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

The First Circuit reversed the decision of the district court refusing to enforce arbitration clauses in the employment agreement between New York Life Insurance Company and Ketler Bosse, which expressly required that any disputes about arbitrability be referred to the arbitrator, holding that the district court abused its discretion.After New York Life terminated its business relationship with him Bosse brought this action alleging race discrimination in violation of 42 U.S.C. 1981 and 1985 and other state law claims. New York Life asked the court to compel arbitration and stay or dismiss the lawsuit, but the district court refused. The First Circuit reversed, holding (1) the district court's analysis contravened the Supreme Court's holdings in Henry Schein, Inc. v. Archer & White Sales, Inc., 139 S. Ct. 524 (2019), First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (1995) and other cases; and (2) the arbitration clause was clear, unmistakable, and unambiguous and should have been enforced on those terms. View "Bosse v. New York Life Insurance Co." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing the claims in Plaintiffs' complaint against WM Capital Management, Inc. and granting summary judgment in favor of WM Capital on its counterclaim, holding that the district court did not err or abuse its discretion.This case arose from a dispute over the enforcement of a contract that controlled the liquidation and assignment of several mortgage notes. Plaintiffs initiated an action against WM Capital bringing claims for redemption of property and breach of contract. WM Capital filed a counterclaim seeking specific performance of the contract and joinder of Tenerife Real Estate Holdings, LLC, a signatory to the contract at issue. The district court joined Tenerife, dismissed Plaintiffs' complaint, and granted summary judgment for WM Capital on its counterclaim. The First Circuit affirmed, holding that the district court did not err. View "Almeida-Leon v. WM Capital Management, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting Handy Technologies, Inc.'s motion to dismiss this putative class action and to compel individual arbitration, holding that the district court did not err in dismissing Maisha Emmanuel's suit.Emmanuel, who worked as a cleaner for Handy Technologies, Inc., brought this complaint on behalf of individuals who had worked for Handy as cleaners, alleging that Handy had misclassified the putative class members as independent contractors rather than employees, in violation of the Fair Labor Standards Act and Mass. Gen. Laws ch. 151, 1. Handy moved to dismiss and compel arbitration, arguing that the Independent Contractor Agreement that Emmanuel signed required arbitration of the claims at issue. The district court granted Handy's motion to compel arbitration and dismissed Emmanuel's putative class action claim. The First Circuit affirmed, holding (1) the district court did not err in ruling that, under Massachusetts law, Emmanuel had entered into an agreement to arbitrate; and (2) Emmanuel's unconscionability-based challenged to the ruling below failed. View "Emmanuel v. Handy Technologies, Inc." on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Insurer and dismissing Insureds' suit seeking to force Insurer to pay for damages Hurricane Maria inflicted on their property, holding that Insureds' claims on appeal failed.Hurricane Maria struck Puerto Rico on September 20, 2017. Insureds brought this suit on January 9, 2019. In granting summary judgment in favor of Insurer, the district court concluded that this suit was time-barred under the terms of the insurance contract. Under Puerto Rico law, prescription of actions is interrupted by their institution before the courts, by extrajudicial claim of the creditor, and by act of acknowledgement of the debt by the debtor. The First Circuit affirmed, holding (1) the district court did not err by crediting Insurer's declarations but not Insureds' declarations; (2) Insureds' claims lacked the specificity required to meet their burden of proving prescription; and (3) the remainder of Insureds' claims on appeal were barred. View "Marcano-Martinez v. Cooperative de Seguros Multiples de Puerto Rico" on Justia Law

In this contract dispute under Massachusetts law between Dahua Technology USA Inc. and Feng Zhang, Dahua's former employee, the First Circuit vacated the district court's grant of summary judgment in favor of Dahua, holding that there were material facts in dispute.Dahua filed a complaint against Zhang seeking a declaratory judgment that a 2017 agreement between the parties was unenforceable and asked the court to reform it due to mutual mistake. Dahua further sought damages for breaching the parties' contact's implied covenant of good faith and fair dealing. Zhang filed a counterclaim alleging that Dahua breached a second 2017 contract. The district court granted summary judgment in favor of Dahua and denied Zhang's motion for summary judgment. The First Circuit vacated the summary judgment, holding that there were at least there triable issues of fact on the record precluding summary judgment. View "Dahua Technology USA, Inc. v. Zhang" on Justia Law

In this dispute between a boat owner and his insurance company, the First Circuit affirmed the judgment of the district court in favor of the insurer, holding that the district court properly applied the doctrine of uberrimae fidei in this case.When Defendant applied for an insurance policy for his yacht from an entity later acquired by Plaintiff he failed to disclose that he had grounded a forty-foot yacht in Puerto Rico. Plaintiff later sought a declaratory judgment voiding the policy on the grounds that Defendant had failed to honor his duty of utmost good faith, known as uberrimae fidei in maritime law, in acquiring the policy and had therefore breached the warranty of truthfulness contained in the policy. The district court concluded that Plaintiff was entitled to void the policy. The First Circuit affirmed, holding that the district court correctly concluded that the uberrimae fidei doctrine entitled Plaintiff to a declaration that the policy was void. View "QBE Seguros v. Morales-Vazquez" on Justia Law

In this insurance dispute, the First Circuit affirmed the district court's grant of summary judgment to Ameriprise Auto & Home Insurance, holding that the arguments on appeal brought by Government Employees Insurance Company (GEICO) were unavailing.An accident that occurred in Florida damaged a Toyota Highlander insured by Ameriprise and a Lamborghini insured by GEICO and injured the driver of the Highlander. Ameriprise rescinded coverage, alleging that its insureds breached their obligations under the policy. Ameriprise brought this suit seeking declaratory relief in federal district court to approve the company's rescission and to confirm that Ameriprise had satisfied its compulsory coverage requirements under Massachusetts law. The district court granted summary judgment in favor of Ameriprise. The First Circuit affirmed, holding (1) the district court did not err in finding that Ameriprise could rescind the insureds' coverage as a matter of law because the insureds' misrepresentation of certain information breached the insureds' duty to inform Ameriprise about about dates to the Highlander's principal place of garaging and customary drivers; and (2) Ameriprise was not estopped from rescinding the insureds' coverage, and GEICO's waiver arguments failed as a matter of law. View "IDS Property Casualty Insurance Co. v. Government Employees Insurance Co." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's disability discrimination suit against the United States Patent and Trademark Office and its director, holding that the district court did not err.The district court dismissed the action on the grounds that Plaintiff waived his discrimination claim in a settlement agreement that allowed him to resign from his job instead of being terminated. On appeal, Plaintiff argued that the district court erred in finding that his allegation of an unenforceable waiver was implausible. Specifically, Plaintiff argued that the agreement was void because he did not knowingly and voluntarily agree to it. The First Circuit disagreed, holding that the district court properly concluded that the waiver was binding. View "Perez-Tolentino v. Iancu" on Justia Law

The First Circuit reversed the order of the district court granting summary judgment in favor of General Star Indemnity Company, the excess insurer of Performance Trans., Inc. and Utica Mutual Insurance Company (collectively PTI) in this Massachusetts breach of contract and unfair and deceptive insurance practices action under Mass. Gen. Laws ch. 93A, 11, holding that the district court erred in finding the relevant excess policy provisions unambiguously excluded coverage.In 2019, a PTI tanker-truck spilled approximately 4,300 gallons of gasoline, diesel fuel, and dyed diesel fuel onto the roadway and into a nearby reservoir. After cleanup costs exceeded PTI's primary insurance limit, PTI made a claim with General Star under the excess liability policy. General Star disclaimed any coverage obligation. When this suit was brought, the district court granted summary judgment in favor of General Star on the breach of contract claim and dismissed the chapter 93A, section 11 claim with prejudice. The First Circuit reversed, holding (1) the excess policy was ambiguous; and (2) because ambiguity in the policy must be construed in favor of the insured, coverage was available to PTI. View "Performance Trans., Inc. v. General Star Indemnity Co." on Justia Law

In this contract dispute between Landlord and Tenant that arose under their lease to a shopping center premises the First Circuit affirmed the judgment of the district court granting summary judgment to Tenant on one claim and to Landlord on another claim, holding that any purported errors were harmless.When Tenant sought mortgage loan from Bank and offered its leasehold interest in the premises as collateral, Bank requested that Landlord execute a "section 3(n) agreement" pursuant to article 6, section 3(n) of the lease. Landlord did not sign the agreement. Bank then terminated the proposed mortgage loan. Tenant sued Landlord for breach of contract. Landlord countersued, claiming that Tenant had violated the lease through its subtenant's use of a pylon sign on the premises. The district court granted summary judgment to Tenant on Landlord's counterclaim. After a trial, the court found that Landlord had no obligation to execute the section 3(n) agreement. The First Circuit affirmed, holding (1) the district court did not clearly err in finding that Landlord did not breach the lease by not signing the section 3(n) agreements proposed by Bank; and (2) the district court did not err in ruling on summary judgment that Tenant's subtenant's use of the pylon sign did not breach the lease. View "58 Swansea Mall Drive LLC v. Gator Swansea Property LLC" on Justia Law