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

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Defendant in this case alleging a violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., holding that genuine issues of material fact precluded summary judgment.Plaintiff, who was Black, sued Bridgewater State university's Board of Trustees and Office of Equal Opportunity and a University administrator (collectively, Defendants) alleging that she was not hired for a University position because of her race. The district court granted summary judgment in favor of Defendants. The First Circuit reversed, holding that Plaintiff's aggregate package of proof sufficed to survive Defendants' motion for summary judgment. View "Taite v. Bridgewater State University" on Justia Law

The First Circuit dismissed Plaintiffs' appeal for want of jurisdiction, holding that the Federal Rules of Bankruptcy Procedure (the bankruptcy rules), and not the Federal Rules of Civil Procedure (the civil rules), govern cases that have come within the federal district court's jurisdiction as cases "related to" a pending bankruptcy proceeding. 28 U.S.C. 1334(b).In this case arising from the derailment and explosion in Lac-Megantic, Canada, Plaintiffs brought thirty-nine separate suits against several defendants. The derailment occurred on the watch of Montreal, Maine and Atlantic Railway (MMA). MMA sought the protection of the bankruptcy court. Plaintiffs' suits were removed to federal district court. Plaintiffs subsequently joined Canadian Pacific Railway Company as an additional defendant. The suits were centralized in the District of Maine. The district court later granted Plaintiffs' request to dismiss their claims against all defendants except Canadian Pacific pursuant to a settlement agreement that was part of MMA's plan of liquidation. The district court entered judgment for Canadian Pacific. Plaintiffs moved for reconsideration of their motion to file an amended complaint. The district court denied the motion as untimely. The First Circuit dismissed Plaintiffs' appeal, holding that the Bankruptcy Rules governed the procedural aspects of this case, Plaintiffs' motion to reconsider was untimely, and the attempted appeal was untimely. View "Roy v. Canadian Pacific Railway Co." on Justia Law

The First Circuit reversed the order of the district court excluding two documents from the summary judgment record and granting summary judgment for Defendant on all of Plaintiff's claims, holding that the district court erred in excluding the two documents from the summary judgment record.Defendant terminated Defendant's employment after he had been employed for thirty-three years. Plaintiff brought this lawsuit alleging wrongful termination of his employment under state law and age discrimination under federal and state law. Defendant moved to strike two of Plaintiff's documents on the grounds that they had been produced after the discovery cut-off date and that they were not properly authenticated. The district court granted the motion to strike the documents and then granted Defendant's motion for summary judgment. The First Circuit reversed the order excluding the documents and vacated the entry of summary judgment, holding that the court erred in striking the documents and that material issues of fact precluded summary judgment. View "Zampierollo-Rheinfeldt v. Ingersoll-Rand de Puerto Rico, Inc." on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Bautista Cayman Asset Company in its action for collection of monies and foreclosure of collateral against Fountainebleu Plaza, S.E., Edwin Loubriel Ortiz, and Sedcorp, Inc., holding that remand was required for the sole purpose of better determining the amount due.Fountainebleu and Loubriel (collectively, Appellants) appealed the district court's judgment, arguing that the district court lacked subject matter jurisdiction over the case and that, alternatively, genuine issues of material fact precluded summary judgment. The First Circuit vacated the judgment, holding that because the record failed to account for payments made to Bautista's predecessor, the case must be remanded for the sole purpose of better determining the amount due. View "Bautista Cayman Asset Co. v. Fountainebleu Plaza, S.E." on Justia Law

The First Circuit affirmed the judgment of the Title III court holding that Claimants, who invested in mutual funds that owned bonds issued by the Commonwealth of Puerto Rico and filed proofs of claim in the Commonwealth's Title III case, lacked standing to recover damages directly from the Commonwealth for losses suffered by the mutual funds, holding that there was not a basis in law for this lawsuit.The Claimants alleged that they had a right to recover damages directly from the Commonwealth for losses suffered by the mutual funds in those investments. The title III court concluded that Claimants lacked standing because they did not own any bonds issued by the Commonwealth and that the Claimants' ownership interest in the mutual funds did not give them a right to recover against the Commonwealth. The Title III court subsequently denied the Claimants' motions for reconsideration. The First Circuit affirmed, holding that the Title III court did not err in its standing analysis, either in its initial decision disallowing the Claimants' claims or in its consideration of the two motions for reconsideration. View "Diaz Mayoral v. Financial Oversight & Management Board for Puerto Rico" on Justia Law

The First Circuit denied Petitioners' petition for review from the decision of the Benefits Review Board affirming an administrative law judge's denial of Petitioners' claims for compensation under the Defense Base Act, holding that there was no error in the proceedings below.After a United States military aircraft carrying nuclear weapons crashed near Thule, Greenland in 1968 and released radioactive materials into the area, military and civilian personnel assisted in the cleanup efforts. In 2010, Petitioners, some of the civilian personnel, filed claims for compensation, asserting that they were exposed to plutonium radiation at the site, leading to their development of various illnesses. An administrative law judge denied the claims, concluding that Petitioners did not establish a causal connection between their illnesses and any alleged plutonium exposure. The Benefits Review Board affirmed. The First Circuit affirmed, holding that Petitioners' arguments were unavailing. View "Carswell v. E. Pihl & Sons" on Justia Law

The First Circuit granted the application of the National Labor Relations Board for enforcement of one of its orders and struck those portions of the order requiring Maine Coast Regional Health Facilities, d/b/a Maine Coast Memorial Hospital (MCMH) to post repudiation notices at facilities operated by other corporate entities, holding that the Board improperly extended its remedy to MCMH's parent corporation.The Board concluded the MCMH violated violated federal labor laws but firing an employee after she wrote a letter to the editor of a local newspaper and committed a separate violation by maintaining a media policy prohibiting contact between employees and the media. The Board extended its remedy to Eastern Maine Healthcare Systems (EMHS), MCMH's parent corporation, which was not a party to the proceeding. The Board then sought enforcement of its order. The First Circuit granted the application but struck the pertinent portions of the order, holding that there was no basis for concluding that EMHS was joined as a party or that MCMH consented to extending the remedy beyond its corporate borders. View "National Labor Relations Board v. Maine Coast Regional Health Facilities" on Justia Law

The First Circuit affirmed Defendant's sentence for several drug-related offenses, including violations of the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. 70503 and 70506, holding that the MDLEA offenses were not eligible for "safety valve" relief under the then-applicable safety valve provision.At the time Defendant pleaded guilty to all counts in the indictment, the MDLEA offenses carried a minimum sentence of ten years' imprisonment. Before sentencing, Defendant argued that he qualified for safety valve relief authorizing a district court to impose a sentence below the statutorily prescribed mandatory minimum sentence. The district court sentenced Defendant to the mandatory minimum sentence of ten years' imprisonment, holding that Defendant was not entitled to safety valve relief because his MDLEA offenses were not among those specifically enumerated in the safety valve statute. The First Circuit affirmed, holding that an MDLEA offense is not offense eligible for safety valve relief. View "United States v. De La Cruz" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's suit against the United States under the Federal Tort Claims Act (FTCA), 28 U.S.C. 1346(b), 2671-2680, holding that the district court properly found that the United States was entitled to sovereign immunity pursuant to the FTCA's "discretionary function exception."As part of an annual "Change of Command" ceremony, the Ancient and Honorable Artillery Company of Massachusetts, a historic military organization with no present-day military functions, arranged for military artillery to be fired within Boston Common by the Massachusetts Army National Guard (MANG). The noise produced from howitzers firing blank rounds cased Plaintiff to suffer permanent hearing damage. The district court dismissed the case for lack of subject matter jurisdiction. The First Circuit affirmed, holding (1) Plaintiff did not meet his burden of alleging facts that would support a finding that MANG's exercise of discretion was not susceptible to policy analysis; and (2) the challenged actions taken in this case did not fall outside the realm of possible policy decisions. View "Davallou v. United States" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants - various prison officials, the Massachusetts Department of Correction (DOC), and Plaintiff's prison physician - and dismissing Plaintiff's complaint for injunctive and declaratory relief and damages, holding that there was no error in the proceedings below.Plaintiff, an inmate at MCI-Concord in Massachusetts, brought this pro se complaint challenging the termination of his access to the prison's first-floor Lexis Nexis terminal and typewriter, where Plaintiff spent more than two years conducting legal research and creating legal documents. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding (1) Plaintiff's speculative arguments as to the summary judgment in favor of his prison doctor were not enough to summary judgment; (2) the district court properly found that the DOC defendants' legitimate explanations were not pretextual; and (3) the district court did not err in determining that there was no triable issue of material fact that Defendants subjected Plaintiff to cruel and unusual punishment by discontinuing Plaintiff's reliance upon the first-floor terminal. View "Snell v. Neville" on Justia Law