Masso-Torrellas v. Municipality of Toa Alta, No. 16-1319 (1st Cir. 2017)Annotate this Case
This case concerned a dispute relating to contracts for the construction of a municipal transportation terminal on land owned by a municipality (Municipality). Municipality awarded the construction project to OSSAM Construction Inc. (OSSAM). After disputes arose regarding payments for the work performed in connection with the construction contracts, Municipality notified OSSAM that the contract between the parties was being terminated. Municipality then took control of the construction site. OSSAM and related individuals (Plaintiffs) filed suit against Municipality and its officials, claiming, inter alia, that Defendants violated 42 U.S.C. 1983 when they acted under color of law to interfere with Plaintiffs' constitutional rights during the construction site takeover and that these actions consisted a breach of contract. The district court (1) dismissed Plaintiffs’ section 1983 claim, concluding that it lacked subject matter jurisdiction because the parties had failed to comply with the mediation/arbitration clause in their contract; and (2) declined to exercise supplemental jurisdiction over related state law claims. The First Circuit affirmed, albeit on different grounds, holding (1) the section 1983 claim should be dismissed for failure to state a claim; and (2) accordingly, there is no supplemental jurisdiction over the state law claims.