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

The First Circuit affirmed the judgment of the district court granting summary judgment to IKO Industries, Inc. (IKO) on the Massachusetts state law contractual and consumer protection claims that Armand Bessette asserted with respect to roofing shingles that IKO manufactured and that he purchased in 1999, holding that there was no error or abuse of discretion.In 2018, after having replaced the singles on the roof his home, Bessette brought suit against IKO in Massachusetts state court alleging claims under Massachusetts law in connection with the alleged premature deterioration of the shingles. IKO removed the case to the federal district court, which granted summary judgment in favor of IKO. Bessette appealed, challenging the summary judgment on his express warranty and implied warranty of merchantability claims and claims alleging a violation of Chapter 93A, the Massachusetts consumer protection law. The First Circuit affirmed, holding that the district court properly granted summary judgment to IKO on the three claims at issue on appeal. View "Bessette v. IKO Industries, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants and dismissing this lawsuit alleging various Massachusetts law claims based on a purported manufacturing defect in a Kawasaki motorcycle owned and ridden by Junior Williams, holding that there was no error.Junior Williams suffered severe injuries, including second- and third-degree burns, when his 2007 Kawasaki motorcycle collided with a Jeep and a fire resulted. Williams brought this lawsuit against the designer and manufacturer and the distributor of Kawasaki brand motorcycles. The district court granted summary judgment for the Kawasaki defendants and against Williams, concluding that the opinions of Williams's proffered liability expert as to defect and causation should be excluded, and therefore Williams lacked expert testimony on these topics. The First Circuit affirmed on other grounds, holding that even assuming that the expert opinion testimony was admissible, Williams failed to satisfy his burden of proving causation by a preponderance of the evidence. View "Williams v. Kawasaki Motors Corp., U.S.A." on Justia Law

The First Circuit affirmed the judgment and order of the district court granting summary judgment for Lender and denying Borrowers' motion for reconsideration in this lawsuit brought by Lender seeking repayment and foreclosure of a loan, holding that the district court did not err.Borrowers defaulted on a loan extended by Lender. The loan was subject to the Farm Credit Act, 12 U.S.C. 2001 et seq., which sometimes requires the lender to restructure the loan rather than foreclose. Borrowers applied to restructure the distressed loan, but Lender rejected the application. Lender eventually brought this action, and the district court ultimately granted summary judgment for Lender. The First Circuit affirmed, holding (1) a lender need not accept a plan of restructuring that the borrower cannot perform; and (2) the district court did not err in finding that Lender properly considered and rejected the requested restructuring. View "Puerto Rico Farm Credit, ACA v. Eco-Parque del Tanama Corp." on Justia Law

The First Circuit affirmed the judgment of the district court granting motions to dismiss filed by defendants Charles Taylor Consulting Mexico, S.A. de C.V., James Heiden, and Pierre Barron (collectively, Charles Taylor) and Universal Insurance Co. for failure to state a claim under the Racketeer Influence and Corrupt Organizations Act (RICO), 18 U.S.C. 1961 et seq., holding that there was no error.Plaintiffs OK Resorts of Puerto Rico, Inc., Executive Fantasy Hotel, Inc., and Riverside Resort, Inc. (collectively, OK Resorts) brought this action against Charles Taylor under RICO and Puerto Rico law. The district court granted Charles Taylor's motions to dismiss after the agreed-upon discovery deadline had passed. On appeal, OK Resorts argued that the district court abused its discretion in dismissing he amended complaint at the time it did. The First Circuit affirmed, holding that the district court did not abuse its discretion. View "OK Resorts of Puerto Rico, Inc. v. Charles Taylor Consulting Mexico, S.A. de C.V." on Justia Law

The First Circuit affirmed Defendant's conviction of one count of possession with intent to distribute cocaine and one count of importation of cocaine and his sentence of a term of imprisonment of 120 months to be followed by a five-year term of supervised release, holding that there was no error in the proceedings below.Specifically, the First Circuit held that the district court did not abuse its discretion in (1) admitting evidence, including the testimony of a canine handler that a drug sniffing dog alerted to Defendant vehicle eighteen days prior as "other-acts" evidence pursuant to Fed. R. Evid. 404(b); (2) admitting testimony of a Homeland Security Investigations agent about the practices of drug traffickers smuggling drugs into Puerto Rico as that of a lay witness opinion pursuant to Fed. R. Evid. 701; and (3) failing sua sponte to order a competency evaluation prior to or during Defendant's sentencing hearing. View "United States v. Agramonte-Quezada" on Justia Law

The First Circuit affirmed the ruling of the district court denying Plaintiffs' motion for a preliminary injunction in this case arising from a decision by the Speaker of the New Hampshire House of Representatives to enforce a House rule precluding any representative from participating in proceedings involving the full House, including House matters, other than in person, holding that there was no error.At issue in this COVID-19 pandemic-related case was whether Title II of the Americans with Disabilities Act (ADA) or section 504 of the Rehabilitation Act (RHA) authorizes a federal court to resolve a dispute among members of a state legislative body about whether votes on bills may be cast remotely rather than in person. The underlying suit named Sherman Packard, the Speaker of the House, in his official capacity. The district court denied a preliminary injunction based on the Speaker's assertion of legislative immunity. A panel of the First Circuit first vacated the injunction, but the Court subsequently granted a rehearing en banc. The First Circuit then affirmed, holding that the district court did not err in holding that the Speaker's assertion of legislative immunity prevented Plaintiffs from obtaining their requested relief. View "Cushing v. Packard" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendants, the Town of Marblehead and its buildings commissioner, and dismissing this lawsuit brought under the Religious Land Use and Institutionalized Persons Act (RLUIPA), holding that the district court did not err.St. Paul's Foundation and the Shrine of St. Nicholas the Wonderworker, Patron of Sailors, Brewers and Repentant Thieves (collectively, St. Paul's), brought this action alleging that Defendants substantially burdened St. Paul's religious exercise. Specifically, St. Paul's sought to reinstate a building permit that it had secured for the redevelopment of a site on which the Shrine of St. Nicholas was located but that had been suspended prior to the completion of that construction. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding that St. Paul's did not successfully advance a basis for reversing the summary judgment in this case. View "St. Paul's Foundation v. Ives" on Justia Law

The First Circuit vacated the order of the district court denying in part Plaintiffs' motion for summary judgment and granting in part Defendants' motion for summary judgment, holding that the case must be dismissed for failure to exhaust administrative remedies.Parents brought this case alleging dissatisfaction with the individualized education plan offered to their son by the Puerto Rico Department of Education. Rather than file an administrative appeal, which was available to them, Parents brought suit in the United States District Court for the District of Puerto Rico. After issuing orders during a period of several years the district court issued an amended opinion and order denying in part Plaintiffs' motion for summary judgment and granting in part Defendants' motion for summary judgment. The First Circuit vacated the district court's judgment and remanded the case with instructions to dismiss, holding that the district court erred in finding that Parents did not need to exhaust their administrative remedies. View "Valentin-Marrero v. Commonwealth of Puerto Rico" on Justia Law

The First Circuit affirmed the judgment of the district court convicting Defendant, pursuant to a jury verdict, of conspiracy to commit a robbery, committing the robbery, and discharging a firearm in relation to a crime of violence resulting in death, holding that none of Defendant's challenges on appeal had merit.After a jury found Defendant guilty of all counts the district court sentenced him to thirty years in prison. The First Circuit affirmed the judgment, holding (1) there was sufficient evidence to support the convictions; (2) Defendant failed to preserve any objection to the use of a Pinkerton instruction; and (3) Defendant's evidentiary challenges were unavailing. View "United States v. Serrano-Delgado" on Justia Law

The First Circuit vacated Defendant's sentence imposed in connection with his plea of guilty to illegally possessing a machine gun and remanded the case for resentencing, holding that the judge's sentence "explanation" was reversible error.The crime for which Defendant was convicted carried a top prison term of ten years. Defendant sought a term of twenty-four months, and the government sought thirty months. The judge varied the sentence to sixty months because, in part, Defendant had a track record of engaging in drug offenses and weapon violations. Defendant appealed, challenging the procedural and substantive reasonableness of the judge's decision. The First Circuit vacated the sentence, holding that because the trial judge gave "weight" to arrests not backed by "convictions or independent proof of conduct," Defendant's sentence could not stand. View "United States v. Torres-Melendez" on Justia Law