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

The First Circuit denied a petition for review sought by Petitioners, four individuals who left El Salvador for fear of harm at the hands of a gang, holding that the decision of the Board of Immigration Appeals (BIA) was supported by substantial evidence in the record.After Petitioners were charged as removable they conceded removability but cross-applied for asylum, withholding of removal, and relief under the United Nations Convention Against Torture. An immigration judge (IJ) rejected Petitioners' claims for relief, concluding that Petitioners failed to show that their claimed persecution bore a nexus to a protected ground. The BIA affirmed. The First Circuit denied Petitioners' petition for review, holding that the agency's determination that family membership was not a central reason for Petitioners' persecution was supported by substantial evidence in the record. View "Jimenez-Portillo v. Garland" on Justia Law

In these two different qui tam cases in which the United States executed a settlement agreement with AthenaHealth, Inc. and multiple relators, the First Circuit affirmed the judgment of the district court denying Relators' denial of their claims for attorneys' fees, holding that the district court did not err.Relators Cheryl Lovell and William McKusick appealed from the district court's denial of their entire claim for attorneys' fees under the False Claims Act (FCA), 31 U.S.C. 3729 et seq., and relator Georgie Sandborn appealed from the omission of certain claimed fees from his attorneys' fees award. The First Circuit (1) affirmed as to Lovell and McKusick, holding that these relators did not receive a relator's share and so were not entitled to attorneys' fees; and (2) affirmed as to Sanborn, thus rejecting his argument that he may be allowed fees associated with his claim, in which the government did not intervene. View "United States, ex rel. Lovell v. AthenaHealth, Inc." on Justia Law

The First Circuit reversed the order of the district court dismissing Plaintiffs' breach of contract claim against Wilmington Savings Fund Society, FSB and otherwise affirmed the district court order dismissing Plaintiffs' complaint against Wilmington Savings and Selene Finance LP, holding that the district court erred in part.Plaintiffs filed a complaint seeking a declaratory judgment that Defendants breached the parties' mortgage contract by selling their property through a non-judicial foreclosure, thus rendering the foreclosure void. Specifically, Plaintiffs alleged that the foreclosure and sale were conducted without providing adequate notice, as required by the mortgage contract. The district court granted Defendants' motion to dismiss. The First Circuit reversed in part, holding (1) Plaintiffs stated a claim that the notice of default failed strictly to comply with the requirements of the mortgage contract, and therefore, dismissal of their claim against Wilmington Savings was improper; and (2) as to the remaining claims, dismissal was proper. View "Aubee v. Selene Finance LP" on Justia Law

The First Circuit vacated the judgment of the district court substituting the United States as a defendant in the place of the physician that Plaintiff originally sued for wrongful death and vacated the district court's subsequent grant of the Government's motion to dismiss the amended complaint for failure to state a claim, holding that gaps in the evidentiary record must be filled by further proceedings in the district court.Plaintiff brought a wrongful death action in state court alleging medical malpractice against a physician who worked for a federally-funded health center. Plaintiff's decedent, the patient, was unaffiliated with the health center. When the United States removed the action to federal court it sought to substitute itself for the physician as a defendant. The district court invoked the Federal Employees Liability Reform and Tort Compensation Act of 1988 (the Westfall Act), 28 U.S.C. 2679, made the substitution, and dismissed the complaint. The First Circuit vacated the judgment below, holding that because the district court repudiated its earlier reliance on the Waterfall Act, new issues that have emerged must now be resolved. View "O'Brien v. United States" on Justia Law

The First Circuit affirmed the judgment of the bankruptcy court dismissing Appellant's voluntary petition for relief under title 11 of the United States Code, holding that the district court did not err in dismissing the petition on the ground that Appellant failed to serve certain quarterly reports on the United States Trustee pursuant to the Bankruptcy Court's confirmation order.The bankruptcy court dismissed Appellant's case on two grounds - that he failed to pay certain fees to the U.S. Trustee pursuant to 28 U.S.C. 1930(a)(6) and that he failed to serve the quarterly reports on the U.S. Trustee. The First Circuit affirmed on the second of the two grounds, holding that the bankruptcy court did not err by dismissing Appellant's case for failure to comply with the confirmation order because that order required that Appellant serve quarterly reports on the U.S. Trustee only while his case was "open." View "Brown v. Harrington" on Justia Law

The First Circuit vacated the approval of a class action settlement under Fed. R. Civ. P. 23(e), holding that the absence of separate settlement counsel for distinct groups of class members made too difficult a determination whether the settlement treated class members equitably.Plaintiffs sued HelloFresh, a subscription service, alleging that its so-called "win back" marketing campaign violated the Telephone Consumer Protection Act. The parties eventually arrived at a proposed settlement conditioned on court approval. The district court adopted the settlement agreement. An objector to the settlement appealed, arguing that the settlement process was unfair and led to an inequitable result. The First Circuit agreed and vacated the district court's approval, holding (1) the district court lacked the requisite basis for certifying the settlement class and approving an allocation among class members as fair, reasonable, and adequate; and (2) incentive payments to named class representatives are not prohibited so long as they fit within the bounds of Rule 23(e). View "Murray v. McDonald" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Defendants - several public school officials, the Town of Chelmsford, and the local school committee - and dismissing the First Amendment retaliation and state law claims brought by Plaintiff - a public school teacher and former president of her local teachers' union - holding that there was no error.In her complaint, Plaintiff alleged that Defendants violated her First Amendments rights and the Massachusetts Civil Rights Act (MCRA), Mass. Gen. Laws ch. 12, 11H by retaliating against her in reaction to her union advocacy efforts while she was president of the Chelmsford Federation of Teachers, a local chapter of the American Federation of Teachers. The district court granted summary judgment in favor of Defendants on all claims. The First Circuit affirmed, holding that there was no prejudicial error in the district court's summary judgment ruling or two other rulings from the pleading and discovery stages of this case. View "Salmon v. Lang" on Justia Law

The First Circuit reversed in part the judgment of the district court dismissing Plaintiff's complaint against Stonehill College for breach of contract, sex discrimination in violation of Title IX, negligence, and defamation, holding that the district court erred in dismissing Plaintiff's breach of contract claim.Plaintiff brought this complaint after he was expelled for violating Stonehill College's sexual misconduct policy by engaging in "nonconsensual sexual intercourse," alleging that the disciplinary process in his case was unfair and biased. The district court dismissed the complaint under Fed. R. Civ. P. 12(b)(6). The Supreme Court reversed the dismissal of the breach of contract claim and otherwise affirmed, holding (1) Plaintiff stated a breach of contract claim under both theories available to him under Massachusetts law; and (2) Plaintiff's remaining claims failed to state a claim. View "Doe v. Stonehill College, Inc." on Justia Law

The First Circuit reversed the order of the district court dismissing Plaintiffs' federal antitrust claims concerning a standard exclusive dealing arrangement between Triple-S Salud, Inc. and Dr. Rodriguez-Blazquez and companies owned by him (Urologics) incident to the maintenance of closed healthcare networks, holding that the complaint, in part, stated a plausible claim to relief.Plaintiffs, who were under contract with Triple-S to provide urology services to urology patients in the area, asserting that the exclusive dealing arrangements in this case caused them to lose business and made it more difficult for patients to obtain urology services in Western Puerto Rico. The district court dismissed the claims. The First Circuit (1) reversed the district court's order dismissing Plaintiffs' federal antitrust claims concerning the exclusive dealing arrangement between Triple-S and Urologics, holding that Plaintiffs adequately stated a claim to relief that was plausible on its face; and (2) affirmed the district court's order dismissing Plaintiffs' federal antitrust claims concerning a different arrangement, holding that the district court properly dismissed these claims. View "Vazquez-Ramos v. Triple-S Salud, Inc." on Justia Law

The First Circuit affirmed in part and vacated in part the judgment of the district court discharging Guardian Life Insurance Company of America from this interpleader action and awarding the death benefit in dispute to Robyn Caplis-Sevelitte (Robyn), holding that remand was required for a determination of who was entitled to the death benefit.In this action, Renee Sevelitte, the ex-wife of Joseph Sevelitte, the decedent, and Robyn, the decedent's widow, asserted competing claims to the death benefit of a life insurance policy owned by Joseph and administered by Guardian. Renee sued Guardian asserting four claims based on Guardian's failure to pay her the proceeds from the policy and cross claimed against Robyn. Guardian asserted a counterclaim for interpleader against Renee, Robyn, and Joseph's estate under Fed. R. Civ. P. 22. The district court entered judgment on the pleadings in Guardian's and Robyn's favor and dismissed Renee's crossclaims against Robyn. The First Circuit affirmed the entry of judgment on the pleadings in favor of Guardian with respect to the death benefit from the policy but vacated and remanded as to Robyn, holding that the district court erred. View "Sevelitte v. Guardian Life Insurance Co. of America" on Justia Law