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

LimoLiner Inc. contracted with Dattco, Inc. to repair a luxury motor coach that LimoLiner owned. LimoLiner later filed this action in Massachusetts state court alleging breach of contract, misrepresentation, negligence, replevin, and violation of 940 C.M.R. 5.05, a Massachusetts regulation. Dattco removed the case to federal district court. The magistrate judge found that Dattco breached the repair contract by failing to do all of the work that LimoLiner had requested. The judge also ruled for Dattco on all of LimoLiner’s other claims, awarding LimoLiner a total of $25,123 in damages. LimoLiner appealed, arguing, among other things, that the magistrate judge erred in ruling that Dattco may not be held liable under 940 C.M.R. 5.05 for certain actions and omissions that occurred on the job. The First Circuit certified a question concerning 940 C.M.R.’s intended scope to the Supreme Judicial Court of Massachusetts and thus did not decide the merits of LimoLiner’s regulatory claims. The Court otherwise affirmed, holding that the magistrate judge did not err in concluding that Dattco did not breach the parties’ oral contract to make the repairs in a timely manner and owed damages only for the loss of use of the vehicle for one limited period of time. View "Limoliner, Inc. v. Dattco, Inc." on Justia Law

Plaintiffs filed a second amended complaint against Defendant, a medical doctor, alleging claims based on medical negligence, Defendant’s failure to obtain informed consent, and battery. The district court granted summary judgment in favor of Defendant as to the medical battery claim. After a trial as to Plaintiffs’ informed consent claim, the jury returned a verdict for Defendant. The First Circuit affirmed in part and vacated and remanded in part, holding (1) the district court properly dismissed Plaintiffs’ battery claim; but (2) the district court erred by excluding expert testimony that a fine-needle aspiration biopsy was a viable non-surgical alternative to a surgical biopsy. View "Bradley v. Sugarbaker" on Justia Law

Defendant, a company that provides skycap services to airlines, was defending against a class action lawsuit when Plaintiff, one of the skycaps that Defendant had employed, brought an individual suit against Defendant, alleging unlawful termination. Specifically, Plaintiff alleged that Defendant fired him for his role in helping to organize the class action. A jury rendered a verdict in favor of Plaintiff, and the district court awarded damages and attorney’s fees and costs. Both parties appealed. The First Circuit (1) affirmed the verdict in favor of Plaintiff and the awarded of damages and attorney’s fees; (2) affirmed the district court’s decisions not to treble the emotional-distress damages award that the district court had ordered on remittitur and not to grant prejudgment interest on the emotional-distress damages; but (3) vacated the district court’s elimination of front-pay damages. Remanded. View "Travers v. Flight Services & Systems, Inc." on Justia Law

These interlocutory appeals were from a district court order that, inter alia, compelled a law firm (Mintz Levin) to produce documents relating to a fraud allegedly committed by David Gorski in his operation of Legion Construction, Inc. in order to qualify for and obtain government contracts. Gorski and Legion appealed the portion of the order that required attorney-client privileged documents connected with Mintz Levin’s representation of Legion to be produced under the crime-fraud exception. The government cross-appealed the portion of the district court decision to exclude communications between Gorski and his personal attorney from the production order. The First Circuit (1) dismissed Gorski’s appeal for want of appellate jurisdiction, holding that the Court did not have jurisdiction over Gorski’s appeal but did have jurisdiction over Legion’s appeal and the government’s cross-appeal; (2) affirmed the production order as to Mintz Levin, holding that a prima facie case for the crime-fraud exception had been made; and (3) vacated the district court’s decision to exclude Gorski’s communications with his personal attorney from the production order, holding that the district court employed incorrect legal reasoning with regard to these documents. View "United States v. Gorski" on Justia Law

Plaintiff filed this lawsuit against two Town of Wareham police officers, the police chief, and the Town, claiming (1) the officers arrested him without probable cause and used excessive force in pushing him into a police vehicle while trying to disperse an unruly crowd, and (2) the police chief and Town were liable because they had known of, or recklessly disregarded, prior false arrests and use of excessive force by the arresting officers and other officers in the police department. The district court bifurcated the trial, requiring Plaintiff to first try his claims against the individual officers. The jury returned a verdict in favor of the officers, and thereafter, the district court dismissed the claims against the Town and its police chief. The First Circuit affirmed, holding that the trial court did not err (1) in excluding all prior complaints against one of the officers and in bifurcating the trial; (2) in denying Plaintiff’s motion for a new trial; and (3) in denying Plaintiff’s motion for leave to amend his complaint three years after he filed his initial complaint. View "Lund v. Henderson" on Justia Law

Plaintiffs - Springfield Terminal Railway Co., Pan Am Systems, Inc., and David Fink, the former President and CEO of Pan Am, the parental corporation of Springfield - sued Defendants - several media defendants - in diversity, alleging defamation. Specifically, Plaintiffs alleged that certain published articles discussing a train derailment on a Springfield-owned line contained false and defamatory statements. The trial judge granted Defendants’ motion for summary judgment, concluding that none of the offending statements were actionable in defamation. The First Circuit (1) reversed as to comments claiming that Springfield ‘loses’ cars on a consistent basis, as the comments were capable of defamatory readings and were provably false; and (2) otherwise affirmed, holding that summary judgment was properly granted on the remaining disputed passages in the offending articles. View "Pan Am Systems, Inc. v. Hardenbergh" on Justia Law

Plaintiff was admitted to Harvard Combined Orthopedics Residency Program, one of the country’s most prestigious orthopedic residency programs. Mid-way through the fourth year of her residency, Plaintiff was placed on academic probation based on what Plaintiff suspected was gender bias. When Plaintiff challenged the decision internally, she alleged she was subjected to further discrimination and retaliation. Plaintiff sued several Defendants in federal district court, asserting state-law claims of unlawful discrimination and retaliation and common-law claims of tortious interference with advantageous business relations. After a trial, the jury returned an across-the-board verdict for Defendants, finding that Defendants’ conduct did not cross the border into unlawful discrimination and retaliation. The First Circuit affirmed, holding that no reversible error occurred regarding the calibration of the statute of limitations, the trial judge’s failure to recuse herself, the trial court’s evidentiary rulings, and the court’s instructions to the jury. View "Shervin v. Partners Healthcare System, Inc." on Justia Law

Relator filed a qui tam action on behalf of the United States, twenty-five states, and the District of Columbia, naming his former employer as the defendant and asserting several claims under the False Claims Act (FCA) and analogous state statutes. Thereafter, Relator filed three amended complaints adding five defendants. Defendants filed motions to dismiss. Relator subsequently filed a fourth amended complaint, asserting that he had an absolute right to amend his complaint under Fed. R. Civ. P. 15(a)(1). The district court granted Defendants’ motion to strike the fourth amended complaint after construing Relator’s filings as a request for leave to amend, concluding that Relator had not established good cause for amending his complaint once again. The district court then dismissed the case with prejudice, concluding that the FCA’s public disclosure bar deprived it of jurisdiction over certain allegations and that, as to the remaining allegations, the third amended complaint failed to state a cognizable claim. The First Circuit vacated the judgment below and remanded, holding that the district court (1) did not err in concluding that Relator exhausted his one-time right to amend under Rule 15(a)(1); but (2) appraised Relator’s request for leave to amend under the wrong legal standard. View "D'Agostino v. ev3, Inc." on Justia Law

In 2012, Plaintiff filed suit seeking money damages against the United States under the Federal Tort Claims Act, alleging that, in 1998-1999, he was wrongfully detained and deported as an unauthorized alien despite his true status as a United States citizen. The district court granted the government’s motion to dismiss the case as time barred, thus rejecting Plaintiff’s claim that the federal discovery rule applied in his case to preclude dismissal. The First Circuit affirmed on statute of limitations grounds, holding that delayed accrual under the discovery rule was foreclosed by the factual allegations in Plaintiff’s complaint. View "Dominguez v. United States" on Justia Law

Homeowners hired Benchmark Construction Services, Inc. to renovate their Massachusetts home. The homeowners hired an architect to design the renovation plans, and the architect hired a decorative painter to apply decorative painting to the interior walls. The painter's employee, Meghan Bailey, was assigned to the task. While Bailey was applying the decorative paint, she fell from a ladder and was injured. Bailey sued Benchmark, alleging negligence. Benchmark sought a defense from its insurer, United States Liability Insurance Company’s (ULSIC). USLIC determined that Bailey’s claims were not covered under Benchmark’s insurance policy and, therefore, USLIC had no duty to defend or indemnify Benchmark against those claims. USLIC then filed a declaratory judgment action to establish that the insurance policy did not provide coverage for Bailey’s claims and that, consequently, USLIC had no duty to defend or indemnify Benchmark against those claims. The district court entered judgment for USLIC, holding that the policy excluded Bailey’s claims. The First Circuit reversed, holding that Bailey’s claims fell within the bounds of insurance coverage, and therefore, USLIC had a duty to defend and indemnify Benchmark in the underlying negligence suit. View "U.S. Liability Ins. Co. v. Benchmark Constr. Servs., Inc." on Justia Law