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

In 1996, TWA Flight 800 exploded in mid-air and crashed eight miles south of Long Island, New York. After an investigation that was the largest and most expensive in the history of the National Transportation Safety Board (NTSB), the NTSB accepted the CIA’s assessment of eyewitness accounts and concluded that a mechanical explosion caused the crash. Theorizing that the CIA was covering up the true cause of the crash, Plaintiff requested certain documents from the investigation. The district granted summary judgment for the CIA, concluding that the Freedom of Information Act permitted the agency to withhold the requested documents. The First Circuit affirmed the district court’s order granting the CIA’s motion for summary judgment, holding that the CIA properly withheld the materials under the Act. View "Stalcup v. Cent. Intelligence Agency" on Justia Law

The “B Prong” of the Massachusetts Independent Contractor Statute, Mass. Gen. Laws ch. 149, 148B(a)(2), requires that workers perform a service outside the usual course of the employer’s business to be classified as independent contractors. The Massachusetts Delivery Association (MDA) filed an action for a declaration that the B Prong is preempted by the Federal Aviation Administration Act (FAAAA), and for an injunction barring the Attorney General from enforcing section 148B(a)(2) against the MDA’s members. The FAAAA preempts state laws that “relate to” the prices, routes, or services of a motor carrier “with respect to the transportation of property.” The district court held that the FAAAA does not preempt section 148B(a)(2). The First Circuit reversed, holding that the district court incorrectly interpreted the preemption test under the FAAAA and incorrectly applied the test to section 148B(a)(2). Remanded. View "Mass. Delivery Ass’n v. Coakley" on Justia Law

The Massachusetts Registry of Motor Vehicles sought proposals from contractors to print and send registration renewal notices along with advertisements to raise revenue to defray costs. RMV would provide the contractor with information (name, address, date of birth, and license number) that was generally exempt from public disclosure under the Driver's Privacy Protection Act, 18 U.S.C. 2721-25, and Mass. Gen. Laws ch. 4, sect. 7, cl. 26(n), that the contractor would need to safeguard from unlawful public disclosure. Defendant's winning bid indicated that it understood and accepted the terms. The contract specified that Massachusetts would continue to exercise ownership over all personal data, and that a violation of the DPPA or the Massachusetts privacy law would cause the contract to terminate. Plaintiff, who received a registration renewal notice that included advertisements, filed a putative class action on behalf of himself and other drivers who, without providing consent, had received advertisements from defendant. The district court granted defendant judgment on the pleadings based on failure to join the Commonwealth as an indispensable party. The First Circuit affirmed, finding no violation of the DPPA. Defendant does not disclose the information it legitimately receives, as the state's contractor, to others. View "Downing v. Globe Direct LLC" on Justia Law

Airline insurance (USAUI) issued to Pace covered certain risks assumed by Pace in contractual arrangements with other companies, which generally consisted of charter programs. The policy referenced "legally obligated to pay as damages." Pace entered into a charter program contractual arrangement with Patriot, which entered into an agreement to transport L&M customers to destinations that L&M had booked for travelers. L&M purchased a required surety bond. In 2002, L&M claimed that Patriot had unlawfully refused to provide aircraft for scheduled flights, and Patriot contended that L&M not fulfilled payment obligations. Patriot terminated the agreement and, two months later, filed for bankruptcy under Chapter 11. L&M filed a proof of claim. The bankruptcy court disallowed the claim. In 2005, L&M filed suit, claiming coverage by policies, including the USAUI policy. The district court held that the policy did not provide coverage for a breach of contract claim. The First Circuit affirmed, finding no ambiguity in policy language.

The Massachusetts Delivery Association claimed that a state law is preempted as to motor carriers under the Federal Aviation Administration Authorization Act of 1994, 108 Stat. 1569, which expressly preempts state attempts to regulate "a price, route, or service of any motor carrier," The challenged state law, part of Mass. Gen. Laws ch. 149, sect. 148B(a)(2), which requires that an individual performing a service for another be classified as an employee unless "the service is performed outside the usual course of the business of the employer." The MDA also claimed that the state statute imposes an undue burden which violates the Commerce Clause. The district court found that Younger abstention was appropriate because, while the Association is not itself a party to relevant state litigation, three of its members are defendants in state civil proceedings brought not by the Attorney General (defendant in this case) but by private parties. The First Circuit remanded for the court to exercise jurisdiction, concluding that any decision will not interfere with pending state cases.

The airline sued federal employees, including an FAA principal maintenance inspector, claiming that intentional and improper delays with respect to inspections and certifications substantially destroyed its business. The district court dismissed most claims, but did not dismiss "Bivens" claims of violation of procedural due process rights and of retaliation for protected First Amendment activity. The First Circuit reversed, holding that the allegations were not sufficient to support denial of qualified immunity.