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

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

In this case stemming from a lengthy and acrimonious family dispute over the property of Donelson Glassie, whose estate remained in probate in Rhode Island eleven years after his death, the First Circuit reversed the judgment of the federal district court dismissing Plaintiff's claims as barred by the probate exception to federal court jurisdiction, holding that the district court erred.Plaintiff, Donelson's daughter, brought this action against several family members, including the executor of Donelson's estate, alleging that Defendants were liable to her under the federal Racketeer Influenced and Corrupt Organizations (RICO) laws, 18 U.S.C. 1962, because they formed an enterprise that engaged in a pattern of fraudulent interstate communications and that Defendants breached fiduciary duties owed to her as a minority member of an entity wholly owned by a company in which the estate held a fifty-eight percent interest, and other claims. The district court dismissed all claims. The First Circuit reversed, holding that the district court erred in finding the probate exception applicable to this case. View "Glassie v. Doucette" on Justia Law

The affirmed the decision of the district court to allow the government to rescind a plea agreement previously entered into with Defendant and proceed to sentence Defendant to a 162-month term of immurement, holding that Defendant was not entitled to relief on his arguments on appeal.Defendant pleaded guilty to conspiracy to distribute and to possess with intent to distribute 400 grams or more of a mixture or substance containing fentanyl. Thereafter, Defendant entered into a plea cooperation agreement with the government, which merged into and supplemented his plea agreement. Defendant, however, refused to perform under the agreement. Consequently, the district court rejected the supplemented plea agreement and sentenced Defendant to a 162-month term of immurement. The First Circuit affirmed, holding (1) the district court did not err in refusing to enforce Defendant's supplemented plea agreement; and (2) there was no error in the sentence imposed. View "United States v. Mejia" on Justia Law

The First Circuit vacated the sentence the district court judge imposed after revoking Defendant's term of supervised release, holding that the district judge's use of alleged facts from the Commonwealth of Puerto Rico court's prosecution of the charge against Defendant to determine Defendant's sentence was plain error.In 2011, Defendant was convicted of violating 21 U.S.C. 841(a)(1), 846, 860, conspiracy to distribute narcotics. While Defendant was serving his term o supervised release, Commonwealth authorities charged him with violating Article 133 of the Puerto Rico Penal Code for attempting to commit lewd acts. A magistrate judge found probable cause that Defendant had violated a condition of his release and imposed a three-year term of imprisonment. The First Circuit vacated the sentence, holding that the district judge procedurally erred by improperly relying on factual allegations that were not in the record when he imposed an upwardly variant sentence. View "United States v. Ramos-Carreras" on Justia Law

The First Circuit affirmed the judgment of the district court determining that couriers who deliver goods from local restaurants and retailers are transportation workers engaged in interstate commerce such that they are exempt from the Federal Arbitration Act (FAA), 9 U.S.C. 1, holding that the district court did not err or abuse its discretion.Plaintiffs, who worked as couriers for Defendants making deliveries in the greater Boston area, filed suit in a Massachusetts state court on their own behalf and on behalf of a putative class of similarly situated couriers, alleging that Defendant had misclassified them as independent contractors rather than employees and that they were entitled to employee benefits and protections under Massachusetts law. The district court concluded that Plaintiffs were not exempt from the FAA, compelled arbitration of the dispute, and dismissed the lawsuit. The First Circuit affirmed, holding that the district court did not err in compelling arbitration and dismissing the underlying complaint. View "Immediato v. Postmates, Inc." on Justia Law