Justia Business Law Opinion Summaries
Articles Posted in U.S. Court of Appeals for the First Circuit
Cornwell Ent., Inc. v. Anchin, Block & Anchin, LLP
Patricia Cornwell, a well-known crime novelist, and her spouse filed suit against their former business managers Anchin Block & Anchin and the company’s principal, Evan Snapper, alleging New York state law claims of negligent performance of professional services, breach of contract, and breach of fiduciary duty. The jury returned a verdict in favor of Plaintiffs on all three claims and awarded Plaintiffs $51 million in damages. Thereafter, the district court vacated the jury’s decision, ruling that it had incorrectly instructed the jury and that Defendants’ statements to the Department of Justice (DOJ) were protected by a qualified privilege and therefore should not have been considered by the jury. The First Circuit reversed in part, holding (1) the district court correctly found that it incorrectly instructed the jury on New York’s statute of limitations for a breach of fiduciary duty claim; and (2) the district court erred in entering judgment as a matter of law for Defendants on the DOJ issue. Remanded for a new trial. View "Cornwell Ent., Inc. v. Anchin, Block & Anchin, LLP" on Justia Law
Rodriguez-Miranda v. Benin
This appeal stemmed from an employment dispute between Angel Edgardo Rodriguez-Miranda (Rodriguez) and Malik Benin (Benin), two former colleagues. At issue in this, the the latest round of litigation, was a judgment entered against Benin’s company, Coquico, Inc., in favor of Rodriguez for $348,821. Benin apparently sought to avoid paying the judgment by transferring Coquico’s assets to his mother, Acquanetta Benin (Acquanetta) and to 18 Degrees North, LLC. The district court used Fed. R. Civ. P. 25(c) to hold Coquico, Benin, Acquanetta, and 18 Degrees North (collectively, Appellants) all liable for the judgment. The court also found Benin in civil contempt and imposed a monetary sanction. The First Circuit affirmed, holding (1) the district court did not plainly err in joining Benin, Acquanetta, and 18 Degrees North under Rule 25(c) as alter egos of Coquico and holding them liable for the judgment originally entered against Coquico only; and (2) the district court did not err in fining Appellants in civil contempt and imposing a $5,000 sanction on Benin. View "Rodriguez-Miranda v. Benin" on Justia Law
Trafon Group, Inc. v. Butterball LLC
Trafon Group, Inc., a Puerto Rico-based wholesale food distributor, filed suit in the District of Puerto Rico alleging that Butterball LLC breached an exclusive distribution agreement in violation of Puerto Rico’s Law 75 of June 24, 1964. Trafon moved for a preliminary injunction enjoining Butterball from further impairing the alleged exclusive distribution agreement. The district court denied the motion, concluding that Trafon’s claim was barred under Law 75’s three-year statute of limitations. The district court then dismissed the case under Fed. R. Civ. P. 56(f). The First Circuit affirmed, holding that Trafon’s action was time-barred under Law 75. View "Trafon Group, Inc. v. Butterball LLC" on Justia Law