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

The First Circuit affirmed the district court's final judgment against Plaintiffs on their claims that Uber Technologies competed unlawfully in the on-demand, ride-hail ground transportation in and around Boston, Massachusetts, holding that Uber did not compete unfairly in violation of statutory and common law prohibitions governing the commercial marketplace.Plaintiffs - owners of companies that dispatched, leased, and maintained taxicab vehicles and owned taxi medallions - brought this complaint alleging that, in violation of Boston regulations, Uber caused asset devaluation by competing unfairly under Mass. Gen. Laws ch. 93A, violating the common law for unfair competition, and aiding and abetting a conspiracy to engage in unfair competition. The district court issued judgment in favor of Defendants. The First Circuit affirmed, holding that Uber's conduct in the transportation market during a period of regulatory uncertainty did not violate the statutory or common law governing the commercial marketplace. View "Anoush Cab, Inc. v. Uber Technologies, Inc." on Justia Law

The First Circuit denied Petitioner's petition for review of the final decision of the Federal Motor Carrier Safety Administration (the FMSCA) determining that Sorreda Transport, LLC's business safety rating was unsatisfactory, holding that the the FMSCA's findings and conclusions were supported by substantial evidence in the record and its decision denying Sorreda's petition for review was not arbitrary or capricious.After the FMSCA, an agency within the United States Department of Transportation that regulates the trucking industry, used a notice informing Sorreda of its proposed unsatisfactory rating, Sorreda appealed. The FMSCA issued a final order denying Sorreda's petition for administrative review. Sorreda then filed a timely petition for review in the First Circuit. The First Circuit denied the petition, holding that the FMSCA's findings were supported by substantial evidence and that its determination that Sorreda's business safety rating was unsatisfactory was neither arbitrary nor capricious under the applicable regulations. View "Sorreda Transport, LLC v. United States Department of Transportation" on Justia Law

The First Circuit reversed the judgment of the district court dismissing for want of jurisdiction under the Tax Injunction Act (TIA) this lawsuit asking that the district court enjoin the collection of certain Rhode Island tolls as violative of the Commerce Clause of the United States Constitution, holding that the TIA's prohibition stating that district courts shall not enjoin levy or collection of "any tax under State law" where a remedy may be had in state courts is inapplicable to the Rhode Island tolls.A Rhode Island statute authorized the Rhode Island Department of Transportation to collect from tractor-trailers certain tolls in order to pay for replacement, reconstruction, maintenance, and operation of Rhode Island bridges. Plaintiff trucking entities brought this lawsuit. The district court dismissed the lawsuit, concluding that it lacked jurisdiction under the TIA. The First Circuit reversed, holding the the tolls in this case were not a "tax" under the statute. View "American Trucking Ass'n v. Alviti" on Justia Law

In this Title III adversary proceeding the First Circuit affirmed the judgment of the district court dismissing Ambac Assurance Corporation's constitutional and statutory challenges to measures the Commonwealth of Puerto Rico has taken to block payments to holders of Puerto Rico Highways and Transportation Authority (HTA) bonds, holding that the Title III court lacked the authority to grant the declaratory and injunctive relief that Ambac sought.Ambac, a financial guaranty insurer and individual holder of HTA bonds, commenced this adversary action in the so-called Title III court within the context of HTA's debt-adjustment proceedings pursuant to the Puerto Rico Oversight, Management, and Economic Stability Act. Ambac brought Contracts Clause, Takings Clause, Due Process Clause, preemption, and statutory challenges to the Commonwealth's actions and sought a negative injunction preventing the Commonwealth from continuing to impair the flow of HTA revenues to bondholders. The Title III court dismissed the complaint with prejudice. The First Circuit affirmed, holding that the Title III court was barred from granting Ambac declaratory or injunctive relief in this case. View "Ambac Assurance Corp. v. Commonwealth of Puerto Rico" on Justia Law

In this consolidated appeal from adversary proceedings challenging an alleged diversion of funds to which Peaje Investments LLC (Peaje) claimed it was entitled, the First Circuit held that Peaje did not hold a statutory lien on certain toll revenues of the Puerto Rico Highways and Transportation Authority (Authority).The Authority and the Commonwealth of Puerto Rico commenced bankruptcy cases under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act, 48 U.S.C. 2101-2241. Peaje, the beneficial owner of $65 million of uninsured bonds issued by the Authority, instituted adversary proceedings alleging that its bonds were secured by a lien on certain Authority toll revenues and that the Authority and the Commonwealth of Puerto Rico were diverting funds to which Peaje was entitled under the lien and using them for purposes other than paying the bonds. The First Circuit affirmed the Title III court’s primary grounds for its order denying Peaje’s request for a preliminary injunction and relief from the stay and otherwise vacated and remanded the matter, holding (1) Peaje did not hold a statutory lien on Authority toll revenues; and (2) now that it is clear that Peaje has no statutory lien, the district court’s alternative reasons for denying relief should be reconsidered de novo on an updated record. View "Peaje Investments LLC v. Puerto Rico Highways & Transportation Authority" on Justia Law

In this action brought under the Interstate Commerce Commission Termination Act (ICCTA) the First Circuit denied the petition for review filed by Petitioners, holding that the Surface Transportation Board (STB) did not err by concluding that certain activities at a Grafton & Upton Railroad Company (G&U) facility involving wood pellets qualified as “transportation by rail carrier” and so fell within the exclusive jurisdiction of the STB.The Upton, Massachusetts board of selectmen concluded that the ICCTA preempted local regulation of the wood-pellet activities at G&U’s local facility. Petitioners, who lived near the facility, asked the STB for a declaratory order that these activities were not part of “transportation by rail carrier” under ICCTA because they were manufacturing activities, and therefore, there could be no federal preemption of otherwise-applicable state and local regulations. The STB concluded that the complained-about activities qualified as “transportation” under the ICCTA and therefore fell within the STB’s jurisdiction. The First Circuit denied Petitioners’ petition for review, holding that Petitioners failed to show that the STB acted arbitrarily or capriciously, abused its discretion, or otherwise violated the law. View "Del Grosso v. Surface Transportation Board" on Justia Law

The Federal Motor Carrier Safety Administration (FMSCA) maintains a database of inspection history and safety records relating to commercial motor vehicle operators. Appellants, a group of commercial motor vehicle operators, brought suit against the FMSCA and the Department of Transportation, arguing that the potential disclosure to employers of “non-serious” driver-related safety records contained in the database violates the Privacy Act. The district court granted the FMCSA’s motion to dismiss for failure to state a claim, concluding that 49 U.S.C. 31150 was ambiguous as to the agency’s authority to include non-serious driver-related safety violations in the database and, further, that the agency’s interpretation of section 31150 was a reasonable and permissible construction of the statute and was entitled to Chevron deference. The First Circuit affirmed, holding (1) section 31150 is ambiguous as to the question of non-serious driver-related safety violations; and (2) the agency’s interpretation of the statute is not arbitrary, capricious, or manifestly contrary to the statute. View "Flock v. United States Department of Transportation" on Justia Law

The Massachusetts Delivery Association (MDA), a trade organization representing same-day delivery companies in Massachusetts, brought this suit on behalf of its members seeking a declaration that “Prong 2” of the Massachusetts Independent Contractor Statute is preempted by the Federal Aviation Administration Authorization Act (FAAAA) as well as an injunction barring the Attorney General from enforcing Prong 2 against its members. After the First Circuit twice remanded the case, the district court held that the FAAAA preempts Prong 2 as to the members of the MDA as a matter of logical effect. Applying the logic of the First Circuit's decision in Schwann v. FedEx Ground Package System, Inc., the First Circuit affirmed, holding that the application of Prong 2 to the members of the MDA is preempted by the FAAAA. View "Massachusetts Delivery Ass’n v. Healey" on Justia Law

Plaintiffs, individuals who contracted with FedEx to provide pick-up and delivery services, filed a complaint claiming that FedEx should have treated and paid them as employees rather than as independent contractors because FedEx could not satisfy all three requirements under the Massachusetts Independent Contractor Statute (Massachusetts Statute). Plaintiffs sought damages for loss of wages, improper wage deductions, and loss of benefits. The district court ultimately granted FedEx summary judgment on all counts, concluding (1) application of one of the requirements of the Massachusetts Statute is preempted by the Federal Aviation Administration Authorization Act (FAAAA), and this preempted requirement is not severable from the two remaining requirements; and (2) the remaining two requirements are preempted. The First Circuit reversed, holding (1) the express preemption provision of the FAAAA preempts the application of one of the Massachusetts Statute’s requirements to FedEx, but the preempted requirement is severable from the two remaining requirements; and (2) the district court erred by concluding, sua sponte, that application of the remaining two requirements was also preempted by the FAAAA. View "Schwann v. FedEx Ground Package Sys., Inc." on Justia Law

The Town of Portsmouth, Rhode Island filed claims against various federal and state transportation agencies and officers in federal district court challenging tolls collected on the Sakonnet River Bridge. The Town alleged that the tolls violated of the anti-tolling provision of the Federal-Aid Highway Act and the National Environmental Policy Act and sought injunctive and declaratory relief, attorney fees, and unspecified general relief. After the Town filed suit, the Rhode Island legislature repealed the tolls. Thereafter, the Town filed a motion seeking restitution of previously collected tolls. The district court granted Defendants’ motion to dismiss all claims as having been rendered moot by the legislative repeal. The First Circuit affirmed, holding (1) the district court correctly found that the legislative repeal rendered moot the Town’s claims for injunctive and declaratory relief; and (2) the Town did not sufficiently allege or preserve a restitution claim, and even if it did, the restitution claim would still fail because the Town lacked a right of action. View "Town of Portsmouth v. Lewis" on Justia Law