Justia Civil Procedure Opinion Summaries

A pregnant inmate, Lidia Lech, filed a lawsuit against several healthcare providers and staff at the Western Massachusetts Regional Women's Correctional Center (WCC), alleging that they ignored her serious medical symptoms and denied her requests to go to the hospital, resulting in the stillbirth of her baby. The district court permitted most of Lech's claims to proceed to trial, but granted summary judgment in favor of one of the correctional officers. The jury returned a verdict in favor of the defense. On appeal, the United States Court of Appeals for the First Circuit found that the district court abused its discretion in two evidentiary rulings. The first error was allowing the defense to use Lech's recorded phone calls to impugn her character for truthfulness. The second error was excluding testimony from Lech's friend, which would have corroborated her version of events. The court concluded that at least one of these evidentiary rulings was not harmless, vacated the jury verdict, and remanded for a new trial against most of the defendants. However, the court affirmed the district court's grant of summary judgment to the correctional officer, as well as the jury verdict in favor of one of the medical providers. View "Lech v. Von Goeler" on Justia Law

The case involves Nicholas Triantos, who sued various parties, including the law firm that represented Deutsche Bank in the foreclosure sale of his home, and the three partners of the firm. The district court dismissed his suit, and the law firm and its partners then moved for sanctions against Triantos under Federal Rule of Civil Procedure 11. The district court granted the motion and ordered Triantos to pay $10,000 in attorneys' fees and $32.00 in costs. Triantos appealed this order. The United States Court of Appeals for the First Circuit reversed and vacated the order. The court found that the district court had imposed sanctions under Rule 11 without following the rule's procedural requirements. The court explained that the law firm served its motion on Triantos only after the district court had dismissed the case, and it did not meet its obligation under Rule 11's safe-harbor provisions to serve the motion on Triantos twenty-one days prior to filing it with the court. The district court also erred by imposing sanctions without describing in its order the sanctionable conduct or explaining the basis for its decision. View "Triantos v. Guaetta & Benson, LLC" on Justia Law

In this case, the United States Court of Appeals for the First Circuit considered an appeal from a ruling by the United States District Court for the District of Puerto Rico concerning the restructuring of debts of the Commonwealth of Puerto Rico's public power company (PREPA) under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The appellants, GoldenTree Asset Management and Syncora Guarantee (the "Bondholders"), held around $1 billion of PREPA's roughly $8 billion in bonds and sought relief from the automatic stay on actions against PREPA's estate, hoping to appoint a receiver for PREPA.The Bondholders argued that the automatic stay lifted by operation of law, because the district court denied their latest motion for relief without first noticing and holding a hearing within the timeframe prescribed by 11 U.S.C. § 362(e)(1). However, the appellate court held that the Bondholders waived their right to a prompt notice and hearing on that motion for relief. The court reasoned that the Bondholders accepted a litigation schedule that postponed any hearing on their request for leave to seek the appointment of a receiver until after a parallel proceeding about whether—and to what extent—the Bondholders had any collateral to protect in the first place. The court therefore affirmed the judgment of the Title III court. View "GoldenTree Asset Management LP v. Financial Oversight and Management Board" on Justia Law

This case involves a medical malpractice suit against Hospital San Cristobal (HSC), Dr. Iris Vélez García, and Dr. Zacarías A. Mateo Minaya by the children of Ramona Rodríguez Rivera, who passed away while in the care of HSC. The plaintiffs alleged that their mother received negligent care at HSC during and following an abdominal surgery performed by Dr. Vélez and Dr. Mateo, leading to her death. The United States District Court for the District of Puerto Rico granted summary judgment in favor of the defendants.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court held that the district court did not err in excluding the plaintiffs' expert witness's testimony under Federal Rule of Evidence 702. The expert's report failed to identify the standard of care that HSC staff should have adhered to in their management of the patient's diabetes and how the staff deviated from that standard. Without this expert testimony, the plaintiffs could not establish a breach of the defendants' duty of care, a necessary element of a negligence claim. The appellate court also found no error in the district court's grant of summary judgment to the defendants as there was no evidence in the record that could show the defendants' negligence. View "Rivera Rodriguez v. Hospital San Cristobal" on Justia Law

The United States Court of Appeals for the First Circuit ruled on a case involving a commercial real estate transaction in Puerto Rico that failed to close. The sellers of the property, located in Valle Arriba Heights, had entered into agreements to sell their respective parcels to KRB Universal Investments, LLC, which later assigned its rights under the agreements to CPC Carolina PR, LLC ("CPC"). The conditions of the sale included the cancellation of restrictive covenants that limited the use of the property to residential purposes. CPC intended to lease the properties to Puerto Rico CVS Pharmacy, LLC ("CVS") for commercial use. However, CVS refused to proceed with the lease due to restrictive covenants and issues with the title insurance policy. The sellers sued CPC and CVS for negligence, alleging that they had been induced into an impossible contract and that CVS's actions had contributed to vandalism on the properties. The district court granted summary judgment in favor of CPC and CVS. On appeal, the appellate court affirmed the district court's decision, holding that the sellers' claims were time-barred and that they failed to establish the necessary elements of their negligence claims. View "Hamdallah v. CPC Carolina PR, LLC" on Justia Law

The United States Court of Appeals for the First Circuit reviewed an appeal concerning personal jurisdiction in a case centered on foodborne illness. Anthony Cappello, a resident of New Hampshire, had consumed a salad from a New Jersey deli, which he alleged was contaminated with E. coli. Following his diagnosis, Cappello filed a lawsuit against the deli, the company that sold the lettuce to the deli (Restaurant Depot, LLC), the distributor of the lettuce (D'Arrigo Brothers, Co.), the grower of the lettuce (Adam Brothers Farming, Inc.), and one hundred John Does. Cappello later dismissed his claims against all defendants except for Restaurant Depot and D'Arrigo Brothers. Both companies moved to dismiss the case for lack of personal jurisdiction, arguing that Cappello's claims did not arise from their contacts with New Hampshire. The District Court dismissed the case, and Cappello appealed. The Court of Appeals affirmed the lower court's decision, albeit on different grounds. The court held that Cappello failed to demonstrate the necessary element of relatedness required to establish specific personal jurisdiction under the due process clause. Neither defendant's contacts with New Hampshire were instrumental in the formation or breach of the contract related to the sale of the salad, nor were they related to the tort claims. The court found that the defendants' contacts with New Hampshire were not sufficiently related to Cappello's claims to establish personal jurisdiction. View "Cappello v. Restaurant Depot, LLC" on Justia Law

In this case, Virginia Cora Ward, as the administratrix of the estate of Edmund Edward Ward, brought a case against AlphaCore Pharma, LLC (ACP) and Bruce Auerbach. The decedent, Edmund Ward, was a participant in a clinical trial for a drug known as ACP-501, which was developed by ACP and administered by the National Institutes of Health (NIH). The trial took place in Maryland, where Ward traveled from his home in Massachusetts to receive treatment. Ward later withdrew from the trial due to deteriorating kidney function.In 2016, Ward filed a complaint against ACP, Auerbach, and several others, alleging fraudulent inducement to participate in the clinical trial. ACP and Auerbach moved to dismiss the case for lack of personal jurisdiction, arguing that they lacked sufficient contacts with Massachusetts. The United States District Court for the District of Massachusetts agreed with them and dismissed the case. Ward appealed to the United States Court of Appeals for the First Circuit.The First Circuit affirmed the district court's decision. The court held that neither ACP nor Auerbach had sufficient related and purposeful contacts in and with Massachusetts to establish personal jurisdiction. The court rejected Ward's claims that ACP and Auerbach had contacts with Massachusetts through their interactions with Ward's Massachusetts-based doctor, their alleged shipment of the drug to Massachusetts, their involvement in drafting the clinical trial protocol, and their alleged reimbursement of Ward's travel expenses. The court found that these claims were either unsupported by evidence or were not sufficient to establish personal jurisdiction. As a result, the court affirmed the district court's dismissal of the case against ACP and Auerbach for lack of personal jurisdiction. View "Ward v. Schaefer" on Justia Law

This case involves the Boston Parent Coalition for Academic Excellence Corp., which challenged the temporary admissions plan for three selective public schools in Boston. The admissions plan was based on students' grade point averages (GPAs), zip codes, and family income, rather than on standardized test scores. The Coalition claimed that the plan had a disparate impact on White and Asian students and violated the Equal Protection Clause of the Fourteenth Amendment and Massachusetts law.The United States Court of Appeals for the First Circuit found that the Coalition's claim lacked merit. It held that the Coalition failed to show any relevant disparate impact on White and Asian students, who were over-represented among successful applicants compared to their percentages of the city's school-age population. The court also found that the Coalition failed to demonstrate that the plan was motivated by invidious discriminatory intent. It pointed out that the Plan's selection criteria, which included residence, family income, and GPA, could hardly be deemed unreasonable.The court noted that any distinction between adopting a criterion (like family income) notwithstanding its tendency to increase diversity, and adopting the criterion because it likely increases diversity, would, in practice, be largely in the eye of the labeler. It emphasized that the entire point of the Equal Protection Clause is that treating someone differently because of their skin color is not like treating them differently because they are from a city or from a suburb.The court also rejected the Coalition's appeal of the district court's denial of its motion under Federal Rule of Civil Procedure 60(b), which sought relief from the judgment based on newly discovered evidence that some members of the School Committee harbored racial animus. The court found that the district court did not abuse its discretion in denying the motion, as the Coalition had failed to show that the newly discovered evidence was of such a nature that it would probably change the result were a new trial to be granted.The court therefore affirmed the judgment of the district court. View "Boston Parent Coalition for Acad. Excellence Corp. v. The School Committee of the City of Boston" on Justia Law

Brian Smith, a Rhode Island resident, sued Prudential Insurance Company of America for breach of fiduciary duty after the company terminated his long-term disability benefits under an insurance policy. The policy stated a three-year limitations period to file a lawsuit, which began on the date Smith was required to submit proof of his disability, not on the date Prudential allegedly breached the policy by stopping payment. Consequently, by the time Smith filed his lawsuit, the limitations period had expired. Smith appealed to the United States Court of Appeals for the First Circuit after the United States District Court for the District of Rhode Island granted summary judgment in favor of Prudential on the grounds that Smith's lawsuit was filed too late.Smith argued that enforcing the limitations scheme would violate Rhode Island public policy. While the Court of Appeals found compelling reasons to believe that the limitations scheme might indeed contravene Rhode Island public policy, they also recognized that reversing and remanding on that ground would potentially expand Rhode Island law. Consequently, the Court of Appeals decided to certify the public policy question to the Rhode Island Supreme Court. The certified question is whether, in light of specific state laws and Rhode Island public policy, Rhode Island would enforce the limitations scheme in this case to bar Smith's lawsuit against Prudential. View "Smith v. Prudential Insurance Company of America" on Justia Law

In this dispute, two renewable-energy generating companies, Tyngsboro Sports II Solar, LLC and 201 Oak Pembroke Solar LLC, appealed to the United States Court of Appeals for the First Circuit after their class-action lawsuit was dismissed by the District Court for the District of Massachusetts due to lack of subject-matter jurisdiction. The plaintiffs had a longstanding disagreement with defendants, utility companies National Grid USA Service Company, Inc. and Massachusetts Electric Company, over certain tax-related fees charged to them. The plaintiffs sought redress in federal court after unsuccessful petitions to state authorities.The plaintiffs argued that the district court had jurisdiction due to the case's connection to federal tax law, however, the appellate court disagreed, stating that the plaintiffs' complaint did not bring any claim that arose under federal law. The plaintiffs had brought forth four claims against National Grid, including a request for declaratory relief, a state-law claim for a breach of the covenant of good faith and fair dealing, a state-law claim for restitution and unjust enrichment, and a state-law claim for violating a statutory requirement that public utilities assess only just and reasonable charges.The appellate court affirmed the district court's dismissal of the case, finding that the plaintiffs could not establish federal-question jurisdiction simply by asserting a state-law claim to which there was a federal defense. The court noted that the state-law claims did not necessarily raise a federal issue, and to the extent that one did, the issue was not substantial. As such, the court concluded that the district court lacked jurisdiction over the claims. View "Tyngsboro Sports II Solar, LLC v. National Grid USA Service Co., Inc." on Justia Law