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

In this case concerning arbitration agreements, nursing homes, and wrongful death claims under Massachusetts law, the First Circuit certified questions to the Massachusetts Supreme Judicial Court (SJC) under its Rule 1:03, holding that the dispute in this case turned on the characterization of wrongful death actions by the Commonwealth and presented an unresolved question of Massachusetts law whose answer was unclear.The personal representative of a deceased former nursing home resident brought a state wrongful death action against a set of organizations that oversaw the nursing home (collectively, nursing home). The nursing home sued to compel arbitration. The federal court compelled arbitration and declined to issue a stay of the state wrongful death action. On appeal, the personal representative argued that she was not bound by the decedent’s agreement to arbitrate with the nursing home because her wrongful death right of recovery was independent of the decedent’s wrongful death claim. In asserting that the arbitration agreement was binding, the nursing home argued that Massachusetts beneficiaries’ wrongful death claims are derivative of the decedent’s wrongful death claim. The First Circuit exercised its discretion in favor of certification, holding that Massachusetts law does not clearly decide the independent/derivative or other relevant questions about the status of wrongful death actions in relation to the decedent. View "GGNSC Chestnut Hill LLC v. Schrader" on Justia Law

The First Circuit affirmed the district court’s entry of summary judgment for Defendants in this case, holding that an objectively reasonable police officer in May 2013 could have concluded that a single use of a Taser to quell a nonviolent, mentally ill person who was resisting arrest did not violate the Fourth amendment and that, in any case, the officer here was shielded by qualified immunity.Plaintiff, a mentally ill person who was tased after absconding from the hospital to which she had been involuntarily committed, sued the officer and the Town of Athol, Massachusetts asserting causes of action under 42 U.S.C. 1983 and Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12131-65, along with supplemental state-law claims for, inter alia, assault and battery and malicious prosecution. The magistrate judge found no violation of the Fourth Amendment under section 1983 and no viable state-law claims, that the officer was entitled to qualified immunity, and that there was no violation of the ADA. The First Circuit affirmed, holding (1) Plaintiff presented sufficient evidence to make out a jury question as to whether the officer used excessive force, but the officer was entitled to qualified immunity; and (2) Plaintiff was not entitled to relief on any of her remaining claims. View "Gray v. Cummings" on Justia Law

The First Circuit affirmed in part and reversed in part the decision of the district court entering judgment for Plaintiff on Mass. Gen. Laws ch. 151B and defamation claims against the City of Fitchburg and its mayor and the award of punitive damages, holding that the award of punitive damages was improper and that the district court erred in entering judgment for Plaintiff on the defamation claim.Plaintiff brought this action against the City and its mayor after the mayor decided not to nominate Plaintiff for the position of the City police chief. Plaintiff alleged that the City violated his rights under Chapter 151B by deciding not to hire him because of his failure to disclose a criminal case against him of which he was later acquitted and that the mayor defamed him through statements she made to the media. A jury found for Plaintiff on both claims and awarded punitive damages. The First Circuit held (1) the district court erred in denying Plaintiff’s motion for judgment as a matter of law and for a new trial on Plaintiff’s defamation claim because the statement at issue was not false; (2) the evidence was sufficient with respect to the Chapter 151B claim; and (3) there was insufficient evidence to support the punitive damages award. View "Heagney v. Wong" on Justia Law

The First Circuit reversed the district court’s dismissal of claims against Schechtl Maschinenbau GmbH, a German company, holding that, contrary to the conclusion of the district court, the exercise of personal jurisdiction over Schechtl comported with due process.Stephen Knox’s hand was injured at his work when he operated a machine manufactured by Schechtl. The machine had been sold to Knox’s employer by MetalForming, Inc., an American company located in Georgia and Schechtl’s U.S. distributor. Knox sued both Schechtl and MetalForming in Massachusetts state court. MetalForming removed the case to Massachusetts federal district court and filed crossclaims against Schechtl. The district court granted Schechtl’s motion to dismiss, concluding that Schechtl had not purposefully availed itself of the privilege of doing business in Massachusetts. The First Circuit reversed, holding that Knox and MetalForming met their burden of demonstrating that Schechtl purposefully availed itself of the privilege of conduct activities within Massachusetts. View "MetalForming, Inc. v. Schechtl Maschinenbau GmbH" on Justia Law

The First Circuit affirmed the order of the district court dismissing Plaintiff’s contract and tort claims for lack of personal jurisdiction, holding that the federal court in Puerto Rico lacked personal jurisdiction over Defendants.Plaintiff, a Puerto Rico tour company, brought this diversity suit in the United States District of Puerto Rico, alleging that a California youth soccer organization and related defendants breached duties that the organization owed to Plaintiff under Puerto Rico contract and tort law. The allegations centered around Defendants’ acts of first requesting that Plaintiff make an offer for a potential soccer trip to Puerto Rico for some of the organization’s teams and their families and then declining after further communications to book the tour. The district court dismissed the claims for lack of personal jurisdiction. The First Circuit affirmed, holding that the exercise of specific jurisdiction in the forum over the out-of-forum defendants did not conform to the federal constitutional test. View "PREP Tours, Inc. v. American Youth Soccer Organization" on Justia Law

The First Circuit affirmed the judgment of the district court entering judgment against Plaintiff on his lawsuit against the United States under the Federal Tort Claims Act, 28 U.S.C. 1346(b), 2671-2680, holding that the district court did not err in dismissing Plaintiff’s claim on the clearly-established step of qualified immunity analysis.In his lawsuit, Plaintiff sought to recover damages for injuries he suffered when a Department of Homeland Security agent shot him during the execution of a search warrant at his residence. The district court ruled for the United States, concluding that the United States could not be held liable unless the unlawfulness of the officers’ conduct was clearly established at the time they acted and that, at the time the officers acted, no precedent clearly established that the officers’ conduct was unlawful. The First Circuit affirmed, holding that the officers’ actions did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. View "Escalera-Salgado v. United States" on Justia Law

The First Circuit affirmed the order of the district court exercising its ancillary jurisdiction to enforce a resolution issue by the Puerto Rico Secretary of Justice (Secretary) directing the Municipality of Juana Diaz (Municipality) to indemnify two municipal police officers found liable under Puerto Rico tort law after a federal jury trial for using excessive force resulting in a death, holding that ancillary enforcement jurisdiction was appropriate.Appellee and other family members filed this action after the shooting death of their relative at the hands of police. The jury returned a verdict for Appellee with respect to her negligence claims against two municipal police officers in their personal capacities, and the district court entered judgment against the officers. After the Secretary issued a resolution under a Puerto Rico statute referred to as “Law 9” requiring the Municipality to pay the judgments against its officers, Appellee filed a motion requesting the garnishment of the Municipality’s assets. The district court granted the motion. The First Circuit affirmed, holding that the district court had jurisdiction to enforce the Secretary’s Law 9 resolution against the Municipality. View "Burgos-Yantin v. Municipality of Juana Diaz" on Justia Law

The First Circuit affirmed the district court’s decision granting Defendants’ motion for summary judgment on Plaintiff’s 42 U.S.C. 1983 claim and dismissing Plaintiff’s Massachusetts state law negligence claim without prejudice, holding that the district court’s judgment was without error.Plaintiff, a pretrial detainee at the Massachusetts Correctional Institute-Framingham, sued Dr. Thomas Groblewski and the Massachusetts Partnership for Correctional Healthcare in federal district court, bringing a state law claim for common law negligence and a federal law claim under section 1983 for a violation of her Eighth Amendment right to be free from cruel and unusual punishment. The district court concluded that no reasonable jury could find that Groblewski acted with deliberate indifference to Plaintiff’s medical needs. The First Circuit affirmed, holding that the district court did not err in granting Defendants summary judgment on Plaintiff’s Eighth Amendment claim. View "Zingg v. Groblewski" on Justia Law

The First Circuit affirmed the district court’s dismissal of Plaintiff’s suit against Bloomberg News and authors of an article Plaintiff claimed rendered Bloomberg liable for several common-law torts, including defamation, holding that the suit was properly dismissed for Plaintiff's failure to allege sufficient facts to make out his claims.This case concerned an online article and TV interview in which Bloomberg reported that the Securities and Exchange Commission had opened an investigation to determine whether Plaintiff, a priest and hedge fund manager, had intentionally published false material about certain public companies. The district court granted Defendants’ motion to dismiss, concluding (1) Plaintiff was required to plausibly allege actual malice because he was at least a limited-purpose public figure, and Plaintiff failed to do so; and (2) Plaintiff failed to allege sufficient facts to make out a claim of intentional interference with prospective economic advantage. The First Circuit affirmed, holding that Plaintiff’s complaint did not narrate a claim for relief. View "Lemelson v. Bloomberg L.P." on Justia Law

The First Circuit affirmed the district court’s summary judgment findings, evidentiary rulings, and denials of various motions on claims brought by a member of the rock band BOSTON against a former BOSTON guitarist alleging trademark infringement and breach of contract and on the guitarist’s counterclaims alleging breach of contract and abuse of process.Donald Thomas Scholz sued Barry Goudreau alleging claims related to impermissible inferences that Goudreau had allegedly made regarding his former association with BOSTON. Goudreau counterclaimed. After the district court granted in part the parties’ respective motions for summary judgment, the remaining claims proceeded to trial. The jury found in favor of the respective defendants on the remaining claims. The parties cross-appealed. The First Circuit affirmed the district court and denied the appeals, holding that there was no error or abuse of discretion requiring reversal. View "Scholz v. Goudreau" on Justia Law