am Railways, Inc., Boston and Maine Corporation, and Springfield Terminal Railway Company (collectively, "Pan Am") in a dispute arising from Pan Am's actions under a contract to provide MBR with access to Pan Am's railroad tracks. The district court held that Pan Am did not breach its duty of good faith and fair dealing when it exercised its contractual right to exclude an MBR employee from its trackage for violating a safety rule. The First Circuit Court of Appeals affirmed, holding that even if Pan Am was bound by a duty of good faith and fair dealing when exercising its right to exclude the employee from its trackage, Pan Am did not breach that duty. View "Milford-Bennington R.R. Co. v. Pan Am Rys., Inc." on Justia Law

Appellant Loan Modification Group, Inc. (LMG) appealed from a jury verdict awarding $414,000 in damages against LMG for breach of partnership duties and responsibilities owed to Appellee, Lisa Reed. The First Circuit Court of Appeals affirmed, holding (1) the jury was entitled to find that although Reed and LMG's partnership was formed in anticipation of and carried out in accordance with the Home Affordable Modification Program (HAMP), it could be fully performed within one year and need not last for the entire four-year duration of HAMP, and thus, the jury could have reasonably rejected application of the Statute of Frauds; (2) the evidence supported the jury's finding that a partnership existed, whether based on an express oral partnership agreement or on an implied partnership agreement; (3) having found that the partnership was never terminated and that LMG breached its fiduciary duties, the jury's damages award was proper; and (4) there was adequate evidentiary support to sustain the jury's damages award. View "Loan Modification Group, Inc. v. Reed" on Justia Law

Appellant was among a number of homeowners in multiple states claiming that their mortgage companies wrongfully demanded an increase in flood insurance coverage to levels beyond the amounts required by their mortgages. In this case, the First Circuit Court of Appeals concluded that the pertinent mortgage provision explicitly gave the lender discretion to prescribe the amount of flood insurance. However, the Court held that the district court dismissal of Appellant's complaint must be vacated, as (1) a supplemental document given to Appellant at her real estate closing entitled "Flood Insurance Notification" reasonably may be read to state that the mandatory amount of flood insurance imposed at that time would remain unchanged for the duration of the mortgage; and (2) given the ambiguity as to the Lender's authority to increase the coverage requirement, Appellant was entitled to proceed with her breach of contract and related claims. View "Lass v. Bank of America, N.A." on Justia Law

This putative class action was one of a number of breach-of-contract suits being brought against financial institutions nationwide by mortgagors who claimed that they were improperly forced to increase flood insurance coverage on their properties. The plaintiff in this case asserted that Bank of America's demand that he increase his flood coverage by $46,000 breached both the terms of his mortgage contract and the contract's implied covenant of good faith and fair dealing. The district court concluded that the pertinent provision of the mortgage unambiguously permitted the lender to require the increased flood coverage and, hence, it granted the defendants' motion to dismiss the complaint. The First Circuit Court of Appeals vacated the judgment of dismissal in favor of the Bank, holding that the mortgage was reasonably susceptible to an understanding that supported the plaintiff's breach of contract and implied covenant claims. Remanded. View "Kolbe v. BAC Home Loans Servicing, LP" on Justia Law

Plaintiff, a resident of Massachusetts, challenged the district court's grant of summary judgment dismissing claims she brought in November 2009 against the Cadle Company and its corporate sibling CadleRock Joint Venture II for unlawful debt collection under Massachusetts law. In November 2005 Plaintiff entered into a settlement with Defendants and furnished a release. Because the release was valid, at issue was whether, given the release of past claims, anything that occurred in or after November 2005 restored or gave rise to a claim by Plaintiff. The First Circuit Court of Appeals affirmed, concluding that because Plaintiff was essentially attacking Defendants' pre-release conduct in the present lawsuit, Plaintiff's claims, which ultimately depended on the wrongfulness of the original debt collection efforts, were without merit. View "Pilalas v. The Cadle Co." on Justia Law