Justia Injury Law Opinion Summaries

Articles Posted in US Court of Appeals for the First Circuit
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The First Circuit affirmed in part and reversed in part the decision of the district court entering judgment for Plaintiff on Mass. Gen. Laws ch. 151B and defamation claims against the City of Fitchburg and its mayor and the award of punitive damages, holding that the award of punitive damages was improper and that the district court erred in entering judgment for Plaintiff on the defamation claim. Plaintiff brought this action against the City and its mayor after the mayor decided not to nominate Plaintiff for the position of the City police chief. Plaintiff alleged that the City violated his rights under Chapter 151B by deciding not to hire him because of his failure to disclose a criminal case against him of which he was later acquitted and that the mayor defamed him through statements she made to the media. A jury found for Plaintiff on both claims and awarded punitive damages. The First Circuit held (1) the district court erred in denying Plaintiff’s motion for judgment as a matter of law and for a new trial on Plaintiff’s defamation claim because the statement at issue was not false; (2) the evidence was sufficient with respect to the Chapter 151B claim; and (3) there was insufficient evidence to support the punitive damages award. View "Heagney v. Wong" on Justia Law

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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

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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

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The First Circuit affirmed the judgment of the district court entering judgment against Plaintiff on his lawsuit against the United States under the Federal Tort Claims Act, 28 U.S.C. 1346(b), 2671-2680, holding that the district court did not err in dismissing Plaintiff’s claim on the clearly-established step of qualified immunity analysis. In his lawsuit, Plaintiff sought to recover damages for injuries he suffered when a Department of Homeland Security agent shot him during the execution of a search warrant at his residence. The district court ruled for the United States, concluding that the United States could not be held liable unless the unlawfulness of the officers’ conduct was clearly established at the time they acted and that, at the time the officers acted, no precedent clearly established that the officers’ conduct was unlawful. The First Circuit affirmed, holding that the officers’ actions did not violate clearly established statutory or constitutional rights of which a reasonable person would have known. View "Escalera-Salgado v. United States" on Justia Law

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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

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The First Circuit affirmed the district court’s decision granting Defendants’ motion for summary judgment on Plaintiff’s 42 U.S.C. 1983 claim and dismissing Plaintiff’s Massachusetts state law negligence claim without prejudice, holding that the district court’s judgment was without error. Plaintiff, a pretrial detainee at the Massachusetts Correctional Institute-Framingham, sued Dr. Thomas Groblewski and the Massachusetts Partnership for Correctional Healthcare in federal district court, bringing a state law claim for common law negligence and a federal law claim under section 1983 for a violation of her Eighth Amendment right to be free from cruel and unusual punishment. The district court concluded that no reasonable jury could find that Groblewski acted with deliberate indifference to Plaintiff’s medical needs. The First Circuit affirmed, holding that the district court did not err in granting Defendants summary judgment on Plaintiff’s Eighth Amendment claim. View "Zingg v. Groblewski" on Justia Law

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The First Circuit affirmed the district court’s dismissal of Plaintiff’s suit against Bloomberg News and authors of an article Plaintiff claimed rendered Bloomberg liable for several common-law torts, including defamation, holding that the suit was properly dismissed for Plaintiff's failure to allege sufficient facts to make out his claims. This case concerned an online article and TV interview in which Bloomberg reported that the Securities and Exchange Commission had opened an investigation to determine whether Plaintiff, a priest and hedge fund manager, had intentionally published false material about certain public companies. The district court granted Defendants’ motion to dismiss, concluding (1) Plaintiff was required to plausibly allege actual malice because he was at least a limited-purpose public figure, and Plaintiff failed to do so; and (2) Plaintiff failed to allege sufficient facts to make out a claim of intentional interference with prospective economic advantage. The First Circuit affirmed, holding that Plaintiff’s complaint did not narrate a claim for relief. View "Lemelson v. Bloomberg L.P." on Justia Law

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The First Circuit affirmed the district court’s summary judgment findings, evidentiary rulings, and denials of various motions on claims brought by a member of the rock band BOSTON against a former BOSTON guitarist alleging trademark infringement and breach of contract and on the guitarist’s counterclaims alleging breach of contract and abuse of process. Donald Thomas Scholz sued Barry Goudreau alleging claims related to impermissible inferences that Goudreau had allegedly made regarding his former association with BOSTON. Goudreau counterclaimed. After the district court granted in part the parties’ respective motions for summary judgment, the remaining claims proceeded to trial. The jury found in favor of the respective defendants on the remaining claims. The parties cross-appealed. The First Circuit affirmed the district court and denied the appeals, holding that there was no error or abuse of discretion requiring reversal. View "Scholz v. Goudreau" on Justia Law

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The First Circuit affirmed the district court’s grant of summary judgment in favor of the government on Plaintiff’s claim under the Federal Tort Claims Act (FTCA) for false imprisonment, holding that while the decision of agents from the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) to prevent Plaintiff and his son from leaving a Puerto Rico post office parking lot was wrong, that decision was reasonable and did not expose the United States to liability. After Plaintiff’s son retrieved some envelopes from the post office Plaintiff and his son began pulling out of the parking lot but were stopped by ATF agents with guns drawn. Plaintiff was removed from the vehicle and handcuffed, and Plaintiff and his son were detained for approximately twenty minutes. ATF agents released Plaintiff and his son when they realized they had stopped the wrong people in searching for the person who had received an illegal shipment of firearms. Based on this incident, Plaintiff filed his complaint. The district court granted the government’s motion for summary judgment. The First Circuit affirmed, holding that even if the agents did not have probable cause to arrest, Puerto Rico would not impose liability for false imprisonment, and, given the vicarious liability premise of the FTCA, the United States was not exposed to liability. View "Soto-Cintron v. United States" on Justia Law

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The First Circuit dismissed this appeal in part for want of appellate jurisdiction and otherwise affirmed the district court’s dismissal of the underlying action asserting a claim under the Alien Tort Statute (ATS), 28 U.S.C. 1350, and common-law claims for negligence and civil conspiracy, holding that this Court lacked jurisdiction to consider two of Defendant's claims on appeal. Plaintiff’s complaint premised jurisdiction both on the ATS and on diversity of citizenship. Plaintiff also invoked the district court’s supplemental jurisdiction over the state law claims. The district court dismissed the ATS claim for want of subject-matter jurisdiction and declined to exercise supplemental jurisdiction over the state law claims. Defendant appealed. The First Circuit held (1) this Court lacked jurisdiction to consider Defendant’s request to purge certain unflattering comments from the district court’s opinion; (2) judicial estoppel barred Defendant’s argument that the district court, even after dismissing the ATS claim, had an alternative basis for federal subject-matter jurisdiction; (3) the district court did not abuse its discretion in declining to exercise supplemental jurisdiction over Plaintiff’s state-law claim; and (4) this Court lacked jurisdiction to entertain Defendant’s claim that the district court erred in declining to grant his first motion to dismiss. View "Sexual Minorities Uganda v. Lively" on Justia Law