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

Plaintiff worked in a luggage factory in France that was owned by Samsonite. Samsonite was controlled by an investment group led by Bain Capital, LLC. Bain wanted to shut down the factory, and to avoid paying millions of dollars in post-termination benefits to the laid-off employees of the factory, Bain and Samsonite hired a third party, HB Group, to buy the factory. In 2007, a French court ordered the judicial liquidation of the factory. Because HB Group had no resources to pay Plaintiff and her coworkers, Plaintiff commenced this putative class action in 2012 seeking to hold Bain liable for losses suffered by the factory’s workers as a result of the sale and liquidation. The district court dismissed the complaint as untimely under the relevant three-year statute of limitations. The First Circuit affirmed, holding that there was no basis to conclude that the statute of limitations was tolled in this case. View "Abdallah v. Bain Capital, LLC" on Justia Law

Plaintiff sued the United States under the Federal Tort Claims Act, alleging that personnel at the Fort Buchanan Post Exchange Store in Puerto Rico had been negligent in failing to both prevent and clean up a spill on the floor, which Plaintiff slipped on, causing her to be injured. After a bench trial, the district court entered judgment in favor of the United States based on Plaintiff’s failure to establish Defendant’s actual or constructive knowledge of the spill. The First Circuit Court of Appeals affirmed, holding that the district court correctly found that Plaintiff failed to carry her burden of making a clear and specific determination on negligence where Plaintiff did not establish that Defendant had either actual or constructive knowledge of the dangerous condition that caused her injuries. View "Calderon-Ortega v. United States" on Justia Law

Plaintiff sought insurance coverage for gastric lap band surgery. Defendant, a health-care insurer that covered Plaintiff by virtue of Plaintiff’s husband’s employment with the federal government, refused to cover the full cost of the surgery. Plaintiff brought tort and breach of contract claims against Defendant in the Puerto Rico Court of First Instance. Defendant removed the action to the federal district court, asserting, inter alia, that the Federal Employees Health Benefits Act of 1959 (FEHBA) completely preempted Plaintiff’s local-law claims, thus conferring original jurisdiction on the federal court. Defendant then moved to dismiss the case, arguing that the FEHBA demanded exhaustion of administrative remedies. Plaintiff, in the meantime, requested that the district court remand the case to the Court of First Instance. The district court (1) denied Plaintiff’s motion to remand, holding that the FEHBA completely preempted Plaintiff’s claims and, thus, federal jurisdiction attached; and (2) dismissed the action for Plaintiff’s failure to exhaust administrative remedies. The First Circuit Court of Appeals reversed the district court’s judgment of dismissal and its order denying remand, holding that the court erred in concluding that the FEHBA afforded complete preemption. View "Lopez-Munoz v. Triple-S Salud, Inc. " on Justia Law

In 2000, Plaintiff, a former scallop fisherman, was prosecuted by an enforcement arm of the National Oceanic and Atmospheric Administration (“NOAA”). The ALJ sustained all charges against Plaintiff. The district court sustained findings of liability on two charges of fishing in a prohibited area, vacated a false statement charge against Plaintiff, and remanded. On remand, Plaintiff reached a settlement with the government. In 2012, Plaintiff filed a complaint alleging that his prior prosecution by the NOAA constituted malicious prosecution and abuse of process under the Federal Tort Claims Act (“FTCA”). The district court dismissed Plaintiff’s claims. The First Circuit Court of Appeals affirmed, holding (1) the actions of federal prosecutors are immune from this type of suit under the FTCA, but there can be FTCA recovery for the actions of investigative or law enforcement officers who have committed the wrongful acts specified; and (2) Plaintiff failed to state a claim that any law enforcement officer wrongfully induced a malicious prosecution or acted to abuse process. View "Yacubian v. United States" on Justia Law

Plaintiff purchased property with a mortgage from Countrywide Home Loans, Inc. In October 2006, Plaintiff took out a loan from Countrywide to cure his breach of a divorce agreement. In December 2006, Plaintiff took out a home equity loan from Countrywide. Because Plaintiff was not able to make payments on his October 2006 loan, Countrywide foreclosed on his property. In May 2009, Plaintiff filed a complaint alleging claims of unjust enrichment, rescission/equitable relief, breach of the implied covenant of good faith and fair dealing, violations of Mass. Gen. Laws ch. 93A, and negligence. Countrywide removed the case to federal court. The district court resolved certain claims as a matter of law and, after a bench trial on the remaining claims, entered judgment in favor of Countrywide. The First Circuit Court of Appeals affirmed, holding that no grounds exited for reversing any of the district court’s decisions. View "Frappier v. Countrywide Home Loans, Inc." on Justia Law

Defendant, a citizen and resident of Puerto Rico, borrowed $700,000 from Plaintiff, a citizen and resident of Greece. Plaintiff’s loan was not evidenced by "even a single scrap of paper." The parties subsequently disputed who the borrower was, whether Caribbean Carrier Holding (Panama), Inc., as Defendant claimed, or Defendant, as Plaintiff claimed. When the parties could not agree on the identity of the borrower, Plaintiff brought a collection action against Defendant in the United States District Court for the District of Puerto Rico. The district judge ruled that Plaintiff had not sustained his burden of proof and entered judgment for Defendant. The First Circuit Court of Appeals affirmed, holding that the district judge (1) substantially complied with the requirements of Fed. R. Civ. P. 52(a)(1), and (2) applied the correct substantive law standard in adjudicating Plaintiff’s claim. View "Valsamis v. Gonzalez-Romero" on Justia Law

David Efron and his former wife, Madeleine Candelario-Del-Moral, were engaged in long-running litigation related to their high-stakes divorce. In 2006, a Puerto Rico court in which the divorce proceedings were pending issued an order attaching the funds held in Efron’s UBS Financial Services Inc. accounts. The court subsequently made a ruling that may or may not have vacated the attachment. UBS treated the attachment as void and dispersed the bulk of the funds. Candelario sued UBS in federal district court for negligently releasing the attached funds. Ultimately, at the district court’s suggestion, UBS and Candelario opted to undertake mediation. Thereafter, Efron moved to intervene as of right in the Candelario-UBS litigation. The district court denied the motion. The First Circuit Court of Appeals affirmed the denial of the motion and denied Candelario’s motion for appellate sanctions, holding (1) the Court had jurisdiction to hear and determine Efron’s interlocutory appeal; (2) the district court did not abuse its discretion in deeming Efron’s motion to intervene untimely and in refusing to grant it; and (3) although Efron’s case for intervention was weak, it was not frivolous. View "Candelario-Del-Moral v. Efron" on Justia Law

In 2002, Grand Wireless, Inc. (“Grand”) and Verizon Wireless, Inc. (“Verizon”) entered into an agreement authorizing Grand to act as a Verizon sales agent. The agreement contained an arbitration provision. In 2011, Verizon notified Grand of its intent to terminate the relationship. According to Grand’s complaint, Verizon subsequently mailed a postcard to Grand’s customers proclaiming that certain Grand stores had “closed." Erin McCahill, a Verizon employee, had allegedly authorized the mailing knowing it to be false. Grand brought this action in Massachusetts state court against Verizon and McCahill, alleging a violation of RICO against McCahill and several state law claims against McCahill and Verizon. The case was removed to the federal district court, where Defendants moved for an order compelling arbitration of Grand’s claims. Grand opposed the motion, arguing that because McCahill was not a signatory to the contract containing the arbitration clause, the claim against her could not be arbitrated. The district court denied Defendants’ motions. The First Circuit Court of Appeals reversed, holding (1) Grand’s claims were within the scope of the parties’ arbitration agreement; and (2) arbitration of the claims against McCahill was not barred despite her status as a non-signatory of the arbitration agreement. View "Grand Wireless, Inc. v. Verizon Wireless, Inc." on Justia Law

Plaintiff filed a seven-count complaint against Defendants, asserting claims related to the alleged breach of various agreements involving the sale of aviation equipment. Ultimately, a jury trial was held, and the jury awarded Plaintiff $1,112,476 in damages. After dismissing the jury, the parties filed several post-trial motions, which the district court resolved partially in favor of Plaintiff and partially in favor of Defendants. The First Circuit Court of Appeals affirmed the district court’s orders, holding that the district court did not err in (1) finding that Defendants did not breach a support agreement with Plaintiffs as a matter of law; (2) holding that Plaintiff waived the issue of prejudgment interest; and (3) upholding the jury’s award of damages for Plaintiff’s claim alleging breach of a purchase agreement. View "Atlantech Inc. v. Am. Panel Corp." on Justia Law

Michael Mahon sued the government under the Federal Tort Claims Act (FTCA) after falling from a second-story portico during a wedding reception at the Commandant’s House at the Charlestown Navy Yard in Massachusetts. Mahon later amended his complaint to add claims against Eastern National and Amelia Occasions, which contracted with the interior Department’s National Park Service to manage the House and handle the events. The district judge granted the government’s motion to dismiss for lack of subject-matter jurisdiction, concluding that the discretionary-function exception to the FTCA applied. The district judge subsequently granted Mahon’s motion for reconsideration and allowed discovery to go forward on the issue of whether the government’s relationship with Eastern National and Amelia Occasions was governed by a “concession contract,” which could have led the government to learn about the portico’s “impermissibly low railing,” thus placing the case beyond the discretionary-function exception’s reach. After discovery, the district judge dismissed the complaint for lack of subject-matter jurisdiction, concluding that, ultimately, Mahon’s case was within the ambit of the discretionary-function exception. The First Circuit Court of Appeals affirmed, holding that the FTCA’s discretionary-function exception barred Mahon’s claims against the government. View "Mahon v. United States" on Justia Law