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

The First Circuit summarily affirmed the district court’s dismissal of Plaintiffs’ claims that HSBC Bank USA, N.A. could not foreclose on their property under Mass. Gen. Laws ch. 244, 14 and that the mortgage encumbering their property was obsolete by operation of Mass. Gen. Laws ch. 260, 33, holding that the district court did not err in dismissing the claims.Plaintiffs borrowed money from a lender to purchase property. Plaintiffs executed a promissory note and mortgage identifying Mortgage Electronic Registration Systems, Inc. (MERS) as the mortgagee. MERS later assigned the mortgage to HSBC. After Plaintiffs defaulted on their loan HSBC provided notice of a foreclosure sale. Plaintiffs sued HSBC and Wells Fargo Bank, N.A., the mortgage servicer, to enjoin the sale. The district court denied Plaintiffs’ request for a preliminary injunction and granted Defendants’ motion to dismiss under Fed. R. Civ. P. 12(b)(6). The First Circuit affirmed, holding (1) Plaintiff's claim that HSBC cannot foreclose on the property on grounds that MERS's assignment of the mortgage to HSBC was invalid was foreclosed by precedent; and (2) the district court also properly dismissed Plaintiffs' obsolete mortgage claim, which had no basis in the plain text of Massachusetts's obsolete mortgage statute or in precedent. View "Hayden v. HSBC Bank USA, N.A." on Justia Law

In this lawsuit arising out of a foreclosure sale the First Circuit affirmed the district court's dismissal of Edythe Dyer's claims arguing that U.S. Bank was not a proper party to utilize the statutory power of sale, holding that U.S. Bank was authorized to exercise the statutory power of sale and that Dyer's Mass. Gen. Laws ch. 93A claim against Wells Fargo Bank, N.A. was properly dismissed.Edythe Dyer executed a promissory note to Dreamhouse Mortgage Corporation and granted a mortgage on her property to Mortgage Electronic Registration Systems, Inc. (MERS). MERS assigned the mortgage to U.S. Bank. Wells Fargo was U.S. Bank’s servicer of the loan. U.S. Bank later notified Dyer that it intended to foreclose on the property by utilizing the statutory power of sale provided for in Mass. Gen. Laws ch. 183, 21. Dyer filed suit naming U.S. Bank and Wells Fargo as defendants. The magistrate judge granted Defendants’ motion for judgment of the pleadings and dismissed all of Dyer’s claims. The First Circuit affirmed, holding (1) none of Dyer's arguments as to why U.S. Bank was not authorized to exercise the statutory power of sale had merit; and (2) the magistrate judge correctly dismissed Dyer’s Massachusetts General Laws Chapter 93A claim against Wells Fargo. View "Dyer v. Wells Fargo Bank, N.A." on Justia Law

The First Circuit affirmed the district court's dismissal of the complaint in this case for want of jurisdiction, holding that personal jurisdiction could not constitutionally be exercised over Defendant in Massachusetts.Defendant was an education institution incorporated in Alabama having its principal place of business there. Plaintiff, who had enrolled in Defendant's doctoral program in sports management, sued Defendant in a Massachusetts state court alleging breach of contract, unfair and deceptive business practices, unjust enrichment, and fraudulent inducement. Defendant removed the case to the federal district court then moved to dismiss the complaint for want of personal jurisdiction. The district court granted the motion, concluding that the court lacked general and specific jurisdiction over Defendant. The First Circuit affirmed, holding that the district court appropriately determined that neither general jurisdiction nor specific jurisdiction may constitutionally be exercised over Defendant in Massachusetts. View "Chen v. United States Sports Academy, Inc." on Justia Law

The First Circuit affirmed in part and vacated in part the decision of the district court dismissing Plaintiff's claims alleging violations of federal copyright law and various Puerto Rico laws, holding that the district court correctly held that the complaint failed to state a copyright claim because it did not allege registration but that the district court erred in holding that the complaint otherwise failed to state a copyright claim and dismissing the complaint with prejudice.Plaintiff sued Enrique Martin-Morales (aka Ricky Martin) and other unknown defendants regarding Plaintiff's music video for a music contest. Plaintiff alleged that Martin's music video for his song Vida was almost identical to the one that Plaintiff composed and created. The district court dismissed Plaintiff's claims pursuant to Fed. R. Civ. P. 12(b)(6). The First Circuit held (1) aside from registration, Plaintiff sufficiently alleged a copyright violation, and remand was required to allow the district court to consider whether the to dismiss the copyright claim without prejudice or to allow Plaintiff to supplement his complaint to allege registration; and (2) the district court correctly dismissed the state law claims. View "Cortes-Ramos v. Martin-Morales" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiffs' breach of contract action against Defendant, their insurer, holding that the district court properly dismissed for failure to state a claim Plaintiffs' claim that Defendant failed to defend and indemnify them in a state court action.Newton Covenant Church (NCC) was comprised of members of the Newton Presbyterian Church (NPC) who withdrew from the Presbyterian Church (USA) and affiliated with a non-Presbyterian organization. NPC and the Presbytery of Boston sued the NCC in the state superior court seeking, among other things, a declaratory judgment that NPC owned church property at 75 Vernon Street in Newton, Massachusetts. NCC submitted a notice to the Great American Insurance Company (GAIC) requesting a defense in the state court action under a Director and Officers insurance policy. GAIC denied coverage on the grounds that the named insured under the policy was NPC, not NCC. After the parties reached a settlement NCC and its individual officers (collectively, Plaintiffs) brought this action against GAIC for breach of contract. The district court dismissed the complaint. The First Circuit affirmed, holding that Plaintiffs' allegations were not reasonably susceptible of an interpretation that would state a claim covered under the policy. View "Newton Covenant Church v. Great American Insurance Co." on Justia Law

The First Circuit affirmed the district court's entry of summary judgment in favor of the Saco, Maine Shaw's Supermarket on Plaintiff's claim that Shaw's owed a duty to protect its patrons from foreseeable harm and that an attack on his wife in the store was foreseeable, holding that, under Maine law of premises liability, the harm must have been foreseeable, and the attack in this case was not foreseeable.Connor MacCalister attacked and killed Wendy Boudreau with a knife in the Saco Shaw's Supermarket. Jeffrey Boudreau, Wendy's husband and the executor of her estate, brought this action against Shaw's asserting wrongful death and conscious pain and suffering under Maine law. The district court entered summary judgment for Shaw's, concluding that Shaw's did not owe a duty under Maine wrongful death law to protect Wendy from the attack because it was not foreseeable. The First Circuit affirmed, holding (1) Shaw's did not owe a duty to protect Wendy from MacCalister; (2) the district court did not err in how it viewed the facts; and (3) there was no error in the district court's evidentiary rulings challenged on appeal. View "Boudreau v. Shaw's Supermarkets Inc." on Justia Law

The First Circuit declared that exclusion of otherwise eligible residents of Puerto Rico from receiving the disability benefits that are granted to persons residing in the fifty States, the District of Columbia, and the Northern Mariana Islands under the Supplemental Security Income (SSI) provisions of Title XVI of the Social Security Act, 42 U.S.C. 1381-1383(f) is not rationally related to a legitimate government interest and is invalid.While residing in New York, Defendant became eligible and commenced receiving SSI disability benefits. The benefits were discontinued when the Social Security Administration became award that Defendant had moved to Puerto Rico. The United States subsequently brought suit against Defendant seeking to collect the amount the SSA claimed was owed by Defendant due to the allegedly improper payment of SSI benefits since Defendant's relocation to Puerto Rico. Defendant raised as an affirmative defense that the exclusion of Puerto Rico residents from the SSI program violated the Equal Protection Clause. The district court granted summary judgment for Defendant, holding that Congress's actions in this case failed to pass rational basis constitutional muster. The First Circuit affirmed, holding that the Fifth Amendment forbids the categorial exclusion of Puerto Rico residents from SSI coverage. View "United States v. Vaello-Madero" on Justia Law

In this lawsuit brought against three Boston police officers who were involved in breaking up a party and arresting Plaintiffs, the First Circuit reversed the judgment for Plaintiffs, holding that the officers were entitled to qualified immunity for entering through the open door of a house under the community care taking exception to the Fourth Amendment's warrant requirement.Plaintiffs brought civil rights claims under 42 U.S.C. 1983 and Mass. Gen. Laws ch. 12, 11H and 11I, as well as state tort claims for, among other things, false imprisonment. The jury reached a unanimous verdict in favor of Defendants on all counts. The district court, however, granted Plaintiffs' motion for a new trial, finding that the verdict was against the law as to the officers' warrantless entry into the home and that the warrantless entry on the facts as presented in the trial was not protected by qualified immunity. The court then amended its judgment so that it reflected a judgment in favor of Plaintiffs as to the section 1983 unlawful entry claim. The First Circuit reversed, holding that the officers were entitled to qualified immunity because, under the community caretaking exception, their entry through the home's open door did not violate Plaintiffs' constitutional rights. View "Castagna v. Jean" on Justia Law

In this case, a byproduct of litigation stemming from the derailment of a Montreal, Maine & Atlantic Railway, Ltd. (MMA) freight train carrying crude oil in Lac-Megantic, Quebec, the First Circuit affirmed the district court's entry of judgment in favor of Robert Keath, the estate representative of MMA, and against creditor Wheeling & Lake Erie Railway Company, holding that, giving due deference to the fact-finder's resolution of the burden of proof, the judgment must be affirmed.One month after the derailment, MMA filed a voluntary petition for protection under Chapter 11 of the Bankruptcy Code. Wheeling instituted an adversary proceeding in the bankruptcy court against MMA and the estate representative, seeking a declaratory judgment regarding the existence and priority of its security interest in certain property of the MMA estate. The case involved intricate questions concerning secured transactions, carriage of goods, and corporate reorganization. After a settlement, the bankruptcy court ruled in favor of the estate representative. The First Circuit affirmed, holding (1) ultimately, this case turned on principals relating to the allocation of the burden of proof and the deference due to the finder of fact; and (2) giving due deference to the fact-finder's resolution of the burden of proof issue, the district court's judgment must be affirmed. View "Wheeling & Lake Erie Railway Co. v. Keach" on Justia Law

In this complaint alleging that Defendants intentionally or recklessly misled investors about Ocular Therapeutix, Inc.'s manufacturing problems the First Circuit affirmed the judgment of the district court dismissing Plaintiffs' complaint for failure to state a claim, holding that Plaintiffs failed to allege facts giving rise to a strong inference of scienter as required by the Private Securities Litigation Reform Act (PSLRA), 15 U.S.C. 78u-4, 78u-5.In 2015, Ocular submitted a new drug application to the FDA for approval of Dextenza. In 2017, the FDA published its observations of issues at Ocular's manufacturing facility, which resulted in a drop in the company's stock price. Plaintiffs, several shareholders, brought this securities fraud action on behalf of themselves and a putative class of investors alleging violations of section 10(b) of the Securities Exchange Act, 15 U.S.C. 78j(b) and section 20(a) of the Exchange Act, 15 U.S.C. 78t(a). The district court dismissed the complaint pursuant to Fed. R. Civ. P. 9(b) and 12(b)(6), the Exchange Act, and the PSLRA. The district court granted the motion and dismissed the complaint with prejudice. The First Circuit affirmed, holding that Plaintiffs did not allege facts giving rise to a strong inference of scienter as required by the PSLRA. View "In re Ocular Therapeutix Inc." on Justia Law