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

Upon an investigation by the Maine Bureau of Insurance (Bureau) and the Maine Attorney General's Office (AG's Office) into the questionable business practices of Bankers Life and Casualty Company (Company), Appellant, the Company's employee, accepted responsibility for his own unlawful conduct. In exchange, several state officials (Appellees) representing the Bureau and the AG's Office agreed to take no further action against Appellant. Appellees, however, subsequently agreed to Appellant's termination in a separate agreement with the Company. Appellant filed a complaint against Appellees, asserting violations of 42 U.S.C. 1983 and 42 U.S.C. 1985(2). The district court dismissed the complaint, concluding (1) Appellees were entitled to absolute immunity on the section 1983 claim, and (2) Appellant failed to plead a plausible section 1985(2) claim. The First Circuit Court of Appeals affirmed, holding (1) Appellees met their burden in establishing they were entitled to absolute immunity for entering into the consent agreements with Appellant and the Company, and the district court did not err by refusing to invoke the doctrine of judicial estoppel on Appellees' immunity defense; and (2) because the complaint failed to allege any racial or class-based invidiously discriminatory animus underlying Appellees' actions, the district court properly dismissed Appellant's section 1985(2) claim. View "Knowlton v. Shaw" on Justia Law

This appeal involved litigation between Coverall North America, Inc. and its franchisees. Proceeding under federal diversity jurisdiction, the franchisees asserted a variety of state-law claims against Coverall. Which of the various plaintiffs were subject to the arbitration provisions of the Franchise Agreement was at issue in this appeal. Appellees were a subgroup of Plaintiffs who became Coverall franchisees by signing consent to transfer agreements, which by reference incorporated under franchise agreements that contained arbitration clauses. The district court determined that Appellees did not have to arbitrate their claims against Coverall because they did not have adequate notice of the arbitration clauses contained in the franchise agreements. The First Circuit Court of Appeals reversed, holding that the district court erred because (1) Massachusetts law, which governed this dispute, did not impose any such special notice requirement upon these commercial contractual provisions; and (2) in any event, any special notice requirement would be preempted by the Federal Arbitration Act. View "Awuah v. Coverall N.A., Inc. " on Justia Law

This case involved an insurance coverage dispute arising from charges of sexual harassment brought by a former employee (Employee) against the one-time president (President) of Jasmine Company, Inc. After President filed an action against Jasmine's liability insurance provider (Insurer), seeking defense and indemnification for the harassment charges, Insurer filed a third-party complaint against Jasmine itself, requesting a declaratory judgment that it had not duty to defend or indemnify Jasmine for the harassment claims. The district court granted summary judgment on the third-party claims for Jasmine, holding that Insurer had to defend and indemnify Jasmine. At issue on appeal was whether a finder of fact must conclude that the conduct underlying the sexual harassment charges did or did not begin before Jasmine's insurance policy took effect. The First Circuit Court of Appeals vacated the judgment and remanded, holding that neither party was entitled to summary judgment, as the question of when the harassing conduct that gave rise to Employee's claims began was a quintessential question for a factfinder. View "Manganella v. Evanston Ins. Co." on Justia Law

This insurance coverage dispute arose from charges of sexual harassment brought by a one-time employee against Appellant, the former president of Jasmine Company, Inc. Appellant sought a defense to and indemnity for the harassment claims from Appellee, Jasmine's liability insurance provider. The district court ruled that Appellant was not entitled to coverage from Appellee because, under the doctrine of issue preclusion, a prior arbitration between Appellant and the purchaser of his business conclusively established that Appellant's conduct fell within an exclusion to Appellee's insurance policy. The First Circuit Court of Appeals affirmed, holding (1) the arbitration presented Appellant with the full and fair opportunity for adjudication on the issue at hand; and (2) therefore, the district court was correct to bar Appellant from disputing the applicability of the exclusion based on the doctrine of issue preclusion. View "Manganella v. Evanston Ins. Co." on Justia Law

Plaintiff appealed a grant of summary judgment to her former employer in this suit for discrimination, retaliation, and hostile work environment under the Age Discrimination in Employment Act, arguing that the district judge slipped by premising dismissal on disputed facts. The First Circuit Court of Appeals dismissed Plaintiff's appeal with prejudice after discussing the circumstances under which appeals will be dismissed for failure to adhere to appellate rules, holding that Plaintiff's substantial noncompliance with important appellate rules were major violations in that they crippled any attempt to review the issues intelligently and constituted sufficient cause to dismiss the appeal. View "Rodriguez-Machado v. Shinseki" on Justia Law

Petitioner's husband was employed by GD Arabia, Ltd. as a military trainer in Saudi Arabia. After he was found dead by asphyxiation by hanging, Petitioner filed a claim for death benefits under the Defense Base Act (DBA). Pursuant to agency policy and as authorized by statute, the matter was transferred to the district director's office in Boston and adjudicated there. An ALJ denied Petitioner's claim, and the Department of Labor's Benefits Review Board affirmed. Petitioner sought direct review in the First Circuit Court of Appeals, raising an issue of jurisdiction on which the circuit courts were divided. The First Circuit denied the petition for review, holding that the Review Board acted reasonably in upholding the ALJ's denial of compensation, as the record supported the inference of suicide and none of Petitioner's suggested hypotheses might entail coverage under the DBA. View "Truczinskas v. Dir., Office of Workers' Comp. Programs" on Justia Law

Defendant, Starbucks Corporation, accumulated tips from containers along individual stores' cash registers and distributed them weekly to baristas and shift supervisors within a store in proportion to the number of hours worked that week by each individual. Plaintiffs, former Starbucks baristas, filed a putative class action state court against Starbucks, asserting that Starbucks' policy violated Massachusetts' Tips Act because it allowed shift supervisors to share in the pooled gratuities. Starbucks removed the case to federal court, alleging class-action diversity jurisdiction. The district court, applying Massachusetts law, concluded that the Defendant's policy regarding pooled gratuities violated the Tips Act, certified a class, and awarded damages in an amount exceeding $14,000,000. The First Circuit Court of Appeals affirmed, holding that the plain language of the Tips Act prohibited Defendant's tip-pooling policy. View "Matamoros v. Starbucks Corp." on Justia Law

After they were fired from their jobs, Appellants filed suit in federal district court against their former employer (Employer) and against the severance plan (Plan) established by Employer pursuant to ERISA. The complaint asserted federal claims under ERISA, ADEA, ADA, and other federal laws, and also asserted a breach of contract claim, an employment discrimination claim, and an unjustified dismissal claim under Puerto Rico law. The district court granted Appellees' motion for summary judgment. Appellants challenged that ruling as well as a number of the district court's other orders. The First Circuit Court of Appeals affirmed, holding that there was no error in the management of this case or the grant of Appellees' motion for summary judgment. View "Cruz v. Bristol-Myers Squibb Co., PR, Inc." on Justia Law

In an effort to reduce costs and achieve greater efficiency, Employer consolidated two lab operations into one, which resulted in a reduction in positions and in a Union losing jurisdiction over lab testing work that its members had previously performed. At issue in this appeal was Employer's obligations under national labor law to bargain with the union representing the affected employees. The National Labor Relations Board found (1) the lab work transfer decision involved a mandatory subject of bargaining so that Employer's refusal to bargain violated the National Labor Relations Act, and (2) the collective bargaining agreement between Employer and Union did not prohibit the work transfer without the Union's consent. The First Circuit Court of Appeals affirmed, (1) holding that the Board made no error of law in reaching its decision; and (2) granting the Board's petition for enforcement of its order requiring Employer to return to the Union certain work that Employer had transferred. View "Nat'l Labor Relations Bd. v. Solutia, Inc." on Justia Law

Plaintiff was severely injured in a workplace accident and sued Trail King, the custom manufacturer of the trailer involved in the accident. The First Circuit Court of Appeals affirmed a jury's finding that Defendant had not been negligent nor in breach of any warranty. In the trial court in that diversity case, Plaintiffs belatedly attempted to amend their complaint to add another claim, one under Mass. Gen. Laws ch. 93A for unfair and deceptive trade practices. The trial judge denied the motion, finding the effort to amend untimely. Plaintiffs did not appeal this denial in their earlier appeal. This case concerned whether Plaintiffs may now maintain an independent suit for the ch. 93A claims against Trail King. The district court dismissed the claims with prejudice, finding that the doctrine of claim preclusion applied. Plaintiffs appealed, arguing that ch. 93A, 9(8) provides an exception to the normal rules of res judicata. The First Circuit affirmed, holding that under the facts of this case, Plaintiffs may not now bring this ch. 93A claim because of the failure to appeal from the denial of the motion to amend. View "Hatch v. Trail King Indus., Inc." on Justia Law