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

The First Circuit affirmed the district court's denial of HIMA San Pablo Caguas's motion for judgment as a matter of law as well as its remitted verdict after a jury found HIMA responsible for ten percent of Plaintiff's damages, holding that the jury had a legally sufficient evidentiary basis to find HIMA responsible for ten percent of Plaintiff's damages and that the district court did not abuse its discretion in remitting the verdict.Plaintiff's father died from complications relating to the removal of his dialysis catheter at a HIMA facility. Plaintiff sued HIMA and other defendants, alleging negligence. The jury found the co-defendants jointly liable for medical malpractice and awarded Plaintiff $1,000,000 in compensatory damages, finding HIMA responsible for ten percent of Plaintiff's damages. HIMA moved for judgment as a matter of law and, in the alternative, for remittitur of the jury's damages award. The district court denied the motion for judgment as a matter of law but granted remittitur, reducing the damages award to $400,000. The First Circuit affirmed, holding that the district court did not err in denying HIMA's motion for judgment of a matter of law and did not abue its discretion in applying the federal standard in its remittitur analysis and remitting the verdict. View "Suero-Algarin v. HIMA San Pablo Caguas" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment against Appellant and dismissing his race discrimination and retaliation claims against the Maine Department of Corrections (MDOC), holding that Appellant lacked the proof needed to reach trial.Appellant left his job with MDOC as a state corrections officer to apply for a position in the federal prison system. Appellant met the minimum qualification and interviewed for each open spot but was turned down each time. Appellant subsequently reapplied for his former job, but MDOC refused to rehire him. Appellant sued MDOC in federal court for race discrimination and retaliation. The district court judge granted summary judgment for MDOC. The First Circuit affirmed, holding that a reasonable jury could not find that MDOC's rejection of Appellant's application for reinstatement was a product of unlawful discrimination or made in retaliation for his complaint to the Maine Human Rights Commission. View "Brandt v. Fitzpatrick" on Justia Law

The First Circuit held that the New Hampshire Judicial Retirement Plan (Plan) does not allow a former judge who resigned with sufficient years of creditable service, but before reaching the minimum retirement age, to receive a Service Retirement Allowance (SRA) upon later reaching the retirement age.Plaintiff was fifty-four years old when she resigned from her position as a superior court justice for the state of New Hampshire. Plaintiff served in that position for sixteen-and-a-half years. At the age of sixty-one, Plaintiff applied for an SRA. The Board of Trustees of the Board of Trustees (Board) of the Plan denied her application. Plaintiff filed suit against the Plan seeking a declaratory judgment that she was eligible for an SRA. The district court granted summary judgment in favor of the Plan as to Plaintiff's claim for violation of N.H. Rev. Stat. 100-C, 5, concluding that the plain language of the statute requires a judge to be in active service when she elects to retire and claim a service retirement allowance. The First Circuit affirmed, holding that, under the circumstances of this case, Plaintiff was not eligible to receive an SRA on her application. View "Coffey v. New Hampshire Judicial Retirement Plan" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Employer in this disability discrimination case brought by Plaintiff, a former employee, holding that the district court did not err in entering summary judgment against Plaintiff on her claims.Plaintiff was a military veteran who suffers from post-traumatic stress disorder (PTSD). After she was discharged from her employment, Plaintiff sued Employer for disability discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Maine Human Rights Act, Me. Stat. tit. 5 4551-4634, alleging that she was wrongfully discharged based on her PTSD. Plaintiff also claimed that Employer unlawfully failed to accommodate her disability. The district court granted summary judgment for Employer. The First Circuit affirmed, holding that the district court properly granted summary judgment for Employer on Plaintiff's discriminatory discharge claim and failure to accommodate claim. View "Trahan v. Wayfair Maine LLC" on Justia Law

The First Circuit affirmed in part and vacated in part the judgment of the district court dismissing Plaintiff's case against various defendants, holding that the district court did not err in dismissing Plaintiff's federal law claims or state law negligent training/supervision claim but erred in dismissing Plaintiff's state law negligence claim.Kelsey Zell, a high school junior, was hit by a fellow student and sustained a concussion. Zell faced a one-day suspension for her role in the altercation. Zell and her parents (together, Plaintiffs) unsuccessfully challenged the suspension decision. Plaintiffs later filed a complaint against the school district's superintendent, the dean of students, and other school officials, alleging several claims. The district court dismissed the claims and denied Plaintiffs' motion to amend their complaint. The court then denied Defendants' motion for sanctions. The First Circuit affirmed in part and vacated in part, holding that the district court (1) did not err in dismissing Zell's federal law claims or state law negligent training/supervision claim and Zell's motion to amend as it relates to these issues; (2) did not err in denying the denial of Defendant's motion for sanctions against Zell's counsel; but (3) erred in dismissing Plaintiff's state law negligence claim. View "Zell v. Ricci" on Justia Law

The First Circuit affirmed Defendant's upwardly variant sentence for one count of possession with intent to distribute cocaine and one count of using a firearm during and in relation to a drug-trafficking crime, holding that the sentence was neither procedurally nor substantively unreasonable.Pursuant to a plea agreement, Defendant pled guilty to drug-related crimes. After a sentencing hearing, the district court sentenced Defendant to an upwardly variant sentence of 180 months of imprisonment, thus declining to impose the government's requested sentence. On appeal, Defendant challenged both the procedural and substantive reasonableness of his sentence. The First Circuit affirmed, holding that the 180-month sentence was neither procedurally nor substantively unreasonable. View "United States v. Diaz-Rivera" on Justia Law

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