Justia Civil Procedure Opinion Summaries

Jonathan Mullane, a law student intern at the United States Department of Justice (DOJ) in 2018, was terminated from his position due to ex parte communications with a law clerk regarding a pro se case he had filed. Subsequently, the United States Securities and Exchange Commission (SEC) rescinded an internship offer to him. Mullane requested documents related to his termination from both the DOJ and SEC under the Freedom of Information Act (FOIA) and the Privacy Act. He claimed that the agencies did not conduct adequate searches and improperly withheld documents. The agencies moved for summary judgment, and the district court granted their motions in full.The United States District Court for the District of Massachusetts granted summary judgment in favor of the DOJ and SEC, dismissing Mullane's claims. Mullane appealed the district court's decision regarding the DOJ, arguing that the DOJ's search for documents was inadequate and that the district court erred in holding that the Privacy Act imposes a jurisdictional exhaustion requirement. Mullane also challenged the district court's denial of his requests for pre-dismissal discovery.The United States Court of Appeals for the First Circuit reviewed the case. The court held that the DOJ conducted an adequate search for documents under FOIA, as the search was reasonably calculated to discover the requested documents. The court also found that Mullane had waived any argument against the district court's conclusion that the Privacy Act's exhaustion requirements are jurisdictional. Consequently, the First Circuit affirmed the district court's grant of summary judgment in favor of the DOJ, dismissing Mullane's FOIA and Privacy Act claims. View "Mullane v. Department of Justice" on Justia Law

Amy Rae, a school nurse employed by Woburn Public Schools (WPS), alleged that she faced retaliatory harassment due to her advocacy for students with disabilities and complaints about her own mistreatment. Rae claimed that the harassment, primarily by Kennedy Middle School Principal Carl Nelson, began in 2011 and continued for over a decade. She filed a lawsuit in November 2022, asserting claims under Section 504 of the Rehabilitation Act, Title II of the Americans with Disabilities Act (ADA), Massachusetts's antidiscrimination statute (Chapter 151B), and for intentional infliction of emotional distress.The United States District Court for the District of Massachusetts dismissed Rae's complaint on May 5, 2023, ruling that she failed to state any claims for which relief could be granted. The court found that Rae could not rely on the continuing violations doctrine to save her untimely discrimination claims and dismissed her timely state and federal discrimination claims on other grounds.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court's dismissal de novo. The appellate court agreed that Rae could not invoke the continuing violations doctrine to rescue her time-barred claims, as her allegations included discrete acts of retaliation that accrued separately. The court also affirmed the district court's dismissal of Rae's timely ADA, Section 504, and Chapter 151B claims, concluding that Rae did not plausibly allege severe or pervasive harassment necessary to sustain a retaliatory harassment claim. The court noted that Rae's allegations of two incidents within the actionable period were insufficient to meet the standard for severe or pervasive harassment. Thus, the appellate court affirmed the district court's decision to dismiss Rae's complaint. View "Rae v. Woburn Public Schools" on Justia Law

Plaintiffs, representing their minor son, sued a hospital and a doctor for medical malpractice after their baby suffered birth injuries during delivery. They sought $6,000,000 in damages. Under Puerto Rico law, damages would be capped at $150,000 if the doctor was a faculty member at the hospital at the time of the birth. The defendants claimed the doctor was a faculty member, but could not produce a contract to prove it. The district court held a pretrial evidentiary hearing and concluded that the doctor was a faculty member, thus applying the statutory cap on damages.The U.S. District Court for the District of Puerto Rico adopted a magistrate judge's Report & Recommendation, which stated that the applicability of the statutory cap was a matter of law. The district court found that the doctor was a faculty member based on testimony and letters from the medical school, despite the absence of a contract. Plaintiffs appealed, arguing that the applicability of the statutory cap was a factual question that should have been decided by a jury.The United States Court of Appeals for the First Circuit reviewed the case. The court held that whether the doctor was a faculty member at the time of the birth was a factual question requiring a jury's determination. The court found that the evidence was not one-sided enough to compel the district court's conclusion and that the district court improperly took the question from the jury. The First Circuit vacated the district court's order and remanded the case for further proceedings consistent with its opinion. View "Perez-Perez v. Hospital Episcopal San Lucas Inc." on Justia Law

Cynthia Roberge, a State of Rhode Island employee, was involved in a car accident with an underinsured motorist while driving her personal vehicle during the course of her employment. She sought uninsured/underinsured motorist (UM/UIM) coverage under the State's insurance policy issued by Travelers Property Casualty Company of America. Travelers denied her claim, stating that she was not entitled to UM/UIM coverage because she was not driving a "covered auto" as defined by the policy.Roberge filed a lawsuit in Providence County Superior Court, asserting claims for breach of contract, declaratory judgment, and bad faith. Travelers removed the case to the United States District Court for the District of Rhode Island. The district court granted summary judgment in favor of Travelers, concluding that Roberge was not entitled to UM/UIM coverage under the policy's terms and that neither the Rhode Island Supreme Court's decision in Martinelli v. Travelers Insurance Companies nor the Rhode Island Uninsured Motorist Statute required such coverage.On appeal, the United States Court of Appeals for the First Circuit reviewed the case. The court noted that the policy's language clearly excluded Roberge from UM/UIM coverage because she was not driving a "covered auto." However, the court found that the case raised unresolved questions of Rhode Island insurance law, particularly regarding the applicability of the Martinelli exception and the requirements of the Rhode Island Uninsured Motorist Statute. The First Circuit decided to certify two questions to the Rhode Island Supreme Court: whether an employee must be considered a named insured under an employer's auto insurance policy when operating a personal vehicle in the scope of employment, and whether it violates Rhode Island law and public policy for an employer's policy to provide liability but not UM/UIM coverage to employees in such circumstances. The case was stayed pending the Rhode Island Supreme Court's response. View "Roberge v. Travelers Property Casualty Co. of America" on Justia Law

The case involves The Satanic Temple, Inc. (TST), an atheistic organization that venerates Satan, which sued the City of Boston. TST alleged that Boston's failure to invite it to give an invocation before City Council meetings violated the Establishment Clause of the First Amendment and the Free Exercise Clause of the Massachusetts Constitution. TST also argued that the district court abused its discretion by issuing a protective order preventing the deposition of Michelle Wu, a former City Councilor and current Mayor of Boston.The United States District Court for the District of Massachusetts granted summary judgment in favor of Boston and denied TST's cross-motion for summary judgment. The court found that TST had not shown that Boston's legislative prayer practice violated the Establishment Clause or the Massachusetts Free Exercise Clause. The court also ruled that the district court did not abuse its discretion by issuing a protective order preventing TST from deposing Mayor Wu.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court held that TST had not demonstrated that Boston's legislative prayer practice, either on its face or as applied, violated the Establishment Clause or the Massachusetts Free Exercise Clause. The court also found that the district court did not abuse its discretion in issuing the protective order preventing the deposition of Mayor Wu. The appellate court emphasized that Boston's practice of selecting invocation speakers based on their contributions to the community was constitutional and did not show evidence of religious discrimination. View "Satanic Temple, Inc. v. City of Boston" on Justia Law

The case involves Edgar Reyes-Colón, who was subjected to an involuntary Chapter 11 bankruptcy petition filed by Banco Popular de Puerto Rico in 2006. The bankruptcy court dismissed the petition in 2016, finding that Banco Popular failed to join the requisite number of creditors. Reyes-Colón subsequently filed a motion for attorney's fees and costs under 11 U.S.C. § 303(i)(1) and initiated an adversary proceeding alleging bad faith under 11 U.S.C. § 303(i)(2).The bankruptcy court denied Reyes-Colón's motion for attorney's fees, ruling it lacked subject-matter jurisdiction as the motion was filed after the case was closed. Reyes-Colón appealed to the District Court for the District of Puerto Rico, which affirmed the bankruptcy court's decision, adding that the motion was untimely under local rules requiring such motions to be filed within fourteen days after the issuance of the mandate. Reyes-Colón then appealed to the United States Court of Appeals for the First Circuit.The First Circuit held that the bankruptcy court had jurisdiction over post-dismissal § 303(i) motions, as such motions necessarily require post-dismissal jurisdiction. However, the court affirmed the denial of the attorney's fees motion on the grounds that it was untimely, as it was filed 365 days after the mandate issued, far exceeding the fourteen-day limit set by local rules.Regarding the adversary proceeding, Reyes-Colón filed a motion for withdrawal of reference to have the district court adjudicate the case. The district court denied the motion as untimely, conflating the timeliness of the motion for withdrawal with the timeliness of the § 303(i) motion. The First Circuit vacated this decision, clarifying that the timeliness of the motion for withdrawal should be measured from the filing of the adversary proceeding, not the dismissal of the involuntary petition. The case was remanded for further consideration of whether there is cause to withdraw the reference. View "Reyes-Colon v. Banco Popular de Puerto Rico" on Justia Law

Eric Cohen, experiencing a psychotic episode, attacked his girlfriend and fled into the cold waters of Portland's Back Cove, where he eventually drowned from hypothermia. His estate sued the City of Portland and several members of its police and fire departments, alleging violations of Cohen's substantive due process rights due to a failure to rescue him from a state-created danger and inadequate crisis intervention training.The United States District Court for the District of Maine dismissed the state-created danger claims against two police officers, Sergeants Christopher Gervais and Michael Rand, under Federal Rule of Civil Procedure 12(b)(6). The court found that the officers' actions did not create or enhance the danger to Cohen. After discovery, the court granted summary judgment to a firefighter, Ronald Giroux, and the City of Portland. The court concluded that Giroux's actions did not cause Cohen's death and that the City could not be held liable for failure to train its employees since no individual defendant was found to have violated Cohen's constitutional rights.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's rulings. The appellate court held that neither Gervais nor Rand's actions constituted an affirmative act that created or enhanced the danger to Cohen. The court also found that Giroux's threat did not factually or legally cause Cohen's death. Finally, the court affirmed the summary judgment in favor of the City of Portland, as there was no predicate constitutional violation by any individual defendant to support a failure-to-train claim. View "Cohen v. City of Portland" on Justia Law

Michele Tourangeau filed a complaint against her former employer, Nappi Distributors, alleging nine employment-related claims. Nappi moved for summary judgment on all claims, but the District Court denied the motion for all but one claim, leading to a jury trial. The jury found in favor of Nappi on all claims. Tourangeau then filed a motion for a new trial, citing juror bias and errors in jury instructions, which the District Court denied.Tourangeau appealed the District Court's decision to the United States Court of Appeals for the First Circuit. She argued that the District Court erred in not disqualifying a juror who allegedly displayed bias and failed to answer voir dire questions truthfully. The District Court had previously determined that the juror's conduct and Facebook activity did not demonstrate bias sufficient to warrant disqualification. The appellate court found no abuse of discretion in the District Court's handling of the juror bias allegations, noting that the District Court had appropriately assessed the juror's behavior and responses.Tourangeau also challenged the jury's verdict on one of her Equal Pay Act (EPA) claims, arguing that the verdict was against the great weight of the evidence and that the District Court erred in not giving a specific jury instruction. The appellate court upheld the District Court's decision, finding that Nappi had provided sufficient evidence that the pay differential was based on a business decision unrelated to sex. The court also agreed with the District Court's refusal to give the requested jury instruction, as there was no evidence of a prior illegal practice of gender discrimination in hiring.The United States Court of Appeals for the First Circuit affirmed the District Court's judgment, concluding that there was no reversible error in the handling of the juror bias allegations or the EPA claim. View "Tourangeau v. Nappi Distributors" on Justia Law

The case involves William Rios, a part-time security guard for Centerra Group LLC, who was fired after being found asleep at his post. Rios, who has diabetes, sued Centerra alleging violations of the Americans with Disabilities Act (ADA). He claimed that he had an episode of hypoglycemic shock which caused him to fall asleep on the job, and thus, Centerra should have accommodated his disability. However, Rios did not present any evidence that Centerra knew about his hypoglycemic episode when it fired him.The district court granted summary judgment to Centerra on all claims. Rios appealed, challenging the district court's decisions on his ADA discrimination claim, ADA claim for failure to provide a reasonable accommodation, ADA claim for hostile work environment, ADA claim for retaliation, and the denial of his Federal Rule of Civil Procedure 56(d) motion seeking additional discovery to respond to the motion for summary judgment.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that Rios failed to present evidence from which a reasonable jury could find that Centerra held a discriminatory animus toward him based on his disability. The court also found that Rios failed to provide any evidence of discriminatory animus that would allow a reasonable jury to infer that Centerra's reasons for firing Rios were pretextual. The court further held that the district court did not abuse its discretion in denying Rios's Rule 56(d) motion given his failure to show good cause or due diligence in pursuing discovery for information regarding similarly situated employees. View "Sheridan v. Centerra Group, LLC" on Justia Law

A defamation lawsuit was filed by Dana Cheng, a New York resident and political commentator, against Dan Neumann and Beacon, a Maine news outlet, for characterizing Cheng as "far-right" and a "conspiracy theorist" in an article. Neumann and Beacon sought dismissal of the case under both federal law and a New York anti-SLAPP law, which applies to meritless defamation lawsuits. The district court conducted a choice-of-law analysis, decided that New York law applied, and granted the motion to dismiss under New York's anti-SLAPP statute.The district court's decision was appealed to the United States Court of Appeals for the First Circuit. The appellate court agreed with the district court's ruling but for a different reason: it decided that Cheng's lawsuit had to be dismissed under binding First Amendment principles protecting free speech by the press. Back at the district court, Neumann requested attorneys' fees under the fee-shifting provision of New York's anti-SLAPP law. The district court denied Neumann's request after determining that Maine, not New York, law applied to the specific issue of attorneys' fees.Neumann appealed again, arguing that the district court erred in its choice-of-law analysis. The appellate court, noting the lack of clear controlling precedent on the issue, certified to the Supreme Judicial Court of Maine the question of which state's law applies to the attorneys' fees issue. View "Cheng v. Neumann" on Justia Law