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

In this case, a law firm, Thompson, MacColl & Bass, LLC, P.A. (TM&B), was sued by its former client, ST Engineering Marine, Ltd. (STEM), for professional negligence. STEM owned a vessel that was arrested due to several entities, including Sprague Operating Resources, LLC (Sprague), asserting maritime liens for unpaid services. STEM had sought advice from TM&B to analyze these lien claims. TM&B advised STEM that Sprague's lien was valid and should be paid. Acting on this advice, STEM paid Sprague and subsequently sued TM&B, alleging that TM&B's advice was negligent as it failed to consider the unsettled state of relevant maritime lien law.The United States Court of Appeals for the First Circuit affirmed the decision of the United States District Court for the District of Maine, which had found in favor of STEM. The Court of Appeals held that TM&B breached its duty of care to STEM by failing to conduct adequate legal research and by not appropriately counseling STEM about the uncertainty of Sprague's lien claim. The court also found that TM&B's negligence was the actual and proximate cause of STEM's loss, concluding that STEM would have prevailed in contesting Sprague's lien claim but for TM&B's erroneous advice. The court ordered TM&B to pay STEM $261,839.04 in damages. View "ST Engineering Marine, Ltd. v. Thompson, MacColl & Bass, LLC, P.A." on Justia Law

A plaintiff, Elvin Torres-Estrada, brought claims against several Federal Bureau of Investigation (FBI) agents and the United States under the Federal Tort Claims Act (FTCA) and Bivens, alleging violations of his constitutional and statutory rights. The district court dismissed his complaint, arguing that some of his claims were not filed within the required time frame and that the FTCA's discretionary function exception stripped the court of jurisdiction over his other claims. Torres-Estrada appealed the dismissal, arguing that his claims are timely, the discretionary function exception does not apply, and even if it does, it does not cover the alleged misconduct of the FBI.The United States Court of Appeals for the First Circuit held that the district court erred in its interpretation of the discretionary function exception. The court explained that this exception does not serve as a bar to FTCA tort claims that plausibly allege constitutional violations. In addition, at least two of Torres-Estrada's claims could be subject to the "continuing violation" doctrine, which means the district court erred in dismissing his claims as untimely without considering this doctrine. Given that new facts have emerged throughout the litigation, the court granted Torres-Estrada leave to amend his complaint. Therefore, the court affirmed in part, reversed in part, and remanded the case for further proceedings.The background facts of the case are that Torres-Estrada was detained at the Metropolitan Detention Center (MDC) in Guaynabo, Puerto Rico, pending prosecution for drug and money laundering offenses. During this time, he was investigated by the FBI as a potential suspect in the murder of a correctional officer at the MDC. Torres-Estrada alleges that the FBI violated his rights through various actions, including the use of informants to elicit incriminating statements about the murder, subjecting him to invasive body searches, and maintaining records falsely linking him to the murder. View "Torres-Estrada v. Cases" on Justia Law

In this case, the Gibson Foundation, a charitable arm of Gibson Brands, sued Rob Norris and The Piano Mill Group, alleging that they breached a contract and bailment when they refused to return a piano that had been used by entertainer Liberace, upon Gibson Foundation's request. The piano was initially transferred from Gibson Brands to Norris and Piano Mill. The United States Court of Appeals for the First Circuit concluded that the breach-of-bailment claim was not time-barred, reversing the lower court's decision. The court explained that a reasonable juror could find that Gibson Brands, the original owner of the piano, and Norris and Piano Mill had a mutual agreement where Gibson Brands would avoid storage costs by leaving the piano with Norris and Piano Mill, who would benefit from using the piano for promotional opportunities. Therefore, the six-year statute of limitations for certain contract claims applied, rather than the three-year limit for tort claims. However, the court affirmed the lower court's decision that a genuine issue of material fact existed as to whether Gibson Foundation, or its predecessor in title, Gibson Brands, owned the piano in question, which is necessary to establish a valid contract or bailment. The court also affirmed the lower court's denial of summary judgment to Gibson Foundation on the breach of contract claim, noting that a reasonable juror could find that Gibson Brands had given the piano to Norris and Piano Mill as a gift. View "Gibson Foundation, Inc. v. Norris" on Justia Law

In this case, the Town of Milton, Massachusetts, petitioned for a judicial review of the Federal Aviation Administration's (FAA) final order authorizing a new flight procedure at Boston's Logan International Airport. The new procedure, aimed at increasing safety and efficiency, covers a narrower swath of airspace over the Town of Milton. The Town argued that the FAA's environmental analysis of the noise impacts failed to comply with the National Environmental Policy Act (NEPA). However, the United States Court of Appeals For the First Circuit dismissed the Town's petition, ruling that the Town does not have standing to challenge the FAA's final order. The court concluded that the harms the Town asserted, including the impact of noise on its residents and the time and money spent addressing these issues, were not legally cognizable harms to the Town itself. The court agreed with other courts of appeals that have dismissed municipal NEPA challenges to FAA orders for lack of Article III standing because those challenges failed to show cognizable injury to the municipalities themselves. View "Milton, MA v. FAA" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants, several city officials of the City of Gloucester, Massachusetts, in this First Amendment action brought by Plaintiff, the Harbormaster of the city, holding that Defendants were entitled to qualified immunity.In his complaint, Plaintiff claimed that Defendants violated his rights under the First Amendment by retaliating against him for his giving expert testimony in a maritime tort dispute. The district court granted summary judgment for Defendants, concluding that they were entitled to qualified immunity. The First Circuit affirmed, holding that, at the time of the alleged retaliation, the law did not clearly establish that the value of Plaintiff's speech outweighed the city's interest in the efficient provision of public services by the Harbormaster's office. View "Ciarametaro v. City of Gloucester" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing all breach of contract claims brought by Universal Trade-in & Investment Company (UTICo) against Ukraine, the Ukrainian Prosecutor General's Office (UPGO), and the Bureau for Representing Ukrainian Interests in International and Foreign Courts, and denying UTICo's motions to amend the complaint and several of its discovery-related requests, holding that there was no error.UTICo, which was instrumental in helping the defendants investigate and freeze millions of dollars of worldwide assets that had been expatriated from Ukraine, alleged, among other things, that the defendants breached their contractual duties. The district court dismissed the breach of contract claims and entered judgment in favor of the Ukrainian defendants. The First Circuit affirmed, holding that the district court (1) did not err in granting summary judgment on the portion of the breach of contract claim related to Swiss assets that were transferred to the Ukrainian treasury; and (2) did not err in denying UTICo's three motions to amend. View "Universal Trading & Investment Co. v. Bureau for Representing Ukrainian Interests" on Justia Law

The First Circuit affirmed the decision of the Board of Immigration Appeals (BIA) affirming the immigration judge's (IJ) denial of Petitioner's applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), holding that Petitioner was not entitled to relief.Petitioner, who was from Nepal, sought relief based on claims that she experienced past persecution and had a well-founded fear of future persecution at the hands of Maoist insurgents on account of political opinion and membership in a particular social group, in particular, her nuclear family. The IJ granted Petitioner's application for voluntary departure but denied her claims for asylum, withholding of removal, and protection under the CAT. The BIA affirmed. The First Circuit affirmed, holding that the lower agencies did not err in concluding that Petitioner failed to establish that the Nepali government was unwilling or unable to protect her. View "Singh v. Garland" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence for one count of transportation of a minor with the intent to engage in criminal sexual activity, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that the trial court erred in admitting hearsay testimony and improper opinion testimony and that his sentence was both procedurally and substantively unreasonable. The First Circuit affirmed, holding that the district court (1) did not abuse its discretion in admitting the hearsay statements under the excited utterance exception; (2) did not abuse its discretion in admitting the opinion testimony; and (3) did not err in sentencing Defendant to 235 months' imprisonment because the sentence was procedurally and substantively reasonable. View "United States v. Irizarry-Sisco" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing the suit brought by Plaintiff seeking to enjoin the New Hampshire Secretary of State from "accepting or processing" the "ballot access documentation" brought by Donald Trump, the former President of the United States, for the 2024 Republican presidential primary in the state of New Hampshire, holding that Plaintiff lacked standing.Plaintiff, a United States citizen and Republican primary presidential candidate, brought this complaint alleging that section 3 of the Fourteenth Amendment barred Tump from "holding" the office of President of the United States again on the ground that he "engaged in insurrection or rebellion against [the U.S. Constitution], or [gave] aid or comfort to the enemies thereof." The district court dismissed the lawsuit on jurisdictional grounds, concluding that Plaintiff lacked standing under U.S. Const. art. III, 2 and that his section 3 claim presented a nonjusticiable political question. The First Circuit affirmed, holding that Plaintiff failed to show that he could satisfy the "injury-in-fact" component of Article III standing. View "Castro v. Scanlan" on Justia Law

The First Circuit affirmed the judgment of the district court ruling that the underlying suit was time barred as to all defendants in this action brought by Plaintiff under 42 U.S.C. 1983 on behalf of her late son's estate on the six-year anniversary of his death, holding that the lawsuit was time barred.Plaintiff sued jail staff and a medical contractor (collectively, Defendants), alleging that while her son was detained in the Somerset County Jail, Defendants failed to recognize his serious mental illness, thus leading to his death following a suicide attempt. Defendants moved to dismiss the suit as time barred. The district court granted the motion. The First Circuit affirmed, holding that Plaintiff was not entitled to relief on her allegations of error. View "Martin v. Somerset County" on Justia Law