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

The First Circuit reversed the judgment of the district court entering summary judgment against a group of jockeys who demanded higher wages and refused to rice and vacated the orders permanently enjoining the work stoppage and imposing $1,190,685 in damages, holding that the district court erred in granting Plaintiffs an injunction and summary judgment.Plaintiffs, an association of horse owners and the owner of a racetrack, brought this action against the jockeys and their spouses who refused to race, alleging that Defendants engaged in a group boycott in violation of federal antitrust law. The district court granted an injunction, concluding (1) the jockeys were independent contractors and had acted in concert to restrain trade, and (2) the jockeys could not benefit from the labor-dispute exemption because of their independent contractor status. The First Circuit reversed, holding (1) the labor-dispute exemption applied in this case; and (2) therefore, the district court erred in granting Plaintiffs and injunction and summary judgment. View "Confederacion Hipica de Puerto Rico v. Confederacion de Jinetes Puertorriqueños, Inc." on Justia Law

The First Circuit affirmed Defendant's sentences imposed in connection with his plea of guilty to two carjacking counts and one firearm possession count, holding that Defendant's arguments on appeal were without merit.Pursuant to a plea agreement, Defendant pleaded guilty to three specified counts. The district court imposed an aggregate sentence of 150 months' imprisonment. On appeal, Defendant argued that his sentence was both procedurally and substantively unreasonable. The First Circuit affirmed, holding (1) Defendant's claims of procedural unreasonableness lacked merit; and (2) the 150-month aggregate sentence was substantively reasonable. View "United States v. Ortiz-Perez" on Justia Law

The First Circuit reversed the order of the district court issued under the stay-put provision of the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1415(j), ordering Portland Public Schools to pay for John Doe's placement at a private school during the pendency of these proceedings, holding that the district court erred.During Doe's fourth-grade year, his parents unilaterally placed him at a private school. The Does subsequently filed for a due process hearing alleging that Portland violated the IDEA by previously finding Doe ineligible for special education services. The district court ordered Portland to pay for Doe's tuition for the duration of this litigation at Aucocisco School, where his parents had unilaterally placed him despite the fact that the hearing officer whose decision was being reviewed had determined that the individualized education plan issued by Portland would provide a free appropriate public education. Portland appealed, arguing that the district court impermissibly ordered it to pay for Doe's placement at the private school during the pendency of these proceedings. The First Circuit reversed, holding that the purposes of the IDEA were not served by having Portland continue to pay for Doe's tuition at Aucocisco. View "Doe v. Portland Public Schools" on Justia Law

The First Circuit vacated the order of the district court dismissing this action, holding that the court erred in characterizing the forum selection clause in this case as mandatory.Plaintiff Zuleyka Rivera, a former Miss Universe, sued Kress Stores of Puerto Rico, Inc. and Mark Berezdivin in federal district court alleging breach of contract and tort claims in connection with an agreement between the parties granting Kress Stores exclusive rights to use Plaintiff's name, pageant title, image, and likeness for the development and promotion of branded items of apparel and fragrances. When Kress Stores failed to pay Plaintiff the stipulated annual stipend she sued in federal district court. The district court granted Kress Stores' motion to dismiss, concluding that the suit was brought in contravention of the agreement's forum selection clause. The First Circuit vacated the judgment below, holding (1) the agreement's forum selection clause did not by its terms exclude jurisdiction in another court; and (2) therefore, the district court erred in dismissing the action based on the forum selection clause. View "Rivera v. Kress Stores of Puerto Rico, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment to IKO Industries, Inc. (IKO) on the Massachusetts state law contractual and consumer protection claims that Armand Bessette asserted with respect to roofing shingles that IKO manufactured and that he purchased in 1999, holding that there was no error or abuse of discretion.In 2018, after having replaced the singles on the roof his home, Bessette brought suit against IKO in Massachusetts state court alleging claims under Massachusetts law in connection with the alleged premature deterioration of the shingles. IKO removed the case to the federal district court, which granted summary judgment in favor of IKO. Bessette appealed, challenging the summary judgment on his express warranty and implied warranty of merchantability claims and claims alleging a violation of Chapter 93A, the Massachusetts consumer protection law. The First Circuit affirmed, holding that the district court properly granted summary judgment to IKO on the three claims at issue on appeal. View "Bessette v. IKO Industries, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants and dismissing this lawsuit alleging various Massachusetts law claims based on a purported manufacturing defect in a Kawasaki motorcycle owned and ridden by Junior Williams, holding that there was no error.Junior Williams suffered severe injuries, including second- and third-degree burns, when his 2007 Kawasaki motorcycle collided with a Jeep and a fire resulted. Williams brought this lawsuit against the designer and manufacturer and the distributor of Kawasaki brand motorcycles. The district court granted summary judgment for the Kawasaki defendants and against Williams, concluding that the opinions of Williams's proffered liability expert as to defect and causation should be excluded, and therefore Williams lacked expert testimony on these topics. The First Circuit affirmed on other grounds, holding that even assuming that the expert opinion testimony was admissible, Williams failed to satisfy his burden of proving causation by a preponderance of the evidence. View "Williams v. Kawasaki Motors Corp., U.S.A." on Justia Law

The First Circuit affirmed the judgment and order of the district court granting summary judgment for Lender and denying Borrowers' motion for reconsideration in this lawsuit brought by Lender seeking repayment and foreclosure of a loan, holding that the district court did not err.Borrowers defaulted on a loan extended by Lender. The loan was subject to the Farm Credit Act, 12 U.S.C. 2001 et seq., which sometimes requires the lender to restructure the loan rather than foreclose. Borrowers applied to restructure the distressed loan, but Lender rejected the application. Lender eventually brought this action, and the district court ultimately granted summary judgment for Lender. The First Circuit affirmed, holding (1) a lender need not accept a plan of restructuring that the borrower cannot perform; and (2) the district court did not err in finding that Lender properly considered and rejected the requested restructuring. View "Puerto Rico Farm Credit, ACA v. Eco-Parque del Tanama Corp." on Justia Law

The First Circuit affirmed the judgment of the district court granting motions to dismiss filed by defendants Charles Taylor Consulting Mexico, S.A. de C.V., James Heiden, and Pierre Barron (collectively, Charles Taylor) and Universal Insurance Co. for failure to state a claim under the Racketeer Influence and Corrupt Organizations Act (RICO), 18 U.S.C. 1961 et seq., holding that there was no error.Plaintiffs OK Resorts of Puerto Rico, Inc., Executive Fantasy Hotel, Inc., and Riverside Resort, Inc. (collectively, OK Resorts) brought this action against Charles Taylor under RICO and Puerto Rico law. The district court granted Charles Taylor's motions to dismiss after the agreed-upon discovery deadline had passed. On appeal, OK Resorts argued that the district court abused its discretion in dismissing he amended complaint at the time it did. The First Circuit affirmed, holding that the district court did not abuse its discretion. View "OK Resorts of Puerto Rico, Inc. v. Charles Taylor Consulting Mexico, S.A. de C.V." on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession with intent to distribute cocaine and one count of importation of cocaine and his sentence of a term of imprisonment of 120 months to be followed by a five-year term of supervised release, holding that there was no error in the proceedings below.Specifically, the First Circuit held that the district court did not abuse its discretion in (1) admitting evidence, including the testimony of a canine handler that a drug sniffing dog alerted to Defendant vehicle eighteen days prior as "other-acts" evidence pursuant to Fed. R. Evid. 404(b); (2) admitting testimony of a Homeland Security Investigations agent about the practices of drug traffickers smuggling drugs into Puerto Rico as that of a lay witness opinion pursuant to Fed. R. Evid. 701; and (3) failing sua sponte to order a competency evaluation prior to or during Defendant's sentencing hearing. View "United States v. Agramonte-Quezada" on Justia Law

The First Circuit affirmed the ruling of the district court denying Plaintiffs' motion for a preliminary injunction in this case arising from a decision by the Speaker of the New Hampshire House of Representatives to enforce a House rule precluding any representative from participating in proceedings involving the full House, including House matters, other than in person, holding that there was no error.At issue in this COVID-19 pandemic-related case was whether Title II of the Americans with Disabilities Act (ADA) or section 504 of the Rehabilitation Act (RHA) authorizes a federal court to resolve a dispute among members of a state legislative body about whether votes on bills may be cast remotely rather than in person. The underlying suit named Sherman Packard, the Speaker of the House, in his official capacity. The district court denied a preliminary injunction based on the Speaker's assertion of legislative immunity. A panel of the First Circuit first vacated the injunction, but the Court subsequently granted a rehearing en banc. The First Circuit then affirmed, holding that the district court did not err in holding that the Speaker's assertion of legislative immunity prevented Plaintiffs from obtaining their requested relief. View "Cushing v. Packard" on Justia Law