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

In this case arising from losses that SAS International, Ltd. (SAS) claimed to have suffered during the COVID-19 pandemic the First Circuit affirmed the judgment of the district court granting General Star Indemnity Company's motion to dismiss the complaint under Fed. R. Civ. P. 12(b)(6), holding that there was no error.SAS filed an amended complaint alleging a breach of contract count based on three coverage provisions and a declaration that the relevant policy covered its claims. The district court granted General Star's motion to dismiss all of SAS's claims, holding that COVID-19 and the virus that causes it were not covered causes of loss. The First Circuit affirmed, holding that the district court did not err in granting General Star's motion to dismiss. View "SAS International Ltd. v. General Star Indemnity Co." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing the claims brought by Legal Sea Foods under Massachusetts law against Strathmore Insurance Co. following Strathmore's denial of Legal's request for coverage losses it claimed to have suffered during the COVID-19 pandemic, holding that there was no error.The second amended complaint asserted two breach of contract counts, one count of a violation of Chapter 93A of the Massachusetts General Laws, and a declaratory judgment count. The district court dismissed all claims for failure to state a claim upon which relief can be granted. The First Circuit affirmed, holding that the district court did not err by granting Strathmore's motion to dismiss for failure to state a claim. View "Legal Sea Foods, LLC v. Strathmore Insurance Co." on Justia Law

The First Circuit affirmed Defendant's convictions for receipt and possession of child pornography, holding that the district court did not err in denying Defendant's pre-trial motion to suppress evidence obtained pursuant to a search warrant and did not abuse its discretion in excluding certain text-message evidence as inadmissible hearsay.On appeal, Defendant argued that the district court erred in denying his motion to suppress because the affidavit filed in support of the search warrant failed sufficiently to describe ether pornographic images to be found and that the court erred in excluding from his trial the text message evidence at issue. The First Circuit affirmed, holding (1) there was no error in the district court's denial of Defendant's motion to suppress; and (2) the district court did not err in barring the text messages from Defendant's trial. View "United States v. Chiu" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment for Arch Insurance Co. and dismissing this diversity case brought by Graphic Builders, LLC, a general contractor, seeking to enforce a performance bond issued by Arch as surety for a subcontractor hired to work on a major project for Graphic, holding that the district court did not err.On appeal, Graphic argued that the district court erred in concluding that Arch's obligation to provide the warranty performance it sought was conditioned on termination of the subcontractor and that both the bond's language and relevant precedent supported its position. The First Circuit disagreed and affirmed, holding that the district court properly granted summary judgment for Arch. View "Arch Insurance Co. v. Graphic Builders LLC" on Justia Law

The First Circuit reversed the decision of the district court that the prosecutor in the underlying Rhode Island case transgressed the Batson rule in the course of jury selection but that Petitioner was not entitled to habeas corpus relief, holding that the decision of the Rhode Island Supreme Court could not withstand habeas review.Petitioner, a Rhode Island state prisoner and an African-American man who was convicted of murder and other crimes, claimed in his petition for writ of habeas corpus that the prosecutor violated Batson during jury selection. The federal district court concluded that Petitioner's rights under Batson were violated but that the Rhode Island Supreme Court did not abuse its discretion in finding sufficient race-neutral reasons for a peremptory challenge against the juror in question. The First Circuit reversed, holding (1) the prosecutor's explanation for his peremptory strike was not race-neutral on its face and thus violated Batson; and (2) the Rhode Island Supreme Court's decision rested on either an unreasonable application of clearly established federal law, an unreasonable determination of the facts, or both. View "Porter v. Coyne-Fague" on Justia Law

The First Circuit affirmed the judgment of the district court entering summary judgment in favor of Dr. Peter Millett and dismissing Joseph Shea's alleged breach of oral contract action, holding that the statute of frauds barred this Court from enforcing any agreement against Millett so as to require him to pay Shea from July 1, 2016 onward.In 2010, Millett spoke with Shea at a medical conference seeking Shea's help in negotiating a certain deal. Shea understood this conversation to create a binding contract. In 2017, Shea brought this lawsuit asserting that he was owed payments beyond a final payment made on June 30, 2016. The district court entered summary judgment in favor of Millett, concluding that any agreement between the parties was unenforceable under the Massachusetts statute of frauds, Mass. Gen. Laws ch. 259, 1, 7. The First Circuit affirmed, holding that there was no enforceable contract between the parties requiring Millett to pay Shea after June 30, 2016. View "Shea v. Millett" on Justia Law

The First Circuit affirmed the judgment of the district court revoking Defendant's supervised release and adding to the terms of his supervised release a monitoring condition as to Defendant's computer activities to provide him with incentives to comply with the law, holding that the condition was not unwarranted.Defendant pleaded guilty to a twenty-four-count indictment charging him with money laundering, mail and wire fraud, and tax evasion and was sentenced to fifteen-years in prison. After he was released, Defendant stipulated to violating the terms of his supervised release. The district court revoked Defendant's supervised release and imposed several new conditions of supervision, including the condition at issue on appeal. The First Circuit affirmed, holding that the imposition of the computer monitoring condition was not an abuse of discretion. View "United States v. Windle" on Justia Law

The First Circuit affirmed the judgment of the district court sentencing Defendant to a 150-month term of immurement in connection with his plea of guilty to conspiracy to distribute and to possess with intent to distribute controlled substances, holding that there was no breach of the plea agreement in this case.On appeal, Defendant argued that the government breached the parties' agreement to recommend a sentence at the low end of the applicable guideline range and that the alleged breach defeated a waiver-of-appeal provision in the plea agreement. The First Circuit affirmed the judgment below, holding that, under the plain error standard, Defendant failed to show that the prosecutor's overall conduct was other than "reasonably consistent with making [the promised] recommendation." View "United States v. Lessard" on Justia Law

In this climate-change case, the First Circuit once more affirmed the order of the federal district court allowing Rhode Island's motion to return to state court its state court complaint against oil and gas companies for damages caused by fossil fuels, holding that Rhode Island's complaint did not give rise to federal removal jurisdiction.Rhode Island originally brought this complaint in state court, alleging state-law causes of action for, inter alia, public nuisance. After the energy companies removed the case to federal district court Rhode Island moved for the case to be remanded to state court. The district court granted the motion and ordered the case remanded to state court. The First Circuit affirmed the remand order. On certiorari, the Supreme Court instructed that the First Circuit give further consideration in light of recent caselaw. The First Circuit received supplemental briefs and then affirmed once more the judge's remand order, holding that removal based on federal-question jurisdiction and on other jurisdictional and removal statutes was not proper. View "State of Rhode Island v. Shell Oil Products Co., LLC" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing all claims in this dispute between brokerage customers of Defendant, who purchased special Puerto Rico securities during a recession but before the bond market crash, holding that there was no error in the proceedings below.Plaintiffs brought a securities class action against Defendant, asserting claims under federal securities laws and Puerto Rico law. The district court entered judgment dismissing the federal law claims with prejudice and the state law claims without prejudice. The First Circuit affirmed, holding that Plaintiffs' claims that there were allegedly material omissions on the part of Defendant were not actionable. View "Ponsa-Rabell v. Santander Securities, LLC" on Justia Law