Justia Class Action Opinion SummariesArticles Posted in US Court of Appeals for the First Circuit
Tyngsboro Sports II Solar, LLC v. National Grid USA Service Co., Inc.
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
Webb v. Injured Workers Pharmacy, LLC
The First Circuit affirmed in part and reversed in part the judgment of the district court dismissing this putative action asserting various state law claims in relation to a data breach that allegedly exposed Plaintiffs' personally identifiable information (PII) and that of more than 75,000 other patients of Injured Workers Pharmacy, LLC (IWP), holding that remand was required.Plaintiffs brought a class action complaint against IWP, a home-delivery pharmacy service registered and headquartered in Massachusetts, asserting state law claims for negligence, breach of implied contract, unjust enrichment, invasion of privacy, and breach of fiduciary duty. Plaintiffs sought to certify a class of United States residents whose PII was compromised in the data breach at issue. The district court granted IWP's motion to dismiss for lack of Article III standing. The First Circuit reversed in part, holding (1) the complaint plausibly demonstrated Plaintiffs' standing to seek damages; and (2) Plaintiffs lacked standing to pursue injunctive relief because their desired injunctions would not likely redress their alleged injuries. View "Webb v. Injured Workers Pharmacy, LLC" on Justia Law
Powers v. Receivables Performance Management, LLC
The First Circuit dismissed the appeal in the underlying putative action removed from Massachusetts state court to the federal district court concerning a motion to compel arbitration, holding that the order was not a final decision and not within an exception that would permit interlocutory review.Plaintiff brought this putative class action alleging that Defendant, a debt collector, alleging violations of Mass. Gen. Laws ch. 93A and 940 Mass. Code Regs. 7.01-.10. Defendant moved to compel arbitration in the state court, relying on an arbitration provision in the service contract between Plaintiff and the holder of the alleged debt Defendant was attempting to collect. The state court denied the motion, after which Defendant removed the case to federal court, where it filed another motion to compel arbitration. The district court treated the motion as a motion for reconsideration of the state court order denying the arbitration and then denied it. The First Circuit dismissed Defendant's appeal, holding that this was an improper interlocutory appeal. View "Powers v. Receivables Performance Management, LLC" on Justia Law
Posada v. Cultural Care, Inc.
The First Circuit affirmed the judgment of the district court granting in part and denying in part Cultural Care, Inc.'s motion to dismiss this putative class action alleging violations of Plaintiffs' rights under various state and federal wage and hour laws, holding that the district court did not err.Plaintiffs sued Cultural Care, a private company that places au pairs with host families in various states, alleging that the company qualified as an "employer" under the respective states' wage and hour laws and not only failed to pay Plaintiffs what they were owed but that Cultural Care violated the Family Leave Act and other laws. Cultural Care filed a motion to dismiss, arguing, inter alia, that it was shielded from immunity under the doctrine of derivative sovereign immunity as set forth in Yearsley v. W.A. Ross Construction Co., 309 U.S. 18, 20-22 (1940). The district court dismissed the state law deceptive trade practices claims under Connecticut and Washington law for lack of standing but otherwise denied the motion. The First Circuit affirmed, holding that Cultural Care was not entitled to protection under Yearsley at this stage of the litigation. View "Posada v. Cultural Care, Inc." on Justia Law
Murray v. McDonald
The First Circuit vacated the approval of a class action settlement under Fed. R. Civ. P. 23(e), holding that the absence of separate settlement counsel for distinct groups of class members made too difficult a determination whether the settlement treated class members equitably.Plaintiffs sued HelloFresh, a subscription service, alleging that its so-called "win back" marketing campaign violated the Telephone Consumer Protection Act. The parties eventually arrived at a proposed settlement conditioned on court approval. The district court adopted the settlement agreement. An objector to the settlement appealed, arguing that the settlement process was unfair and led to an inequitable result. The First Circuit agreed and vacated the district court's approval, holding (1) the district court lacked the requisite basis for certifying the settlement class and approving an allocation among class members as fair, reasonable, and adequate; and (2) incentive payments to named class representatives are not prohibited so long as they fit within the bounds of Rule 23(e). View "Murray v. McDonald" on Justia Law
Immediato v. Postmates, Inc.
The First Circuit affirmed the judgment of the district court determining that couriers who deliver goods from local restaurants and retailers are transportation workers engaged in interstate commerce such that they are exempt from the Federal Arbitration Act (FAA), 9 U.S.C. 1, holding that the district court did not err or abuse its discretion.Plaintiffs, who worked as couriers for Defendants making deliveries in the greater Boston area, filed suit in a Massachusetts state court on their own behalf and on behalf of a putative class of similarly situated couriers, alleging that Defendant had misclassified them as independent contractors rather than employees and that they were entitled to employee benefits and protections under Massachusetts law. The district court concluded that Plaintiffs were not exempt from the FAA, compelled arbitration of the dispute, and dismissed the lawsuit. The First Circuit affirmed, holding that the district court did not err in compelling arbitration and dismissing the underlying complaint. View "Immediato v. Postmates, Inc." on Justia Law
Ponsa-Rabell v. Santander Securities, LLC
The First Circuit affirmed the judgment of the district court dismissing all claims in this dispute between brokerage customers of Defendant, who purchased special Puerto Rico securities during a recession but before the bond market crash, holding that there was no error in the proceedings below.Plaintiffs brought a securities class action against Defendant, asserting claims under federal securities laws and Puerto Rico law. The district court entered judgment dismissing the federal law claims with prejudice and the state law claims without prejudice. The First Circuit affirmed, holding that Plaintiffs' claims that there were allegedly material omissions on the part of Defendant were not actionable. View "Ponsa-Rabell v. Santander Securities, LLC" on Justia Law
McIntyre v. RentGrow, Inc.
The First Circuit affirmed the order of the district court entering summary judgment in favor of RentGrow, Inc. and dismissing Plaintiff's complaint alleging that RentGrow willfully violated the Fair Credit Reporting Act (FCRA), 15 U.S.C. 1681-1681x, holding that summary judgment was properly granted.Plaintiff commenced a civil action in the United States District Court for the District of Massachusetts, sued on her own behalf and as the representative of a putative class of similarly situated persons, alleging that Defendant was liable for both negligent and willful noncompliance with the FCRA. The district court entered summary judgment in Defendant's favor, denied class certification, and dismissed the action. The First Circuit affirmed, holding that Plaintiff did not meet her burden of adducing competent evidence sufficient to prove each and every element of her claim. View "McIntyre v. RentGrow, Inc." on Justia Law
Pereira Brito v. Garland
The First Circuit affirmed in part and vacated in part the declaratory judgment and permanent injunction issued by the district court in this class action challenging the bond procedures used to detain noncitizen during the pendency of removal proceedings under 8 U.S.C. 1226(a), the discretionary immigration detention provision, holding that the district court lacked jurisdiction to issue injunctive relief in favor of the class.Specifically, the First Circuit held (1) the district court did not err in declaring that noncitizens "detained pursuant to 8 U.S.C. 1226(a) are entitled to receive a bond hearing at which the government must prove the alien is either dangerous by clear and convincing evidence or a risk of flight by a preponderance of the evidence"; (2) the classwide injunction in this case unlawfully enjoined or restrained the operation of section 1226(a); and (3) the remaining portion of the district court's declaration was advisory. View "Pereira Brito v. Garland" on Justia Law
Torres-Ronda v. Nationwide Mutual Insurance Co.
The First Circuit affirmed the judgment of the district court granting two summary judgment motions in favor of Defendants in this class action lawsuit, holding that Defendants' actions in this case could not support a claim under the Racketeer Influenced and Corrupt Organizations Act (RICO).In granting the two summary judgment motions at issue, one filed on behalf of all Defendants and on filed behalf of certain Defendants, the district court adopted the findings of law of the Court of Appeals of Puerto Rico in Collazo Burgos v. La Asociación de Suscripción Conjunta del Seguro de Responsabilidad Obligatorio, No. K AC2010-0179, 2017 WL 6884428 (P.R. Cir. Nov. 30, 2017). The court further held that Defendants' actions were required under Puerto Rico law and thus could not support a RICO claim. The First Circuit affirmed, holding that the district court did err under the Erie doctrine in adopting the reasoning of the court of appeals in Collazo Burgos. View "Torres-Ronda v. Nationwide Mutual Insurance Co." on Justia Law