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

Plaintiff refinanced his home mortgage and entered into a refinancing loan and mortgage agreement with IndyMac Bank, which assigned the mortgage to OneWest Bank. The mortgage was serviced by IndyMac Mortgage Services (all three services are referred to as "OneWest"). After Plaintiff fell behind on his payments, Harmon Law Offices, counsel to OneWest, informed Plaintiff that his home would be foreclosed. Fannie Mae purchased Plaintiff's house at a subsequent foreclosure sale. Eleven days later, Harmon served Plaintiff with an eviction notice. Plaintiff sued OneWest, Fannie Mae, and Harmon, asserting negligence and negligent misrepresentation and seeking an injunction against the pending eviction, an order nullifying the foreclosure, and monetary damages. The district court dismissed the complaint, concluding that the economic loss doctrine barred Plaintiff's tort claims and that the tort claims failed because Defendants had not breached any duties owed to Plaintiff. The First Circuit Court of Appeals affirmed, holding that the district court did not err in dismissing Plaintiff's claims. View "Schaefer v. IndyMac Mort. Servs." on Justia Law

Mother, an Egyptian citizen, acted in violation of a court order when she, together with her two children, boarded an EgyptAir Airlines Company flight to Cairo, Egypt. The father of the children and Mother's former husband (Father) brought this lawsuit against Mother and EgyptAir. Father claimed EgyptAir was negligent in allowing Mother to board the flight despite "red flags" suggesting she was abducting the children. The district court granted summary judgment for EgyptAir, concluding that the airline did not know of Mother's plan to abduct the children and did not owe Defendant or the children a duty to investigate the red flags. The First Circuit Court of Appeals affirmed the dismissal of Father's claims, holding (1) the district court had jurisdiction over the claims; and (2) the claims, which challenged airline ticketing, check-in, and boarding procedures, were preempted under the Airline Deregulation Act. View "Bower v. El-Nady Bower" on Justia Law

Brian Harnett worked as an account executive and salesman for Corporate Technologies, Inc. (CTI), which provided Harnett information technology solutions to sophisticated customers. When Harnett was hired, he signed an agreement that contained non-solicitation and non-disclosure provisions. Harnett later left CTI and began working for OnX USA LLC (OnX), where he participated in sales-related communications and activities with certain of his former CTI customers on behalf of OnX. CTI sued Harnett, alleging breach of contract and tortious interference with CTI's contractual rights and advantageous relationships. CTI sought a preliminary injunction restraining Harnett from doing business with certain customers, which the district court granted. The First Circuit Court of Appeals affirmed the issuance of the preliminary injunction, holding that the district court's conclusion that Harnett likely engaged in solicitation in violation of the agreement was reasonable, and therefore, the court did not err in granting injunctive relief. View "Corporate Techs., Inc. v. Harnett" on Justia Law

This case arose from a Hampton Inn & Suites renovation and construction in Rhode Island. Stonestreet Construction, as the construction manager and general contractor, entered into a construction contract with Weybosset Hotel. Because of cost overruns and other delays, Allstate Interiors & Exteriors, one of the subcontractors on the project, filed a complaint against Stonestreet. Stonestreet counterclaimed against Allstate and brought a third-party complaint against Weybosset, bringing several state law causes of action arising from the construction project. After a trial on Stonestreet's third-party complaint against Weybosset, the district court ruled in favor of Stonestreet on its breach of contract claim and awarded damages in the amount of $571,595. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) exercising supplemental jurisdiction following Allstate and Stonestreet's partial settlement; (2) interpreting the construction contract for the purpose of calculating damages; and (3) denying Weybosset's discovery motion regarding supplemental expert reports. View "Stonestreet Constr., LLC v. Weybosset Hotel, LLC" on Justia Law

For nearly twenty years, Plaintiff, Condominium Associations, and several IDC development entities disputed the ownership and use of certain property in Rhode Island. IDC Properties constructed and Defendant, IDC Clambakes, operated the Newport Regatta Club on the contested property after Plaintiff asserted that the rights of the IDC entities to own or develop the property had lapsed. The Rhode Island Supreme Court found in favor of Plaintiff. Defendant later declared bankruptcy. This case came to the First Circuit Court of Appeals from a bankruptcy court decision and concerned the question whether Defendant trespassed on Plaintiff's property or whether, through its actions during the pendency of the litigation, Plaintiff impliedly consented to operation of the Club by Defendant while title to the property was in dispute. The First Circuit affirmed the bankruptcy court's decision that Plaintiff impliedly consented to Defendant's operation of the Club, holding that the bankruptcy court's decision was fully reasoned and supported by the evidence. Remanded for a determination whether compensation was owed for Defendant's authorized use and occupancy. View "Goat Island S. Condo., Inc. v. IDC Clambakes, Inc." on Justia Law

Plaintiffs, current and former employees of Boston Medical Center (BMC), brought this wage-and-hour action against BMC, BMC's former president and COE, and BMC's former senior human resources officer, alleging that Defendants deprived them of their wages through the use of timekeeping policies and employment practices that required them to put in extra work time in addition to their regularly scheduled work shifts and to work through their meal and rest periods. Plaintiffs asserted causes of action under the Fair Labor Standards Act (FLSA) and Massachusetts common law. The federal district court granted Defendants' motion to dismiss in its entirety. The First Circuit Court of Appeals (1) vacated the dismissal of the FLSA claim against BMC and its former CEO, the contract claims, and the money had and received, unjust enrichment, and conversion claims; (2) vacated the district court's order striking the class and collective action allegations; and (3) otherwise affirmed. Remanded. View "Manning v. Boston Med. Ctr. Corp." on Justia Law

Plaintiff sought to open a Victoria's Secret franchise and sought assistance from Richard Domingo, an employee of Rekomdiv International. At the recommendation of Domingo, Plaintiff retained the law firm of Venable, LLP to assist him in establishing a business relationship with Victoria's Secret. Plaintiff paid Venable a $400,000 retainer fee, and paid $225,000 to Rekomdiv. Plaintiff later discovered Victoria's Secret franchise was not available. Plaintiff sued Rekomdiv and Domingo for breach of contract and dolo. The jury found in favor of Plaintiff and assessed damages in the amount of $625,000. In the meantime, Plaintiff sued Venable, and the parties settled. The court later found that it could not offset the damages award in the Rekomdiv suit by the Venable settlement amount. While their appeal was pending in this matter, Rekomdiv and Domingo filed a legal malpractice suit against Lamboy, their trial counsel. The district court dismissed the complaint against Lamboy. The First Circuit Court of Appeals (1) affirmed the district court's denial of offset of the damages award, as offset was not required; and (2) affirmed the court's dismissal of the legal malpractice suit, holding that the allegations in the complaint failed to establish the causation element necessary to make out a plausible legal malpractice claim. View "Portugues-Santana v. Rekomdiv Int'l, Inc." on Justia Law

Plaintiff was withdrawing money from an ATM when Tortfeasor struck her with his car. Tortfeasor was insured under a policy written by Insurer to a limit of $100,000 for bodily injury to one person. Plaintiff and several of her family members brought this action against Tortfeasor and his brother, the named insured on the policy, (collectively, Tortfeasor) and Insurer. The district court originally entered judgment ordering Insurer and Tortfeasor to pay one-and-a-half million dollars to Plaintiffs. Insurer paid into court $75,000, the remainder of its policy limit. The district court later amended its judgment, holding Tortfeasor and Insurer liable for six million dollars in damages. Plaintiffs then unsuccessfully sought to compel Insurer to pay postjudgment interest on the full judgment. The First Circuit Court of Appeals reversed the deniial of Plaintiff's request for postjudgment interest, holding that Insurer was responsible for postjudgment interest from the date of entry of the original judgment and the date of the deposit of the policy limit. View "Vazquez-Filippetti v. Cooperativa de Seguros Multiples de P.R." on Justia Law

These consolidated appeals comprised two putative class actions brought by skycaps affiliated with two major airlines. After Defendants, the airlines, each introduced a $2 per bag fee for curbside service for departing passengers at airports that did not inure to the benefit of the skycaps, Plaintiffs sued the airlines for unjust enrichment and tortious interference, among other claims. The district court dismissed the unjust enrichment and tortious interference claims as preempted by the Airline Deregulation Act (ADA). Plaintiffs appealed, contending that the ADA does not preempt common-law claims. The First Circuit Court of Appeals affirmed after an analysis of statutory language, congressional intent, and case law, holding that the ADA preempted Plaintiffs' common-law claims. View "Brown v. United Airlines, Inc." on Justia Law

Plaintiff was a company that sold aviation fuel at a Puerto Rico airport. Plaintiff filed this action Defendants, the Puerto Rico Ports Authority (PRPA), Airport Aviation Services (AAS), and employees of those entities, claiming that Defendants wrongfully interfered with its business. Specifically, Plaintiff alleged that a corrupt relationship existed between AAS and PRPA and that Defendants took improper actions in order to drive Plaintiff out of business. Before trial, the district court dismissed the claims against some defendants and, after a bench trial, granted judgment for the remaining defendants. The First Circuit Court of Appeals affirmed, holding (1) Plaintiff did not indicate a sufficiently clear intent to appeal the judgments dismissing the PRPA defendants from the case; and (2) the district court did not err in finding no conspiracy on the part of AAS and its employees to restrain trade, and the court correctly concluded that Plaintiff failed to proffer evidence to prove Defendants' actions were unreasonable or anticompetitive. View "Diaz Aviation Corp. v. Airport Aviation Servs., Inc." on Justia Law