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

The First Circuit affirmed the judgment of the district court dismissing Plaintiff’s claims under 42 U.S.C. 1983 and various state laws, holding that the district court properly dismissed Plaintiff’s claims under Fed. R. Civ. P. 12(b)(6).Plaintiff, a captain in the Chicopee Police Department, brought this action against the City, its police chief and mayor, a fellow police officer, and other defendants, alleging that his First Amendment rights were violated after Defendants improperly targeted him for “speaking out and participating in a government investigation.” The district court dismissed Plaintiff’s claimed under Rule 12(b)(6). The First Circuit affirmed, holding that the district court (1) properly dismissed Plaintiff’s First Amendment claim because al of Plaintiff’s speech was made within the scope of his official duties rather than as a citizen; and (2) did not err in dismissing the state law claims. View "Gilbert v. City of Chicopee" on Justia Law

In these consolidated appeals, the First Circuit affirmed the judgments of the district court finding that Thomas & Betts was “liable to” New Albertson’s and other parties were “liable to” Thomas & Betts for certain portions of “response costs” that had been incurred in the cleanup of Mother Brook, a canal in Boston, Massachusetts, following the canal’s contamination by polychlorinated biphenyls.The canal’s cleanup resulted in a lawsuit in which Thomas & Betts and New Albertson’s brought Massachusetts law claims against each other and various third parties. The claims were primarily brought under Mass. Gen. Laws ch. 21E, 4 seeking reimbursement for the money each party had spent on the cleanup. The jury allocated the percentage of the response costs that each of the various parties were responsible for reimbursing to, respectively, New Albertson’s and Thomas & Betts. The district court awarded prejudgment interest to New Albertson’s and Thomas & Betts on the funds that had been awarded to each of them on their chapter 4 claims and then awarded New Albertson’s attorney’s fees. The First Circuit affirmed, holding that no reversible error occurred in the proceedings below. View "Thomas & Betts Corp. v. Alfa Laval Inc." on Justia Law

The First Circuit affirmed Defendant’s conviction of attempted coercion and enticement of a minor to engage in sexual activity for which Defendant could be charged with sexual assault under the laws of Puerto Rico, holding that the evidence was sufficient to support the conviction and that Defendant could not prevail on his challenges to the jury instructions.At issue on appeal was whether Defendant could be charged with sexual assault under Puerto Rico law when the person he tried to entice was an adult federal agent posing as a minor. The First Circuit held (1) because Defendant was clearly attempting to have sex with a child, he was plainly violating Puerto Rico law; and (2) Defendant’s challenges to the jury instructions failed. View "United States v. Saldana-Rivera" on Justia Law

In these appeals involving bonds issued in 2008 by the Employees Retirement System (the System) of the Government of the Commonwealth of Puerto Rico, which were purchased by bondholders (the Bondholders), the First Circuit held that the Bondholders satisfied the filing requirements for perfection of their security interest as of December 17, 2016, thus reversing the district court’s ruling that the Bondholders’ interest was not perfected and so could be avoided.The bond documentation here offered as security certain property belonging or owed to the System. When the Bondholders claimed a perfected security interest in that property, the System filed suit seeking declaratory judgments relating to the Bondholders’ asserted security interest. The Bondholders counterclaimed. The district court granted summary judgment in favor of the System, concluding that the Bondholders’ interest was not perfected. The First Circuit disagreed, holding that while financing statements filed in 2008 did not perfect the Bondholders’ security interest in the pledged property, financing statement amendments filed in 2015 and 2016 satisfied the filing requirements for perfection when read in conjunction with the 2008 financing statements. View "Altair Global Credit Opportunities Fund v. Employees Retirement System" on Justia Law

The First Circuit reversed the district court’s dismissal of claims against Schechtl Maschinenbau GmbH, a German company, holding that, contrary to the conclusion of the district court, the exercise of personal jurisdiction over Schechtl comported with due process.Stephen Knox’s hand was injured at his work when he operated a machine manufactured by Schechtl. The machine had been sold to Knox’s employer by MetalForming, Inc., an American company located in Georgia and Schechtl’s U.S. distributor. Knox sued both Schechtl and MetalForming in Massachusetts state court. MetalForming removed the case to Massachusetts federal district court and filed crossclaims against Schechtl. The district court granted Schechtl’s motion to dismiss, concluding that Schechtl had not purposefully availed itself of the privilege of doing business in Massachusetts. The First Circuit reversed, holding that Knox and MetalForming met their burden of demonstrating that Schechtl purposefully availed itself of the privilege of conduct activities within Massachusetts. View "MetalForming, Inc. v. Schechtl Maschinenbau GmbH" on Justia Law

In these consolidated appeals arising out of two “off-label” prescription drug marketing cases aggregated for pretrial proceedings in the district court by order of a multidistrict litigation panel, the First Circuit reversed the dismissal of claims brought by two of the four plaintiffs, vacated the denial of Plaintiffs’ motion to compel the production of additional documents, and otherwise affirmed the district court's rulings.In their complaint, Plaintiffs claimed that Defendants, Forest Pharmaceuticals, Inc. and Forest Laboratories, Inc., engaged in an off-label marketing scheme aimed at fraudulently inducing doctors to write pediatric prescriptions of their antidepressant drugs when the FDA had not approved the use of these medications for minors. After discovery, the district court entered summary judgment for Defendant on Plaintiffs’ Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1962(c)-(d), claims and dismissed Plaintiffs’ state-based allegations as deriving from their noncognizable RICO claims. The First Circuit (1) reversed the district court’s entry of summary judgment on certain plaintiffs’ RICO and state-law claims and on another plaintiff’s RICO and unjust-enrichment claims on the basis that the evidence was insufficient on these claims; (2) vacated the denial of Plaintiffs’ motion to compel; (3) affirmed the denial of class certification; and (4) otherwise affirmed. View "Painters & Allied Trades District Council 82 Health Care Fund v. Forest Pharmaceuticals, Inc." on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Employer on Plaintiff’s claims alleging handicap discrimination and retaliation under Massachusetts state law, holding that there was no probative evidence of discrimination or retaliation.While Employer maintained that Plaintiff was fired because she violated company policy on unexcused absences, Plaintiff argued in her claim that she was fired because of her disability and that Employer retaliated against her for filing a complaint with the Massachusetts Commission against Discrimination. The district court granted summary judgment in favor of Employer. The First Circuit affirmed, holding that neither of Plaintiff’s claims could survive summary judgment. View "Miceli v. JetBlue Airways Corp." on Justia Law

The First Circuit reversed in part and affirmed in part the district court’s grant of summary judgment to all Defendants on Plaintiff’s claims of discrimination, unlawful retaliation, and violations of the Equal Protection Clause and the First Amendment, holding that summary judgment was properly granted as to Rodney Bouffard and Troy Ross but improperly granted as to Correct Care Solutions, LLC (CCS) and Maine Department of Corrections (MDOC).Plaintiff was employed by CCS at a MDOC prison. After MDOC revoked Plaintiff’s prison security clearance and CCS terminated Plaintiff’s employment, Plaintiff sued CCS, MDOC, and Bouffard, the warden, and Ross, the deputy warden, bringing claims under the Maine Human Rights Act (MHRA) and 42 U.S.C. 1983. The district court granted summary judgment for Defendants on all claims. The First Circuit held (1) a reasonable jury could find that Plaintiff’s work environment was hostile; (2) summary judgment was properly granted in favor of the warden and deputy warden based on qualified immunity; (3) an employer can be liable for a hostile work environment created by non-employees as long as the employer knew of the harassment and failed to take reasonable steps to address it; and (4) summary judgment was improper was to MDOC and CCS. View "Roy v. Correct Care Solutions, LLC" on Justia Law

The First Circuit affirmed the decision of the district court dismissing Plaintiff’s action on the grounds that the lawsuit was, in essence, an appeal from a state-court judgment, and therefore, the court lacked jurisdiction to hear it under the Rooker-Feldman doctrine, holding that the district court correctly held that it lacked jurisdiction to hear Plaintiff’s claims.This appeal arose from Plaintiff’s legal challenge seeking to void two Massachusetts Superior Court conditions of probation imposed on the adult male who was convicted of statutory rape after impregnating Plaintiff when she was a minor. One of those conditions ordered the defendant to acknowledge paternity of the child. The district court decided that it did not have jurisdiction over the claims. The First Circuit affirmed, holding that because the relief Plaintiff sought was based on her claim that the Massachusetts Supreme Judicial Court erred in the adjudication of her case, the district court properly dismissed this case for want of jurisdiction. View "Tyler v. Supreme Judicial Court of Massachusetts" on Justia Law

The First Circuit denied Petitioner’s petition for review of the order of the Board of Immigration Appeals (BIA) upholding the immigration judge’s (IJ) denial of Petitioner’s application for both withholding of removal and protection under the Convention Against Torture (CAT), holding that the BIA’s decision was supported by substantial evidence.Specifically, the BIA ruled that the only social group to which Petitioner claimed to belong was not a social group that was statutorily protected and that Petitioner was not entitled to protection under the CAT. The First Circuit affirmed, holding that Petitioner’s challenges to the BIA’s decision failed. View "Agustin v. Whitaker" on Justia Law