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

The First Circuit affirmed the judgment of the district court dismissing the claims in Plaintiffs' complaint against WM Capital Management, Inc. and granting summary judgment in favor of WM Capital on its counterclaim, holding that the district court did not err or abuse its discretion.This case arose from a dispute over the enforcement of a contract that controlled the liquidation and assignment of several mortgage notes. Plaintiffs initiated an action against WM Capital bringing claims for redemption of property and breach of contract. WM Capital filed a counterclaim seeking specific performance of the contract and joinder of Tenerife Real Estate Holdings, LLC, a signatory to the contract at issue. The district court joined Tenerife, dismissed Plaintiffs' complaint, and granted summary judgment for WM Capital on its counterclaim. The First Circuit affirmed, holding that the district court did not err. View "Almeida-Leon v. WM Capital Management, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Broadridge Financial Solutions, Inc. and dismissing Plaintiff's lawsuit claiming a violation of the Massachusetts Wage Act, Mass. Gen. Laws ch. 149, 148, 150, holding that the district court did not err.Plaintiff claimed that Broadbridge failed to make timely payment under the Act, arguing that, as a matter of statutory interpretation, the day an employee is discharged from employment under the Wage Act is the day the employee is told to stop performing work for his employer. The district court disagreed. The Supreme Court affirmed, holding that the day of discharge is the time for a final accounting and payment, the day of an employee's official discharge. View "Knous v. Broadridge Financial Solutions, Inc." on Justia Law

The First Circuit dismissed this appeal from the United States District Court for the District of Massachusetts denying Appellant's first preliminary injunction motion, holding that this Court had no appellate jurisdiction.Appellant filed a class action complaint in the Massachusetts district court under the Class Action Fairness Act, 28 U.S.C. 1332(d)(2) alleging that Uber Technologies, Inc. misclassified him and other drivers as independent contractors instead of employees. Appellant filed a motion for a preliminary injunction requiring Uber to alter its classification. The district court denied the motion. The First Circuit affirmed, holding that, due to the procedural posture of this case, this Court did not have jurisdiction to hear the appeal. View "Capriole v. Uber Technologies, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting Handy Technologies, Inc.'s motion to dismiss this putative class action and to compel individual arbitration, holding that the district court did not err in dismissing Maisha Emmanuel's suit.Emmanuel, who worked as a cleaner for Handy Technologies, Inc., brought this complaint on behalf of individuals who had worked for Handy as cleaners, alleging that Handy had misclassified the putative class members as independent contractors rather than employees, in violation of the Fair Labor Standards Act and Mass. Gen. Laws ch. 151, 1. Handy moved to dismiss and compel arbitration, arguing that the Independent Contractor Agreement that Emmanuel signed required arbitration of the claims at issue. The district court granted Handy's motion to compel arbitration and dismissed Emmanuel's putative class action claim. The First Circuit affirmed, holding (1) the district court did not err in ruling that, under Massachusetts law, Emmanuel had entered into an agreement to arbitrate; and (2) Emmanuel's unconscionability-based challenged to the ruling below failed. View "Emmanuel v. Handy Technologies, Inc." on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Insurer and dismissing Insureds' suit seeking to force Insurer to pay for damages Hurricane Maria inflicted on their property, holding that Insureds' claims on appeal failed.Hurricane Maria struck Puerto Rico on September 20, 2017. Insureds brought this suit on January 9, 2019. In granting summary judgment in favor of Insurer, the district court concluded that this suit was time-barred under the terms of the insurance contract. Under Puerto Rico law, prescription of actions is interrupted by their institution before the courts, by extrajudicial claim of the creditor, and by act of acknowledgement of the debt by the debtor. The First Circuit affirmed, holding (1) the district court did not err by crediting Insurer's declarations but not Insureds' declarations; (2) Insureds' claims lacked the specificity required to meet their burden of proving prescription; and (3) the remainder of Insureds' claims on appeal were barred. View "Marcano-Martinez v. Cooperative de Seguros Multiples de Puerto Rico" on Justia Law

The First Circuit denied Petitioner's petition for relief from removal on the grounds of asylum, withholding of removal under the Immigration and Nationality Act, and protection under the United Nations Convention Against Torture (CAT), holding that the Board of Immigration Appeals (BIA) did not err in affirming the immigration judge's (IJ) decision to deny Petitioner's application.Specifically, the First Circuit held (1) the record did not indicate that Petitioner either faced or would face persecution on the basis of his nationality, his religion, or his political beliefs; and (2) therefore, Petitioner was not able to meet the higher threshold for his claim of withholding of removal and his CAT claim. View "Thile v. Garland" on Justia Law

The Supreme Court affirmed Defendant's 2019 sentence in the District of Maine for one count of conspiracy to distribute and to possess with intent with distribute forty grams or more of fentanyl, holding that the sentence was not unreasonable.Defendant pled guilty pursuant to a plea agreement. Under the plea agreement, Defendant and the government agreed that they would both recommend a base offense level (BOL) under the Guidelines of twenty-eight. The district court, however, adopted the presentence investigation report's calculation of Defendant's guidelines sentencing range (GSR), which was based on a BOL of thirty. The Supreme Court affirmed the sentence, holding that the sentence was neither procedurally nor substantively unreasonable. View "United States v. Ayala" on Justia Law

In this civil forfeiture action against a 2008 33' Contender Model Tournament Vessel, the First Circuit affirmed the judgment of the district judge striking Appellants' answer and claims and granted the government's motion for default judgment, holding that the district court did not err.The district court entered default judgment in favor of the government due to Appellants continually missing their discovery deadlines. After Appellants once again missed a discovery deadline, the district court denied their motion for an extension. The court then granted the government's motion to strike Appellants' answer and claims and the motion for default judgment. The First Circuit affirmed, holding that the district judge was well within her discretion in striking Appellants' answer and claims and granting the government's motion for default judgment. View "United States v. De Jesus-Gomez" on Justia Law

The First Circuit affirmed the judgment of the district judge imposing three special conditions of supervised release after the revocation of Defendant's supervised release, holding that the special conditions were not unreasonable.On appeal, Defendant argued that the imposition of the conditions was procedurally unreasonable because the judge's explanation for the special conditions was insufficient and that the contested special conditions were substantively unreasonable. The First Circuit disagreed, holding (1) the special conditions were procedurally reasonable; and (2) Defendant's substantive unreasonableness challenge failed. View "United States v. McCullock" on Justia Law

The First Circuit denied Petitioners' petition for a writ of mandamus claiming that the district court erred in denying their bail application despite the ongoing COVID-19 pandemic, holding that the petition was without merit.Petitioners, immigration detainees held primarily at the Bristol County House of Correction, brought this petition for a writ of mandamus against Respondents, state immigration officials and federal United States Immigration and Customs Enforcement officials who secured Petitioners' detention after they were picked up and found to be in the United States illegally. Petitioners had all been denied bail and claimed that the district court erred in denying their bail applications. The First Circuit denied relief, holding that, under the circumstances of this case, there was no basis for either supervisory or advisory mandamus relief. View "Da Graca v. Souza" on Justia Law