Justia Arbitration & Mediation Opinion SummariesArticles Posted in US Court of Appeals for the First Circuit
University of Notre Dame (USA) in England v. TJAC Waterloo, LLC
The First Circuit affirmed the judgment of the district court confirming certain damages awarded to The University of Notre Dame (USA) in England (Notre Dame) by a foreign arbitral tribunal in a contractual dispute relating to construction defects, holding that Notre Dame's petition for judicial confirmation of the awards was not time-barred.Notre Dame brought this action against TJAC Waterloo, LLC and ZVI Construction Co., who were, respectively, the seller and renovator of a dormitory that Notre Dame had agreed to purchase. The dispute was submitted to arbitration. After the arbitrator entered the awards, Notre Dame moved the district court to confirm the awards and entered summary judgment in its favor. The district court granted Notre Dame's request for judicial confirmation. The First Circuit affirmed, holding that Notre Dame's motion for judicial confirmation was not time-barred. View "University of Notre Dame (USA) in England v. TJAC Waterloo, LLC" on Justia Law
Rodriguez-Rivera v. Allscripts HC Sol., Inc.
The First Circuit affirmed the judgment of the district court dismissing this case against Allscripts Healthcare Solutions, Inc. (AHS) on personal jurisdiction grounds but vacated the dismissal as to Allscripts Healthcare, LLC (Allscripts), holding that the district court improperly granted the motion to dismiss as to Allscripts.Dr. Juan M. Rodriguez-Rivera (Rodriguez) brought this action against AHS and Allscripts in Puerto Rico federal court after his electronic patient records from his medical practice were destroyed. AHS and Allscripts filed a motion to dismiss. The district court granted the motion, finding that the disputes should be arbitrated, that it lacked jurisdiction over both AHS and Allscripts, and that Rodriguez's complaint failed to state a claim as a matter of law. The First Circuit affirmed in part and vacated in part, holding (1) the district court improperly granted the motion to dismiss for lack of personal jurisdiction with respect to Allscripts; (2) whether a valid arbitration existed was a factual matter to be resolved by the district court; and (3) the district court erred in concluding that Rodriguez's complaint failed to state a claim against Allscripts. View "Rodriguez-Rivera v. Allscripts HC Sol., Inc." on Justia Law
United Steelworkers v. National Grid
The First Circuit reversed the judgment of the district court denying arbitration requested by two unions - the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union and the United Steelworkers Local 12203 (collectively, Union) - on behalf of former two employees of the Boston Gas Company (Company) as to their claims for pension benefits, holding that this matter called for arbitration.The Union represented the two members in filing grievances regarding their underpaid pensions. The Union submitted the grievances to the Joint Pension Committee, which was unable to resolve the dispute. The Union subsequently sought arbitration over the grievances, but the Company refused to arbitrate. The First Circuit reversed, holding that it was up to an arbitrator, not a court, to determine the matters at issue in this case. View "United Steelworkers v. National Grid" on Justia Law
Johnson Controls Security Solutions, LLC v. Int’l Brotherhood of Electrical Workers, Local 103
The First Circuit reversed the judgment of the district court in this dispute between the International Brotherhood of Electrical Workers, Local 103 (the Union) and Johnson Controls Security Solutions, LLC over Johnson Controls' compliance with the terms of the parties' collective bargaining agreement (CBA), holding that the district court erred by failing to order arbitration as called for by a clause in the CBA.Johnson Controls' Norwood, Massachusetts facility entered into a CBA with the Union, a labor organization that represented employees of the company, that contained an arbitration clause. The Union filed a grievance concerning Johnson Controls' reduction in its matching contribution to the company's 401(k) plan, which Johnson Controls denied. When the Union filed a demand for arbitration Johnson Controls brought this lawsuit seeking a declaratory judgment that the dispute was not arbitrable under the CBA. The district court concluded that the dispute was not arbitrable. The First Circuit reversed, holding that nothing in the record showed that the parties intended to exclude this type of dispute from the scope of the arbitration clause. View "Johnson Controls Security Solutions, LLC v. Int'l Brotherhood of Electrical Workers, Local 103" on Justia Law
Air-Con, Inc. v. Daikin Applied Latin America, LLC
The First Circuit reversed the judgment of the district court requiring the parties to arbitrate their dispute in this case, holding that the district court erred in compelling arbitration.In 2000, Air-Con signed a written distribution agreement with Daikin Industries, LTD to be an authorized distributor in Puerto Rico of air conditioning and refrigeration equipment. The agreement contained an arbitration provision requiring the parties to arbitrate any disputes in Japan. Also in 2000, Air-Con established a distribution relationship with Daikin Applied Latin America, LLC, Daikin Industries' subsidiary. In 2018, Air-Con filed suit against Daikin Applied seeking injunctive relief and damages under Puerto Rico's Dealer Protection Act. After the case was removed to federal court Daikin Applied filed a motion to compel arbitration, arguing that the written agreement between Air-Con and Daikin Industries governed Daikin Applied's relationship with Air-Con. The district court agreed with Daikin Applied. The First Circuit reversed, holding that the district court erred in concluding that Air-Con agreed to arbitrate the claims at issue in this case. View "Air-Con, Inc. v. Daikin Applied Latin America, LLC" on Justia Law
McKenzie v. Brannan
The First Circuit vacated the judgment of the judgment of the district court granting a motion to compel arbitration filed by the personal representative of the estate of a famous American artist (Estate), dismissing an art publisher's (Publisher) motion for a preliminary injunction as moot, and eventually dismissing the case, holding that the district court erred.At issue was an agreement between the Estate and Publisher. Publisher asserted that the parties' original contract, which included an agreement to arbitration, was terminated and supplanted by a superseding contract that did not contain an arbitration provision. In question was whether the arbitrability of the parties' dispute about the newer contract's enforceability and impact on the earlier agreement to arbitrate should be decided by the court or by arbitrators. The district court concluded that the gateway question of arbitrability was for the arbitrators. The First Circuit reversed, holding that it is the court, and not the arbitrators, that must resolve the disagreement in this case. View "McKenzie v. Brannan" on Justia Law
Cunningham v. Lyft, Inc.
The First Circuit reversed the order of the district court denying Lyft Inc.'s request to compel arbitration in this purported class action but affirmed the denials of preliminary injunctive relief, holding that the Federal Arbitration Act (FAA) applied.Plaintiffs were Massachusetts-based rideshare drivers who used the Lyft application and platform to find passengers. In their complaint, Plaintiffs claimed that Lyft misclassified them as independent contractors rather than employees. At issue on this appeal were rulings concerning Plaintiffs' requests for preliminary injunctive relief and the denial of Lyft's request to compel arbitration. The First Circuit reversed in part, holding (1) the FAA applies in this case; and (2) the district court did not err in denying Plaintiffs' requested injunction. View "Cunningham v. Lyft, Inc." on Justia Law
Toddle Inn Franchising, LLC v. KPJ Associates LLC
The First Circuit affirmed the judgment of the district court judge confirming an arbitration award, holding that none of Appellant's legal theories for reversal were meritorious.KPJ Associates, LLC ran a daycare in Maine as a franchisee of Toddle Inn Franchising, LLC. When KPJ ended the franchise agreement on Friday and told Toddle it would open another daycare at the same site the following Monday Toddle filed a federal complaint alleging unfair competition under the federal Lanham Act and breach of contract and trade secret misappropriation under Maine law. Toddle then moved to compel arbitration and stay court proceedings. The judge compelled arbitration, and the arbitrator found for Toddle. The First Circuit affirmed, holding that the district court judge (1) did not lack subject matter in this case because Toddle did not present a frivolous Lanham Act claim; (2) did not err in ruling that Toddle did not waive its right to arbitrate by its litigation conduct; and (3) did not err in awarding additional attorneys' fees and costs. View "Toddle Inn Franchising, LLC v. KPJ Associates LLC" on Justia Law
Union Internacional, UAW Local 2415 v. Bacardi Corp.
The First Circuit affirmed the judgment of the district court summarily affirming an arbitration award dismissing Union Interacional UAW, Local 2415's wage grievance claim against Bacardi Corporation, holding that the Union did not identify an error in the arbitration award so egregious as to permit this Court to vacate it.The arbitrator found that the Union's claim was not procedurally arbitrable because the Union failed to comply with the contractual wage grievance procedure. On appeal, the Union argued that either the arbitrator should have deemed the procedural arbitrability defect waived or that the procedural defect did not justify dismissing the entire claim. The First Circuit affirmed, holding that, while the Union's waiver arguments had merit, the arbitrator acted within the scope of his authority in dismissing the entire claim for lack of procedural arbitrability. View "Union Internacional, UAW Local 2415 v. Bacardi Corp." on Justia Law
American Institute for Foreign Study, Inc. v. Fernandez-Jimenez
The First Circuit affirmed the judgment of the district court granting a preliminary injunction to the American Institute for Foreign Study, Inc. to enjoin class arbitration in this dispute with an au pair, holding that the agreement between the parties did not authorize class arbitration, and the au pair's claim was moot.The Institute, which places au pairs with host families in the United States, entered into a contract with Plaintiff, an au pair from Spain, that required the parties to arbitrate their disputes. Plaintiff filed a class arbitration demand against the Institute and its CEO, William Gertz (together, Defendants). Defendants subsequently filed suit seeking to enjoin class arbitration. The district court denied relief to Gertz and granted a preliminary injunction to the Institute. The First Circuit affirmed, holding (1) the agreement did not provide an affirmative basis to conclude that the parties agreed to class arbitration; and (2) Gertz's claim was moot. View "American Institute for Foreign Study, Inc. v. Fernandez-Jimenez" on Justia Law