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

The First Circuit reversed the district court’s grant of summary judgment for Plaintiffs in this alleging that certain assets should have been distributed to the estate of the decedent in this case, holding that the district court improperly granted summary judgment for Plaintiffs.In 2003, the decedent established an individual retirement account (IRA) with Mesirow Financial (Mesirow IRA) and designated Alyssa Jane D’Amore, his then-wife, as beneficiary. The couple divorced, but the decedent never revoked the beneficiary of the designation. The decedent later transferred the majority of his Mesirow IRA assets to a TD Ameritrade IRA. Upon the decedent’s death, Mesirow distributed the remaining assets in the Mesirow IRA to D’Amore. Plaintiffs, the primary beneficiary of the decedent and the executor of the decedent’s estate, filed suit against D’Amore, alleging that the Mesirow assets should have instead been distributed to the decedent’s estate. The district court granted summary judgment for Plaintiffs. The First Circuit reversed and remanded with directions to enter summary judgment for D’Amore, holding that because a request to transfer all assets was never made, the beneficiary designation was never revoked and D’Amore was entitled to the remaining assets in the account upon the decedent’s death. View "Cooper v. D'Amore" on Justia Law

The First Circuit reversed the judgment of the district court and remanded this case involving the ownership of the Touro Synagogue building and associated land and rimonim used in the worship in the Touro Synagogue. Congregation Jeshuat Isreal (CJI) brought a declaratory judgment against Congregation Shearith Israel (CSI), and CSI counterclaimed. The district court concluded that CJI was owner of the rimonim and that CSI was owner of the building and real estate subject to a trust for CJI as representing the practitioners of Judaism in Newport, Rhode Island. The First Circuit reversed, holding that the only reasonable conclusions to be drawn from the parties’ own agreements determining property rights by instruments customarily considered by civil courts are that CSI owns both the rimonim and the real property free of any trust or other obligations to CJI except as lessor to CJI as holdover lessee. View "Congregation Jeshuat Israel v. Congregation Shearith Israel" on Justia Law

This case concerned defects in the execution of two life insurance annuity polices that the decedent purchased through National Western Life Insurance Co. Plaintiffs, the decedent’s wife and children, sued National Western seeking a declaration that the policies were void and a return of the premiums paid by the decedent. National Western filed a motion to dismiss because Plaintiffs failed to join a necessary party - the decedent’s brother, who was named under both policies as the sole beneficiary - even though National Western had already paid him. The district court denied the motion, ruling that the beneficiary at issue was not “required to be joined if feasible” under Fed. R. Civ. P. 19(a). The court then granted summary judgment for Plaintiffs. The First Circuit vacated the judgment of the district court, holding that the sole beneficiary of the annuities was required to be joined if feasible under rule 19(a). The court remanded the case to the district court to determine whether it was equitable for the case to proceed without him. View "Maldonado-Vinas v. National Western Life Insurance Co." on Justia Law

When the decedent in this case died he owed over $340,000 in unpaid federal income tax liabilities. The decedent was survived by his wife, Appellant, and four minor children. Appellant, the decedent’s wife, was appointed executrix of the decedent’s estate. When Appellant told the IRS she was not cooperate with the IRS’s attempt to collect on the estate’s federal tax debts, the IRS served Appellant with a formal notice of potential liability under the federal priority statute, 31 U.S.C. 3713. The government then sued the decedent’s estate and Appellant, both individually and in her capacity as executrix. The district court concluded that Appellant was personally liable for the value of the estate’s assets Appellant transferred to herself without first paying the estate’s federal tax debts. The district court then entered judgment holding that estate and Appellant as executrix liable for $351,218 and holding Appellant, individually, liable for $125,938. The First Circuit affirmed, holding that the district court did not err in entering summary judgment against Appellant personally, as the government showed that Appellant’s conduct satisfied the requirements of section 3713(b) to be held personally liable for amounts not paid to the United States. View "United States v. McNicol" on Justia Law

Father, a Florida resident, filed this diversity suit against Daughter, a Massachusetts resident, in the District of Massachusetts, alleging that Daughter, to whom he had given a power of attorney, breached her fiduciary duty to him. The jury returned a verdict in Father’s favor. Daughter appealed, and Father cross-appealed. The First Circuit affirmed, holding that the district court (1) did not err in denying Daughter’s motion for judgment as a matter of law; and (2) did not err in awarding Father prejudgment interest from the date that he filed this lawsuit rather than the date Daughter breached her fiduciary duty. View "Berkowitz v. Berkowitz" on Justia Law

Father, a Florida resident, filed this diversity suit against Daughter, a Massachusetts resident, in the District of Massachusetts, alleging that Daughter, to whom he had given a power of attorney, breached her fiduciary duty to him. The jury returned a verdict in Father’s favor. Daughter appealed, and Father cross-appealed. The First Circuit affirmed, holding that the district court (1) did not err in denying Daughter’s motion for judgment as a matter of law; and (2) did not err in awarding Father prejudgment interest from the date that he filed this lawsuit rather than the date Daughter breached her fiduciary duty. View "Berkowitz v. Berkowitz" on Justia Law

Appellant, acting in the capacity as the executor of the estate of Marion Bingham, brought this lawsuit against Supervalu, Inc., alleging that Supervalu acted as an insurer of one of its subsidiaries and violated Mass. Gen. Laws ch. 176D and Mass. Gen. Laws ch. 93A by failing to promptly and equitably resolve prior litigation between the subsidiary and the State. Supervalu removed the action to federal court, arguing that it was not in the business of insurance and was thus not subject to regulation under Chapter 176D. The district court granted summary judgment in favor of Supervalu, ruling that Supervalu was not in the business of insurance. The First Circuit affirmed, holding that the district court did not err in concluding that Supervalu was not in the business of insurance. View "Bingham v. Supervalu, Inc." on Justia Law

The litigation resulting in these consolidated appeals stemmed from disputes within the Cohen family. Maurice placed his assets the “Maurice Trust,” and after he died, the trust assets were passed to trust (“the QTIP Trust”), and to a charitable organization (“Fund”). After Maurice’s wife died, the remaining assets of the QTIP Trust rolled over to the Fund. Later, half of the Fund’s assets were given to a new charity, the C-S Foundation (“C-S”). The Fund’s successor, the FPE Foundation (“FPE”) filed this federal case against the Cohens’ two children, one of their spouses, and the advisor to the co-trustees of the QTIP Trust. FPE filed this federal case against members of the Cohen family, alleging that certain Defendants exceeded their powers as co-trustees of the QTIP trust and that the co-trustees’ advisor breached his fiduciary duty to that trust. C-S intervened and counterclaimed against FPE. Defendants filed a motion to dismiss and to compel arbitration, relying on an arbitration clause contained in the Maurice Trust. The district court allowed the motion. The First Circuit affirmed, holding (1) Defendants did not waive their right to arbitration, and thus, dismissal was appropriate; and (2) C-S’s counterclaim was subject to the arbitration clause in the Maurice Trust. View "FPE Found. v. Cohen" on Justia Law

T&N Limited (T&N), an asbestos manufacturer, chose to address the liability it faced after the deadly qualities of asbestos were discovered through a Chapter 11 bankruptcy reorganization plan (the Plan). Then Plan transferred to a Trust certain of T&N’s assets and rights, with which the Trust was to pay asbestos claims brought by persons who could have sued T&N but for T&N's bankruptcy. The Plan provided that T&N’s asbestos liability would continue after plan confirmation and that the Trust would bring asbestos suits against T&N as the agent of the actual claimants. In this lawsuit, the Trust brought an asbestos claim that had accrued a decade earlier. The district court dismissed the Trust’s suit on statute of limitations grounds, thus rejecting the Trust’s argument that it was allowed to bring asbestos claims that had not become stale prior to T&N’s filing for bankruptcy protection whenever it wished to do so. The First Circuit affirmed, holding that the Trust’s argument failed because the Plan unambiguously terminated the automatic stay and contained no provision that provided for any further tolling of the limitations period beyond that granted by the Bankruptcy Code. View "Barraford v. T&N Ltd." on Justia Law

The decedent died from electrocution while working on a telephone pole that was the purported partial responsibility of Puerto Rico Electric Power Authority (PREPA). Appellants, the decedent’s sisters, filed a wrongful death suit against PREPA and others in federal district court. PREPA filed a motion to dismiss for lack of subject matter jurisdiction, arguing that an additional, non-diverse member of the decedent’s estate, who was not made a party to the action, was indispensable, and his joinder destroyed the parties’ complete diversity. The district court agreed and dismissed the entire action, including the decedent’s estate survivorship action as well as individual actions by estate members and Appellants, who were not the decedent’s heirs. The First Circuit reversed, holding that the district court erred in dismissing Appellants’ personal actions, as the non-diverse absent party was not required to adjudicate the action because the members of the estate requested voluntary dismissal of their claims, which eliminated the survivorship action, leaving only Appellants’ claims, which were jurisdictionally sound. View "Aguayo-Cuevas v. P.R. Elec. Power Auth." on Justia Law