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

The First Circuit affirmed the order of the district court granting partial summary judgment for Plaintiff and its subsequent judgment in Plaintiff's favor in this breach of contract case, holding that the plain language of the controlling agreement entitled Plaintiff to the retirement compensation which he claimed.Plaintiff sued Northeast Investors Trust and the trustees then in office alleging that Defendants improperly withheld his retirement compensation in violation of the parties' agreement. The district court granted partial summary judgment on Plaintiff's breach of contract claim and then entered judgment in Plaintiff's favor for the sum of $794,500. The First Circuit affirmed, holding that the plain language of the controlling agreement entitled Plaintiff to the claimed compensation. View "Minturn v. Monrad" on Justia Law

In this case concerning the regulation of gambling licenses in the Commonwealth the First Circuit reversed in part the summary judgment for Defendants and certified questions of law to the Massachusetts Supreme Judicial Court (SJC).An option contract for the purchase of land gave Encore Boston Harbor the option to purchase land from FBT Realty, LLC for $75 million should the Massachusetts Gaming Commission grant Encore a gaming license. The Commission ultimately conditioned the grant of the license on a $35 million purchase price for the sale of the land and signed certification by each member of FBT, except for Plaintiff, that they were sole members of the company. Defendants presented Plaintiff with an offer that would "make him whole" if he signed the certification in a contract. Plaintiff executed the required certification and then brought this action alleging, among other claims, breach of contract. The district court granted summary judgment for Defendants, finding no valid or enforceable contract. The First Circuit reversed in part, holding that genuine issues of material fact existed as to certain claims and that the question of whether the contract was unenforceable as contrary to state law and/or as a violation of public policy must be resolved by the SJC. View "Gattineri v. Wynn MA, LLC" on Justia Law

In this dispute over indemnification arising from an underlying negligence case, the First Circuit vacated the decision of the district court as to a contractual crossclaim for indemnification, holding that the district court erred.John Caruso was staying at the Omni Hotel in Providence, Rhode Island when he tripped and fell on a curb separating the hotel's valet from its main entrance. Caruso brought this complaint against the both the hotel's valet operator and its owner, claiming that Defendants negligently maintained the premises and had a duty to warn him of an unreasonably safe condition, causing his injuries. The hotel owner filed crossclaims against the valet in the action, seeking indemnification for its litigation costs. As to the indemnification crossclaims the district court held that Omni was not entitled to relief. The First Circuit vacated the judgment for the valet and directed the district court on remand to enter judgment for the hotel owner, holding that the district court's rejection to the hotel owner's right to contractual indemnification was premised on an incorrect view of both Rhode Island law and the language of the parties' contractual agreement. View "Omni Hotels Management Corp. v. Ultimate Parking, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court determining that this case could not be adjudicated and dismissing the suit, holding that there was no error.Plaintiff, a foreign counterterrorism corporation, brought this lawsuit seeking an order freezing some of its Massachusetts assets based on allegations that a former government official misappropriated billions of dollars from the corporation. Defendants argued that the funds were lawfully received in connection with clandestine operations that were sometimes undertaken alongside the United States government. The United States government then asserted the state secrets privilege and successfully got state secrets and other information excluded from the case. The district court dismissed the suit, concluding that it could not examine the claims and defenses or award the preliminary equitable relief sought without weighing the privileged information and risking disclosure of state secrets. The First Circuit affirmed, holding that Plaintiff failed to demonstrate that it was entitled to any of the relief it requested. View "Sakab Saudi Holding Co. v. Aljabri" on Justia Law

The First Circuit affirmed the judgment of the federal district court dismissing Plaintiff's complaint alleging contract claims against Defendant, holding that Plaintiff insufficiently pled that her claims met the amount in controversy required by 28 U.S.C. 1332(a).Plaintiff filed a complaint against Defendant in the United States District Court for the District of Rhode Island asserting diversity jurisdiction. Plaintiff asserted claims for breach of contract, breach of implied warranty, and breach of the duty of good faith and fair dealing, alleging that her claims exceeded the statutory amount-in-controversy requirement. The district court granted Defendant's motion to dismiss for lack of jurisdiction. The First Circuit affirmed, holding that Plaintiff did not meet her burden of establishing the amount in controversy required for diversity jurisdiction. View "Andersen v. Vagaro, Inc." on Justia Law

The First Circuit affirmed the judgments of the district court dismissing part of Plaintiff's putative class action for failure to state a claim and entering summary judgment disposing of the remainder of his claims, holding that there was no error in the proceedings below.In his complaint, Plaintiff argued that an increased coverage limit on his house and premium violated the terms of his contract with Amica Mutual Insurance Company and that he and other Amica insureds paid too much to insure their homes. The district court dismissed the breach of contract and implied covenant of good faith and fair dealing claims and then granted summary judgment for Amica on the unjust enrichment, money had and received, and Mass. Gen. Laws ch. 93A claims. The First Circuit affirmed, holding that there was no reversible error in the proceedings below. View "Gottlieb v. Amica Mutual Insurance Co." on Justia Law

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