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

The First Circuit reversed the order of the district court dismissing Plaintiffs' breach of contract claim against Wilmington Savings Fund Society, FSB and otherwise affirmed the district court order dismissing Plaintiffs' complaint against Wilmington Savings and Selene Finance LP, holding that the district court erred in part.Plaintiffs filed a complaint seeking a declaratory judgment that Defendants breached the parties' mortgage contract by selling their property through a non-judicial foreclosure, thus rendering the foreclosure void. Specifically, Plaintiffs alleged that the foreclosure and sale were conducted without providing adequate notice, as required by the mortgage contract. The district court granted Defendants' motion to dismiss. The First Circuit reversed in part, holding (1) Plaintiffs stated a claim that the notice of default failed strictly to comply with the requirements of the mortgage contract, and therefore, dismissal of their claim against Wilmington Savings was improper; and (2) as to the remaining claims, dismissal was proper. View "Aubee v. Selene Finance LP" on Justia Law

The First Circuit reversed in part the judgment of the district court dismissing Plaintiff's complaint against Stonehill College for breach of contract, sex discrimination in violation of Title IX, negligence, and defamation, holding that the district court erred in dismissing Plaintiff's breach of contract claim.Plaintiff brought this complaint after he was expelled for violating Stonehill College's sexual misconduct policy by engaging in "nonconsensual sexual intercourse," alleging that the disciplinary process in his case was unfair and biased. The district court dismissed the complaint under Fed. R. Civ. P. 12(b)(6). The Supreme Court reversed the dismissal of the breach of contract claim and otherwise affirmed, holding (1) Plaintiff stated a breach of contract claim under both theories available to him under Massachusetts law; and (2) Plaintiff's remaining claims failed to state a claim. View "Doe v. Stonehill College, Inc." on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court granting Evenflo Company Inc.'s motion to dismiss this amended class action complaint brought by forty-three plaintiffs from twenty-eight states alleging that certain representations made by Evenflo were false or misleading, holding that Plaintiffs' pleadings plausibly demonstrated their standing to seek monetary relief.Plaintiffs alleged that Evenflo made several misrepresentations about the safety and testing of its children's Big Kid car booster seat and that Plaintiffs purchased the seat relying on the misrepresentations and that, but for the misrepresentations, Plaintiffs would not have purchased the seat or would have paid less for it. Plaintiffs sought both monetary relief and declaratory and injunctive relief. The district court concluded that Plaintiffs lacked standing to bring their complaint and granted Evenflo's motion to dismiss. The Supreme Court remanded the case for further proceedings, holding (1) Plaintiffs had standing to pursue monetary relief; and (2) Plaintiffs lacked standing to seek declaratory and injunctive relief. View "In re Evenflo Company, Inc. v. Xavier" on Justia Law

The First Circuit affirmed the conclusion of the district court conclusion that the insurance policy issued by Motorists Commercial Mutual Insurance Company to the dealership that owned a motor vehicle that killed and injured several people did cover the accident at issue in this case, holding that the district court did not err.This dispute arose from an auction at which a motor vehicle being displayed for bidding suddenly accelerated into a group of auction attendees, killing five people and injuring several more. Motorists brought this action seeking a declaration that its policies did not provide coverage for the victims' claims against the auctioneer or its employee who was behind the wheel of the vehicle when it struck the victims. The district court granted summary judgment for Motorists. The First Circuit affirmed, holding that the policies at issue did not provide coverage for the accident. View "Motorists Commercial Mutual Insurance Co. v. Hartwell" on Justia Law

The First Circuit reversed the ruling of the district court granting summary judgment in favor of a general liability insurer (Insurer) and dismissing Insured's complaint seeking full coverage of its defense when the company faced a trade secrets lawsuit brought by a competitor, holding that Insured was entitled to summary judgment on the duty to defend.Insured brought this action after Insurer only paid for some of Insured's defense. Insurer counterclaimed seeking a declaratory judgment of absolution from policy coverage. During discovery, both parties moved to compel responses. A magistrate judge denied Insurer's request for information exchanged between Insured and its lawyers and then stayed discovery until it ruled on cross-motions for summary judgment. The district court then granted summary judgment for Insurer. The First Circuit held (1) the district court erred in granting summary judgment for Insurer, and Insured was entitled to summary judgment on the duty to defend; (2) on the reasonableness of the defense, the case is remanded for further proceedings; and (3) the district court correctly granted Insurer's motion to compel. View "Lionbridge Technologies, LLC v. Valley Forge Insurance Co." on Justia Law

In these consolidated appeals arising from the district court's grant of summary judgment in favor of Triangle Cayman Asset Company and Oriental Bank in a foreclosure action brought by Triangle against Appellants, who brought counterclaims against Triangle and brought in Oriental as a third party defendant, the First Circuit held that remand was required for further proceedings.While the procedural history of this case was complex, the First Circuit held, ultimately, that (1) several aspects of the appeals here as to Triangle were moot and required dismissal; (2) the district court did not err in dismissing the breach of contract and fraud counterclaims against Triangle; (3) the district court did not err in entering summary judgment in favor of Oriental; and (4) as to appeal number three, in which Appellants challenged the district court's judgments entered on January 3, 2020, the judgments were void. View "Triangle Cayman Asset Co. v. LG & AC, Corp." on Justia Law

The First Circuit affirmed the judgment of the district court appointing a receiver in an interlocutory appeal occurring during litigation between solar energy companies and the bank that funded the companies' development and expansion, holding that the district court did not abuse its discretion when it granted the bank's motion to appoint a receiver.The companies filed an amended complaint against the bank claiming that the bank breached certain contracts with the companies. The bank, in turn, initiated a federal action against the companies alleging breach of contract and other claims. The companies filed an answer and asserted several counterclaims, including claims based on the same allegations as in the other case. After consolidating the two cases the district court granted the bank's motion for the appointment of a receiver. The First Circuit affirmed, holding that the district court did not abuse its discretion when it granted the bank's motion to appoint a receiver. View "Green Earth Energy Photovoltaic Corp. v. Keybank National Ass'n" on Justia Law

The First Circuit affirmed the decision of the district court entering summary judgment in favor of Defendants on Plaintiffs' claims for breach of contract and other related causes of action, holding that the district court properly granted summary judgment in Defendants' favor.Plaintiff and Defendants negotiated the terms of a stock transfer agreement (STA) through an exchange of emails. Later, Defendants terminated the STA pursuant to the contract's termination clause, and Plaintiff sued. The district court entered summary judgment for Defendants, concluding (1) no enforceable contract had been formed, and (2) even if the STA constituted an enforceable contract, Defendants properly exercised their right of termination. The First Circuit affirmed, holding (1) Defendants' properly exercised their termination right; and (2) Plaintiffs' two alternative theories of recovery were unavailing. View "FinSight I LP v. Seaver" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Amyndas Pharmaceuticals, S.A.'s claims against Zealand Pharma A/S and vacated the dismissal of Amyndas's claims against Zealand Pharma U.S., Inc., holding that the district court erred in dismissing Amyndas's claims against Zealand Pharma U.S.When Amyndas was considering separate joint ventures with Zealand Pharma and Alexion Pharmaceuticals, Inc. it shared trade secrets before understanding that neither of the joint ventures would materialize. Zealand Pharma and Zealand US, its newly established affiliate, subsequently announced a partnership with Alexion Pharmaceuticals, Inc. Amyndas sued for misappropriation of trade secrets and other confidential information. The district court (1) dismissed Amyndas's claims against Zealand Pharma on the ground that Amyndas was required to litigate those claims in Denmark; and (2) dismissed Amyndas's claims against Zealand US for failure to state a claim. The First Circuit vacated in part and remanded the case for further proceedings, holding that the district court (1) correctly dismissed Amyndas's claims against Zealand Pharma; and (2) erred in concluding that Amyndas's claims against Zealand US were futile. View "Amyndas Pharmaceuticals, S.A. v. Zealand Pharma A/S" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Family Medicine Associates (FMA) and one of its members (together, Defendants) and dismissing this lawsuit alleging breach of contract, breach of the implied covenant of good faith and nonpayment of wages, holding that Plaintiff's claims on appeal were unavailing.Plaintiff, a licensed physician, brought this lawsuit against his former employer nearly three years after his employment relationship was terminated. In his complaint, Plaintiff alleged that Defendants' breached their oral promise of a partnership that was never committed to writing. The district court granted summary judgment in favor of Defendants on all counts. The First Circuit affirmed, holding that Plaintiff failed to put forth sufficient evidence to survive summary judgment. View "Guldseth v. Family Medicine Associates LLC" on Justia Law