Justia Civil Procedure Opinion Summaries

A noncitizen who arrived in the United States from Cambodia as a child and later became a lawful permanent resident was convicted in Rhode Island state court in 1996 of a controlled substance offense. This conviction led to deportation proceedings, and an immigration judge found him deportable in 1998. The Board of Immigration Appeals (BIA) dismissed his appeal in 1999. Over twenty years later, the Rhode Island prosecutor dismissed his conviction in 2020, citing equitable reasons. The noncitizen then unsuccessfully filed his first motion to reopen his removal proceedings with the BIA, which denied it as untimely and found no substantive or procedural defect in the original conviction.Following this, the noncitizen obtained a consent order from the Rhode Island Superior Court in 2023, vacating his prior plea and sentence based on a violation of Rule 11 of the Rhode Island Rules of Criminal Procedure, which relates to due process in plea colloquies. In April 2024, he filed a second motion to reopen his removal proceedings with the BIA, this time invoking the BIA’s sua sponte authority. The BIA again denied reopening, treating the motion as statutory, finding it time and number barred, and concluding he failed to demonstrate due diligence or a defect in the conviction.On review, the United States Court of Appeals for the First Circuit found that the BIA committed legal error by mischaracterizing the second motion as statutory rather than sua sponte. The appellate court held that sua sponte motions are not subject to the same time and number limitations or equitable tolling standards as statutory motions. The court also found that the BIA erred by overlooking the Superior Court's order, which clearly indicated the conviction was vacated due to a procedural defect. The First Circuit granted the petition for review and remanded for further proceedings. View "Kim v. Blanche" on Justia Law

A mother brought suit on behalf of herself and her minor son, alleging that the son developed leukemia after attending school near and residing close to a manufacturing plant operated by General Electric Company. The plant, located in Pittsfield, Massachusetts, produced electrical transformers and capacitors containing polychlorinated biphenyls (PCBs) for decades. The plaintiff claimed that GE’s use, disposal, and storage of PCBs caused the son’s illness, and sought recovery under various legal theories, including strict liability, negligence, fraudulent misrepresentation, nuisance, improper transportation of hazardous material, and loss of consortium. The complaint included claims related to the defective design and use of PCB materials, as well as their disposal and remediation.The plaintiff originally filed suit in Massachusetts state superior court. GE removed the case to the United States District Court for the District of Massachusetts, asserting federal officer removal jurisdiction under 28 U.S.C. § 1442(a)(1), based on its wartime production of PCB-containing devices for the federal government and its later remediation efforts pursuant to a consent decree with the EPA. The plaintiff moved to remand the case to state court, arguing that GE failed to meet the requirements for federal officer removal. The district court agreed, ordered remand, and stayed that order pending appeal.The United States Court of Appeals for the First Circuit reviewed the district court’s jurisdictional determination de novo. It held that GE satisfied both the “acting under” and “for or relating to” elements of the federal officer removal statute, due to its extensive work producing PCB-containing devices for the federal government. The court reversed the district court’s remand order and remanded the case for the district court to determine whether GE has a colorable federal defense. View "Czerno v. General Electric Company" on Justia Law

The plaintiff worked for over twenty years in various administrative roles for the Drug Enforcement Agency (DEA) in Puerto Rico, eventually becoming Secretary to the Assistant Special Agent in Charge. In 2016, after suffering a foot injury, she requested workplace accommodations, some of which were denied. She filed an Equal Employment Opportunity (EEO) complaint alleging discrimination based on disability and national origin. Subsequently, other DEA agents filed an EEO complaint against her, and she filed a retaliation complaint with the Department of Justice’s Office of the Inspector General. A series of workplace conflicts followed, including a verbal altercation, revocation of outside work permission, and eventual suspension. After further absence and issues with communication with supervisors, she was reassigned to another office. An internal investigation led to her termination for insubordination and alleged lack of candor.She appealed her termination to the Merit Systems Protection Board (MSPB), arguing it was retaliatory and unsupported by evidence. The MSPB found no lack of candor, but upheld the insubordination charge and her termination. She then sought judicial review in the United States District Court for the District of Puerto Rico, which denied her discovery motions and granted summary judgment to the government, finding no prima facie case of retaliation and holding that the MSPB’s decision was supported by substantial evidence.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s rulings. The court held that the denial of the plaintiff’s Rule 56(d) motion for additional discovery was not an abuse of discretion, as she did not show good cause for her delay. On the merits, the court concluded that the MSPB’s finding of insubordination was supported by substantial evidence and that the plaintiff failed to show the employer’s stated reasons for termination were pretext for retaliation under Title VII. View "Hernandez v. Blanche" on Justia Law

Plaintiffs had their property taken by the Commonwealth of Puerto Rico through eminent domain. They received over two million dollars in compensation, including interest accrued up to the time of payment. However, they alleged a second violation occurred when the court-administered disbursement process failed to notify them of further accrued interest and deducted a 15% administrative fee from that interest. They challenged these practices as unconstitutional takings and violations of due process, seeking declaratory and equitable relief against the Administrator of the Administration of Tribunals.The United States District Court for the District of Puerto Rico initially dismissed most claims, finding plaintiffs lacked standing because they had not alleged an attempt to withdraw the accrued interest, making their injury speculative. After reconsideration, the court revived the claim challenging the deduction of administrative fees, but limited relief to prospective injunctive relief due to Eleventh Amendment constraints. The court ultimately granted summary judgment to the defendant, finding the administrative fee reasonable and not an unconstitutional taking, as plaintiffs provided no evidence to the contrary.The United States Court of Appeals for the First Circuit reviewed the case and confronted jurisdictional issues arising from Puerto Rico’s Title III bankruptcy under PROMESA. The court held that the administrative fee claim was void for violating the automatic stay provisions, as it amounted to a demand for property of the debtor (the Commonwealth), and dismissed that portion of the appeal. Regarding the interest claim, the court affirmed the district court’s dismissal, ruling plaintiffs lacked standing because they failed to allege they sought disbursement or challenged existing procedures. The First Circuit thus dismissed the appeal from summary judgment and affirmed the district court's dismissal. View "Hernandez-Castrodad v. Steidel-Figueroa" on Justia Law

The case centers on Tyler Jon Taker, a resident of Maine, who became subject to a state court order for protection from abuse, which he agreed to. This order prohibited him from possessing firearms and certain other weapons until March 22, 2026. While the protective order was in effect, Taker applied for a concealed handgun permit, but his application was denied by the local police chief due to the existence of the order. Taker then filed a federal lawsuit against various federal, state, and local officials, seeking declaratory and injunctive relief from federal and state statutes that prohibit individuals with certain convictions or protective orders from possessing firearms. He also sought damages against the police chief under 42 U.S.C. § 1983 for the denial of his concealed carry permit.The United States District Court for the District of Maine dismissed Taker’s claims. The court found that Taker was not a law-abiding citizen due to his prior felony drug conviction and that the statutes prohibiting his possession of firearms were consistent with historical tradition and thus constitutional. The District Court did not specify whether it dismissed for failure to state a claim or lack of subject matter jurisdiction but appeared to rule on the merits. Taker appealed this dismissal.The United States Court of Appeals for the First Circuit reviewed the case. The court held that Taker lacked Article III standing to pursue declaratory and injunctive relief because the protective order itself independently barred him from possessing firearms, so the relief sought would not redress his alleged injury. As for the damages claim against the police chief, the court found that the chief was entitled to qualified immunity because Taker’s constitutional rights were not clearly established in this context. The First Circuit affirmed the dismissal of the damages claim, vacated the dismissal of the declaratory and injunctive claims, and remanded with instructions to dismiss those claims for lack of jurisdiction. View "Taker v. Blanche" on Justia Law

A tenured professor at a university was terminated in 2022 following a classroom incident where students objected to terminology used in an assigned reading and a subsequent discussion of LGBTQ+ rights in Latin America. The professor alleged that her Department Chair encouraged students to submit complaints against her, and that there was a coordinated effort to undermine her reputation. After complaints were submitted, the university held a student meeting about the professor’s conduct, restricted some of her duties, and ultimately terminated her employment "for cause," citing continued misconduct and failure to fulfill faculty responsibilities. The professor appealed her termination to the Faculty Hearing Board, which upheld the decision by a narrow margin, citing procedural issues but attributing them to outdated dismissal procedures rather than prejudice. The Board found her teaching was not culturally responsive and noted longstanding concerns about her interaction with students. The minority opinion of the Board disagreed, finding the process unfair. The university’s Board of Trustees unanimously affirmed the termination.The professor then filed a verified complaint in Rhode Island Superior Court against the university, its Board of Trustees, and several colleagues. She alleged violations of federal and state anti-discrimination laws, as well as state tort and contract claims related to her termination. The university removed the case to the United States District Court for the District of Rhode Island and moved to dismiss. The district court dismissed the federal and state anti-discrimination claims for failure to state a claim, finding insufficient factual allegations connecting protected characteristics to the termination. The court declined to exercise supplemental jurisdiction over the state claims and remanded them to state court.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s judgment. The First Circuit held that the professor failed to plead sufficient facts to make her discrimination, hostile work environment, and retaliation claims plausible, and found no error in the district court’s consideration of certain documents. View "Crawford v. Salve Regina University" on Justia Law

Four residents of Worcester County, Massachusetts alleged that the Massachusetts State Police (MSP) secretly recorded their phone conversations with officers and stored the recordings in an online database. They claimed the MSP used these recordings to propose charges in at least 181 criminal cases but did not disclose the existence of the recordings to prosecuting agencies. The plaintiffs, none of whom alleged pending charges or convictions related to these recordings, sought declaratory and injunctive relief, asserting violations of the Massachusetts Wiretap Act (later voluntarily dismissed) and their federal constitutional rights under the Sixth and Fourteenth Amendments via 42 U.S.C. § 1983.The United States District Court for the District of Massachusetts allowed voluntary dismissal of the state law claim but denied the Superintendent’s motion to dismiss the § 1983 claim. The district court found that sovereign immunity did not bar the official-capacity suit under the Ex parte Young exception, as the plaintiffs sought only prospective relief for alleged ongoing violations of federal law. The court further concluded that the plaintiffs had standing, reasoning that the MSP’s counsel had not unequivocally stated that the challenged recording and withholding practices had ceased or that all recordings had been disclosed.On interlocutory appeal, the United States Court of Appeals for the First Circuit reviewed the standing determination. The First Circuit held that the plaintiffs failed to allege an injury in fact with sufficient concreteness or imminence to establish standing for prospective relief. Their allegations were found to be generalized and lacked any indication that they personally faced a substantial risk of future harm. As a result, the First Circuit reversed the district court’s denial of the Superintendent’s motion to dismiss and remanded for further proceedings. View "Courtemanche v. Noble" on Justia Law

The plaintiff, a member of the New Progressive Party and a former System Technician Coordinator for the Municipality of Aguadilla, Puerto Rico, alleged that after a new mayor from the Popular Democratic Party took office, he was subjected to politically motivated adverse employment actions. Specifically, he claimed his server access was revoked, he received a poor employment evaluation, and his work environment became intolerable, all of which led to his constructive resignation. He asserted that these actions were taken because of his political affiliation.Following discovery, several individual defendants moved for summary judgment on the claims against them in their individual capacities, arguing that the plaintiff had not established a prima facie case of political discrimination under the First Amendment and raising a qualified immunity defense. Importantly, they did not address the claims against them in their official capacities, the municipality, or the equal protection and Puerto Rico law claims. The plaintiff opposed the motion, but the district court, adopting a magistrate judge’s report and recommendation, granted summary judgment for the individual defendants and sua sponte dismissed the entire case with prejudice, citing waiver and a lack of evidence.The United States Court of Appeals for the First Circuit reviewed the case and held that the district court erred in granting summary judgment based on waiver alone and in concluding there was no evidence supporting the plaintiff’s claims. The appellate court found that the plaintiff’s deposition testimony created genuine disputes of material fact regarding the involvement and knowledge of the defendants. The court also held that the district court improperly dismissed claims against parties who had not moved for summary judgment without giving the plaintiff notice. The judgment was reversed and the case remanded for further proceedings. View "Arocho-Rodriguez v. Roldan-Concepcion" on Justia Law

Elizabeth and Cale Putnam, residents of Massachusetts, traveled to the Hotel Valcartier in Québec, Canada, with their five-year-old son, Anthony. While staying at the hotel, an unsecured Murphy bed fell on Anthony, causing fatal injuries. The Putnams had booked their stay at the hotel and its associated Ice Hotel through the hotel’s website, received receipts and marketing communications at their Massachusetts address, and noticed other Massachusetts vehicles at the hotel during their visit.Following Anthony’s death, the Putnams filed a wrongful death lawsuit in the United States District Court for the District of Massachusetts against Premier Parks, LLC, which they believed operated the hotel, and EPR Properties, which they believed owned it. Both Premier and EPR moved to dismiss for lack of personal jurisdiction, submitting affidavits asserting they neither owned nor operated the hotel, nor marketed or contracted with Massachusetts residents regarding the hotel. The Putnams submitted documentary evidence suggesting connections between Premier, EPR, and the hotel, but the district court dismissed the case with prejudice and denied their request for jurisdictional discovery.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The court found that, as to Premier Parks, the Putnams presented enough documentary evidence to create a genuine dispute regarding Premier’s involvement in the hotel’s operations, marketing, and staffing. The court held that the district court abused its discretion by denying jurisdictional discovery with respect to Premier and reversed the dismissal as to Premier, remanding for discovery. Regarding EPR, the court concluded that the Putnams failed to contradict EPR’s affidavit that it did not own or operate the hotel or market it to Massachusetts residents. The court affirmed the dismissal as to EPR but modified the judgment to be without prejudice. View "Putnam v. EPR Properties" on Justia Law

The plaintiffs, who were long-time friends of the defendants, invested significant sums in a biopharmaceutical company controlled by the defendants. The defendants did not disclose that the company was in serious financial distress, under a substantial obligation to a lender, and prohibited from incurring additional debt. The investment was structured through promissory notes, which included false warranties regarding the company’s financial status and claimed the formation of a new entity that never materialized. Instead of funding a new venture, the defendants used the investment to pay off existing company debt. Less than two years later, the company declared bankruptcy, making the notes essentially worthless.The plaintiffs brought claims under federal and Massachusetts securities laws, the Massachusetts consumer protection statute, and for common law fraud and negligent misrepresentation in the United States District Court for the District of Massachusetts. The defendants moved to dismiss the action, relying on a forum selection clause in the promissory notes requiring litigation in Delaware courts. The district court granted the motion and dismissed the case without prejudice, concluding that the clause applied to the plaintiffs’ claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the dismissal de novo. The plaintiffs argued that their claims did not “arise out of” the notes and that the forum selection clause was unenforceable as contrary to Massachusetts public policy. The First Circuit rejected both arguments, holding that the claims arose from the notes and that the plaintiffs did not meet the heavy burden required to invalidate the clause on public policy grounds. The First Circuit affirmed the district court’s dismissal without prejudice, leaving the plaintiffs free to pursue their claims in the contractually designated Delaware courts. View "Manzo v. Wohlstadter" on Justia Law