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

At 4 a.m. one night, Plaintiff broke into his estranged wife’s apartment to talk about their relationship. The woman reported the break-in and provided a description of the car Plaintiff was driving. Defendant, a police officer, began to follow Plaintiff. The pursuit led to a tussle, which led to Defendant firing two shots in Plaintiff’s direction. Plaintiff later filed suit against Defendant, alleging that Defendant had violated his Fourth Amendment rights and committed common law assault. The district court awarded summary judgment to Defendant on the grounds of qualified immunity and discretion act immunity. The Supreme Court affirmed, holding that Defendant was entitled to qualified immunity. View "Mitchell v. Miller" on Justia Law

In two separate murder trials in Puerto Rico’s courts, jurors convicted a group of individuals based in large part on the testimony of a single witness. When that witness later recanted her testimony, the Commonwealth courts vacated the convictions and dropped the charges against the convicted individuals. Thereafter, the wrongfully convicted individuals (and/or their heirs and family members) filed these consolidated civil damages actions against police officers and prosecutors involved in their prosecutions, asserting claims under 42 U.S.C. 1983 and various constitutional and tort claims under Puerto Rico law. Defendants moved for summary judgment based on absolute or qualified immunities. The district court rejected the defenses. The First Circuit (1) reversed in part the denial of summary judgment for the assistant district attorney, holding that absolute immunity shielded the assistant district attorney from having to stand trial for Plaintiffs’ malicious prosecution and conspiracy claims under section 1983; and (2) otherwise affirmed the district court’s denial of summary judgment, holding that, to the extent the appeal was predicated on Defendants’ qualified immunity defense under federal or state law, Defendants’ claims were waived for inadequate briefing. View "Diaz-Colon v. Solivan-Solivan" on Justia Law

Plaintiffs, a New York resident and her boyfriend, were both employed by the United States Department of Homeland Security (DHS). Following an encounter between Plaintiffs and Defendant, a local police chief, Defendant called DHS to complain about Plaintiffs’ behavior during the incident. As a result of the telephone call, DHS launched investigations into Plaintiffs’ conduct. Ultimately, DHS took no action against either plaintiff. Plaintiffs subsequently filed suit in district court, alleging, among other claims, slander and libel, malicious falsehood, and interference with advantageous business relations (IABR). The district court dismissed all of Plaintiffs’ claims butter the slander and IABR claims. The court then granted summary judgment to Defendant on the two remaining counts. The First Circuit affirmed the district court’s grant of summary judgment to Defendant, holding that the statements concerning Plaintiffs’ conduct during the encounter constituted non-actionable opinions where Defendant fully disclosed the non-defamatory facts undergirding his opinion. View "Piccone v. Bartels" on Justia Law

The parties in this case were two law firms that disputed how to split attorneys’ fees due them as a result of their mutual clients’ recovery (Plaintiffs) in the personal injury lawsuit that gave rise to this action. The district court awarded a forty percent share to Appellant’s firm. Appellant appealed, asking the First Circuit to reapportion the fees. The First Circuit affirmed, holding that the district court (1) had ancillary jurisdiction over the attorneys’ fees dispute; (2) did not err in finding that Appellant was not credible and intended to mislead the court; (3) did not abuse its discretion in determining the relative value of Appellant’s legal services; and (4) did not violate the prohibition on ex parte communications of the Code of Conduct for United States Judges by communicating ex parte with Plaintiffs in order to resolve a dispute about which lawyer represented them. View "Law Offices of David Efron v. Matthews & Fullmer Law Firm" on Justia Law

Home Orthopedics Corp. was a medical equipment supplier based in Puerto Rico. Raul Rodriguez, the president of another home medical supplier in Puerto Rico, attempted to collect a consulting fee Home Orthopedics agreed to pay him. Home Orthopedics refused to continue paying the fee when it discovered that the contract upon which it was based was fraudulent. Soon companies in the health insurance field started terminating their contracts with Home Orthopedics. Home Orthopedics filed an amended complaint seeking relief against numerous defendants - some of whom worked with Rodriguez and others of whom worked for the companies that terminated their contacts with Home Orthopedics - for violating, among other laws, the Racketeer Influenced and Corrupt Organizations Act (RICO). Specifically, Home Orthopedics alleged that Defendants conspired to help Rodriguez strong-arm more money from Home Orthopedics. The district court dismissed Home Orthopedics’ claims. The First Circuit affirmed, holding (1) Home Orthopedics failed to sufficiently allege a “pattern of racketeering activity” necessary to sustain its RICO claim; and (2) the district court did not err in denying Home Orthopedics’ motion to conduct limited discovery and then to amend its complaint for a second time. View "Home Orthopedics Corp. v. Rodriguez" on Justia Law

Plaintiff obtained a $23 million judgment against a Corporation. Plaintiff sought to secure payment on that judgment by filing suit in federal district court against the Corporation’s president and its corporate parent, alleging that Defendants had looted the Corporation of more than $18 million in assets in order to render it judgment-proof. After Plaintiff learned that one of the Corporation’s corporate parents planned to merge with an Austrian subsidiary, the district court issued a temporary restraining order, later converted into a preliminary injunction, barring the merger. Defendants nevertheless effected the merger. The district court issued civil contempt sanctions on Defendants for violating the court’s preliminary injunction order. Plaintiff subsequently moved for default judgment based on Defendants’ assertion that they had no intention of complying with the contempt order. The district court entered judgment for Plaintiff and awarded $75 million to Plaintiff. The First Circuit affirmed, holding (1) the district court properly exercised personal jurisdiction over Defendants; (2) Plaintiff’s complaint adequately stated valid causes of action for, inter alia, tortious interference with contractual relations and veil piercing; (3) the district court did not abuse its discretion in entering default judgment as a sanction for Defendants’ discovery violations; and (4) the district court did not err when it entered a damage award without an evidentiary hearing. View "AngioDynamics, Inc. v. Biolitec AG" on Justia Law

T&N Limited (T&N), an asbestos manufacturer, chose to address the liability it faced after the deadly qualities of asbestos were discovered through a Chapter 11 bankruptcy reorganization plan (the Plan). Then Plan transferred to a Trust certain of T&N’s assets and rights, with which the Trust was to pay asbestos claims brought by persons who could have sued T&N but for T&N's bankruptcy. The Plan provided that T&N’s asbestos liability would continue after plan confirmation and that the Trust would bring asbestos suits against T&N as the agent of the actual claimants. In this lawsuit, the Trust brought an asbestos claim that had accrued a decade earlier. The district court dismissed the Trust’s suit on statute of limitations grounds, thus rejecting the Trust’s argument that it was allowed to bring asbestos claims that had not become stale prior to T&N’s filing for bankruptcy protection whenever it wished to do so. The First Circuit affirmed, holding that the Trust’s argument failed because the Plan unambiguously terminated the automatic stay and contained no provision that provided for any further tolling of the limitations period beyond that granted by the Bankruptcy Code. View "Barraford v. T&N Ltd." on Justia Law

Plaintiff, a town official for the town of Raymond, claimed that Michael Reynolds, a fellow town official, told the sheriff’s department that Plaintiff had driven while intoxicated, that the reports were false, and the false statements damaged his reputation. Plaintiff brought suit in state superior court, alleging state law claims for defamation and false light invasion of privacy, as well as federal claims under 42 U.S.C. 1983. The case was removed to federal court on the basis of the federal claims. The district court dismissed the federal claims and proceeded to resolve the state law claims. The First Circuit (1) affirmed the dismissal of the federal claim; and (2) vacated the dismissal of Plaintiff’s state law claims as to Reynolds and remanded the claims to state court, holding the state law claims involved resolution of a potential conflict between Maine’s Anti-SLAPP statute and Maine’s Constitution, a conflict that “is best resolved by the Maine courts.” View "Desjardins v. Willard" on Justia Law

A package was shipped from a FedEx location in Eureka, California to an address in Plymouth, Massachusetts. The printed address label inadvertently showed an incorrect address, that address being Plaintiff’s address. When the package was delivered, Plaintiff and her eleven-year-old daughter opened the package to find two bags of marijuana. Plaintiff alerted the police. That same day, a man came to Plaintiff’s door asking whether Plaintiff had received a package. As a result of these events, Plaintiff and her minor daughters suffered fear and anxiety. Plaintiff, on her own behalf and on behalf of her minor children, sued FedEx, alleging invasion of privacy, infliction of emotional distress, and negligence. Specifically, Plaintiff claimed that FedEx mislabeled and misdelivered the package and that FedEx disclosed Plaintiff’s address to third parties. The case was removed to federal district court. The court granted summary judgment for FedEx, concluding that Plaintiff’s claims were preempted by the Airline Deregulation Act (ADA). The First Circuit affirmed, holding that Plaintiff’s three common-law claims were barred by the preemption provision of the ADA. View "Tobin v. Fedex Corp." on Justia Law

This appeal concerned a commercial dispute between business rivals. Ira Green, Inc. (Green) sued Military Sales & Service Co. (MilSal) in federal district court, alleging tortious interference and defamation. After an eight-day jury trial, the district court entered a final judgment for MilSal on all the tried counts. The district court denied Green’s motion for a new trial and taxed costs in favor of MilSal. Green appealed, asserting that a new trial was necessary because of a serious of legal errors, including error in the trial court’s failure to poll the jury despite Green’s request for such a poll. The First Circuit affirmed, holding (1) Green waived its request for a jury poll due to its failure to act reasonably to preserve its rights, and even if the jury-poll request was merely forfeited, the poll’s omission cannot be said to have affected Green’s substantial rights; and (2) upon consideration of the remainder of Green’s claims, there was no reversible error. View "Ira Green, Inc. v. Military Sales & Serv. Co." on Justia Law