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

In a prior suit, Appellees obtained a state court judgment against Appellant, Boston Property Exchange Transfer Company (BPE), for Defendant's financial misconduct. At the time of that judgment, BPE was about to begin arbitration of claims against PaineWebber, which it claimed was responsible for its financial troubles. Appellees successfully sought to compel assignment of BPE's legal claims to them to help satisfy their judgment against BPE. In this federal action, BPE claimed damages from the appellee assignees and their lawyers for allegedly mishandling the PaineWebber arbitration. The district court dismissed all of BPE's claims. The First Circuit Court of Appeals affirmed, holding (1) summary judgment for Appellees was proper on BPE's tort claims because BPE failed to prove that Appellees cause it to suffer damages; and (2) summary judgment was properly granted for Appellees on their breach of contract claim, as the assignment order in this case was not a contract. View "Boston Prop. Exch. Transfer Co. v. Iantosca" on Justia Law

Plaintiff filed a disparate screening claim in the U.S. district court alleging that she arrived at the emergency department of Hospital with an emergency medical condition as defined by the Emergency Medical Treatment and Active Labor Act (EMTALA), that Hospital failed to screen her appropriately, and that Hospital failed to stabilize or properly transfer her before release, thus violating the requirements of EMTALA. The district court dismissed Plaintiff's complaint as stating facts limited to a medical malpractice claim and holding that EMTALA does not create a federal cause of action for medical malpractice. The First Circuit Court of Appeals vacated the district court's dismissal, holding that Plaintiff presented sufficient evidence to show that a trialworthy issue existed as to her disparate screening claim. Remanded for trial on Plaintiff's EMTALA claim as well as her Puerto Rico law claims. View "Cruz-Vazquez v. Mennonite Gen. Hosp., Inc." on Justia Law

In an attempt to avert the foreclosure of her home, Plaintiff sought to modify the terms of her mortgage pursuant to the Home Affordable Modification Program (HAMP), a federal initiative that incentivizes lenders and loan servicers to offer loan modifications to eligible homeowners. When Plaintiff's efforts did not result in a permanent loan modification, she sued Wells Fargo Bank and American Home Mortgage Servicing, alleging that their conduct during her attempts to modify her mortgage violated Massachusetts law. The district court dismissed Plaintiff's complaint for failure to state a claim. The First Circuit Court of Appeal (1) affirmed the district court's judgment as to the dismissal of Plaintiff's claims of breach of contract, breach of the implied covenant of good faith and fair dealing, and intentional and negligent infliction of emotional distress; and (2) vacated the dismissal of Plaintiff's other breach of contract claim, Plaintiff's unfair debt collection practices claim under Mass. Gen. Laws ch. 93A, and her derivative claim for equitable relief. Remanded. View "Young v. Wells Fargo Bank, N.A." on Justia Law

Plaintiff, who uses a wheelchair, was on the premises of the Veterans Affairs (VA) Hospital in San Juan when he was injured. After filing an administrative claim, Plaintiff sued the United States under the Federal Tort Claims Act (FTCA), alleging that the VA negligently maintained the restroom in the hospital and that a loose toilet seat provoked his fall. The district court granted summary judgment for the United States, finding that there was no evidence to support that the VA had knowledge of the dangerous condition, the loose toilet seat. The First Circuit Court of Appeals affirmed, holding (1) a rational factfinder could not conclude that the VA breached its duty of care in the circumstances of this case; and (2) the district court did not err in ruling on the summary judgment motion prior to the expiration of an extended discovery period. View "Nieves-Romero v. United States" on Justia Law

The United States Postal Services (USPS) terminated Plaintiff's employment contract after discovering, through a sting operation, that Plaintiff had stolen mail containing money. The Postal Service Board of Contract Appeals (PSBCA) convened an evidentiary hearing and determined that Plaintiff's breach of his employment contract justified the decision to terminate his contract. Plaintiff did not appeal this decision. Meanwhile, Plaintiff initiated a Federal Tort Claims Act (FTCA) suit against the United States for the actions of USPS employees on the date of the sting, alleging six torts. The district court dismissed three of the claims and granted summary judgment to the government on the remaining claims. The First Circuit Court of Appeals affirmed the district court as to all claims, holding (1) the district court correctly concluded that the PSCBA's findings precluded relitigation of the factual issues in Plaintiff's FTCA suit; and (2) summary judgment was properly granted as to Plaintiff's FTCA claims for negligent supervision, malicious prosecution, and invasion of privacy by postal inspectors. View "Rios-Pineiro v. United States" on Justia Law

Kaiser Foundation Health Plan and Kaiser Foundation Hospitals (together, Kaiser), Aetna, Inc. and Guardian Life Insurance Company (Guardian) filed a coordinated complaint against Pfizer, Inc. and Warner-Lambert Company (together, Pfizer). The coordinated plaintiffs asserted violations of, inter alia, the Racketeer Influenced and Corrupt Organizations Act (RICO) and the California Unfair Competition Law (UCL). Ultimately, Kaiser prevailed, and Aetna and Guardian's claims were dismissed on summary judgment. After a jury trial, the district court entered judgment in favor of Kaiser on its RICO and state UCL claims. The court subsequently denied Pfizer's motion for a new trial or, in the alternative, to alter or amend judgment. The court awarded Kaiser damages and ordered Defendants to pay restitution. Finding no error, the First Circuit Court of Appeals affirmed the verdicts for Kaiser. View "Kaiser Found. Health Plan v. Pfizer, Inc." on Justia Law

Aetna, Inc. filed a coordinated complaint with Kaiser Foundation Health Plan and Kaiser Foundation Hospitals (together, Kaiser) and Guardian Life Insurance Company (Guardian) against Pfizer, Inc. and Warner-Lambert Company (together, Pfizer). The coordinated plaintiffs asserted that they had suffered injury from the fraudulent marketing of Neurontin for off-label uses, and alleged violations of, inter alia, the Racketeer Influenced and Corrupt Organizations Act (RICO) and the Pennsylvania Insurance Fraud Statute (PIFS). The district court dismissed the claims of Guardian and Aetna but denied summary judgment as to Kaiser's claims. The court then entered judgment against Guardian and Aetna and in favor of Pfizer. The First Circuit Court of Appeals (1) reversed the dismissal of Aetna's RICO claim, as Aetna presented evidence of causation and damages sufficient to survive summary judgment; and (2) vacated the district court's dismissal of Aetna's claim under the PIFS. Remanded. View "Aetna, Inc. v. Pfizer, Inc." on Justia Law

Plaintiff, her son Kyle, and Kyle's girlfriend Catherine lived together. In 2008, Kyle was the driver of a vehicle involved in an accident in New Hampshire. Defendant was among the police officers who responded to the scene. Kyle was then arrested. Catherine, who witnessed the accident, and Plaintiff went to the police station. Defendant warned Catherine against leaving the police department and threatened to obtain a warrant for her arrest if she left. Plaintiff, however, counseled Catherine to leave and escorted her out of the police station. Defendant subsequently filed a criminal complaint charging Plaintiff with witness tampering. The charge was later dismissed. Plaintiff then filed an action against Defendant in the U.S. district court for false arrest under the Fourth Amendment and malicious prosecution under state law. The district court granted summary judgment for Defendant, concluding that Defendant was entitled to qualified immunity on the federal constitutional claim and official immunity on the state-law claim. Finding no error, the First Circuit Court of Appeals affirmed. View "Moses v. Mele" on Justia Law

Brothers Thomas and Michael Tessier allegedly swindled brothers Frederick and Thaddeus Jakobiec and the estate of their mother out of millions of dollars. This lawsuit covered the Tessiers' theft of almost $100,000 in life insurance proceeds due to a trust benefitting Thaddeus. Thaddeus and various persons affiliated with the trust and estate (collectively, Plaintiffs) filed this action against Merrill Lynch, the company that issued the life insurance policy, claiming that Merrill Lynch made out the insurance proceeds check to the wrong trust entity in breach of the insurance contract, thus allowing the Tessiers to steal the money. The First Circuit Court of Appeals granted summary judgment for Merrill Lynch, concluding that even if Merrill Lynch did breach the contract, its breach was not the cause of Plaintiffs' losses because the Tessiers would have stolen the money even if the check had been made out correctly. The First Circuit Court of Appeals affirmed, holding (1) because the extensive groundwork laid by the Tessiers for their criminal scheme, they could have and would have stolen the insurance money regardless of how Merrill Lynch made out the check; and (2) therefore, the district court correctly granted summary judgment for Merrill Lynch. View "Jakobiec v. Merrill Lynch Life Ins. Co." on Justia Law

Plaintiff, an international affairs specialist at the Puerto Rico State Department, filed a complaint against the Department, ten of its employees, the Commonwealth (collectively, the State Department defendants), and the Puerto Rico Ports Authority. Plaintiff alleged that the State Department defendants had discriminated against her due to her political views and that they had denied her the rights and benefits to which she was entitled under federal and local law. As against the Ports Authority, Plaintiff alleged it slandered her by publishing false information regarding an arrest for marijuana, which prevented her from fulfilling her work duties. The district court found that Plaintiff's complaint failed to state a claim upon which relief could be granted and dismissed the complaint. Plaintiff appealed, requesting a reversal of the district court's refusal to grant leave to amend the complaint based upon its finding that amendment would be futile. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in denying the requested amendment. View "Flores-Silva v. McClintock-Hernandez" on Justia Law