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

In this personal injury action, the First Circuit affirmed the judgment of the district court granting Defendant’s motion for judgment on the pleadings under Fed. R. Civ. P. 12(c) after treating it, under Fed. R. Civ. P. 12(d), as a motion for summary judgment, holding that the district court properly found that Plaintiff expressly consented by contract to assume the risk of injury caused by Defendant’s negligence.Plaintiff was injured after colliding with unmarked snowmaking equipment while skiing at a New Hampshire resort. Plaintiff brought this action against Defendant, the resort’s owner. The district court ruled for Defendant on the basis of the liability release printed on Plaintiff’s lift ticket. The First Circuit affirmed, holding (1) the district court correctly rejected Plaintiff’s contention that the question of whether there was a “meeting of the minds” with respect to the release was for the jury to resolve; (2) the scope of the release was not so limited as to not bar Plaintiff’s suit; (3) the liability release was not unenforceable on public policy grounds; and (4) Plaintiff failed to provided a basis upon which a jury could supportably find Defendant to have been reckless. View "Miller v. Sunapee Difference, LLC" on Justia Law

The First Circuit reversed the order of the district court dismissing aggravated identity theft counts against three doctors and three employees of a durable medical equipment supplier in Puerto Rico, holding that the motion to dismiss a grand jury indictment did not provide an occasion in this case for determining, over the government’s objection, whether the facts alleged in the indictment were sufficient to establish the charged offense.A United States grand jury indictment indicted Defendants on counts of health care fraud and conspiracy to commit health care fraud and aggravated identity theft. In dismissing the aggravated identity theft counts, the district court concluded that the facts alleged in the indictment did not adequately make out a case for aggravated identity theft. The First Circuit reversed, holding that the proceedings as they stood at this stage provided no occasion for determining whether the government’s proof was sufficient to sustain a conviction, and the record lacked any agreed upon completeness. View "United States v. Rodriguez-Rivera" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant’s motion to suppress incriminating evidence found during a search and seizure by a local police officer after approaching Defendant, who was seated in a car with his friend in a parking lot, and asking him several questions, holding that the search and seizure were lawful.Based on Defendant’s answers to the officer’s questions, the officer searched the vehicle, found drugs and drug paraphernalia, and arrested Defendant. After Defendant consented to the search of his backpack, further incriminating evidence was found. Defendant moved to suppress the government’s evidence, arguing that the officer lacked reasonable suspicion to initiate and continue the inquiries that led to the discovery of the contraband. The district court denied the motion. The First Circuit affirmed, holding that the district court did not err in finding no Fourth Amendment violation and denying Defendant’s motion to suppress. View "United States v. Tanguay" on Justia Law

The First Circuit affirmed the judgment of the district court entering judgment against Defendant on Plaintiff’s discrimination action and awarding Plaintiff compensatory and punitive damages, holding that the district court did not err in denying Defendant’s motions for judgment as a matter of law and a new trial, and Defendant’s other assignments of error were unavailing.Plaintiff, a citizen of Massachusetts, brought suit against Defendant, a New York-based real estate firm and Plaintiff’s former employer, claiming that Defendant fired him because of his age and disability. Defendant removed the suit from the Massachusetts Superior Court to a federal district court in Boston. The district court applied the New York City Human Rights Law (NYCHRL), N.Y.C. Admin. Code 8-101-10. The jury found that Defendant discriminated against Plaintiff on the basis of age and awarded him $1,275,000 in both compensatory and punitive damages. The First Circuit affirmed, holding (1) the district court correctly applied the NYCHRL; (2) the district court judge correctly instructed the jury; and (3) there was sufficient evidence to support the jury’s verdict. View "Rinsky v. Cushman & Wakefield, Inc." on Justia Law

The First Circuit affirmed the district court’s denial of Appellant’s motion to dismiss the indictment against him on double jeopardy and issue preclusion grounds, holding that the Double Jeopardy Clause had no application and that Appellant’s issue preclusion claim would fail on the merits even if it were not waived.In preliminary hearings, Puerto Rico courts concluded that Commonwealth weapons charges against Appellant were not supported by probable cause. Thereafter, Appellant plead guilty to equivalent federal charges based on the same conduct. Appellant later moved the district court to dismiss his indictment as a violation of the Double Jeopardy Clause. After a magistrate judge made a report and recommendation, Appellant raised for the first time his issue preclusion claim. The district court denied Appellant’s motion. The First Circuit affirmed, holding that Appellant was not entitled to relief on his claims. View "United States v. Rosado-Cancel" on Justia Law

The First Circuit denied Petitioner’s petition for review of the decision of the U.S. Department of Labor Benefits Review Board (Board) affirming an administrative law judge’s (ALJ) denial of attorney’s fees and costs to Appellant, holding that Appellant's request for benefits did not result in a “successful prosecution” under the Longshore and Harbor Workers’ Compensation Act (LHWCA), 33 U.S.C. 901 et seq., so as to warrant an award of attorney’s fees.At a hearing before the ALJ it was undisputed that Appellant was entitled to medical benefits due to his back injury, including for surgery in Puerto Rico. The ALJ stated that Appellant could have the surgery done in New York but would have been responsible for the additional expenses he incurred. Appellant then submitted a request for attorney’s fees on the theory that his claim had been a victory because he obtained his “right to choose” to have the surgery in New York. The ALJ denied the request, determining that Appellant did not gain any additional benefit beyond what he would have received had he not initiated the claim. The Board affirmed. The First Circuit affirmed, holding that Appellant’s request for attorney’s fees and costs was properly denied because he did not secure any additional compensation by filing his claim. View "Garcia v. Director, Office of Workers’ Compensation Programs, United States Department of Labor" on Justia Law

The First Circuit reversed an vacated the order of the district court granting Defendant’s motion to suppress identification evidence and giving preclusive effect to a Puerto Rico Court of Appeals’ order suppressing the same evidence in a local proceeding for different offenses, holding that the district court deviated from this Court’s precedent in so ruling.The district court concluded that because Puerto Rico and the United States are a single sovereign for purposes of the Double Jeopardy Clause, the court was bound by the local court’s judgment suppressing identification evidence, even where federal prosecutors did not participate in the proceedings. The First Circuit reversed, holding (1) the district court deviated from the holding in United States v. Bonilla Romero, 836 F.2d 39, 43-44 (1st Cir. 1987), that suppression of evidence by a Puerto Rico court does not require a federal court to suppress that same evidence unless federal prosecutors were a party, or were in privity with a party, to the suppression hearing in the Puerto Rico court; and (2) because there was no privity between the two prosecuting authorities in this case, collateral estoppel was inapplicable. View "United States v. Santiago-Colon" on Justia Law

In this case concerning arbitration agreements, nursing homes, and wrongful death claims under Massachusetts law, the First Circuit certified questions to the Massachusetts Supreme Judicial Court (SJC) under its Rule 1:03, holding that the dispute in this case turned on the characterization of wrongful death actions by the Commonwealth and presented an unresolved question of Massachusetts law whose answer was unclear.The personal representative of a deceased former nursing home resident brought a state wrongful death action against a set of organizations that oversaw the nursing home (collectively, nursing home). The nursing home sued to compel arbitration. The federal court compelled arbitration and declined to issue a stay of the state wrongful death action. On appeal, the personal representative argued that she was not bound by the decedent’s agreement to arbitrate with the nursing home because her wrongful death right of recovery was independent of the decedent’s wrongful death claim. In asserting that the arbitration agreement was binding, the nursing home argued that Massachusetts beneficiaries’ wrongful death claims are derivative of the decedent’s wrongful death claim. The First Circuit exercised its discretion in favor of certification, holding that Massachusetts law does not clearly decide the independent/derivative or other relevant questions about the status of wrongful death actions in relation to the decedent. View "GGNSC Chestnut Hill LLC v. Schrader" on Justia Law

The First Circuit affirmed Defendant’s conviction of interstate domestic violence and discharge of a firearm during and in relation to a crime of violence and sentence of life imprisonment, holding that there was no reason to vacate Defendant’s convictions or sentence on the grounds that he presented on appeal.Specifically, the First Circuit held (1) the district court did not err in denying Defendant’s motion to suppress evidence; (2) the evidence was sufficient to support Defendant’s convictions; (3) Defendant’s sentence was both procedurally and substantively reasonable; and (4) the district court did not err in denying Defendant’s motion to dismiss the indictment on double jeopardy grounds. View "United States v. Owens" on Justia Law

The First Circuit affirmed the district court’s grant of summary judgment in favor of a Church on its lawsuit seeking a declaratory judgment that its claim filed pursuant to its property insurance policy with an Insurance Company was improperly denied, holding that ambiguities in the policy resulted in coverage for the collapse of a ceiling in one section of the church.The Insurance Company denied the Church’s claim, citing the “faulty construction” exclusion in the policy. In its complaint, the church argued that the collapse was caused by hidden decay such that the “additional coverage - collapse” provision applied. The First Circuit affirmed, holding that the meaning of “decay” was ambiguous and that ambiguity must be resolved in the Church’s favor. View "Easthampton Congregational Church v. Church Mutual Insurance Co." on Justia Law