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

Elizabeth and Cale Putnam, residents of Massachusetts, traveled to the Hotel Valcartier in Québec, Canada, with their five-year-old son, Anthony. While staying at the hotel, an unsecured Murphy bed fell on Anthony, causing fatal injuries. The Putnams had booked their stay at the hotel and its associated Ice Hotel through the hotel’s website, received receipts and marketing communications at their Massachusetts address, and noticed other Massachusetts vehicles at the hotel during their visit.Following Anthony’s death, the Putnams filed a wrongful death lawsuit in the United States District Court for the District of Massachusetts against Premier Parks, LLC, which they believed operated the hotel, and EPR Properties, which they believed owned it. Both Premier and EPR moved to dismiss for lack of personal jurisdiction, submitting affidavits asserting they neither owned nor operated the hotel, nor marketed or contracted with Massachusetts residents regarding the hotel. The Putnams submitted documentary evidence suggesting connections between Premier, EPR, and the hotel, but the district court dismissed the case with prejudice and denied their request for jurisdictional discovery.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court found that, as to Premier Parks, the Putnams presented enough documentary evidence to create a genuine dispute regarding Premier’s involvement in the hotel’s operations, marketing, and staffing. The court held that the district court abused its discretion by denying jurisdictional discovery with respect to Premier and reversed the dismissal as to Premier, remanding for discovery. Regarding EPR, the court concluded that the Putnams failed to contradict EPR’s affidavit that it did not own or operate the hotel or market it to Massachusetts residents. The court affirmed the dismissal as to EPR but modified the judgment to be without prejudice. View "Putnam v. EPR Properties" on Justia Law

The plaintiff brought a suit under Puerto Rico law after her mother died while residing in an assisted living facility. The plaintiff alleged that the facility's staff, including a licensed practical nurse, incorrectly informed treating physicians that her mother was a Jehovah's Witness. As a result, necessary blood transfusions were not administered, and the mother died from heart failure. The facility’s insurer had denied coverage for the incident under its general liability policy, claiming that the alleged wrongful acts were excluded as “professional services.”The United States District Court for the District of Puerto Rico first granted partial summary judgment for the insurer, finding that certain actions—such as failing to call 911—were excluded as “professional services,” but allowed the case to proceed on claims related to record-keeping and miscommunication, concluding those were not “professional services” under existing precedent. After the case was reassigned, the new district judge reaffirmed that ruling, and a damages trial resulted in a verdict against the facility. Subsequent to a decision by the Puerto Rico Supreme Court in Rivera-Matos v. Commonwealth, which clarified the scope of “professional services” exclusions, the district judge permitted the insurer to relitigate the coverage issue, ultimately finding that the exclusion did apply to the acts in question and entering judgment for the insurer.On appeal, the United States Court of Appeals for the First Circuit held that the plaintiff had forfeited her argument that the Puerto Rico Supreme Court’s decision should not be applied retroactively, as she had not raised it below. The court further found no plain error in the application of the new precedent. The judgment of the district court in favor of the insurer was affirmed. View "Garcia-Navarro v. Universal Insurance Company" on Justia Law

A mother of four regularly sought care at a federally funded health center in Rhode Island from 2006 onward. Over a period of several years, she repeatedly reported persistent, weeks-long headaches with changing characteristics to her primary-care providers, also disclosing experiences of domestic abuse. Despite these reports, she was diagnosed with migraines and prescribed medication, but was never referred to a neurologist or for neuroimaging. In 2019, her symptoms worsened, and she lost consciousness, leading to hospitalization and the discovery of a slow-growing brain tumor, which had caused a buildup of cerebral fluid. Surgery to remove the tumor resulted in cerebellar strokes and permanent neurological damage, severely limiting her mobility and ability to care for her family.After the Department of Health and Human Services denied her administrative claim, she and her family filed suit under the Federal Tort Claims Act (FTCA) in the United States District Court for the District of Rhode Island. The district court found negligence by the primary-care providers, awarded her damages for medical expenses, pain and suffering, and homemaker loss, and awarded her children damages for loss of consortium. The government appealed, arguing that the children’s consortium claims were not properly presented administratively, that the homemaker damages were excessive, and that the findings on standard of care, causation, and medical expenses were erroneous.The United States Court of Appeals for the First Circuit held that the children’s loss-of-consortium claims were barred for failure to exhaust administrative remedies and reversed those damages. The court vacated the homemaker damages award as excessive and unsupported by the evidence, remanding for further proceedings. The court affirmed the district court’s findings on negligence and causation and upheld the pain and suffering awards, but reduced the medical expense award by the cost of an unrelated spinal MRI. The judgment was thus affirmed in part, reversed in part, modified in part, and remanded. View "Urizar-Mota v. US" on Justia Law

The City of Boston, along with its Public Health Commission and Housing Authority, brought suit against two pharmacy benefit managers (PBMs), OptumRx and Express Scripts, alleging that the PBMs had worked with opioid manufacturers to misrepresent the risks of opioid drugs. The City claimed that this conduct violated Massachusetts public nuisance law and resulted in harm to the City. The PBMs removed the case to federal court and argued that the suit was untimely because it was brought after the three-year statute of limitations had expired. The City responded by asserting that its complaint sufficiently alleged a continuing nuisance and that the statute of limitations should be tolled due to the PBMs’ fraudulent concealment of their wrongdoing.The United States District Court for the District of Massachusetts granted the PBMs’ motion to dismiss, finding that the City either knew or should have known of its injuries and of the PBMs’ alleged role before 2021, based on public records and prior litigation, and thus failed to file suit within the statutory period. The district court further ruled that the City had not adequately pled a continuing nuisance, as it did not allege any specific, recent unlawful acts within the limitations period, and rejected the City’s claim of fraudulent concealment, determining that the City had the means to discover the facts needed for its claim. The district court also denied a motion by the PBMs to disqualify the City's law firm, Motley Rice.On appeal, the United States Court of Appeals for the First Circuit affirmed both the dismissal of the City’s state law claim and the denial of the motion to disqualify Motley Rice. The court held that the action was time-barred and that the City had not met the requirements for tolling the statute of limitations or for pleading a continuing nuisance under Massachusetts law. View "The City of Boston v. OptumRx, Inc." on Justia Law

A laser-cutting system operator died after being trapped between components of an industrial laser-cutting system when a steel beam descended into a gap, resulting in fatal injuries. The system, designed, sold, installed, and maintained by one company, consisted of several components, including a material handler, load frame, and main frame. On the day of the incident, the operator entered a narrow gap between the material handler and the load frame; when the system was activated, a steel beam pinned him, leading to his death. There were multiple possible routes into the gap, and prior incidents indicated the operator had previously entered the area. The estate of the deceased operator sued the designer and installer for negligent design, negligent installation, breach of warranty of merchantability (based on design and manufacturing defects), and negligent failure to maintain and warn of dangerous conditions.The case was initially filed in state court, then removed to the United States District Court for the District of Massachusetts. After discovery, the district court granted summary judgment to the defendant on all claims. The district court found that the system included a barrier fence at installation, making the system adequately protected and negating breach of warranty or negligent design claims. For the claims related to maintenance and failure to warn, the court found no triable issue on causation, as there was insufficient evidence that the operator had entered the gap through the unguarded wall-side opening.On appeal, the United States Court of Appeals for the First Circuit vacated the district court’s summary judgment on the design-related claims, finding a genuine factual dispute as to whether a reasonable alternative design—such as additional safety devices—could have mitigated the system’s risks. However, the appellate court affirmed summary judgment on the installation, maintenance, and failure to warn claims, concluding there was insufficient evidence to establish causation for those theories. The case was remanded for further proceedings on the design claims. View "Alicea v. Cincinnati Incorporated" on Justia Law

A Pennsylvania-based company operating an online marketplace for firearms was sued under New Hampshire law by a former Boston police officer and his wife. Their claims alleged that the company’s website facilitated the sale of a firearm in New Hampshire in 2015, which was later used to shoot the officer in Boston in 2016. The plaintiffs asserted causes of action including negligence, aiding and abetting tortious conduct, public nuisance, loss of consortium, and loss of support, based on the website’s alleged design and operation in encouraging illegal gun sales.Previously, the plaintiffs had filed a similar suit in the Massachusetts Superior Court against the company and other defendants, but that court dismissed the claims against the company based on Section 230 of the Communications Decency Act, without ruling on personal jurisdiction. After jurisdictional discovery, the Massachusetts Superior Court subsequently dismissed the claims for lack of personal jurisdiction. The plaintiffs then filed the present action in the United States District Court for the District of New Hampshire, which denied their request for jurisdictional discovery and dismissed their claims for lack of personal jurisdiction, finding the company had not purposefully availed itself of the protections of New Hampshire’s laws.On appeal, the United States Court of Appeals for the First Circuit affirmed the District Court’s ruling in part and vacated it in part. The First Circuit held that the plaintiffs failed to make a prima facie case of purposeful availment based on contacts up to 2016, but concluded that evidence of thousands of “New Hampshire” firearm listings on the website from 2018 onward, when considered with other evidence, sufficed for a prima facie showing of purposeful availment. The court remanded for consideration of relatedness and reasonableness and affirmed denial of jurisdictional discovery. View "Stokinger v. Armslist, LLC" on Justia Law

Rebecca Blakesley, a nurse, ended her marriage with Andrew Blakesley in early 2021 after a tumultuous relationship marked by alleged abuse. Shortly after she obtained a protective order and filed for divorce, Andrew’s mother, Colleen Marcus, and his sister-in-law, Jennifer Marcus, reported Rebecca to various public and private organizations. They accused her of violating patient confidentiality, fraudulent billing, academic dishonesty, and faking a COVID test. These reports led to investigations, the loss of Rebecca’s employment, and the suspension of her application for a professional license.Rebecca filed a lawsuit in the United States District Court for the District of Massachusetts, alleging defamation and intentional interference with business relations. She claimed the Marcuses’ actions were motivated by retaliation for her divorce. The Marcuses responded with a special motion to dismiss under the Massachusetts anti-SLAPP statute, which is designed to protect individuals from lawsuits intended to chill their right to petition the government. The district court denied the motion, finding that Rebecca’s claims were not based solely on petitioning activity because the Marcuses’ reports to private employers and a nursing school did not qualify as protected petitioning under the statute.On appeal, the United States Court of Appeals for the First Circuit reviewed whether the anti-SLAPP statute applied. The court held that the Marcuses failed to show their conduct was solely petitioning activity, as required by the Massachusetts Supreme Judicial Court’s recent clarification in Bristol Asphalt, Co. v. Rochester Bituminous Prods., Inc. The First Circuit affirmed the district court’s denial of the anti-SLAPP motion, holding that mixed claims involving both petitioning and non-petitioning conduct are not subject to dismissal under the statute, and remanded the case for further proceedings. View "Blakesley v. Marcus" on Justia Law

A 68-year-old man experiencing abdominal pain was brought to a hospital emergency room in Bayamón, Puerto Rico, in January 2016. After a delayed CT scan revealed a perforated intestine, he underwent surgery and remained in intensive care until his death in February 2016. His son, a physician residing in Florida, later learned of the seriousness of his father’s condition during a visit. The son filed a lawsuit against several doctors, the hospital, and related entities, alleging that negligent medical care led to his father’s death.The United States District Court for the District of Puerto Rico reviewed the case after a contentious discovery period. The court granted summary judgment in favor of five defendants: three doctors, a corporate entity managing the emergency room, and the emergency room’s medical director. The court found that the claims against the doctors and the corporate entity were time-barred under Puerto Rico’s one-year statute of limitations for tort claims, and that Puerto Rico law did not provide a basis for liability against the medical director, as he had not directly treated the patient. The court also disregarded certain evidence submitted by the plaintiff and denied his motion for reconsideration.On appeal, the United States Court of Appeals for the First Circuit found that the district court erred in converting two doctors’ motions to dismiss into motions for summary judgment without giving the plaintiff adequate notice or an opportunity to present evidence. The appellate court also held that the district court abused its discretion in disregarding the plaintiff’s declaration regarding when he learned of one doctor’s involvement. The court vacated and remanded the summary judgments for the three doctors and the medical director on the first cause of action, but affirmed summary judgment for the corporate entity and the medical director on the second cause of action. Each party was ordered to bear its own costs. View "Calderon-Amezquita v. Rivera-Cruz" on Justia Law

A husband and wife brought a lawsuit after the wife suffered a pelvic fracture during a forceps-assisted delivery performed by a doctor at a women’s health group. They alleged that the doctor failed to obtain the wife’s informed consent by not disclosing the risks associated with the procedure. The plaintiffs claimed that this omission violated Massachusetts law and sought damages for the resulting injury.The United States District Court for the District of Massachusetts handled the case initially. During pretrial proceedings, the defendants moved to strike the plaintiffs’ expert witnesses, arguing that the plaintiffs had not made their experts available for deposition as required by the Federal Rules of Civil Procedure. The plaintiffs did not respond to this motion, and the District Court granted it, excluding the expert testimony. The plaintiffs later failed to appear at a pretrial conference, citing email issues, and only addressed the missed conference, not the exclusion of their experts. The District Court declined to vacate its order striking the experts, finding the plaintiffs’ delay and lack of explanation unjustified. Subsequently, the District Court granted summary judgment to the defendants, concluding that expert testimony was necessary to support the informed consent claim under Massachusetts law.On appeal, the United States Court of Appeals for the First Circuit reviewed the District Court’s decisions. The appellate court held that the District Court did not abuse its discretion in refusing to reconsider the order striking the expert witnesses, given the plaintiffs’ prolonged inaction and failure to address the underlying issues. The First Circuit also held that, under Massachusetts law, expert testimony was required to establish that the risk of pelvic fracture from a forceps-assisted delivery was more than negligible, and thus, summary judgment for the defendants was appropriate. The judgment of the District Court was affirmed. View "Meka v. Haddad" on Justia Law

The plaintiff was indicted by a Rhode Island grand jury, along with several co-defendants, on charges related to an alleged mortgage fraud conspiracy. He filed multiple motions to dismiss the charges in Rhode Island Superior Court, arguing that the indictment was tainted by prosecutorial misconduct and the presentation of misleading or missing evidence. After evidentiary hearings, a Magistrate denied his motions, and an Associate Justice of the Superior Court, on de novo review, adopted the Magistrate’s decision and added that the plaintiff had not shown sufficient prosecutorial misconduct to justify dismissal. The plaintiff did not appeal this ruling. Later, the charges against him were dismissed by the state as part of a plea agreement with a co-defendant.Subsequently, the plaintiff filed a malicious prosecution suit in the United States District Court for the District of Rhode Island against state law enforcement defendants. The defendants moved for summary judgment, arguing that collateral estoppel barred the plaintiff from relitigating whether the indictment was procured by fraud or misconduct, since that issue had already been decided in state court. The plaintiff responded only that the issues were not identical, and did not contest the “final judgment” or “full and fair opportunity to litigate” elements of collateral estoppel.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the plaintiff had waived his arguments regarding the “final judgment” and “full and fair opportunity” elements by failing to raise them in the district court, and that no exceptional circumstances justified excusing this waiver. The First Circuit affirmed the district court’s grant of summary judgment to the defendants, holding that collateral estoppel applied and barred the plaintiff’s malicious prosecution claim. Costs were awarded to the defendants. View "Shabshelowitz v. Rhode Island Department of Public Safety" on Justia Law