Articles Posted in US Court of Appeals for the First Circuit

by
The First Circuit affirmed the judgment of the district court determining that Appellant was barred from relitigating his argument that Plaintiffs should be compelled to arbitrate various tort claims, holding that the district court did not err in denying Appellant’s motion to compel arbitration. At issue in this procedurally complicated case was whether Appellant’s association with a certain law firm required that Plaintiffs’ various tort claims, including their claims of legal malpractice, be submitted to arbitration. After adopting a magistrate judge’s report and recommendation and applying principles of collateral estoppel derived from Rhode Island law, the district court denied Appellant’s motion to compel. The First Circuit affirmed, holding that Appellant waived any claim of error regarding the magistrate judge’s analysis under Rhode Island collateral estoppel law. View "Patton v. Johnson" on Justia Law

by
The First Circuit reversed the district court’s dismissal of claims against Schechtl Maschinenbau GmbH, a German company, holding that, contrary to the conclusion of the district court, the exercise of personal jurisdiction over Schechtl comported with due process. Stephen Knox’s hand was injured at his work when he operated a machine manufactured by Schechtl. The machine had been sold to Knox’s employer by MetalForming, Inc., an American company located in Georgia and Schechtl’s U.S. distributor. Knox sued both Schechtl and MetalForming in Massachusetts state court. MetalForming removed the case to Massachusetts federal district court and filed crossclaims against Schechtl. The district court granted Schechtl’s motion to dismiss, concluding that Schechtl had not purposefully availed itself of the privilege of doing business in Massachusetts. The First Circuit reversed, holding that Knox and MetalForming met their burden of demonstrating that Schechtl purposefully availed itself of the privilege of conduct activities within Massachusetts. View "MetalForming, Inc. v. Schechtl Maschinenbau GmbH" on Justia Law

by
The First Circuit affirmed the decision of the district court dismissing Plaintiff’s action on the grounds that the lawsuit was, in essence, an appeal from a state-court judgment, and therefore, the court lacked jurisdiction to hear it under the Rooker-Feldman doctrine, holding that the district court correctly held that it lacked jurisdiction to hear Plaintiff’s claims. This appeal arose from Plaintiff’s legal challenge seeking to void two Massachusetts Superior Court conditions of probation imposed on the adult male who was convicted of statutory rape after impregnating Plaintiff when she was a minor. One of those conditions ordered the defendant to acknowledge paternity of the child. The district court decided that it did not have jurisdiction over the claims. The First Circuit affirmed, holding that because the relief Plaintiff sought was based on her claim that the Massachusetts Supreme Judicial Court erred in the adjudication of her case, the district court properly dismissed this case for want of jurisdiction. View "Tyler v. Supreme Judicial Court of Massachusetts" on Justia Law

by
The First Circuit affirmed the order of the district court dismissing Plaintiff’s contract and tort claims for lack of personal jurisdiction, holding that the federal court in Puerto Rico lacked personal jurisdiction over Defendants. Plaintiff, a Puerto Rico tour company, brought this diversity suit in the United States District of Puerto Rico, alleging that a California youth soccer organization and related defendants breached duties that the organization owed to Plaintiff under Puerto Rico contract and tort law. The allegations centered around Defendants’ acts of first requesting that Plaintiff make an offer for a potential soccer trip to Puerto Rico for some of the organization’s teams and their families and then declining after further communications to book the tour. The district court dismissed the claims for lack of personal jurisdiction. The First Circuit affirmed, holding that the exercise of specific jurisdiction in the forum over the out-of-forum defendants did not conform to the federal constitutional test. View "PREP Tours, Inc. v. American Youth Soccer Organization" on Justia Law

by
In this case against members of the Rhode Island Board of Bar Examiners the First Circuit reversed the district court’s grant of attorneys’ fees in favor of Plaintiff and affirmed the court’s dismissal of Plaintiff’s amended complaint, holding that Plaintiff’s supposed “prevailing party” status was not justified. Plaintiff, an individual with attention deficit/hyperactivity disorder and anxiety, filed suit against members of the Board challenging the Board’s denial of his request for certain accommodations to assist him in taking the Rhode Island bar exam. The district court issued a temporary restraining order (TRO) requiring the Board to permit Plaintiff the requested accommodations, dismissed Plaintiff’s amended complaint, and allowed Plaintiff’s motion for attorneys’ fees. On review, the First Circuit held (1) Plaintiff’s success in gaining a TRO did not warrant an award of attorneys’ fees; and (2) the district court’s decision to allow the Board’s motion to dismiss the damage claim in the complaint was correct. View "Sinapi v. Rhode Island Board of Bar Examiners" on Justia Law

by
The First Circuit dismissed as moot a school district’s challenge to the district court’s order compelling the school district to determine a student’s eligibility for an Individualized Education Program (IEP) without first obtaining its own evaluations and reversed the district court’s award of attorneys’ fees to the student’s parents, holding that the challenge to the order was moot and the attorneys’ fee award was mistaken. M.S., a student formerly enrolled in the Westerly School District in Westerly, Rhode Island, suffered from Lyme Disease and other tick-borne illnesses. Plaintiffs, M.S.’s parents, unsuccessfully sought to have Westerly determine that M.S. was eligible for an IEP under the Individuals with Disabilities Education Act. During the dispute, the district court entered an order forcing Westerly to forego conducting its own evaluations and decide immediately if M.S. was eligible for an IEP, resulting in a determination that M.S. was not eligible. The court then awarded Plaintiffs attorneys’ fees as the prevailing parties. On appeal, the First Circuit held (1) because M.S. and Plaintiffs have since moved out of the Westerly school district, this Court lacked the power to review the order that Westerly determine M.S.’s eligibility without first conducting its own evaluations; and (2) the attorneys’ fees award was not proper because Plaintiffs were not the prevailing parties. View "J.S. v. Westerly School District" on Justia Law

by
The First Circuit granted a writ of advisory mandamus sought by the Rhode Island Department of Education and Training (Department) and directed the district court to vacate its denial of a motion to quash a federal grand jury subpoena of certain Department records, holding that the District of Rhode Island erred in ruling that the attorney-client privilege is categorically unavailable to a state government in receipt of a federal grand jury subpoena. A federal grand jury sitting in the District of Rhode Island subpoenaed certain records from the Department. The Department moved to quash the subpoena to the extent it sought to compel production of documents containing confidential communications between Department staff and legal counsel. The district court denied the motion to quash, concluding that, as a categorical matter, the attorney-client privilege does not shield communications between government lawyers and their clients from a federal grand jury. The First Circuit granted the Department’s petition for a writ of advisory mandamus directing the district court to quash the subpoena, holding that this Court does not sustain the categorical rule that a state government has no attorney-client privilege that can be invoked in response to a grand jury subpoena. View "In re Grand Jury Subpoena" on Justia Law

by
The First Circuit affirmed the order of the district court exercising its ancillary jurisdiction to enforce a resolution issue by the Puerto Rico Secretary of Justice (Secretary) directing the Municipality of Juana Diaz (Municipality) to indemnify two municipal police officers found liable under Puerto Rico tort law after a federal jury trial for using excessive force resulting in a death, holding that ancillary enforcement jurisdiction was appropriate. Appellee and other family members filed this action after the shooting death of their relative at the hands of police. The jury returned a verdict for Appellee with respect to her negligence claims against two municipal police officers in their personal capacities, and the district court entered judgment against the officers. After the Secretary issued a resolution under a Puerto Rico statute referred to as “Law 9” requiring the Municipality to pay the judgments against its officers, Appellee filed a motion requesting the garnishment of the Municipality’s assets. The district court granted the motion. The First Circuit affirmed, holding that the district court had jurisdiction to enforce the Secretary’s Law 9 resolution against the Municipality. View "Burgos-Yantin v. Municipality of Juana Diaz" on Justia Law

by
The First Circuit affirmed the judgment of the district court dismissing this contract action for lack of personal jurisdiction over the defendants in Maine, holding that the district court did not err in concluding that the exercise of jurisdiction over Defendants would not comport with due process. The underlying dispute involved agreements about Defendants’ interests in an Illinois limited partnership, Elm Street Plaz Venture, LLLP. LP Solutions LLC (LPS), a Maine company, offered to buy limited interests owned by Defendants, who mostly resided in Illinois. Defendants accepted the offer and made distribution payments. When Defendants later refused to deliver partnership distributions that LPS said were assigned to it, LPS sued Defendants in Maine. The case was removed to federal district court, which determined that there was no personal jurisdiction because Defendants' contacts with Maine did not make the exercise of personal jurisdiction foreseeable. The First Circuit affirmed, holding that Defendants could not foresee the exercise of jurisdiction. View "LP Solutions LLC v. Duchossois" on Justia Law

by
The First Circuit affirmed the district court’s order dismissing the case brought by Plaintiff seeking to have the district court address the same grievances she brought without success in the Massachusetts state courts, holding that Supreme Court case law divests federal courts of subject-matter jurisdiction in such cases. A bank commenced a summary process action in the Worcester Housing Court seeking to evict Plaintiff. Plaintiff counterclaimed. The Housing Court eventually entered final judgment awarding possession of the property to the bank. Plaintiff’s appeal was unsuccessful. Thereafter, Plaintiff filed a civil action against the bank in the United States District Court for the District of Massachusetts, alleging wrongful foreclosure and other claims relating to the same issues she addressed in the summary process action. The district court granted the bank’s motion to dismiss, concluding that the doctrine set forth in D.C. Court of Appeals v. Feldman, 460 U.S. 462, 482 (1983) and Rooker v. Fidelity Trust Co., 263 U.S. 413, 415-16 (1923), deprived the federal courts of subject-matter jurisdiction. The First Circuit affirmed, holding that under the Rooker-Feldman doctrine, the district court lacked jurisdiction where Plaintiff’s federal suit sought to invalidate the antecedent state courts’ judgments. View "Klimowicz v. Deutsche Bank National Trust Co." on Justia Law