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

The First Circuit affirmed the judgment of the district court granting in part and denying in part Cultural Care, Inc.'s motion to dismiss this putative class action alleging violations of Plaintiffs' rights under various state and federal wage and hour laws, holding that the district court did not err.Plaintiffs sued Cultural Care, a private company that places au pairs with host families in various states, alleging that the company qualified as an "employer" under the respective states' wage and hour laws and not only failed to pay Plaintiffs what they were owed but that Cultural Care violated the Family Leave Act and other laws. Cultural Care filed a motion to dismiss, arguing, inter alia, that it was shielded from immunity under the doctrine of derivative sovereign immunity as set forth in Yearsley v. W.A. Ross Construction Co., 309 U.S. 18, 20-22 (1940). The district court dismissed the state law deceptive trade practices claims under Connecticut and Washington law for lack of standing but otherwise denied the motion. The First Circuit affirmed, holding that Cultural Care was not entitled to protection under Yearsley at this stage of the litigation. View "Posada v. Cultural Care, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court denying Jose Santiago, Inc.'s (JSI) motion for a preliminary injunction under Puerto Rico's Law 75, holding that the district court did not err in concluding that a preliminary injunction was not warranted under the facts of this case.JSI, a distributor of food-service products in Puerto Rico, brought this action alleging that one of its suppliers violated Law 75 by refusing to revoking JSI's status as an exclusive distributor and by refusing to continue filling JSI's orders unless JSI agreed to a written distribution agreement that would limit the products it could order. The district court denied JSI's motion for a preliminary injunction, and JSI appealed. The First Circuit affirmed, holding that there was no error in the district court's findings and that the court properly denied a preliminary injunction. View "Jose Santiago, Inc. v. Smithfield Packaged Meats Corp." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing this action against Blue Cross Blue Shield of Massachusetts (BCBSMA) and dismissing the Massachusetts Laborers' Health and Welfare Fund's (Fund) three claims brought under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., holding that there was no error.For sixteen years, BCBSMA served under contract as a third-party administrator for a self-funded multi-employer group health plan administered by the Fund. In 2021, the Fund brought this suit alleging that, in violation of its contractual obligations, BCBSMA paid medical providers in amounts exceeding rates that BCBSMA negotiated with a network of medical providers. The district court dismissed the action under Fed. R. Civ. P. 12(b)(6) on the grounds that the Fund had failed plausibly to allege that BCBSMA was an ERISA fiduciary with respect to the actions subject to the Fund's complaint. The First Circuit affirmed, holding that the Fund's argument that BCBSMA was a fiduciary failed. View "Mass. Laborers' Health & Welfare Fund v. Blue Cross Blue Shield of Mass." on Justia Law

The First Circuit reversed the judgment of the district court granting Defendant's motion to dismiss this lawsuit alleging unfair and deceptive business practices under Massachusetts law by intentionally obfuscating information regarding the sales of Plaintiff's published books, holding that this action was not barred.Plaintiff filed a putative class action complaint against Defendant on behalf of himself and other authors alleging a single count for violation of Mass. Gen. Laws ch. 93A, seeking declaratory and injunctive relief requiring Defendant to disclose its royalty calculation methods and provide reasonable disclosures of royalty-related information. The district court granted Defendant's motion to dismiss, concluding that the choice of law in Plaintiff's publishing agreement mandating that all disputes be resolved according to New York law barred the assertion of a claim arising only under Massachusetts law. The First Circuit reversed, holding that Plaintiff's Chapter 93A claim was not precluded by the choice of law clause before the Court. View "Kleiner v. Cengage Learning Holdings II, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant of possession with intent to distribute a controlled substance, holding that the district court did not err in denying Defendant's motion to suppress drug evidence.Defendant was a passenger in a single-vehicle car accident on the Maine Turnpike. Suspicion that the vehicle and/or its occupants were transporting drugs Maine police officers searched Defendant's bag and discovered narcotics. Defendant filed a motion to suppress, arguing that the evidence was obtain in violation of her Fourth Amendment rights. The district court denied the motion, after which Defendant conditionally pleaded guilty. The First Circuit affirmed, holding that Defendant's arguments for suppression failed. View "United States v. Howard" on Justia Law

The First Circuit reversed the judgment of the district court ruling that Insured's claim of unfair claim settlement practices in violation of Mass. Gen. Laws ch. 176D and 93A was barred by the choice-of-law provision of the marine insurance policy he purchased from Great Lakes Insurance SE (GLI), holding that the district court erred.Insurer, the insurer of Insured's forty-seven-foot catamaran sailing vessel, brought a declaratory judgment action to determine whether the "constructive total loss" of Insured's vessel was covered under the relevant policy. Insured brought a counterclaim alleging violations of Mass. Gen. Laws ch. 176D, 3(9) and ch. 93A, 9(3A). The district court ruled that pursuant to the policy's choice-of-law provision, New York law barred Insured's Massachusetts counterclaim because New York law does not provide for a chapters 176D and 93A claim. The First Circuit reversed, holding (1) Insured's statutorily-based counterclaim was extra-contractual; (2) the plain language of the choice-of-law provision was not broad enough to unambiguously encompass an extra-contractual claim; and (3) any ambiguity in the policy must be construed in favor of Insured. View "Great Lakes Insurance SE v. Andersson" on Justia Law

In this civil enforcement action, the First Circuit affirmed the interlocutory order of the district court ruling that a violation of the right to poll each of the jurors individually under Civil Rule 48(c) is per se reversible and that, therefore, Defendant was entitled to a new trial, holding that there was no error.At issue was whether, under this Court's precedent, the district court's denial of Defendant's right to poll each juror individually after the jury had collectively been polled was per se reversible error. The trial court judge ruled that the error was per se reversible. The First Circuit affirmed, holding that the arguments raised by the Securities and Exchange Commission on appeal were unavailing. View "U.S. Securities & Exchange Comm'n v. Sargent" on Justia Law

The First Circuit affirmed Defendant's conviction for possession of firearms by a felon and his thirty-month sentence, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant challenged the procedural reasonableness of his sentence, asserting that the district court relied upon a clearly erroneous finding of fact regarding his use of a firearm on a previous occasion. The First Circuit affirmed, holding that the sentencing court did not clearly err in its factual findings and in crediting the account of a witness of the incident at issue over Defendant's own account. View "United States v. Lilly" on Justia Law

The First Circuit dismissed in part and denied in part Petitioner's petition for judicial review of the decision of the Board of Immigration Appeals (BIA) affirming the decision of the immigration judge (IJ) ordering Petitioner's removal, holding that the Court lacked jurisdiction in part and that Petitioner was not entitled to relief on his remaining allegations of error.Petitioner, a Jordanian national, was granted status as a conditional permanent resident of the United States due to his marriage to a citizen, but an IJ later ordered his removal due to his inability to prove that he entered the marriage in good faith. The BIA affirmed. Thereafter, Petitioner filed a petition for judicial review. The First Circuit affirmed, holding (1) this Court lacked jurisdiction to review the agency's factual findings; and (2) Petitioner's remaining challenges to the BIA's decisions were unavailing. View "Alzaben v. Garland" on Justia Law

The First Circuit affirmed Defendant's conviction and sentence, holding that Defendant's arguments on appeal did not meet the exacting plain error standard.Defendant pleaded guilty to using a firearm during a carjacking, a crime of violence, in violation of 18 U.S.C. 2, 924(c)(1)(A)(ii). The district court imposed a sentence of 108 months in prison, twenty-four months longer that the Guidelines recommendation, and a special condition upon his release requiring him to receive psychotherapy services. On appeal, Defendant argued for the first time that his sentence was procedurally unreasonable and that the sentencing judge erred by delegating to the probation department the authority to have the final say about when his mandated therapy was completed. The First Circuit affirmed, holding (1) Defendant was not entitled to relief on his argument that faulty fact-finding made his upwardly variant sentence procedurally unreasonable; and (2) Defendant did not show any plain error on the part of the district court in imposing the therapy condition. View "United States v. Morales-Cortijo" on Justia Law